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ABC AUDIENCE AND CONSUMER AFFAIRS INVESTIGATION REPORT

5 April 2012

Summary
Content

‘Coal Seam Gas: By the Numbers’ on abc.net.au, published November 2011.

Background

The website ‘Coal Seam Gas: By the Numbers’ (http://www.abc.net.au/news/specials/coal-seam-

gas-by-the-numbers/) was established and produced by the ABC Radio division and published in
November 2011.

The Australian Petroleum Production and Exploration Association Ltd (APPEA) on 9 December 2011
submitted a detailed and comprehensive complaint about the website. APPEA alleged 35 separate
instances of inaccuracy, and that the site “displays a bias that misleads and misinforms the
audience”.

For clarity, this report includes summarised details of the complaint in addition to Audience and
Consumer Affairs’ assessment of the matters raised and conclusions. The numbers used below
correspond with the APPEA complaint of 9 December 2011. All points of accuracy were assessed
against Section 2.1 of the Editorial Policies. Impartiality is addressed towards the end of this report,
and was assessed against Section 4 of the Editorial Policies.

1. Complaint:

The data use is “poor”, demonstrates a “scattergun approach” and understates the benefits of
CSG. For instance, if there were 40,000 wells developed by 2030 there would be a greater
economic benefit than that indicated by the site.

Some data relates to ‘maximum’ projections from a variety of sources, other data refers to either
single projects or multiple approved projects.

The “Did you know” section of the website is a snapshot of some of the interesting information on
the site that might be new to readers and encourage them to explore the site more fully. The nature
of the title and the conditional phrasing of the statements (i.e. “could be...”) suggest that it is not
intended to be a complete summary of the contents of the site or a definitive description of the
future of the industry.

The website has drawn together information from a very large number of sources. There exists no
single database from which it is possible to extract validated data across all the categories of
relevant information. Consequently, the site draws on data across different geographical areas,
varying time scales and uses estimates from companies and organisations which have used different
assumptions and inputs. Inevitably, not all data sets are directly comparable.
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Audience and Consumer Affairs are satisfied this approach is reasonable as long as the sources of the
data are revealed and reasonable efforts have been made to ensure credible data was used and,
where possible, verified.

For this reason we believe it was reasonable to have the estimated numbers of wells (40,000) within
the same graphic as the estimated number of jobs in Queensland by 2030 (18,000). The figure of
18,000 jobs was the estimate of the Queensland government for a medium-sized industry, as quoted
by Santos in a submission to the Senate Rural Affairs and Transport References Committee’s inquiry
into management of the Murray Darling Basin and the impact of coal seam gas mining.

The assumptions underpinning this estimate are not revealed and it is not necessarily the case that it
is based on a number of wells closer to 18,650 or 40,000. Both numbers are estimates based on
industry and/or government sources and are accurately represented.

It is not indicative of a “scattergun” approach to the site; it is indicative only of the inevitable
limitations of reporting on a comparatively new industry which is conducted by multiple companies
in a number of different jurisdictions.

Nonetheless, on review, ABC Radio have agreed to make some slight changes to the graphic, to
provide more precise context and information on sources.

In summary, Audience and Consumer Affairs are satisfied that the graphic was materially accurate.

2. Complaint:

Much of the terminology used sensationalises the issues.

The complaint is that the site uses the term “toxic” (in relation to chemical toxicants) and
“contaminated” (in relation to salt) inappropriately. The words “toxic” and “contaminated”
appeared on various pages including the home page and ‘toxic waste’ page.

“Toxic” was used in a number of different contexts on the site. It was used to refer to a number of
specific toxicants that have been detected in the treated water at the Chinchilla plant (specifically
boron, silver, chlorine, copper, cadmium cyanide and zinc) and to the water containing those
toxicants. These are all known to be potentially toxic to humans and to the environment and were
found to be in the water released from the plant. In general terms, Audience and Consumer Affairs
are satisfied it is accurate to describe those substances as “toxic chemicals”. Whether it is accurate
in relation to waste water as in “toxic water release” is discussed in detail in point 18 below.

The term “contaminated” was not used in reference to salt.

3. Complaint:

Using the term “rush” biases the content by implying greed and haste.

(See also point 7 for a response to the complaint about the use of “rush” specifically in relation to
Camden.)
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Audience and Consumer Affairs do not agree that the use of the word “rush” implied greed or undue
haste. None of the 35 definitions of “rush” in the Macquarie Dictionary refers to greed. In our view
“rush” suggests rapid growth in the industry and participants moving quickly to take advantage of
the opportunities presented by a relatively new and rapidly expanding industry; in our view that is
accurate and does not carry negative imputations.

4. Complaint:

The site refers repeatedly to coal seam gas being “mined”; natural gas is not mined, it is extracted.

The word “mining” is commonly used in relation to the CSG industry. In addition to the Senate
inquiry referred to at complaint one above, see for instance:

US study links coal-seam gas mining process to water pollution by Amos Aikman, The Australian
December 10, 2011 http://www.theaustralian.com.au/national-affairs/us-study-links-coal-seam-gas-
mining-process-to-water-pollution/story-fnaxx2sv-1226218585566

Origin Energy demonstration farm to show mining and agriculture can co-exist by Andrew Fraser,
The Australian December 12, 2011 http://www.theaustralian.com.au/national-affairs/origin-energy-
demonstration-farm-to-show-mining-and-agriculture-can-co-exist/story-fnaxx2sv-1226219404841

Winemaker sees red over coal seam gas mining by Josephine Tovey, The Sydney Morning Herald
November 8, 2011 http://www.smh.com.au/environment/winemaker-sees-red-over-coal-seam-gas-
mining-20111108-1n4mh.html

New US crackdown on gas mining method known as fracking, Mining News December 14, 2011 (via
The Australian) http://www.theaustralian.com.au/business/mining-energy/new-us-crackdown-on-
gas-mining-method-known-as-fracking/story-e6frg9df-1226221545375

The website through graphics and copy makes it quite clear what the process is; that of extraction
through drilling. The term ‘mining’ was not used pejoratively by the site and it was properly
contextualised.

5. Complaint:

The website says Roma, Queensland, is “located in prime agricultural land on the Darling Downs”
and “The tension between farmers and miners might best be summed up as a battle over land
use”.

The complaint claims that Roma is not in the Darling Downs, is not prime agricultural land and that
the community supports the gas industry.

Roma is considered to be in the “Western Downs”. Although some may dispute whether the
Western Downs is part of Darling Downs, Audience and Consumer Affairs do not regard the
difference between “Western Downs” and “Darling Downs” to be material. There is a wide range of
both grazing and cropping activity in the Roma area: http://queenslandplaces.com.au/roma and
http://en.wikipedia.org/wiki/Roma,_Queensland
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The oil and gas industry has a long history in the Roma region and we accept that it enjoys
considerable support among townspeople and others in the community. However, there is also
opposition to the expansion of the CSG industry among some farmers, and conflict over land use and
land access is a major issue.

For instance, in July 2011, the Senate Inquiry into the CSG industry held hearings in Roma where a
number of local farmers detailed their concerns. Local cattle producer Kate Scott expressed concerns
at the prospect of 15 wells coming to their property, “I don't think there is enough protection for the
landholder. And so the option is do we sell and go? But I do not know that anyone would really want
to buy our place at the moment. It's not think (sic) it is as saleable as it was prior to coal seam gas I
don't think.”

Another local beef producer David Foote said, “It’s likely to add costs through the fact you can’t
continue to be as productive on the lands you have chosen to be productive on”.

See http://www.aph.gov.au/senate/committee/rat_ctte/mdb/hearings/index.htm for transcripts.

Other reports of concerns among farmers can be seen at:

http://www.couriermail.com.au/spike/columnists/lee-cattle-empire-near-roma-under-threat-from-
coal-seam-gas-project/story-e6frereo-1225872688646 Lee cattle empire near Roma under threat
from coal seam gas project by Des Houghton, The Courier Mail May 29, 2010.

Audience and Consumer Affairs are satisfied that reference to Roma was in keeping with ABC
accuracy standards.

6. Complaint:

The comment on the “battle over land use” is misleading. This is also perpetuated on the webpage
“The Promise?” which has a subheading “Competition for land”.

The complaint states that farmers and the CSG industry are not in competition, and that the
footprint of CSG in the production phase is small and enclosed by 15m x 15m perimeter fences.

While APPEA claims that there is no competition or conflict with farmers and graziers, there are
clearly farmers and graziers who believe there is. The website and the term “battle over land use”
reflect this political and social debate.

