1. The mill process is simple: Resource is extracted, factory processed, then product is distributed and the waste dumped. The resource is Tasmanian native forest but the Government has directed the RPDC thus:
In considering issues relating to the supply of timber resources for the Project, the Commission must give effect to the Regional Forest Agreement made between Tasmania and the Commonwealth of Australia on 8 November 1997. (Premier Paul Lennon)
It appears that the RPDC has interpreted this as meaning that there is no need, or reason, to assess the impact the mill may have on native forests and logging intensity. What part of the word ‘resource’ does the Resource Planning Development Commission not understand? Native forests are the resource for the pulp mill. It is a linked process: Resource; Industry; Product and Waste. It is a bit like assessing a uranium mine and ignoring the uranium mining part.
2. The United States EPA has a protocol for testing effluent that is the international standard. It is called, ‘Guidelines Establishing Test Procedures for the Analysis of Pollutants; Whole Effluent Toxicity Test Methods; Final Rule (November 19, 2002).’ In these guidelines are directions on how old samples must be for tests to be valid. The Eucalyptus pulp mill effluent that Gunns chose as ‘representative’ of the the Bell Bay mill effluent comes from a pulp mill in Thailand. The toxicity testing was done in Sydney. The US EPA guidelines for off-site testing say that ideally, effluent should be tested within 24 hours of collection, testing within 36 hours is acceptable but that, ‘In no case should the sample be used for the first time in a test more than 72 h after sample collection’. The draft IIS chain-of-custody document shows that the samples were 74 hours old when they were collected from Australian customs at 5:10 pm. The consultants would have probably started work the next morning and if the samples were a 24-hour composite this means that when the consultants started work the sample was 114 hours old. This means that the samples breached the US EPA guidelines and the toxicity test results are invalid. Yet these are the results that the draft IIS says shows the proposed pulp mill will have effluent that is very safe for us and the environment.
3. The pine effluent sample was taken from a pulp mill in South America. This sample was from a mill that dumps 42 cubic metres of effluent for every air-dried tonne of pulp. The draft IIS says that the proposed mill will produce 25 cubic metres of effluent for every air-dried tonne of pulp. This means that the effluent tested for the draft IIS is about twice as dilute as the proposed mill. This dilution is noted by the consultants but not addressed. This means that the testing was done on a sample that is half the concentration of the proposed mill effluent and is in no way ‘representative’ of the pollution the mill may release. Yet this is the evidence of how ‘non-toxic’ the mill effluent will be.
4. The proposed pulp mill will release air pollution. The Australian Medical Association notes in their submission that:
The model for predicting air pollution in the Tamar Valley Air Shed as used in the IIS largely fails to meet the acceptance criteria as set out by the United States Environmental Protection Agency (US EPA).
The model predicts the levels of PM10 particles to be only one-fifth of the actual measured values in Launceston.
Air pollution particles that are the size called PM2.5 are dangerous, they are small enough so that when you breathe them in they can actually cross from the lungs into the body and into your blood. The AMA submission notes that the draft IIS does not, does not, mention PM2.5 particles.
5. Dioxins are a class of chemicals that are among the most toxic known to science (another is PCB, widely used by the Hydro and considered as toxic as dioxin — yet it was sprayed on dirt roads to keep dust down!). The draft IIS considered the dioxin issue and came up with a surprising conclusion: Dioxins are not a problem. This is despite the easily calculated figure that the mill will dump at least 140 tonnes of dioxin-like chemicals into Bass Strait each year for the 30-year operation of the mill. The draft IIS report that showed that dioxins are not a problem has come under widespread criticism; from experts in DPIW (see the TT story here: (Mill: that leaked report), to TT commentators, to other groups submitting comment to the RPDC. The conclusion that dioxins present no problem flies in the face of World-wide scientific knowledge. A Google search will show this; or go to the story: http://www.tasmedia.org/node/1199
6. This is the D.I.Y. part, I can go on for hours stripping the draft IIS down to little, irrelevant, misleading bits, hmm … where to start? The sixth reason is like the sixth extinction, make your own contribution. There must be many people who each know a factual, methodological, or analytical error in the draft IIS. Add them here, please. Each substantive error and flaw will break the draft IIS down and maybe, just maybe, the RPDC will listen.
Jon Sumby has trained and worked as a professional photographer, high-rise window cleaner, and marine ecologist. He worked for five years as the Australian representative for the Sea Shepherd Conservation Society and crewed on the 2002/03 Antarctic whaling campaign. He is presently working on a PhD in science and policy-making.