19 February, 2004
Resource Planning and Development Commission
GPO Box 1691
Hobart
TAS 7001
To Whom It May Concern:
Development of Environmental Guidelines
for New Bleached Kraft Pulp Mills in Tasmania
The Tasmanian Fishing Industry Council is the peak representative body for Tasmanian licenced commercial fishermen, seafood processors and marine farmers.
This covering letter is to introduce the Resource Planning and Development Commission (RPDC) to our submission (attached) on behalf of TFIC members who have valid comment on the development of the new environmental guidelines for Kraft pulp mills in Tasmania.
A study of the local/international history of bleached Kraft pulp mills reveals a clear picture of how the riverine/estuarine systems and the marine environment (aquatic ecosystems downstream from pulp mill discharges) have had to bear the unsustainable brunt of undesirable pollution emissions from this industry.
There should perhaps be some reassurance from reading Deputy Premier Lennon's media statement of November 13, 2003, where he clearly states:
"In the new Tasmania we are building, we will not accept second best. The best available techniques should be applied and they will be required… (We) will not compromise on standards"
However, taken at face value, this declaration does seem to be at variance with the comments in the 'Reference to the Resource Planning and Development Commission Development of Environmental Guidelines for New Bleached Eucalypt Kraft Pulp Mills in Tasmania', footnotes (page 2, para's 3 and 4).
These interpretive notes taken from the State Policy on Water Quality Management and the Environmental Management and Pollution Control Act 1994 appear to be stressing the issue of 'cost-effectiveness' rather than the far more relevant and pressing need for world’s best practice in maximising environmental protection and benefit.
In the 21st Century in Tasmania, responsible environmental management must include world's best practice. Deputy Premier Lennon's media release has a far more responsible ring to it when compared to the State Policy or Acts that any pulp mill will be regulated by. Perhaps there is an opportunity here for these Policies and Acts to be revisited and revised to allow them to become more environmentally responsible as well.
We only have one environment; an environment (within and around Tasmania) that already has many terrestrial areas and aquatic ecosystems disastrously degraded after only a mere 200 years of European unrestrained exploitation.
The key to the success of these Kraft pulp mill guidelines will be to ensure that they reflect Deputy Premier Lennon's media statement, demanding no less than 'world's best practice' that embodies demonstrable and validated ecologically sustainable use of Tasmania's significant natural resources.
Deputy Premier Lennon declares that Tasmania deserves the best. The 'best' is obviously a totally closed system with the only outputs being pulp and heat with no impact on the marine and terrestrial environment. Environmental guidelines should reflect this 'world's best practice'.
Yours faithfully
Ralph Mitchell
Executive Officer
Development of Environmental Guidelines
for New Bleached Kraft Pulp Mills in Tasmania
A Submission from the
Tasmanian Fishing Industry Council (TFIC)
By: Ralph Mitchell
Executive Officer
19th February, 2004
Introduction:
This submission makes no attempt to address specific ambient emission limits from bleached Kraft pulp mills. We are in the commercial fishing industry. We do not have sufficient expertise in the field of Kraft pulp mills to assess and understand precise effluent emission values, while we do know that any added pollution load to Tasmanian ecosystems is too much. We have little grasp of informed opinion about the effects of these poisons when they are released into the environment, neither are we qualified to make a validated and informed comment on them. Given time and resources, it is likely that we could have strong input there, but why should we devote expensive energy, dollars and resources to this process?
It should be the responsibility of any proposal to prove that the proposed project or activity will not adversely affect the environment or existing resource users and investors. In offering input to these guidelines, it would be inappropriate for us as an industry to have to employ a consultant to do this work. The precise scientific evaluation of Kraft pulp mill emissions (for the purposes of these revised guidelines) should be the responsibility of the RPDC commission to engage an audited independent consultant with appropriate credentials for a thoroughly validated external review of these values and all associated factors. It is the independent report from this process that we should be considering in the consultation process (along with all other salient factors) and then commenting on.
However, that said, this submission from the seafood industry does have a valid comment on this whole issue. The primary recipient of any effluent from the Kraft pulp industry is invariably the same marine environment that all of our members rely upon 100% for their part in the extremely valuable seafood industry in Tasmania.
The Tasmanian Seafood Industry
TFIC represents the interests of more than 700 licenced commercial fishermen, over 80 seafood processors and in excess of 100 marine farmers who operate 180+ marine farm leases around Tasmania. These members currently catch, produce and process approximately 22,400 tonnes of product valued well in excess of AU$300 million annually. In financial terms, this already represents a multi-million dollar investment without trying to evaluate the enormous historic investment of time and energy as the seafood industry has been developed. This is both an investment and a powerful industry that should not be trifled with lightly.
Employment in the contentious Tasmanian forestry sector gets regular media headlines but there are thousands of Tasmanians employed in the seafood industry. And just like forestry, many entire communities are totally reliant on the income from this seafood industry employment. Returns to the Tasmanian community are measured in multi-millions of dollars annually. Royalties paid into the Tasmanian Treasury coffers from Tasmania's high value fisheries add up to millions of dollars annually.
Sovereign Risk
When considering these guidelines, it is vitally important to consider risk to other industries and businesses as well. Government decisions, actions or changes to government policies pose a risk (sovereign risk) to our seafood industries. Industries and businesses cannot insure against sovereign risk and are virtually powerless to control that risk. They must bear the full cost of that risk.
Downstream…
The seafood industry is an industry that has to handle (downstream) whatever those upstream care to throw at it. Regulatory controls appear to be biased against those downstream with little interest shown by regulators in redressing the imbalance.