The “battle” has been reflected in the government inquiries; the debate in national and local media;
the moratorium on new CSG wells and fracking; the concern within the National Party and their
desire to protect agricultural land; and the concerns of the NSW and Queensland Farmers’
Federations.

The issue has been characterised as a “battle” by other media. For example:

Battle over coal seam gas is part of an escalating resource struggle by Henry Ergas, The Australian
August 19, 2011. http://www.theaustralian.com.au/national-affairs/opinion/battle-over-coal-seam-
gas-is-part-of-an-escalating-resource-struggle/story-e6frgd0x-1226117710775

Ergas writes:
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There is therefore nothing efficient about greater gas extraction if its value is less than the
harm it imposes on farmers and rural communities.

That such issues of balancing competing demands have arisen is not surprising. Our history
abounds with instances of resource booms generating conflicts as some parties seize the
resources whose value has increased without taking account of the damage their actions
impose on others.

Audience and Consumer Affairs are satisfied that the references to “a battle over land use” and
“competition for land” were in keeping with ABC accuracy standards.

Audience and Consumer Affairs are satisfied that it is appropriate to take into account all aspects of
the CSG industry and not just the area immediately adjacent to production wells, when assessing its
impact. The footprint of the CSG is more than a well enclosed by a 15 m perimeter fence. There are
also the roads, the gas and water gathering pipes, the dams, salt pits and so on.

7. Complaint:

Camden, NSW, is identified as a CSG “hotspot”. The website says, “It is not only rural areas
experiencing the coal seam gas rush. There are more than 100 wells at Camden, 60 kilometres
south of Sydney.”

The complaint notes that there is a relatively small number of producing wells (86) in the Camden
area, and that because it has been in production for a decade that does not constitute a “rush”.

ABC Radio advises that the numbers given when a user zooms into Camden (73 production wells, 83
exploration wells) accurately reflect the information in the government-published files that were
downloaded after July 2011. ABC Radio relied on that government data to describe those 156 wells
as “more than a hundred”. In Audience and Consumer Affairs’ view, by using recent government-
published files, ABC Radio made reasonable efforts to ensure the accuracy of the data displayed on
the map.

Given the rapid acceleration of CSG activity across Australia over the last 10 years, it is entirely
appropriate to collectively describe the CSG in Australia a 'rush'.

8. Complaint:

In some instances the marked location of a well and the actual location are about a kilometre
apart. In one case, the actual drill site is visible on the satellite view. In another case, wells appear
to be in the middle of a river.

Audience and Consumer Affairs requested clarification from APPEA about which wells were
inaccurately marked and whether they believed any errors materially impacted on the accuracy of
the site. APPEA responded on 22 December 2011that a search of Moranbah on the map showed
seven instances of wells located in the Isaacs River, and expressed concern that if there were a
pattern of such inaccuracies it could unnecessarily raise community concerns that drilling occurs
without proper consultation.
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APPEA claims that a search of Camden shows 73 production wells and 83 exploration wells when in
fact there are 86 producing wells and no active exploration wells. Some of those producing wells are
conventional gas wells and not CSG wells. APPEA further claims that the map shows the Kingfisher
well (near Casino), which is a conventional gas well.

The original complaint also alleges that many of the leases displayed on the maps have never hosted
CSG exploration or operations but have been used for conventional oil and gas explorations or
production. No specific leases were identified in either the original complaint or the clarification
letter.

In light of APPEA's further information Radio agreed to include more context with the map. The
following text and an editor's note have been added:

“(Note: Data collected and provided by government authorities does not disambiguate coal seam gas
wells from conventional gas wells and some other activities. There is no data set from government or
industry that provides that level of detail. Therefore, some of the wells shown on this map may be
conventional gas wells, core holes, stratigraphic or chip holes. The map reflects the most current and
accurate data on coal seam gas activity that was available from government agencies at the time of
publication.)"

ABC Radio also noted that the data rendered on the map comes from the government databases
and files that are listed in the 'sources' section of the page and are attributed accordingly. It is
possible that the government databases (which have been in the public domain for some time)
contain errors but to the best of ABC Radio’s knowledge, the industry has not requested that the
government-published data be corrected.

ABC Radio advised that there are at least two potential explanations for wells appearing to be in the
middle of a river. Firstly, there are a number of different views or modes available in Google Maps.
They show subtly different information. In many cases, including the section of the Isaac River near
Moranbah, the edge of the river in the Google Maps' 'map view', may not accurately track the
riverbank. On the 'satellite view' the satellite images of the river appears in a different position.
Secondly, as already stated, it is possible that the government files contain incorrect data.

In relation to the display of leases, the site does not say that the leases have hosted CSG
explorations or operations. The website states above the map that the leases represent areas where
companies have the right to look for gas, not where production or exploration is currently occurring.

In Audience and Consumer Affairs’ view ABC Radio made reasonable efforts to ensure that
government-provided data was accurately represented on Google Maps and Google Satellite view, in
keeping with ABC accuracy provisions. At this level it is not surprising that the Map view, which is
schematic, is not as accurate as the Satellite view and may produce some anomalous results.
However, Audience and Consumer Affairs do not believe these relatively minor inconsistencies
would materially mislead readers.

No evidence has been provided by the complainant to indicate that the location of any well is
significantly misrepresented.
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Further, in Audience and Consumer Affairs’ view, any group or individual that is likely to be directly
affected by the location of wells is unlikely to rely on the maps without checking on the ground or
with the company.

In relation to the conventional gas well wells near Camden, the complainant has not identified
specifically which wells are conventional gas wells. However, APPEA has identified the Kingfisher E1
well in Casino as a conventional gas well.

ABC Radio has added a note above the map to indicate that some of the wells may be conventional
gas wells. The gas field of which Kingfisher E1 is a part is a mixture of both coal seam gas and
conventional gas, but is principally a CSG field. The company’s 2011 Annual Report states that the
estimated CSG reserves in its tenements in and around Casino are 24,000 PJ, while the estimated
conventional gas reserves are 2,000 PJ, although it notes that there may be more conventional gas in
deeper, unexplored geological structures. http://www.metgasco.com.au/files/1032165.pdf

It is also apparent from the Annual Report and the Metgasco website generally
(www.metgasco.com.au) that the company considers the gas field as a single operation in which
both CSG and conventional gas will be extracted and used together.

In light of this Audience and Consumer Affairs does not consider the inclusion of exploration wells
such as Kingfisher E1 in the graphic map to have been materially misleading.

In relation to the leases, the description of the nature of the leases is accurate and not misleading.

9. Complaint:

The map groups “Proposed, suspended and production wells” together.

The complaint argues that grouping these different types of wells together creates confusion as
evidenced by errors in an article in the Beaudesert Times, which used the website as a source to
incorrectly say that there are production wells in the area.

While the different types of wells are of the same colour on the map, the status of each well can be
seen by clicking on the icon. The site clearly says that there are 13 development wells, including 8
abandoned wells and 3 wells under appraisal and that there are no producing wells in the
Beaudesert area. The ABC cannot be responsible for the errors of the Beaudesert Times.

10. Complaint:

The website notes that “there are wild disparities in the estimates of CSG’s water use”. However,
it fails to examine what these disparities indicate, leaving a misleading implication that industry
figures are grossly understated.

The Water Group advising the federal government has estimated water extraction of up to 1500
GL/y, while the National Water Commission puts the figure above 300GL/y.
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According to the website, “the industry suggests it will pull out somewhere between 126 gigalitres
and 280 gigalitres a year” – a figure which is from an outdated Queensland Government LNG
Blueprint.

The complaint outlines various reasons why these estimates are incorrect, and that it is mistaken to
suggest that the Australian government’s National Water Commission (NWC) projections are
conservative simply because they are lower than those of The Water Group.

APPEA also complains that the estimate of 126 to 280 gigalitres fails to link the water production
figures with the scale of industry gas production.

The aim of the website was to show readers the lack of certainty in relation to water use and the
implications this may have for water sustainability and waste salt production. The copy under the
story headed “The full story on CSG water use” explains: “Coal seam gas production is a thirsty
business, but there is no agreement on just how thirsty”.

The website shows a range of estimates to demonstrate the uncertainty surrounding predictions of
water use. There is no comment – either explicit or implicit – that the industry figures are grossly
understated.

The numbers themselves are accurately reported and referenced to their sources (with one
exception – see separate response in relation to the referencing and validity of one of The Water
Group projections in response to point 12).

Given that there is a wide range in the estimates, it was reasonable for the website to report as
many as practical from reputable sources rather than make a determination about which estimate(s)
is the most accurate. This is consistent with established journalistic practice where matters are
contested and judgements about accuracy are unable to be made with complete certainty.

