Mill: That leaked report

Kim Booth Press Release

Leaked internal DPIW report slams pulp mill IIS impact analysis

Content Criticised As ‘Misleading’, ‘Inaccurate’ & ‘Unsubstantiated’

Download the document, here: Sept24_DPIW_Second_Seal_Response_July06_K_Booth_ATTACH.pdf

The Tasmanian Greens today (Sunday) released a leaked document apparently written by the Wildlife and Marine section of the government Department of Primary Industries and Water (DPIW), which presents a damning critique of the study done for the Gunns’ pulp mill Integrated Impact Statement (IIS) on the impact of effluent upon nearby seal colonies, which the Department’s response periodically criticises as presenting material which is “misleading”, “inaccurate”, and “unsubstantiated.”[1]

Greens Shadow Pulp Mill spokesperson and Member for Bass Kim Booth MHA said that the internal working draft highlighted serious deficiencies in the pulp mill IIS study’s methodology when assessing the accumulative level of dioxins in seals and fish, the lack of necessary research and modelling undertaken rendering as speculative key findings, and raises concerns about whether due diligence has been undertaken when assessing the potential impact of marine life exposure to toxic chemicals in the effluent content.

Mr Booth again reiterated the need for the community and affected stakeholders, such as tourism and the fishing industries, to have the time to assess this latest information which has now come to light, and has called on the RPDC to allow an extension on tomorrow’s closing date of submissions or permit late submissions to be made.

“This internal working document apparently from the Wildlife and Marine section of DPIW is a damning indictment of the pulp mill IIS’ assessment of the potential impact of effluent on seals in Bass Strait, is critical of ‘misleading’, ‘inaccurate’ and ‘unsubstantiated’ content in the IIS report, and also highlights areas where the necessary research has still not been done,” Mr Booth said.

Mr Booth said that the DPIW internal working document highlighted the following critical problems with the Toxikos report:

Fish

“Toxicos states that dioxins are not significantly bioaccumulated by fish. This statement is profoundly inaccurate, misleading and directly contradictory to references cited by Toxicos…”[2]

“It is suggested that Toxicos has demonstrated a complete lack of understanding of the meaning of the term biomagnification and inappropriate use of the term has been used misleadingly to suggest dioxins do not significantly bioaccumulate in fish.”[3]

“The second paragraph states that the extent of accumulation in fish is determined by the average concentration to which the organism is exposed. This statement is wholly incorrect and demonstrates a complete lack of understanding for the process of bioaccumulation!”[4]

Seals

“ a) Therefore the conclusion by Toxicos that seals are unlikely to experience direct toxicity is only speculation. It is suggested that the risk of direct toxicity to seals is important and must be assessed based on accurate knowledge.”[5]

“Seals do not feed on cultured mussels and therefore the conclusions on bioaccumulation risk to fish and seals are unsubstantiated by this discussion.”[6]

“The Toxicos report reviews the potential for health impacts on seals resulting from bioaccumulation of pollutants in effluent however the title of the report suggests that the content of the report addresses all potential impacts of the effluent on nearby seal colonies…It is suggested that title of the report be changed to reflect the content or be substantiated by ensuring due diligence has been met on other potential health impacts on seals.” [7]

Effluent Concentrations

“The assessment using effluent concentration by Toxicos is invalid and misleading and it is suggested that all conclusions based on this information are unsubstantiated.”[8]

“It is suggested that discussion on the effluent mixing zone is speculative and reference to expert technical advice has not been provided. Therefore the assessment of the risk of exposure to effluent in seawater is unsubstantiated…”[9]

“The screening process which derives dioxin as a potential chemical of concern is inconsistent and misleads the reader on whether dioxin is of concern.”[10]

“It is reasonable to expect that a professional toxicology assessment states clearly and accurately what the chemicals of concern are and bases further discussion only upon this foundation.”[11]

“Mercury and Cadmium – Given the large uncertainty associated with current levels of exposure of mercury and cadmium stated by Toxicos it is suggested that due diligence has not been undertaken on these substances to understand the potential impact of additional exposure provided by the content of effluent.” [12]

Insufficient Research

“The preceding references and reports provide a weight of evidence that the potential for seals to bioaccumulate dioxins from exposure to pulp mill effluent is significant. Therefore the Toxicos implication is misleading and their conclusion false…Accurate information on the expected level of bioaccumulation of dioxins in seals potentially exposed to the Bell Bay pulp mill effluent is fundamental to this impact assessment and has not been provided by Toxicos.” [13]

“b) Citation 4 states that hydrodynamic modeling will be undertaken by GHD to estimate the mixing zone – the absence of this information for the Toxicos assessment indicates that estimates used by Toxicos are speculative.”[14]

“An assessment must be made of the potential for fish, which ultimately become seal food, to access chemicals in the effluent through the food chain and the quantity of bioaccumulating substances likely to be consumed during the life the fish.”[15]

“The revelations of this strong internal criticism come barely a week following the discovery that Gunns’ consultants Toxikos had underestimated the dioxin release by 45 times – this leaves in tatters any credibility that may have existed surrounding the research rigour undertaken for this polluting mill proposal,” Mr Booth said.

