The potential to mislead Parliament

Professor Andrew Wadsley Australian Risk Audit

The SWECO PIC report is not fit for purpose; it does not meet the requirements of the Pulp Mill Assessment Act 2007 and, if relied upon, has the potential to mislead the Tasmanian Parliament. SWECO PIC appear not to have acted impartially; they appear to have selectively reviewed the data made available to them and have ignored facts which conflict with their client’s objective of securing the compliance of Gunns’ proposed design basis with the Guidelines.

This review of the report “/Assessment of the Gunns Limited Bell Bay Pulp Mill against the Environment Emission Limit Guidelines/” by SWECO PIC Oy is limited, in the main, to factors affecting pulp mill effluent and emissions. The main findings are:

1. SWECO PIC make false and misleading statements, and omit significant issues required for assessment under the Pulp Mill Assessment Act 2007.

2. The report confirms the “deficiencies” identified by the RPDC in Gunns’ draft IIS and supplementary material.

3. The report and associated references support calculations, reported previously, demonstrating the likelihood of extensive pollution of the coastal and marine environment near the outfall of the proposed mill.

4. With respect to dioxin pollution, the Premier publicly stated that “this is a matter that SWECO PIC is looking at” (7.30 Report, 5 June 2007); the impact of dioxin is not addressed in the report.

5. SWECO PIC do not assess appropriate environmental impacts as required under the Pulp Mill Assessment Act 2007. In particular, the capacity of the Tamar Valley airshed to cope with the increased pollution load from the mill (Section D.3.10 of the Guidelines) is critical to determining the impact of the mill on human health and mortality. SWECO PIC do not say whether the mill complies with this Section. On the basis of this omission alone the report fails to meet the requirements of the Pulp Mill Assessment Act 2007.

6. The report is deficient in that it does not address technical issues which would have been addressed under the RPDC assessment. In particular, it does not include an assessment of noise emissions, impacts on surface or estuarine waters, effects on flora and fauna, transport implications, construction impacts, and does not include impacts from off-site infrastructure developments such as the raw water supply pipeline or effluent pipeline.

7. SWECO PIC abrogates its responsibility with respect to the impact of emissions on human health, society and the environment. This is in breach of its obligations under the /Code of Ethics/ of FIDIC (The International Federation of Consulting Engineers) and the Swedish Partnership for Global Responsibility (Globalt Ansvar) to which SWECO AB, the parent company, is a signatory.

8. Their report states: “/SWECO PIC has limited its work to checking the validity of the individual statements and data (numbers) in the DIIS [draft integrated impact statement] that have been identified as requiring special emphasis/”. In my opinion, based on the outcome of this review, SWECO PIC have been improperly selective with respect to the data they have reviewed and they have been negligent in checking and certifying the validity of critical assertions of the draft IIS.

The SWECO PIC report is not fit for purpose; it does not meet the requirements of the Pulp Mill Assessment Act 2007 and, if relied upon, has the potential to mislead the Tasmanian Parliament.

SWECO PIC appear not to have acted impartially; they appear to have selectively reviewed the data made available to them and have ignored facts which conflict with their client’s objective of securing the compliance of Gunns’ proposed design basis with the Guidelines.

In my opinion, SWECO PIC have been improperly selective with respect to the data they have reviewed and they have been negligent in checking and certifying the validity of critical assertions of the draft IIS.

Professor Andrew Wadsley
Australian Risk Audit