At the time of publication, it was reasonable for the team to consider all these estimates to be
credible. The complaint states that none of the estimates make allowance for the reduction in water
flow in each well over time. While that is true in relation to The Water Group estimates based on
Robert Kane’s data (see point 12) it is either not true (as in relation to the Waterlines report which
does make explicit allowance for declining flows) or is misleading in that the other estimates use
different methodologies to estimate total water use.

In relation to the line “The industry suggests it will pull out somewhere between 126 gigalitres and
280 gigalitres a year”; while the original estimate was made by the Queensland government , ABC
Radio advise that the source for describing it as an industry estimate was the APPEA website. A
screen shot of APPEA’s website – Thursday 15 December, 2011 – is provided below.
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The APPEA website itself does not link that figure directly with the scale of gas production.

The word “conservative” was used in the following contexts:

“conservative estimates suggest coal seam gas wells could draw 300 gigalitres of water from
the ground each year?” (homepage)
And:
“While there are wild disparities in the estimates of CSG's water use, even the conservative
numbers will test the sustainability of Australia's underground water reserves.” (the Water
Story page)

The first reference uses the lower estimate of the two independent Government studies cited; in this
case the National Water Commission. It intended to convey the idea that this was a moderate
figure in the range of estimates. Other estimates vary from much higher to considerably lower, as
illustrated by the graphics presented on the site where water use is discussed in more detail. The
word ‘conservative’ indicated that the 300 gigalitres a year figure cited by the National Water
Commission estimate was on the lower side of the range of estimates. Furthermore, the tentative
wording of the statement on the home page (‘suggest’ and ‘could’) appropriately conveyed the
uncertainty attached to the various estimates. In view of this, Audience and Consumer Affairs are
not persuaded that ABC editorial standards for accuracy have been breached.

The second reference to conservative, in the context used, means simply that water use even at the
level of the various lower estimates could affect the sustainability of underground water reserves.
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We note that concerns regarding CSG and the sustainability of water reserves have been expressed
by various authoritative organisations. For instance:

GeoSciences Australia – “We have noted that the current groundwater modelling is inadequate in
terms of scale and detail to identify the impacts of multiple CSG developments on groundwater
interactions in the GAB. ”(Sept 2010)

http://www.basinsustainabilityalliance.org/cms-assets/documents/Technical%20Reports/15966-
735053.geosceinces-aust-report---sept-2010.pdf

National Water Commission – “The commission is concerned that CSG development represents a
substantial risk to sustainable water management given the combination of material uncertainty
about water impacts, the significance of potential impacts and the long time period over which they
may emerge and continue to have effect.” (CSG position statement, December 2010)
http://www.nwc.gov.au/reform/position/coal-seam-gas

A CSIRO scientist who was quoted by the Federal Senate Inquiry noted – “The complex movement
and interactions of different layers of water can be hard to detect but they have a direct effect on the
sustainable use of the resource, such as protecting fresh groundwater from being polluted by nearby
saline layers.” (Andrew Herczeg, Groundwater, in CSIRO, Water, (2011), p. 47)

11. Complaint:

The Water Use graph on the front page states that farmers and other bore users extract
540GL/year from the Great Artesian Basin. A more appropriate and authoritative figure to use
would have been 616.166 GL/year, the assessment of the Great Artesian Basin Coordinating
Committee.

The 540 GL/y figure was cited by the National Water Commission’s (NWC) Waterlines Report
September 2011:

“The estimated co-produced water volume over the next 25-35 years is projected to average over
300GL/y from known reserves. To put this in perspective, 540 GL/y is the approximate annual
groundwater extraction in Queensland from the Great Artesian basin, which underlies most of the
CSG reserves.”(NWC Waterlines report. p.VIII)

http://nwc.gov.au/__data/assets/pdf_file/0007/18619/Onshore-co-produced-water-extent-and-
management_final-for-web.pdf

ABC Radio advises that their understanding is that the NWC derived this figure from the CSIRO. They
advise that in his evidence before the Senate Inquiry into Management of the Murray Darling Basin,
the CSIRO’s Dr Glen Walker agreed that the present extraction from the Great Artesian basin was in
the region of 500 gigalitres. He also said that the CSIRO estimated extraction by the CSG industry
was between 200 and 400 gigalitres. (Source: Senate transcript Rural Affairs and Transport
References Committee, Tuesday, 9 August 2011)
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The complainant cites the Great Artesian Basin Coordinating Committee’s GAB resource Study
Update which presents a figure of 616.166GL/y (page 86). This includes water from South Australia,
the Northern Territory and NSW. The figure for Queensland is 451,681GL/y.

Audience and Consumer Affairs are satisfied that the National Water Commission is a credible
source for this data and the site accurately represented it.

12. Complaint:

It is grossly misleading for the website (on the Coal Seam Gas and Water page) to state that
“Robert Caine” of Origin Energy has estimated water extraction of between 666GL and
5400GL/year.

The complaint alleges:

Robert Kane’s name was misspelled as Robert Caine;

The ABC attributed an assessment of water use to Mr Kane which was actually a calculation
made by The Water Group based on information provided by Mr Kane to an industry publication
Gas Today; and
The methodology applied by The Water Group is flawed, producing a maximum figure that is in
error to a “staggering” magnitude.

The misspelling of Robert Kane’s name

The origin of the error in spelling Robert Kane’s name was in the Gas Today article. This incorrect
spelling was repeated by the Water Group, and again by the ABC. It has been corrected. It was
reasonable to rely on the spelling used by The Water Group and by Gas Today and the error is not
material.

The attribution of the estimate in the graphic and footnote

The original Gas Today story stated:

“According to Origin Energy Senior Engineer Water Management Robert Caine (sic), by-
product water on an individual wells can vary between 0.1 mega litres per day (ML/D) and
0.8 ML/d.”

The Water Group document in Appendix 3 stated:

“Original estimates of how much groundwater could be produced were derived from a limited
amount of published information ....(including) In Gas Today Magazine ... (Kane) is quoted as
saying that bores will produced (sic) between 0.1 ML/day to 0.8ML/day. For a production life of
15 years and 18,500 bores for 0.1 ML/day this results in a figure of approximately 10,000GL and
for 0.8ML/day 81,000GL.”

The graphic underneath the heading “The full story on CSG water use” originally attributed an
estimate up to 5,400 GL to “Robert Caine (sic) from Origin Energy”.
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The footnote said: “Robert Caine(sic), Origin Energy Senior Engineer Water management quoted in
'Gas Today' May 2009 estimating 10,000GL to 81,000GL over 15 years cited by "Water Group" advice
to Federal Environment Minister Tony Burke”.

The Water Group’s original document (Appendix 3) clearly showed that the calculation,
methodology and some of the critical assumptions used were from The Water Group and not Mr
Kane. By attributing the estimate to a senior engineer in a CSG company, the estimate was given
greater credibility, which could have misled readers.

It was also misleading to describe the 666 to 5,400 gigalitres per annum estimate as “Water Group
advice”. The estimate presented to the Minister in the body of the advice was the 468.8 to 1,500
gigalitres per annum estimate. The 666 to 5,400 gigalitres per annum estimate was included in an
appendix to demonstrate the methodology used to determine their advice and other published
material that The Water Group had sourced. It was not presented in the document in a way that
indicated that the Water Group considered this to be a likely range. Audience and Consumer Affairs
considered that the prominence given to this extrapolation, in the absence of details of how it had
been derived, misled readers as to its credibility.

Accordingly, Audience and Consumer Affair’s has concluded that the presentation of the Water
Group figure was not in keeping with the ABC’s standard of accuracy as outlined in section 2.1 of the
Editorial Policies. The website has been corrected and an editor’s note appended.

Correction of the footnote

While the graphic was changed following receipt of the APPEA complaint of 9 December 2011, the
footnote was unchanged apart from correcting the spelling of Robert Kane’s name.

Accordingly, Audience and Consumer Affairs have concluded that this amendment was not in
keeping with the ABC’s standard for the correction of errors as outlined in section 3.1 of the Editorial
Policies.

The methodology of the estimate

The complaint argues that the upper end of the estimate is too high to be credible and therefore
should not be included in the site. That case is based on the assertion that the water flows attributed
to Robert Kane and originally quoted in Gas Today were for initial well flows and were therefore
inappropriate to apply as a flat rate of flow over 15 years for each well.

Origin Energy in separate correspondence confirmed that is also its interpretation of the estimate.

