Don't frack the Roper.

To the Controller of Water Resources,
I am very concerned about the impact of fracking on our precious water systems. I am particularly worried by Imperial Oil and Gas’ plans to frack in the fragile Roper River catchment, a system which is treasured by people across the Northern Territory.
I am writing to ask that you reject Imperial Oil and Gas’ groundwater extraction licence application for the following reasons:
<ul>
<li>The precautionary principle dictates that you should reject the licence;</li>
<li>It is clear that there is no water available in the Cambrian limestone aquifer in the area where Imperial wishes to undertake extraction. In 2021, Minister Fyles overturned a groundwater extraction licence in the same area as Imperial’s application on the basis that the aquifer was fully allocated. Using the same reasoning, Imperial’s licence application should be rejected;</li>
<li>Relatedly, you must not apply the arid zone contingent allocation rules in the Water Allocation Planning Framework to assess the consumptive pool available for extraction in this region, as this would permit the unsustainable mining of the aquifer and could have serious impacts on the aquifer and the Roper River;</li>
<li>There is insufficient evidence to support the feasibility of extracting groundwater from the “Unnamed Base Cambrian Sandstone” or the “Neoproterozoic Jamison Standstone”. I reject the suggestion by Imperial that these aquifers are “non-competitive”. The application is highly speculative and uncertain as to the nature, location and storage of these aquifers, and makes no reference to their likely connectivity with surrounding groundwater systems;</li>
<li>Recent research undertaken by the Commonwealth indicates that there is a high degree of horizontal and vertical connectivity between aquifers in the Beetaloo Basin. This research suggests that these aquifers should be considered as an interconnected system, and that there may be risks to other parts of the groundwater system and the Roper River itself if water is over-extracted in one location;</li>
<li>The application contains no information about the storage of the aquifer/s, sustainable yields, nor the proposed allocation rules, making it impossible for the public to be properly informed about its impacts and denying natural justice with respect to the application;</li>
<li>The location of bores to be drilled are not identified in the application, which breaches the requirements of section 71B of the Water Act and common law rules of procedural fairness;</li>
<li>Given the uncertainty regarding the resource, no licences for fracking should be granted until a water allocation plan is declared which provides an estimated sustainable yield for the Beetaloo Basin as a whole.</li>
</ul>
I therefore ask that you reject Imperial’s licence.