A submission made by Fullerton Cove resident and architect Justin Hamilton on behalf of residents and businesses has raised major concerns with the DART energy plan for two exploratory wells.

The plan is being assessed by the federal government, who will decide if it requires their approval on top of any state response.

The Department of Environment had been due to make a decision on November 21, but has deferred ruling pending more information from the company.

Mr Hamilton said that while he was not opposed to coal seam gas mining, he believed the Fullerton Cove area’s natural resources made it too risky a prospect.

He said residents’ core concern was potential damage to groundwater resources including the Tomago sandbeds, which provide about 20 per cent of the Lower Hunter’s drinking water.

‘‘The risks to groundwater quality should be identified before they occur and in a proactive way rather than after the effects ... are found to have altered the ecosystems leaving a reactive Orica-style situation to have to endure,’’ Mr Hamilton wrote.

DART’s self-assessed application to the Department of Environment also included differences with a report on the same area by DART subsidiary Macquarie Energy in 2010, Mr Hamilton said.

While the 2010 report included 54 fauna and flora species on a checklist for review, the latest assessment identifies only 43.

‘‘These ... discrepancies leave a real question mark over the validity of any self-assessed environmental report, especially when it is produced simply as a mandatory reporting compliance item by a mining company,’’ Mr Hamilton wrote.

A DART spokesman said both figures were correct because a difference existed between the Commonwealth and state databases used.

‘‘This difference simply reflects the difference in the NSW and Commonwealth reporting and environment databases,’’ the spokesman said.

A DART spokesman said the company had also sought Hunter Water advice and ‘‘a number of studies’’ to avoid impacting on local aquifers.

‘‘Dart believes it can develop the coal seam gas resource at Fullerton Cove in a responsible and sustainable manner,’’ the spokesman said.