It is widely accepted that water flows from wells decline significantly over the life of a well. For
instance, the National Water Commission in explaining its estimates notes that “water production
rates are typically highest in the initial stages of CSG production and decrease over time”
http://nwc.gov.au/__data/assets/pdf_file/0007/18619/Onshore-co-produced-water-extent-and-
management_final-for-web.pdf page 5. This report refers to one well operated by Santos where the
water production declined from 0.2 ML/d to 0.02 ML/d over 12 years. It also notes that water
volumes vary greatly from well to well and from region to region. Neither the original Gas Today
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article nor The Water Group included reference to the flows being initial flows in relation to the
estimate of 666 to 5,400 gigalitres per annum.

ABC Radio advises that the decision to use The Water Group estimate was based on the fact that it
had been published by a reputable body, was presented to the Commonwealth minister and
illustrated the more general point that there is a wide range of estimates of the possible volumes of
water that will be extracted by the CSG industry.

The ABC Editorial Policies recognise that content makers cannot verify all factual information, which
includes estimates, and it is reasonable to rely on experts. However, Origin Energy has since written
to the ABC to assert that the original estimate by Robert Kane described initial flows only and that
they consider the use of their data in this way to be seriously misleading.

In light of that ABC Radio has significantly modified the presentation of all three of the estimates
included in Appendix 3 of The Water Group advice. The new presentation makes it clear that these
estimates were inputs into The Water Group’s decision making, which help illustrate both how their
final figure was derived and the uncertainties surrounding water extraction data. It also makes the
basis of the calculation, including the crudity of the extrapolation and the weakness inherent in using
only initial flows, more transparent.

Audience and Consumer Affairs are satisfied that these changes will ensure readers are not misled
about the status or plausibility of the estimate.

Other issues

The estimate by The Water Group (based on Kane’s Gas Today quote) is not for “the whole coal
seam gas industry” as was presented in the table, it is for the ‘Big Three’. This has been corrected.

The Queensland Government estimate which appeared under the heading ‘Estimates for whole coal
seam gas industry’ is for Queensland only and not the entire industry. The new presentation of this
area of the site makes this clearer.

Audience and Consumer Affairs do not consider these errors would have materially misled readers.

13. Complaint:

According to the website’s front page, “The Queensland Government says that if CSG mining
causes groundwater levels to drop below specified ‘trigger’ points then companies must ‘make
good’ to affected water users.

APPEA alleges the site erred in reporting the triggers and that no mention is made in the
government factsheet of ‘agricultural bores’.

Further, the complaint claims that the trigger points have been misrepresented in that they are
management tools used to identify potential problems and do not automatically result in the
triggering of make-good arrangements.

The ‘make good’ policy is clearly in reference to restoring the impact of CSG operations on bores.
ABC Radio agrees, however, that this includes domestic as well as agricultural bores.
 14

The factsheet produced by the Queensland government sets out the triggers:

 “A five metre drop for consolidated aquifers such as sandstone

 a two metre drop for shallow alluvial aquifers
 the trigger threshold value for springs will be a 0.2 metre drop”

The use of the word “agricultural bores” on the website was intended to convey for the common
reader that most of these bores are used by landholders on farms.

However, ABC Radio agrees that the website needed to clarify the triggers, and the website now
says:

“The Queensland Government says that if CSG mining causes groundwater levels to drop
below specified "trigger" points then companies must "make good" to affected water users.
The trigger points are:

a five-metre drop in bore-water levels for sandstone and fractured rock aquifers;
a two-metre drop in bore-water levels for alluvial aquifers; and
a 20-centimetre drop in the water table surrounding springs.

On the remaining matters, Audience and Consumer Affairs are satisfied that the original wording
was not substantially misleading; the description in the fact sheet was intended to include
agricultural bores.

14. Complaint:

The website states in the “How much water will the CSG industry use” section that, “The make-
good arrangements have not yet been fully spelt out by government.”

The complaint claims that the make-good arrangements have been made clear.

According to the document Protecting groundwater and the environment, the Queensland Water
Commission will “assist in negotiations regarding ‘make good’ arrangements when more than one
CSG operator is involved”:

“If water extraction by a CSG operation is affecting an existing water bore, then the responsible CSG
company must undertake restoration measures to restore the bore’s capacity to supply water, or
provide the bore owner with an alternative water supply.

The actual restoration measure will be negotiated between the bore owner and the CSG company.
Restoration measures may include:

• adding a rising main to lower the pump setting in the bore, increasing the water column
above the pump

• improving the pressure at the bore head, including new headworks and piping, if the
affected supply is artesian

• changing the pump so that it is better suited to the decreased water level in the bore
 15

• deepening the bore to allow it to tap a deeper part of the aquifer

• reconditioning of the water bore to improve its hydraulic efficiency

• drilling a new bore

• providing an alternate water supply.

The bore owner and CSG company may also agree to a monetary settlement.”

The fact sheet indicates that the Queensland government considers the make-good arrangements
are spelt out. It outlines procedures for identifying impacts on bores and resolving disputes about
make good arrangements. These include, in addition to those listed above, provisions in the Water
Act for the Queensland government to declare ‘cumulative management areas’, so it can assign
responsibilities to individual companies where more than one company’s operations may have
affected an aquifer and for unresolved disputes to be referred to the Land Court.
http://www.derm.qld.gov.au/environmental_management/land/documents/protecting-
groundwater.pdf

ABC Radio advised that there is uncertainty as to how the “make good policies” will work,
particularly where more than one operator is involved. For instance the Queensland Farmers’
Federation in its submission to the Senate Inquiry noted:

“The (Act) ... provides for an adaptive management approach backed by requirements on
project companies to ‘make good’ on any impacts on farm.

Landowners are yet to be convinced that this adaptive management process will ensure that
companies will make-good for bores being unable to supply water in the quantities and
quality required.

https://senate.aph.gov.au/submissions/comittees/viewdocument.aspx?id=454855f9-b37c-442a-
9586-6f56b3385e35

Similar reservations have been expressed by The Basin Sustainability Alliance and the international
agricultural food and agribusiness banker Rabobank.

However, in Audience and Consumer Affairs’ assessment there is a material difference between
saying that a set of arrangements has not been ‘spelt out’ and saying that some are concerned the
arrangements may not work.

Accordingly, Audience and Consumer Affairs have concluded that the statement “The make-good
arrangements have not yet been fully spelt out by government” was not in keeping with the ABC’s
standard of accuracy as outlined in section 2.1 of the Editorial Policies.

The website has been corrected, more detail about the make-good arrangements has been included
and an editor’s note appended.

15. Complaint:

The Coal Seam Gas and Water page says that: “While there are wild disparities in the estimates of
CSG’s water use, even the conservative numbers will test the sustainability of Australia's
 16

underground water reserves.” The complainant argues that the numbers referred to are not
conservative and in any event will not test the sustainability of water reserves.

This statement is an analysis of the possible consequences of water extraction by the CSG industry.
As such it is not verifiable but should none the less be based on demonstrable evidence. There is a
substantial public debate among experts and stakeholders about the consequences of CSG
extraction on Australia’s underground water reserves. ABC Radio provided the following
information in support of their analysis:

The unanimous interim report into the impact of mining coal seam gas on the management
of the Murray Darling Basin by the Senate Rural Affairs and Transport References Committee
stated (November 2011):

“2.58 The committee recommends that, given the degree of uncertainty about the
long-term consequences of the CSG industry on the water resources of the Great
Artesian Basin, that the Commonwealth not give any further approvals for
production of CSG in that part of the Murray-Darling Basin overlying the Great
Artesian Basin pending the completion of the Queensland Government's regional
groundwater model and the CSIRO & Geoscience Australia basin scale investigation
of water resources.”

The National Water Commission (CSG position statement December 2010):

“The commission is concerned that CSG development represents a substantial risk to

sustainable water management given the combination of material uncertainty about
water impacts , the significance of potential impacts and the long time period over
which they may emerge and continue to have effect”

Geosciences Australia (Sept 2010)

“We have noted there the current groundwater modelling is inadequate in terms of
scale and detail to identify the impacts of multiple CSG developments on
groundwater interactions in the GAB.”

CSIRO “Water Availability in the MDB” (2008):

“Current groundwater extraction is assessed as unsustainable in the Condamine,

Border Rivers, Lower Namoi…

The Federal Government’s Water Group said “monitored groundwater extraction in the
Condamine-Balonne for 2004/05 was 160 GL/y” and the rate of extraction exceeded
recharge by nearly 40%.