“The Greens believe that with this alarming information coming to light barely days before Monday’s close of submissions deadline, that the RPDC must consider extending that deadline or allow for late submissions.”

“The enormity of this internal analysis will have grave implications for the community and potentially affected industries including tourism and the fishing industry, so it is only fair that they get to assess the implications of the DPIW report and factor that into their own submissions.”

Government ‘Spin’ Massaging the Message

Mr Booth also pointed out that the Wildlife and Marine internal working draft is in the template format of State government departmental responses to large scale projects, which also includes a list of ‘spin’ prompts suggesting how criticism should be presented.

“The government department template reminds those completing it that ‘it should be noted that the comments will be publicly released by the RPDC, and should be worded appropriately for external distribution’,” Mr Booth said.[16]

“Apparently that means clear directions such as ‘must’, ”should generally be avoided” and other comments should be phrased as positive suggestions.”[17]

The report template provides a list of suggested phrases for authors to use when writing their assessment of the IIS including:

· “’Suggest rewording this section as follows…’” and

· “’It is suggested that…’”.

“So it would be fair to interpret the following statement made by the Wildlife & Marine branch, “therefore it is suggested that the Toxicos [sic] discussion referring to biomagnification is unsubstantiated, irrelevant and misleading to this assessment,” as being as strong as an indictment upon the veracity of this IIS material as the authors thought they could say within their political masters’ directions.”[18]

“It will be interesting to see whether the final document from DPIW submitted to the RPDC still contains the strong critique of this working draft, or whether it has been altered to be less damning, especially since we keep being told by the government that the scientists must be listened to in this debate – the test will be whether they are prepared to listen to their own,” Mr Booth said.

Attached: Wildlife & Marine Section DPIW Internal Working draft, 17 July 2006: Response to Toxikos “Comment on Bell Bay effluent and potential impact on nearby seal colonies”, Gunns’ IIS Volume 10 (Appendix 23).

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[1] Wildlife & Marine Section DPIW Internal Working draft, 17 July 2006: Response to Toxikos “Comment on Bell Bay effluent and potential impact on nearby seal colonies”, Gunns’ IIS Volume 10 (Appendix 23).

[2] Pg4; Wildlife & Marine Section DPIW Internal Working draft, 17 July 2006: Response to Toxikos “Comment on Bell Bay effluent and potential impact on nearby seal colonies”, Gunns’ IIS Volume 10 (Appendix 23).

[3] Pg5; ibid.

[4] Pg6; ibid.

[5] Pg7; ibid.

[6] Pg9; ibid.

[7] Pg9; ibid.

[8] Pg5; ibid.

[9] Pg6: ibid.

[10] Pg7; Wildlife & Marine Section DPIW Internal Working draft, 17 July 2006: Response to Toxikos “Comment on Bell Bay effluent and potential impact on nearby seal colonies”, Gunns’ IIS Volume 10 (Appendix 23).

[11] Pg8; ibid.

[12] Pg8; ibid.

[13] Pg3; ibid.

[14] Pg6; ibid.

[15] Pg7; ibid.

[16] Pg2; Wildlife & Marine Section DPIW Internal Working draft, 17 July 2006: Response to Toxikos “Comment on Bell Bay effluent and potential impact on nearby seal colonies”, Gunns’ IIS Volume 10 (Appendix 23).

[17] Pg1; ibid.

[18] Pg 6; ibid.

ABC Online:
Fishing council concerned
Deadline looms

Christine Milne:
MEDIA RELEASE

Monday, 25 September 2006

AMA pulp mill public health warning must be heeded: Greens

The Australian Greens today called on the federal and state governments to heed the Australian Medical Association’s (AMA) damning assessment that Gunns’ proposed pulp mill will release measurable important pollutants and could cause more deaths.

Greens Senator for Tasmania, Christine Milne, said the AMA’s assessment of the Integrated Impact Statement (IIS), submitted to the Resource Planning and Development Commission, provides further evidence in support of the case against the pulp mill.

“It is of concern that the AMA has found that the atmospheric modelling in Gunns’ IIS is inadequate and that none of the claims that Gunns makes on air quality in the study can be substantiated,” Senator Milne said.

“The Tamar Valley was rejected as a possible site for a Bleached Eucalypt Kraft Chlorine pulp mill in 1988 because the atmospheric inversion would result in unacceptable air pollution. Now we know that smaller particulate matter (2.5ppm) is even more dangerous than the previous benchmark of 10ppm.

“The federal government has spent millions of dollars in recent years trying to reduce the air pollution load in the Tamar Valley during winter by reducing wood smoke pollution.

“It makes no sense now to allow a wood-fired power station to compromise public health.

“It is time that both the Liberal and Labor parties recognised that the public interest needs to be served rather than the corporate profits of Gunns and its shareholders.

“The federal government must reverse its decision to contribute $5 million to the pulp mill project and ensure that public health is prioritised.”