How to write a submission to the Victorian government

You have until this Friday afternoon 10 July 2015 to get a submission in.

This is the best chance we will ever have to knock this toxic industry off before it gets a foothold in our state. Please write a brief submission by close of business Friday. A short letter is all that is required.

Below are some suggestions on how to write a submission to the Victorian Government’s Unconventional Gas Mining Inquiry

Tips are in red font colour. Terms of Reference are in black

By Cam, Friends of the Earth, and Alison, Frack Free Moriac

Submission Tip Sheet

Start by introducing yourself (a little bit about who you are/ where you live / what you do for a living / why you’re concerned about unconventional gas mining)

Make it clear in your opening statement that you do not support any form of unconventional gas mining (including coal seam gas, tight gas, shale gas and underground coal gasification)

If you live in a community that has conducted a survey, mention these results and that you and your community have removed the social licence for this industry to operate in your area and that you will never support it, no matter the potential regulations put in place.

When writing a submission it would be best to address all (of the following) terms of reference, but you can add/ remove the issues that matter to you.

(ADD – That’s right, if the terms of reference do not cover all the issues you want to talk about, then add them in, this is allowed and will strengthen your submission)

Don’t forget to recommend that Victoria ban all unconventional gas drilling permanently (and the benefits of a total ban eg. giving certainty to existing industry (agriculture & tourism), making Victoria a more attractive place for investments in these industries plus new investments such as renewables. Which will create more long term jobs in sustainable industries.

The prospectivity of Victoria’s geology for commercial sources of onshore unconventional gas.

Talk about why we would put at risk water, farmland, community health, food security, environment and jobs in other sectors such as agriculture & tourism for little or no financial gain.


The environmental, land productivity and public health risks, risk mitigations and residual risks of onshore unconventional gas activities.

We can all go to town in this section, make references to peer reviewed studies if you like or the experiences of those in the US and Queensland and that the impacts felt in QLD will be even worse here due to our more densely populated region.

The coexistence of onshore unconventional gas activities with existing land and water uses

A key issue relating to this industry is the question of its likely impacts on agricultural production and domestic and export market requirements.

Use figures from local council and government websites to show what our existing industries (agriculture in particular) are worth to the states economy and the potential for growth here and why that cannot happen if unconventional gas mining goes ahead.

If you’re a farmer talk about how the infrastructure required for gas wells (all weather access roads, cleared well pads, compression stations, evaporation dams) would make the day to day running of your farm unviable. 

Agricultural production and domestic and export market requirements

If you are a farmer, food producer or work in the agriculture industry please answer point (a) in as much detail as possible. 

The legal rights of property owners and the impact on property values; and

Any implications for local and regional development, investment and jobs

Point (c) is very important and something that we can all answer as we will all be impacted. Also the state labor government say they are a ‘jobs’ government so we need to show them and give them examples of why UCG will not create jobs but put at
risk jobs in other sectors.

The ability of potential onshore unconventional gas resources contributing to the State’s overall energy sources

Unconventional gas is a fossil fuel. By definition, unconventional gases are harder to extract than conventional gas.

an ability to provide a competitive source of energy and non energy inputs for Victorian industries

An affordable energy source for domestic consumers

Because they need to be fracked to release the gas from the coal seam or rock, the energy cost of the gas is high compared with conventional LNG. Additionally, with the government plans to export massive volumes of gas through ports in QLD, Victorian consumers will be competing with international energy prices in
coming year. So UCG is unlikely to be an affordable energy source for consumers. A much better option is to look at ways we can reduce our need to use gas (for instance through ensuring better energy efficiency standards in new homes and a government funded energy efficiency retrofit program for existing houses etc

Carbon dioxide emissions from these sources;

Use examples of emissions and fugitive emissions from UCG comparing these to renewable energy sources. Air pollution from gas treatment plants is also important to mention and it’s human health impacts.

The resource knowledge requirements and policy and regulatory safeguards that would be necessary to enable exploration and development of onshore unconventional gas resources

Give examples of why this industry (regardless of regulation) has failed to be proven safe elsewhere. Put forward that the industry has had a long time to prove that their practices are safe and yet have been unable to do so. Talk about why the industry, however much it can reduce it’s risks by regulation will always pose a rick and any risk is too great.