They concluded that “if groundwater extraction … were allowed to increase to the current
entitlement levels, the system would be severely over-allocated and additional streamflow
impacts would occur.”
 17

Resources Minister Martin Ferguson stated that the Coal Seam gas industry had grown too
quickly and needed to be developed according to scientific principles, the Australian’s chief
political correspondent Matthew Franklin reported:

“The nation's top science organisation, the CSIRO, appears to have given MPs mixed
messages about the risks involved in CSG mining, producing information sheets
suggesting the process is low-risk but conceding conclusions cannot be drawn about
the cumulative effect of multiple wells on water systems.”

The document cited by the complainant to suggest that CSG will not impact the
sustainability of groundwater is a 12 page summary of a National Land and Water Resource
Audit Water Resources in Australia by the National Heritage Trust published in 2001.

This document does not discuss sustainability of groundwater in any detail, nor does it do so
in the context of the current CSG debate or the Murray Darling Basin plan.

The claim that this document says, “Australia can sustainably use about 26,000GL of
groundwater” is not correct. It says, “Australia has about 26000 GL of groundwater that
could be used on a sustainable basis”.

On review of the material provided by ABC Radio, Audience and Consumer Affairs have concluded
that there is ample evidence that experts and government bodies believe that the volume of water
which is likely to be extracted by the CSG industry will present a challenge to the sustainability of
groundwater resources.

16. Complaint:

The Coal Seam Gas and Water page says, “The forthcoming Murray Basin Plan will set limits on
groundwater extraction, including by the CSG industry. The states must enact these limits by
2019.”

The complainant notes that the Basin Plan will set a sustainable level of water use without
determining how the water is used or who uses it, which is the responsibility of the states.

The limits that will be set by the Murray Darling Basin Authority (MDBA) will include the CSG
industry as they will include every other water user. The states have until 2019 to legislate for those
limits.

Audience and Consumer Affairs are satisfied the meaning an ordinary reader would understand is
that the CSG industry would be included within the overall limits, and would not necessarily be
specifically identified.

17. Complaint:

In the section ‘What’s in all that water?’ (on the website’s homepage), reference is made to CSG
water as being “very salty”.

The site originally said, “The water is very salty and contains many chemicals, radionuclides and
heavy metals that occur naturally”.
 18

APPEA argue that “very salty” is an exaggeration and is misleading. The complainant also argues
that the wording implies radionuclides and heavy metals normally occur in all CSG water, which is
not the case.

ABC Radio have pointed out that the industry publication Gas Today referred to CSG water as having
“a very high salt content…” (CSG water : quenching the industry’s thirst, May 2009). Further, the
Queensland Coordinator General observed that “Coal Seam gas water typically contains significant
concentrations of salt” (CG report – APLNG p106).

The complainant argues that CSG water is considerably less salty than seawater on average and
should be described as “mildly salty” or “brackish”.

In Audience and Consumer Affairs’ view there is no definitive distinction between “mildly” and
“very” salty. It is well established that salt in CSG water is a considerable environmental and
management issue. CSG operations require desalination plants and the disposal of leftover salt is an
ongoing and unresolved problem. While we accept that salt levels vary and are usually lower than
seawater, in our view it is fair and reasonable to say – as a generalisation – that CSG water is “very
salty”.

However, Audience and Consumer Affairs agree that not all coal seam gas water contains heavy
metals and radionuclides. The site has been changed to read:

“The water that's pumped from the ground as part of the coal seam gas mining process is
very salty and contains a range of naturally present chemicals. It may also include heavy
metals and radionuclides.”

While unfortunate, in the view of Audience and Consumer Affairs this error in the context used was
not material to an understanding of the subject.

18. Complaint:

In the section, “What’s in all that water?” a box labelled “toxic water release” leads to an article
on the release of treated CSG water into the Condamine river from APLNG’s Talinga water
treatment facility. APPEA claims there is no evidence that the releases from APLNG’s Talinga
water treatment facility are toxic.

The complaint relates to content that exists on several pages of the site, and alleges that the ABC
has incorrectly applied the Australian and New Zealand Environment Conservation Council
(ANZECC) guidelines.

The original ABC story and the website references to it were predicated on a misunderstanding that
ANZECC guidelines for aquatic environments should be applied to the APLNG discharge into the
Condamine River, and that DERM should have insisted on applying ANZECC guidelines to the
discharge water. Conclusions that flowed from this misunderstanding were incorrect and the site has
been substantially changed to address these issues.

While Audience and Consumer Affairs has concluded that the material presented on the site was
incorrect and required correction, we have determined that these errors occurred notwithstanding
the reasonable efforts made by ABC Radio to ensure accuracy.
 19

This point is important because ABC editorial standards for accuracy place great weight on the
efforts made to ensure that material facts are accurate and presented in context. Reasonableness is
to be judged by taking into consideration the relevant circumstances at the time the report was
prepared. Where reasonable efforts have been made, the accuracy standard will not have been
breached, even if information is later found to be wrong.

It is therefore necessary to set out in some detail the circumstances in which this material was
prepared and the efforts made by ABC Radio to ensure accuracy.

In August 2011 ABC Radio became aware of publicly available data from APLNG that showed that the
company had discharged into the Condamine River water that contained cadmium and boron. The
concentrations appeared to be approximately three times over the trigger points set out in the
ANZECC guidelines.

The reporter approached an acknowledged academic expert and asked him for his views on the data
and “whether the Queensland government might have assumed dilutions of the chemicals into the
river which would reduce the potential risk... and whether this is fair and reasonable” (2 Sept 2011).

In his reply the academic noted the Queensland Government had applied Australian Drinking Water
Guidelines (ADWG) in its environmental authority for the project but “better guidelines in this
situation would be the ANZECC Freshwater Guidelines.... To comply with the (Environmental) Act the
discharges should not exceed the ANZECC Freshwater Guidelines”.

Another ABC reporter then approached the Queensland Department of Environment and Resource
Management (DERM) which is the appropriate regulator. She wrote to DERM on 19 October 2011
alerting them that she was writing a story and that:

“Based on a report from APLNG (the Talinga Water Treatment Facility Discharge Water
Quality Report) they are discharging water containing contaminants that exceed the
environmental guidelines (ANZECC) into the Condamine River.”

DERM responded on October 25:

“The EA requires released water to meet certain guidelines to protect human health and
impacts on the environment. The guidelines to protect human health were formulated in
consultation with Queensland Health.

The Australian and New Zealand Guidelines for Fresh and Marine Water Quality 2000 are
designed to protect a range of aquatic ecosystems across a variety of conditions. Whilst
these guidelines are not referenced in APLNG’s EA, site specific conditions were included to
manage environmental impacts to the Condamine River, which must be monitored on a
weekly basis.”

The reporter then outlined the details of the boron and cadmium findings and asked DERM by email
on 26 October 2011:

“Can you please provide details of the environmental guidelines you used to set the release
limits for the protection of environmental values, referencing the example cited above (Boron
and Cadmium)? Did you specifically use the ANZECC guidelines? Could you please provide the
 20

details of the site specific conditions that were included/used to manage environmental
impacts on the Condamine River?”

On 3 November DERM sent the ABC a media release, which in part stated:

“Analysis of source CSG water at the time APLNG’s environmental authority was issued did
not identify the presence of boron or cadmium.

“However ... the human health guidelines for these compounds were applied to the
approvals ....

“The monitoring program ... requires ongoing testing for boron and cadmium.

“It is standard practice to amend environmental authorities if the composition of the source
CSG water changes which results in a change in the potential contaminants released to the
environment. This change would adopt relevant standards such as to enforce the 95%
environment protection level under the ANZECC guideline.

Recently, monitoring has detected low-level boron and cadmium in source CSG water. These
detections have been below the ADWG guidelines and within environmental authority limits.
To ensure any potential impact on environmental values are managed DERM is in the course
of issuing a notice concerning the amendment of the EA to apply standards under the
ANZECC guidelines in relation to boron and cadmium.”

This seemed to ABC Radio to be confirmation that DERM considered the ANZECC guidelines relevant
and that DERM had not considered those guidelines in its Environmental Approval.

In Audience and Consumer Affairs’ view, it is significant that the response from DERM, while at best
ambiguous, certainly does not challenge the reporters’ assumption that it is relevant to apply the
guidelines in this situation.

ABC Radio notes that their view that the ANZECC guidelines were relevant was reinforced by a
report written by the Queensland Coordinator General. In his November 2010 report into the APLNG
project the Queensland Coordinator General compares source CSG water (i.e. before it is treated)
with various guidelines, including ANZECC guidelines. A table compares levels of toxicants in CSG
water with ANZECC guidelines for aquatic ecosystems and states:

[T]he stated contaminant concentrations of CSG water also exceed the ANZECC water quality
guidelines for discharge to aquatic ecosystems in respect of some contaminants.

