Tasmanian Times


Six reasons why the draft IIS sucks

Jon Sumby

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).

And that:

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.

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  1. Dave Groves

    September 30, 2006 at 7:12 pm

    Only six????? ha ha ha ha ha ha ha ha ha

  2. John Legge

    September 28, 2006 at 12:46 am

    A vision of the future courtesty of the present…

    North Coast Journal – Humboldt County – California, USA

    DRAT THAT CLOUD: Like Pigpen’s black cloud of fly-speckled grit that follows him wherever he goes, the Evergreen Pulp Mill’s past keeps hanging around. On April 12, the Environmental Protection Agency released its national Toxics Release Inventory of data from 2004.

    The EPA puts out this cheery news on industry emissions every year, and sometimes it is cheery. The EPA data shows that, overall, emissions are declining. However, every year, the pulp mill out on the Samoa Peninsula seems to star in the top 10 ranking of California polluters. In 2004 the mill, then owned by Stockton Pacific Enterprises, released 2.3 million pounds of toxics into the environment — second only to an outfit called Chemical Waste Management in Kettleman City, Kings County (12.2 million pounds). The mill polluted more than the oil refineries in Martinez.

    Stockton Pacific was fined last year for the mess it made in Humboldt County’s water before it left the mill in the care of new owner Evergreen Pulp Inc. And ever since, Evergreen Pulp Inc. has been busy swatting at a cloud of protest over the mill’s continuing expulsion of excess emissions. Evergreen has been given until April 2007 to clean up its act.

  3. David Obendorf

    September 27, 2006 at 8:07 pm

    But Mike, Damon Thomas, CEO of the TCCI has assured Tasmania that this pulp mill development will ‘turbo-charge’ the economy of Tasmania. Surely that IS the definitive word on this.

    Is this mere word-spin? Such cliché would find universal appeal for the masses. Damon has also stated that the TCCI accepts the Gunns IIS ‘on face value’.

    What does that mean precisely?

    On that reassuring basis you wonder why we need bother with the RPDC assessment at all.

    As Mark Twain eloquently put it: “It’s hard to explain something to somebody, if what you are explaining affects their salary.”

    And that IS the ‘bottom line’!

  4. Mike Bolan

    September 27, 2006 at 4:36 pm

    Well done Jon, another well thought out piece.

    The entire IIS is embarrassing, in fact it would be interesting to get it marked by a University as if it were an honours paper.

    The economic models should be of interest because they omit the impacts of the mill’s operations on rural Tasmania and on businesses that rely on the same resources as Gunns is demanding (tourism, fishing, timber workers).

    Agricultural land earns 5 to 20 times as much as land under plantation, so each time Gunns converts a farm to a plantation, rural Tasmanians pay a hefty price. Plus the conversion is paid from tax avoidance schemes so we’re paying for this conversion.

    Add downstream agricultural value added processing and we see rural Tas losing billions of dollars over the period of the mill. Rather than being revenue positive for Tasmania, this one-sided proposal will destroy many rural communities and lose our State at least as much as the mill is supposed to earn, and more likely 2 or 3 times as much.

    This is probably the core reason for leaving that aspect from consideration.

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