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Tasmanian Seafood Industry Council 
Tasmanian Seafood Industry Council


 

Pulp Mill  


    What is the Tasmanian seafood industry’s view of the proposed Pulp Mill?
    The industry recognises that if Tasmania is to meet the needs and/or expectations of its community then there is a need for growth based on sound social, economic and environmental principles. This “growth” then facilitates the provision of essential services such as schools, hospitals, support services for the disadvantaged; and other important infrastructure and services.

    Therefore, as part of this “growth” strategy a new Pulp Mill utilising the best technology available, using timber that is harvested on a sustainable basis and with no discharge of substances that damage the marine environment, especially in the long-term, would be considered in a favourable light.


    What is the current position?
    Tasmania has a sad history of industrial development resulting in major and long-term damage to the environment. All those who have lived and live in Tasmania are only too aware of the damage that has been done in the name of “economic progress.” Not wanting to repeat these past mistakes Tasmanian’s through their political representatives and governing processes now demand absolute transparency and community involvement in any decision making of matters that have the potential to impact in a negative way on them and their children’s children.


    Where does this view leave us?
    Because of the current lack of information and the confusing nature of that which is available there is a tendency for many of us to say “hold on, we need more information particularly from credible sources, before we can decide if this is what we want”.

    The proponents of the Mill and the Government’s Pulp Mill Task Force, seem to have recognised that we need more, not less, information before we can sign-off on this potentially important element of Tasmania’s future “growth.” As a result the flow of good information is steadily increasing as is the opportunity to meet with those directly involved in the process.


    What is the preferred end point for the Tasmanian seafood industry?
    Based on the above, if a Pulp Mill is built in the proposed location and the discharge into Bass Strait has no discernible effect on any of the marine organisms contained within - having allowed for the rather unique behaviour of the water mass contained within Bass Strait (see Figure 1) - then the Tasmanian seafood industry would have no issues of concern knowing that at least 33% of its entirety is not threatened by such a development.


    The alternative position?
    If it becomes clear that the proposed Pulp Mill has the potential to damage the marine environment, particularly through the application of the wrong process or the lowering of “best possible” environmental standards then the Tasmanian seafood industry would actively oppose the Mill being built.


    Gunn’s Pulp Mill Proposal Update 27/10/06
    – Shane Fava (TFIC Project Officer)

    Over the last eighteen months TFIC has been accumulating information through their participation in various information sessions and debates regarding Gunn’s Pulp mill proposal for Bell Bay, and discussing with stakeholders its potential impact on the State’s fishing industries. The result of this process was their recent submission to the Resource Planning and Development Commission (RPDC) highlighting the issues and concerns of the State’s commercial fishing industry.

    This process was strengthened greatly by TFIC’s engagement of Associate Professor Barbara Nowak to conduct an external review of Ecotox’s report Toxicity Assessment of a Pulp Mill Effluent for Proposed Tasmanian Pulp Mill” that formed part of the Gunn’s integrated impact statement (IIS). The Ecotox report details the effect of effluent (supplied from two similar overseas kraft mills) on a number of local marine species over set time periods. Associates Professor Nowaks review of this report highlighted a number of data gaps and uncertainties contained with in Ecotox’s report. These particularly related to the lack of sub chronic or chronic testing carried out (longest effluent exposure time was only 96hrs) and also the omission of any chemical analyses of the effluent tested. Associate Professor Nowaks review also identified deficiencies regarding the status of any proposed monitoring programs (there are currently none available for assessment) and the lack of detail about the effects of dredging in the Tamar River during the proposed mill’s construction phase.

    After recent consultation with a number of industry sector groups/individual members and a review of the recommendations put forward by Associate Professor Nowak serious concerns about a number of aspects of the proposal were identified. These focused primarily around the perceived inadequate level of robustness and completeness of the scientific methodologies used in much of the testing conducted as part of Gunn’s (IIS). Stakeholders acknowledged the following issues as potential areas of concern that needed more detailed analysis to be provided by the Gunn’s (IIS);
    • Effluent characteristics such as temperature, colour and salinity need greater definition as they will play an important role in determining the plume dispersal characteristics.
    • The capability of Bass Strait to flush 73, 000 tonnes of effluent per day, this leads to a number of issues related to a build up of the contaminants in the sediment increasing the potential levels of bioaccumulation.
    • The effect of prevailing weather systems of the dispersal of effluent, northerly patterns would see the effluent pushed back to shore and even up the Tamar River.
    • Potential damage to local fisheries caused by effluent dispersal. These wild fisheries include abalone, Australian salmon and scallop (potentially) as well as farmed species such as abalone and Atlantic salmon. The renowned poor flushing characteristics of surrounding water body may also see effluent affecting the Marine Protected Areas of the Bass Strait Islands.
    • To what standard will any monitoring programs be conducted, and would they include penalties for breaches of standards.
    • What is the potential for contaminants to leach form the mill site into the river.
    These concerns formed part of a comprehensive list of issues that TFIC believed needed greater clarification/analysis and were forwarded as part of their RPDC submission.

    To view both Associate Professor Nowak’s review and TFIC’s RPDC submission see below.

    Gunns Pulp Mill Assessment review

    Pulp Mill Symposium Handout

    TFIC Submission to RPDC

    TFIC Revised Project Scope

    Pulp Mill Symposium Presentation
    Gunn’s Pulp Mill Proposal Update 07/06/07

    Since our last report on the progress of the long reach pulp mill proposal the assessment process has taken a substantial change. The initial mill approval process was being sought through the RPDC as a project of state significance. However, in late February 2007 after a significant restructure of the RPDC panel Gunns pulled out of the RPDC approval process on the grounds that the time frames being set by the commission were too broad and costing the project an exorbitant amount of money, therefore jeopardising the viability of the proposal.

    The proposal was then referred to the Department of Environment and Water Resources (DEW) to be reviewed under Environmental Protection Biodiversity and Conservation Act (EPBC). This Act is recognised as the Austalian Governments key piece of environmental legislation and protects matters of environmental significance from potential impacts caused by projects, developments and altering activities. Matter of national significance can include,
      • World Heritage properties
      • National Heritage places
      • Wetlands of International importance
      • Threatened species and ecological communities
      • Migatory species
      • Commonwealth marine areas
      As part of this approval process the project proponent has the opportunity to provide information to DEW detailing how there will be no impacts upon matters of environmentall significance, this is done through the submission of a referal document. (see Gunns' referral document to DEW attached below)

      Gunns Limited Bell Bay Pulp Mill Referral[1].pdf

      The purpose of this stage is to determine whether the project requires approval under the EPBC Act. Referrals are subject to a 10 day public comment period after which DEW will determine if the project will have a significant impact or not. (see TFIC's public comment submission below).

      TFIC Submission.pdf

      If the project is deemed to have a potential impact on matters of national significance it is classed as a 'controlled action' and will require further assessment, this is the current stage that the pulp mill process has reached. At this stage the public are also able to forward comments to the projects proponent questioning various aspects of the proposal. (see TFIC's submission to Gunns below)

      Pulp Mill EPBC June 2007.pdf

      A comprehensive discription of DEW's approval process is attached below.

      assessment-process.pdf



    © Tasmanian Seafood Industry Council (TSIC) - 2010