However the EIS [from APLNG] proposes that all releases to the open environment, whether
to surface or groundwater or to land will be treated before discharge, to relevant water
quality standards.”

ABC Radio also notes that in relation to the EIS examined by the Queensland Coordinator General he
stated (http://www.deedi.qld.gov.au/cg/resources/project/curtis-lng/queensland-curtis-lng-project-
cg-report.pdf):
 21

“I note that the EIS reports the CSG water contaminant concentrations exceed many
contaminant guideline limits for the protection of aquatic ecosystems and for irrigation uses.
According to information supplied by the proponent the average concentrations of many
Contaminants found in CSG water exceed ANZECC83 2000 water quality guidelines for
discharge to aquatic ecosystems.

Average concentration of contaminants, for which the proponent found guideline limits to be
available, are provided in the table below.”

The Queensland Coordinator General observed that the CSG company had stated it would be
matching these standards prior to the release of water.

On the basis of the understanding that the ANZECC guidelines were relevant and had been
exceeded, ABC Radio wrote on the website, inter alia, that:

“The Queensland Government ignored environmental safety guidelines when it gave two
companies permission to release toxic water into the headwaters of the Murray Darling
Basin.”

And:

“The approval ... allows the companies to release 17 chemicals and heavy metals into the
Condamine River south of Chinchilla at levels considered to be toxic to animals, plants and
micro-organisms that live in freshwater ecosystems under the ANZECC guidelines.”

We note that the material initially published on the website did not suggest that the company had
breached any of the environmental conditions set out in the Environmental Authority .The essence
of the story was that the conditions set by DERM in that Environmental Authority were inadequate
in that they allowed for the release of ‘toxic’ water. The site implicitly defined toxic water as water
that has chemicals in concentrations greater than the trigger points referred to in the ANZECC
guidelines. It also asserted that for two chemicals, boron and cadmium, the discharge water
contained levels of those chemicals that were three or more times the levels identified in the
ANZECC guidelines as trigger points for slightly to moderately disturbed aquatic systems (i.e. the
Condamine River). We further note that the basis used by DERM to determine the allowed levels of
various chemicals, including toxic chemicals, in the discharge water was the Australian Drinking
Water Guidelines (ADWG).

To the extent that use of the term ‘toxic’ was predicated on the understanding that contaminant
levels in the discharge water exceeded what is permissible under ANZECC guidelines, the use of that
language was incorrect and misleading due to a lack of context and qualification. While the water in
the Condamine River does contain toxic chemicals, notably cadmium and boron, the levels are well
within Australian Drinking Water Guidelines. Audience and Consumer Affairs are aware of no
evidence that these chemicals have been found in the river at levels above the ANZECC guidelines. In
Audience and Consumer Affairs’ view, for something to be described as toxic, without qualification,
it should have the properties and effects of a toxin or a poison. There is no evidence that the water
has caused harm to living organisms in the river.
 22

Furthermore, in relation to whether it was accurate to say that the Queensland Government ignored
environmental safety guidelines, it should be noted that notwithstanding the impression given by
DERM in the material they provided to reporters working on this story, the Environmental Authority
(EA) does reference the ANZECC guidelines in the context of applying the guidelines to the Receiving
Environment Monitoring Program (REMP). According to DERM, boron and cadmium were not
included in that list because they were not found in the initial testing of the CSG water that was
conducted before the Environmental Authority was granted. The Environmental Authority does,
however, include references to applying the ANZECC guidelines in the monitoring program.

As indicated earlier, in assessing whether ABC Radio has breached ABC Editorial Policies in relation
to accuracy, Audience and Consumer Affairs must consider whether reasonable efforts were made
to ensure the accuracy of the content in relation to the discharge water.

We note repeated actions as outlined above by the reporters to check the accuracy of the
information. Initially - and in our view, appropriately - a qualified and independent scientist was
approached. His advice indicated strongly that the ANZECC guidelines were relevant and that they
should have been applied to the discharge water.

The reporters then approached DERM on several occasions with specific questions that clearly
outlined the allegation. The reporters repeatedly pursued responses from DERM. DERM’s response
was ambiguous at best and did not challenge the relevance of applying ANZECC guidelines to the
discharge water.

The Queensland Coordinator General’s reports also reinforced the impression that the ANZECC
guidelines could be applied to the discharge water.

On balance, Audience and Consumer Affairs are satisfied that reasonable efforts were made. While
Audience and Consumer Affairs are satisfied that the accuracy standards were not breached, it is
clear that a significant material error was made. The site has been corrected and an editor’s note
published.

19. Complaint:

The water cycle graphic on the “What happens to all the water?” page depicts a water treatment
plant as being little more than a shed. In fact, these are large and expensive high‐tech facilities.
QGC, for example, will spend around $1 billion on water management.

The graphic is schematic and is not intended to describe the actual appearance of a water treatment
plant. In Audience and Consumer Affairs view, a reasonable reader would assume that the actual
plant would be a more substantial structure.

20. Complaint:

The case study on CSG water facilities near Chinchilla says farmers “will be fined $160 a megalitre
if they don't take the water they have agreed to. The intention is to force farmers to build dams on
their properties so they can store the water, thereby transferring the cost of CSG water storage
onto the user.” APPEA complains this description is “inaccurate and biased”.
 23

This section accurately describes the process by which farmers can commit to purchasing water and
the conditions under which they accept that water. It is described as a “carrot and stick” approach in
as much as it includes both incentives and potentially penalties (fines) for non compliance with
agreements. Clearly the intention of the companies is to create a scheme in which farmers will build
dams to store water. However, it is not demonstrated how the companies can “force” farmers to
participate in the scheme. They may be strongly encouraged but “forced” implies an element of
coercion which is not established.

The website text has been changed to:

“The intention is to encourage farmers to build dams on their properties so they can store the
water, thereby transferring the cost of CSG water storage onto the user.”

and an editor’s note has been published which reads:

“The coal seam gas and water page previously reported that the intention of selling water to
farmers at cheap prices was to ‘force’ the farmers to build dams on their properties. That has
been corrected to say the intention is to ‘encourage’ farmers to build dams.”

In Audience and Consumer Affairs’ view, this was an unfortunate way to characterise the process
and Radio changed the copy following receipt of the APPEA complaint.

However, Audience and Consumer Affairs are satisfied that a reasonable reader would not have
been materially misled by the use of the word because the process is otherwise accurately and fairly
described.

21. Complaint:

The website says, “This carrot and stick model delivers farmers insurance against drought and it
also guarantees the mining companies they can dispose of their water.” The use of the phrase
‘carrot and stick’ puts a sinister interpretation on a project that clearly benefits all parties.

As noted above, Audience and Consumer Affairs are satisfied that “carrot and stick” is a fair way to
describe a regime which involves both incentives (cheap water) and penalties (fines).

22. Complaint:

The Department of Environment and Resource Management document CSG/LNG Compliance Plan
2011 Update: January 2011 to June 2011 is selectively referenced on the “Who regulates the coal
seam gas industry?” section of The Promise webpage. The website ignores the fact that no
landholder bores had been found to be impacted by CSG water extraction.

The report covered many aspects of compliance – land access issues, issues around TEP’s
(transitional environment programs) to authorise discharge of CSG water into rivers, requests to
discharge water from dams, questions around vegetation clearing, noise, sewage and spills etc.

In short, the regulation is not focused on bores, nor did the infographic go into the details of the
“compliance related incidents” or to highlight that Santos, QGC (Queensland Gas Company) and
Arrow were mentioned for contravening their operational conditions.
 24

The report does state “no landholder bores had been found to be impacted as a result of CSG
extraction” but was not included because it was not considered germane to the infographic.

The full quote to which the complaint refers is qualified with the following:

“No landholder bores had been found to be impacted as a result of CSG extraction and seven were
under investigation” http://www.derm.qld.gov.au/environmental_management/coal-seam-
gas/pdf/csg-lng-compliance-update1.pdf .

Audience and Consumer Affairs have concluded that the report does not constitute definitive
evidence that CSG extraction is not having a detrimental effect and its inclusion was not necessary.

23. Complaint:

Because Coal Seam Gas: By the Numbers is using inflated water production figures, its calculations
of salt production are also grossly inflated.

The complaint states that the likely figure for salt production is 10 million tonnes but does not
source or explain the figure.

Salt production estimates are highly variable – the website’s intention was to publish a range of
estimates based on reputable sources. Those estimates ranged from 7.8 million tonnes (below the
estimate in APPEA’s complaint letter) to 154 million tonnes, which was described as a “worst case
scenario”. As with the water estimates, given the uncertainties the site chose to publish a range of
credible estimates rather than choose one contestable number.