Because (like their terrestrial based primary producer ‘cousins’) marine farmers produce food for humans, they have to pay significant ongoing costs for water quality testing due to some of their ‘cousin’s’ agricultural activities upstream from them. They can be closed down for weeks at a time when floodwaters become a vehicle for microbiological ‘nasties’ that constitute a hazard to human health. This is not ‘user pays’ but ‘victim pays’.
Accumulation
Accumulation of toxins (often from diverse sources) and the synergetic effects of these chemicals provide difficulties for the Tasmanian aquaculture/marine-farming sector. Once the water carries a pollution loading and then other sources of pollution add to that loading in the ecosystem, the effect is often far more serious than could be expected when considering the separate levels of the contributing pollutants. Ecological damage is always the result of the mixing of polluting substances.
Provenance of scientifically verifiable causal links between upstream activities and the effects downstream is prohibitively expensive, however, this is the 21st Century and Tasmania is not a third world state with a subsistence culture. Any proposal that could potentially have a detrimental effect on the Tasmanian seafood industry should be prepared to proceed with nothing less than ‘world’s best practice’ and a great degree of caution.
The value of estuaries and the near coastal environment
Many (up to 70%) of all commercial and non-commercial marine species rely on estuarine and near coastal environments at some stage of their life cycle. Non-commercial species often form a part of the life cycle and food chain for commercial species, so any thought of a potential for further degradation or pollutant loading of Tasmanian aquatic ecosystems is both alarming and intolerable.
On a ‘per hectare’ basis, and in economic terms, the returns to the community from sustainable estuarine marine farming activities far outweigh the returns to the community from land-based primary production activity (See Costanza et al, The value of the world’s ecosystem services and natural capital. Nature 387, 253 – 260).
It is encouraging to see (internationally) the enormous developmental strides forward in the expertise and technology used by the pulp industry, bringing about a significant shift in environmental awareness and responsibility as well a phenomenal reduction in the pollutants that are released into the environment. Tasmania should use this expertise and cutting edge technology to develop guidelines that have the potential to make Tasmania’s pulp industry an exemplar for the world. And as Deputy Premier Lennon declared, second best is not good enough for our island State.
Why Kraft?
It is apparent that Kraft is not the only method for producing pulp. When considering the environmental impacts, why are all other methods summarily discounted? It would appear that alternatives such as soda, soda-anthraquinone and potassium pulping processes are effective in turning not only eucalypt hardwoods into quality pulp, but other resources such as soft-woods, cotton, hemp and crop stalks (such as sunflower, sorghum and wheat) into pulp as well. Some methods appear to have less impact upon the environment.
- Is branding an issue that takes precedence over environmental protection values?
- Should this be a part of guidelines?
- Would a process such as this RPDC review benefit from assessing alternatives to the Kraft process?
Resource Inputs:
The environmental assessment of any Kraft pulp mill in Tasmania must address the resources that go into growing the plantations that will be used to manufacture the pulp. Without any doubt, any bleached eucalypt Kraft pulp mill must not use Tasmanian old growth forest as a source for pulp. Plantation timber is becoming plentiful with it likely to be oversupplied worldwide within the next two decades. Plantation forests are becoming more prevalent around Tasmania, often being planted with little or no real assessment of the amount of water that the plantation will use.
This ground and surface water is a vital part of the entire ecosystem process. When hungry plantation forests suck up immeasurable quantities of fresh water resources upstream, ecosystem processes and biodiversity suffer downstream. There is no recourse for any deprived downstream user to claim against the activities upstream and the environmental flows don’t have a voice unless someone is adversely affected. The best use of water resources must be evaluated when considering the resource inputs for any pulp mill.
Environmental flows must be maintained to allow ecosystem processes to continue to function downstream from plantations and in the near coastal environment. Our seafood industry places a great deal of reliance upon both quality and quantity of water. As in parts of Scandinavia, ecological sustainability in the Kraft pulp industry should recognise that the Tasmanian catchment is an entire ecosystem, taking into account the best returns to the community from validated sustainable resource usage.
Bleaching and other processes:
Pulp production includes a bleaching process. Literature is full of the effects of the pollution that has been released after this process. Without needing specific references, a plethora of documents are accessible to indicate that chlorine gas and chlorine dioxide discharges contaminate waters with organochlorines and other toxic compounds. These chemicals have a serious effect on health. Dioxins are measured in parts per trillion due to their extreme toxicity and are related to a wide variety of health problems in humans and other species.
We could wax eloquent in this submission about the various processes and techniques that we have barely got a grasp on, but will it actually count for anything?
World’s Best Practice…
Deputy Premier Lennon claims in a media statement (endorsed by the State Government) on November 13th 2003 that nothing short of world’s best practice is good enough for Tasmania. In that case, if his statement is true, then we can short circuit this entire process and make the assumption that any Kraft pulp mill built in Tasmania will have no choice but to be a ‘closed system’. Timber, water and other resources will be the inputs with pulp and heat (or power generation from that heat) being the only outputs. This means a totally closed cycle with no effluent outfalls, no dioxins, no organochlorines, no pollutants and above all, no effect on resource users downstream.
Energy production and a truly ecocyclic process
Such a system exists. It is called the Kretsloppsanpassad massafabrik Ecocyclic Pulp Mill. This three and a half-year Swedish interdisciplinary research program included input and research from ten universities and institutions. Eleven pulp and paper companies supervised the industrial relevance of the program with the investment in the research/program costing the equivalent of US$13 million. The report of the outcomes of this cutting edge research was released in July 2003.
This ecocyclic system would appear to be world’s best practice. It even produces energy. According to the Deputy Premier, second best will not be good enough. The Tasmanian seafood industry fervently hopes that his words have some substance and are not simply empty political rhetoric.