Further scientific work to inform the effective regulation of an onshore unconventional gas industry, including the role of industry and government, particularly in relation to rigorous monitoring and enforcement, and the effectiveness of impact mitigation responses; and

Performance standards for managing environmental and health risks, including water quality, air quality, chemical use, waste disposal, land contamination and geotechnical stability;


Relevant domestic and international reviews and inquiries covering the management of risks for similar industries including, but not limited to, the Victorian Auditor-General Office’s report Unconventional Gas: Managing Risks and Impacts
(contingent upon this report being presented to Parliament) and other reports generated by the Victorian community and stakeholder engagement programs.


How to lodge a submission

Submissions can be sent via email: or ESubmission on the government website:

Written submissions can be sent via post to:
Keir Delaney, Secretary, Environment & Planning Committee Parliament House, Spring Street, Melbourne VIC 3002

Closing date for submissions: Friday 10 July 2015.

Examples for inspiration

» Click here to download six examples of submissions, for your inspiration.

They were compiled by Frack Free Moriac, who wrote: “You are welcome to use the attached submissions, you’ll just have to put your name and address at the bottom, before sending. The submissions can be personal, how you feel about this industry. It can be technical, quoting research, or just concerns you have. You may like to edit some of the attached submission, to suit you.”

» Click here for a tip sheet which Friends of the Earth have put together (which includes how to lodge the submission), a draft submission from Cam Walker (this is to be used as a guideline, do not copy-paste) from Friends of the Earth, and an email from Ali from the Frack Free Moriac group – for your inspiration.

» Click here for an easy submissions format by Ellen Sandell.

It is important that the submission is in your own words.

Every submission against the industry will help – and shows the Government how many VOTES are at stake here. It only needs to be short and from the heart.

Interesting reading

» If you would like to see submissions already posted by Victorians, go to

You could also mention…

CSG is a hit and ruyn assault on families, communities and agricultural land. CSG is the asbestos of our time.

Health Impacts

• local children have near universal and sever skin irritations and asthma which worsens with proximity to the gas fields. Severe and recurrent nosebleeds are common.

• Severe neurological effects: McCarron found one third of children at Tara had parasthesia (abnormal sensations and numbness) and some had “abnormal movements” (central nervous damage).

• Severe effects on the unborn: US studies have shown 100% increase in neural tube defects and 30% increase in congenital hear defects. Other studies have shown under we

• Huge increase in particulates which are class one carcinogens

• Wide range of toxic chemicals which show levels 10-100x above safe levels

• Existing health reports have suffered from poor methodology such as being based on affected people volunteering information only or intermittent testing which was discontinued, and are also hampered by the confidentiality agreements

Enviromental Impacts

• release of very potent green house gases including methane, that nullify any GHG saving associated with the transition from coal to gas

• unconventional gas extraction uses masses of water, draining our scarce water resources

• aquifer contamination with toxic chemicals

• release of naturally occurring BTEX compounds and other contaminates into the atmosphere and into groundwater

• “produced water” is left in ponds that will inevitably leak or spill or sprayed on local roads

• multiple earthquakes are associated with fracking and csg globally

• toxic acid rain which strops paint off cars (Ph 4.36 McCarron)

• failure rates of gas wells increase each year

Agricultural Impacts

• contamination of water (flammable water) with toxic chemicals, leading to poisoning of livestock and contamination of our high quality agricultural industry products

• increase in groundwater and soil salinity

• depletion of groundwater

• contamination of water (flammable water) with toxic chemicals

Community Impacts

• immediate community impacts include division and mistrust, then falling property values as the industrial process occurs and health impacts start to bite, agriculture being impacted, followed by families being bought out under confidentiality agreements, and communities being closed or relocated.

• unconventional gas extraction has near universal local disapproval, is strongly resisted, and proceeding is against communities self determination


We need jobs but not ones which poison our children and destroy our future.


Where to look for more information

Lock the Gate, Australia



New York

United Kingdom


Now that you are at it – your support in shape of a comment and your signature is needed here as well:

Friends of the Earth’s petition: Ban UCG in Victoria


» Read more: Put a submission together and send it off before 10 July