Audience and Consumer Affairs have concluded that the website’s methodology for calculating
those estimates was sound and transparent, and reasonable efforts were made to ensure their
accuracy.

24. Complaint:

The website fails to mention that the salt content and chemical composition of CSG water is in
many cases similar to bore water in parts of the Surat Basin.

In Audience and Consumer Affairs’ view it was not necessary to compare CSG water with bore water.
In relation to salt, there is no dispute that the level of salt in CSG water combined with the volumes
that are produced means that the disposal of that salt is a serious management issue.

25. Complaint:

The website fails to mention a major industry project aimed at dealing with salt production.

The major project referred to is a salt production trial plant in South Australia, which has not been
built and has not yet been proven to be an economically viable solution for waste salt originating in
Queensland:
http://www.penrice.com.au/pdf/ASX%20Penrice%20GE%20Consortium%20241011%20Final.pdf

It is worth noting that the site states:

 25

“These (the various types of salt) can be converted into the salts used in many chemical and
industrial applications. You can also make table salt.”

And

“All the coal seam gas companies say they are pursuing options to sell their waste salt.”

On review, Audience and Consumer Affairs are satisfied that the site accurately presented that salt is
a major issue that both industry and government are actively addressing, but which is yet to be
resolved.

26. Complaint:

‘The promise?’ page begins, “Exploration, extraction and export will bring undoubted economic
benefits, but will also come at an environmental and social cost”.

APPEA allege that this is editorialising, and that it does not accept that environmental costs will
“outweigh” the economic benefits and does not accept that there will be an overall social cost.

This sentence does not imply that the environmental and social costs will outweigh the economic
benefits. It merely states that there will be benefits and there will be environmental and social costs.
The site does not express an opinion on whether one outweighs the other.

27. Complaint:

‘The promise?’ page refers to three projects that “received state and federal approval last year” as
being “Origin Energy/Conoco Phillips, QGC and BG International/Santos”. In fact, QGC is the
wholly owned subsidiary of BG International and Santos is not in partnership with BG. Further,
not all projects were approved last year.

ABC Radio advises that this was a typographical error and agrees it could have been confusing.

The copy has been corrected by Radio and now reads:

“The infographic below provides estimates and details of the windfall exports, income tax
and exports that coal seam gas projects will generate, with a focus on three projects from
Origin Energy/Conoco Phillips, Santos and QGC that received state and federal approval in
2010/2011.”

Audience and Consumer Affairs have concluded that the error was not material.

28. Complaint:

‘The promise?’ page states, “The coal seam gas industry is rapidly expanding, and proponents say
it will deliver economic benefits for regional towns and cities, as well as the country as a whole.”

This implies that the economic benefits are being touted solely by the CSG industry. But it is not
just the industry that says CSG will deliver major economic benefits. Governments, economists,
local chambers of commerce and even some opponents of the industry recognise its economic
benefits.
 26

The use of the question mark brings the benefits into question.

Audience and Consumer Affairs do not agree that the statement implies that only the industry is
suggesting that CSG will benefit the country.

Likewise, we do not believe that using a question mark implies any editorial judgement about the
proposed benefits of the industry. Any promise brings with it a question of whether it will be
fulfilled, which is at the heart of the current debate about CSG.

In relation to job creation, a reasonable reader would assume that if the industry’s future expansion
will create thousands of jobs, as the site says, then it will have already created many jobs.

29. Complaint:

‘The promise?’ page in the section “Who regulates the CSG industry?” says, “Last year,
Queensland Premier Anna Bligh set up the Coal Seam Gas Enforcement Unit.” In fact it is called the
“LNG Enforcement Unit”.

While the unit is called the LNG Enforcement Unit, it is frequently referred to as the CSG/LNG
enforcement unit by Queensland Ministers and in government publications.

See:

http://www.cabinet.qld.gov.au/MMS/StatementDisplaySingle.aspx?id=75524

http://mines.industry.qld.gov.au/assets/land-tenure-pdf/PGGD04-completion-fraccing-info-
sheet.pdf

http://www.cabinet.qld.gov.au/mms/StatementDisplaySingle.aspx?id=76635

For ease of communication, the website referred to the CSG Enforcement Unit. However, ABC Radio
has now changed the text to CSG/LNG Enforcement Unit.

In Audience and Consumer Affairs’ view, the original reference was reasonable and not materially
misleading.

30. Complaint

The section ‘Who regulates the gas industry?’ stated: “The ABC has analysed the enforcement
unit’s first year of operations, and can reveal that ‘scheduled’ inspections – where companies have
forewarning of a visit – have uncovered no regulatory breaches. However, unscheduled
inspections have showed up 45 compliance-related incidents.” The complaint alleges that this text
implies all 45 incidents are actual breaches, and that the section suggests CSG companies do the
wrong thing when they think they can get away with it.

Audience and Consumer Affairs have concluded that the original presentation of information in this
section, which was based on the Department of Environment and Resource Management’ CSG/LNG
Compliance Plan 2011 Update (http://www.agforceqld.org.au/file.php?id=1032&open=yes ) failed
to provide the important context that some of the ‘unscheduled’ visits were as a result of the CSG
 27

self-reporting compliance-related incidents, and did invite readers to conclude that CSG companies
were in some way caught out by ‘unscheduled visits’.

This section also failed to provide context on the outcomes, where available, of the 45 compliance-
related incidents, some of which have already been concluded and no further action taken.

In addition, Audience and Consumer Affairs were concerned that the text and table only highlighted
11 scheduled audits. The Update states that a wide range of scheduled audits were in fact made:
“DERM has conducted 11 inspections of level 1 activities and 20 inspections of level 2 activities ...
DERM has conducted nine dredging inspections of the construction phases of LNG facilities .... DERM
has conducted 11 island inspections of the construction phases of LNG facilities ...”

Further, the Update states that there was one warning letter issued for level 2 activities and in the
section “Audit follow-up and enforcement’ that “DERM has issued three warning notices as a result
of detecting low level compliance during proactive compliance activities”. This was at odds with the
statement on the website that “The ABC has analysed the enforcement unit's first year of operations,
and can reveal that 'scheduled' inspections – where companies have forewarning of a visit – have
uncovered no regulatory breaches.”

Audience and Consumer Affairs concludes that the lack of context in the original text which failed to
make clear that unscheduled audits were in part self-reported; combined with the information
included in the table, implied that the CSG industry was in some way ‘caught out’ by unscheduled
audits. The section was not in accordance with the accuracy provisions of section 2.1 of the ABC’s
Editorial Policies.

A number of changes have now been made to the presentation of the information in this section.
They include providing data on all inspections, modifying the text to clarify the context of the various
inspections; reworking the layout of the infographic and appending an editor’s note to the website.

31. Complaint:

A section of ‘The Promise?’ page says, “According to Origin Energy, approved coal seam gas and
liquefied natural gas projects – including gas field operations, LNG plants and associated
infrastructure – could generate 39 million tonnes of carbon dioxide equivalent each year.”

There are two parts to this complaint. Firstly that Origin Energy did not say that CSG/LNG projects
could generate 39 million tonnes of CO2-e/yr. That number, drawn from an Origin Energy EIS
included non CSG/LNG projects.

Secondly, it alleges that this section lacks balance and misleads readers on the impact of the
industry on Greenhouse Gas (GHG) emissions because it does not present the emission-reducing
benefits of LNG from replacement of coal and oil.

ABC Radio notes that they first became aware of the calculation of 39 million tonnes of CO2-e/yr in
the Coordinator-General’s report on the environmental impact statement of the Australia Pacific
LNG Project. That report references the original APLNG EIS Vol 5, Chapter 13,section 8, which states:
 28

“For this cumulative impact assessment, the impact of all major projects in the region on
state and national GHG emissions inventories was assessed in comparison to the year 2007.
The impact on Australia’s projected GHG emissions for 2030 was also considered.”

It goes on to note projects which were excluded from the calculation because no reliable data was
available. These included the Gladstone Steel Plant, the East End Mine Expansion, the Wiggins Island
Coal Terminal and the Yarwun Alumina Refinery – none of which are CSG/LNG related
developments. Shortly after, it compares the same data with estimates of total Australian GHG
emissions forecast in the Garnaut Report:

“A second scenario considers if all projects were operational in 2030. From the Garnaut
Report (Garnaut 2008), Australia’s GHG emissions under a business as usual scenario without
a CPRS could reach approximately 800 Mt CO2-e. If it is assumed that all facilities would
continue their GHG emissions at their current or presently projected levels then total GHG
emissions from the major projects in the Gladstone region represent 4.9% of Australia’s net
GHG emissions. Of this 4.9%, 3.2% is related to LNG projects, which could avoid global
emissions of 190 Mt CO2-e/yr based on 42 Mtpa of export LNG substituting for coal in power
generation (refer to section 7). This avoidance is equivalent to 24% of Australia’s emissions
in 2030.” (emphasis added)
http://www.aplng.com.au/pdf/eis/Volume_5/Vol_5_Att_31_GreenhouseGasAssessment.pd
f (APLNG EIS Vol 5, Chapter 13, section 8, p 35)

In Audience and Consumer Affairs’ view, this clearly suggests that a proportion of the projects for
which there were GHG estimates were not LNG related. A table attached to this section breaks down
the individual sources of emissions and includes developments that do not seem to be linked to the
CSG/LNG industry such as the Boyne Smelters Reduction Line, Gladstone Pacific Nickel and the
Moura Link Railway. It is worth noting that the table itself does not state whether projects are
CSG/LNG related or not.

In relation to the complaint that the section lacks balance and was misleading in that it did not
accurately represent the benefits of LNG as a cleaner alternative to coal and oil, Audience and
Consumer Affairs have assessed this aspect of the complaint against the accuracy standard 2.1,
specifically whether the site presents the impact of the CSG industry on Australia’s output of
greenhouse gases in context.

The EIS from which the data on GHG emissions were drawn also prominently argued that the overall
impact of the developments would be positive to GHG emissions. It estimates that by using this LNG
(of all the Queensland projects) to replace coal powered electricity generators 190 MtCO2-e/yr of
GHG could be avoided, equivalent to 24% of Australia’s emissions in 2030 (based on Garnaut’s
business as usual estimate).

While there is legitimate debate over how much positive impact CSG can have on total global
emissions and the specific estimates made in the EIS are contestable, the belief that LNG will have a
positive effect is one of the key reasons cited in public debate for support for the industry. It is a
position supported by many reputable scientists and public officials, including the UN Panel on
Climate Change.
 29

This section links to a story titled “CSG emissions ignored in greenhouse targets”
(http://www.abc.net.au/news/2011-11-24/greenhouse-gases-and-coal-seam-gas/3685964) which
repeated the figure of 39 Mt CO2-e/yr and made the point that this figure had not been included in
Federal government calculations for Australia’s compliance with Kyoto targets. It quoted the
department of Climate Change’s comment that such projects have “an intrinsically low CO2 content”
but the overall conclusion of the article was that the effect of the various LNG projects would be
detrimental to efforts to meet Kyoto targets. There was no reference to the claims of the EIS that
the projects could have a significant positive impact on GHG emissions by displacing coal fired power
stations overseas.

Audience and Consumer Affairs have concluded that it was misleading to quote and highlight the
EIS’s calculations of its emissions without also referring to the EIS’s calculations of the estimated
GHG benefits derived from displacing coal in Australia and overseas. The argument that LNG will
reduce global GHG emissions is central to the justification for the industry’s development. Omitting
this information may have misled readers to understand that the overall effect on GHG emissions of
the industry is wholly negative.

In summary, in relation to the use of 39 Mt CO2-e/yr Audience and Consumer Affairs concludes the
number was materially inaccurate and reasonable efforts were not made to verify the figure and was
not in keeping with section 2.1 of the ABC Editorial Policies.

In relation to the presentation of GHG emission estimates without reference to estimates of

potential benefits to GHG emissions, Audience and Consumer Affairs concludes the data was
presented without adequate context in a way that could materially mislead readers and was not in
keeping with section 2.1 of the ABC Editorial Policies.

The 39 Mt CO2-e/yr figure and associated figures have been recalculated. Estimates of benefits that
relate to that figure as well as reference to the debate over the calculation of GHG emissions in
relation to CSG extraction have also been included. An editor’s note has been appended to the
website.

32. Complaint:

In relation to the Origin Energy/Conoco Phillips data presented, 572,000ha is termed “total area
covered by gasfield”.

The complaint alleges this is misleading because only 2% of this area would be covered by wells
and associated infrastructure.

The term “gasfields” is commonly used by CSG/LNG companies, including Origin Energy/Conoco
Phillips (APLNG) to describe the tenements.

Furthermore, read in context an ordinary reader would infer that the statistic refers to the whole
area of the tenements and not just those surface areas physically affected by infrastructure.

33. Complaint:

The section also says 32,800ha is the area of “Predicted ‘direct’ and ‘indirect’ disturbance to
gasfield by mining company”.
 30

The complaint alleges that this implies that the project would impact on 32,800 ha of high
conservation value.

Audience and Consumer Affairs do not agree that there is any implication the 32,800ha is of high
conservation value. There is no reference at all to the conservation value of this area.

34. Complaint:

There is no mention of the stringent conditions (secondary approvals, species management plans
etc) that apply to work associated with the 1232ha and 212.3ha covered by Environmental
Protection and Biodiversity Conservation (EPBC) Act approvals.

This refers to the same section of the website as the previous point.

The section under the heading, ‘How else does CSG affect the environment?’ begins:

“The Federal Government has given major coal seam gas companies permission to clear land
containing species and ecosystems protected under federal threatened species legislation
(the EPBC Act).

Click on the different company names in the interactive graphic below to see which
threatened species will be impacted by their activities, how much land the companies say
their activities will effect, and the maximum disturbance levels set by the Environment
Minister under the EPBC Act.”

While ABC Radio advises that the purpose of this section is to show the footprint of CSG operations,
the effect of the introduction is to suggest that threatened species will be affected by the operations
and there will be disturbance of ecosystems. There is no mention of any efforts by the authorities or
the companies to mitigate the effects.

There is no dispute that there will be disturbance of ecosystems that include threatened species but
APPEA argues that it will be significantly mitigated by a range of measures known as environmental
offsets.

Audience and Consumer Affairs conclude that due to a lack of context the data was presented in a
way that could be misleading and was in breach of section 2.1 of the Editorial Policies.

The website has been modified to include reference to environmental offsets and to the debate
surrounding their effectiveness. An editor’s note has been appended to the website.

35. Complaint:

The website states that, “At the end of the production cycle, the gas will be compressed into
liquefied natural gas (LNG) for use in electricity production.” Gas is in fact chilled to the point of
liquefaction. It is not compressed.

The website has been changed to say:

“At the end of the production cycle, the gas will be chilled into liquefied natural gas (LNG) for
use in electricity production.”
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The original wording was not materially misleading.

Impartiality

The ABC’s Editorial Policies direct that to achieve impartiality content-makers should gather news
impartially; present a diversity of perspectives; not take an editorial stance; and not misrepresent or
unduly favour any perspective.

The hallmarks of impartiality include:

Balance
Fair treatment
Open mindedness
And diversity of perspectives

A failure to achieve these in every instance does not necessarily indicate bias.

Audience and Consumer Affairs consider that the accuracy breaches outlined in the findings are
relevant to an assessment of impartiality. The omission of important context in the presentation of
carbon dioxide emissions data (31) and the failure to include reference to environmental offsets (34)
arguably had the effect of excluding a principal relevant perspective on the matters to hand. The
presentation of information relating to audits of the CSG industry (30) erroneously implied that the
CSG industry was in some way ‘caught out’ by unscheduled audits and was hiding something from
regulators. The material inaccuracies over-emphasised the negative aspects of the CSG industry, or
implied inadequate regulation by Government of the industry.

However, the website should be seen in its entirety. Overall it gave prominence to some of the most
important arguments in favour of the development of the CSG industry: that it will contribute
enormously to economic growth, employment and government revenue for the country as a whole.

It presented a diversity of perspectives. The production team approached DERM and an

independent expert on the most contentious aspect of the site – the allegation that the Queensland
government was ignoring environmental guidelines.

It is also worth highlighting that the production team accurately and clearly presented an enormous
amount of data sourced from a variety of mostly industry and government sources.

We understand that the industry feels that its projections about matters such as water use, salt
volumes, environmental effects and social impacts have more validity and should be given more
weight than those of groups such as the Water Commission, The Water Group or the Farmers’
Federation. However we believe it was a sound editorial judgement to include as many reputable
projections and estimates as was practicable.

Comparing these different data sets obviously created methodological problems but we are satisfied
that the production team presented them in an honest and fair manner and no particular
perspective was unduly favoured or discriminated against.
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Overall, while conceding that errors of judgement were made, Audience and Consumer Affairs
conclude the production team sought to gather and present information for the website in an
impartial manner.