This has the effect of herding larger numbers of eels into the region that the traps are set up, hence the high catch rates. The cable is clearly redistributing the catches. With evidence such as this from the very man who conducted the other studies quoted by Basslink, there is little doubt that the EMFs generated by a HVDC cable (such as the proposed Basslink cable) do have a significant effect upon migratory species.
Dr. Westerberg indicated a willingness to be engaged as a consultant, due to his concern for the Bass Strait Shark fisheries. His concern was that the cable could effectively divide the populations, preventing the males and females from schooling together while breeding or migrating. He indicated that the hypersensitivity of sharks to electrical and magnetic stimuli was a matter of significant concern for the Bass Strait fisheries.
When asked to summarise, Dr. Westerberg was very clear that the monopole sytem with electrodes has negative effects upon the marine environment. To use the same system with a metallic return cable instead of electrodes reduces the effects but does not eliminate the EMF’s. The best practice available is the true bipolar technique that has both cables in the same casing. There are virtually no side effects from this technology on the marine environment.
Basslink Shark Supporting Study No. 29
It is very interesting to note that the Basslink Shark Supporting Study No. 29 (2nd Draft: 26 March 2001) marked ‘Not For Citation’ included references to a paper by Souza et al. on the effect from magnetic fields on eels. The final version of this supporting study released with the IIAS had the Souza et al. paper removed from the text and reference section, prompting some curiosity to find out why this would be the case.
Souza et al. (1988) state clearly in the first sentence of the Discussion section of their paper that "…the results of this study strongly indicate that freshwater American eels perceive and respond to a magnetic field."
The American eel (Anguilla rostrata) is a very close relative of the European eel (Anguilla anguilla)studied in Sweden, both species even having overlapping breeding grounds in the Sargasso Sea. Reading the text of the document gives a clear insight into the study, the techniques and methods, previous studies and clear unambiguous results. It is little wonder it was removed from the final version of the supporting study if we are to assume that the Basslink perspective is the only one to be relied upon.
If these supporting (desktop) studies are as selective as this has illustrated, then they are worthless due to the extreme bias. There are few studies available worldwide about the effects of this type of technology (Westerberg, 1999) and to be selective and as unscientific as this evidence has indicated is patently unfair on all who have to assess and comment on the IIAS.
The Basslink IIAS admits that there is a "potential for problems" with the shark fishery (10-52). This is a $12 million fishery that has significant capital, infrastructure and livelihoods invested in it. For Basslink to suggest that "…only a relatively small proportion of the population may be potentially affected in any one year..." …is demonstrating a total lack of appreciation for the environmental and economic factors that are involved in this fishery.
The shark fishery in Bass Strait is primarily school and gummy shark. School shark numbers are already demonstrably low. A potential reduction of 5 to12% as is suggested in the IIAS could easily be the factor that makes the fishery unsustainable or economically nonviable for those fishing industry members within that fishery.
TFIC vigorously opposes the proposed monopole technique on those grounds alone.
The fact that a personal communication from Italy is quoted in the IIAS as saying there are many sharks around the Piombino Channel near Italy (where there is a subsea monopole cable) means very little. Where are the studies to quantify the comment?
Perhaps a percentage of those sharks are actually affected, but due to exclusion zones in the area of the cable, the shark populations may still be sustainable due to no fishing effort. There are no studies, neither can the quote constitute any sort of scientific proof. This sort of argument detracts significantly from the value of a serious IIAS as this is supposed to be.
The Bass Strait Shark Fishery
Within the region from the Tamar River to Stony Head, there are a number of very important fisheries, or areas that have a significant bearing on adjacent fisheries due to the vital role of the area for spawning, breeding and as a nursery area. This is vitally important for the shark fishery as the females come into this and other adjacent regions to ‘pup’ (their young are born live).
The shark fishery is ‘quota’ managed, meaning that there is a maximum amount of fish that each fisherman can take, i.e. an ‘individual transferable quota’ (ITQ). Most fishermen will fish for both school and gummy shark, with a specific limit on each species. As mentioned before the ‘school’ shark component of this fishery is already under pressure. It is generally accepted that male and female sharks stay apart until it is time for them to reproduce. The females come ashore in the warmer months to drop their pups.
There are three issues here. The electro-magnetic forces (or the potential gradient, as has been suggested) may cause a barrier across Bass Strait in such a way that prevents the sharks from crossing the cable in satisfactory numbers.
This creates the possibility that the male and female sharks could have difficulty getting together in sufficient numbers to reproduce enough to keep the fishery sustainable. This would have significant economic repercussions for those fishermen and families who have a substantial investment in this fishery.
- The sharks could find it difficult to cross the cable and choose the path of least resistance, i.e. parallel to the cable, which would culminate in them schooling at beaches on either side of Bass Strait. This would in turn constitute a significant threat to public safety.
- The shark fishery could effectively be cut into two discrete fisheries, a situation that could again prove to be unsustainable with current fishing pressure.
Any impact from the Basslink proposal can only impact negatively on this very important fishery. There is no way that the installation can be positive for the shark fishery. With the obvious scientific uncertainty, the Precautionary Principle would dictate that the world’s best technology or ‘industry’s best practice’ should be the HVDC configuration used. This is a true ‘bipolar’ system with both the power cable and the return cable encased in the same casing.
Other Bass Strait Fisheries
Other fished species in this region are numerous and diverse. They include the following:
- Southern Rock Lobster
- Blacklip abalone
- Trevally
- Garfish
- Wrasse
- Pike
- Australian Salmon
- Southern Calamary
- Octopus
- Barracouta
- Mackerel (Schools)
- Arrow Squid
- Flounder
- Bastard Trumpeter
- Sweep
- Scallops
- Misc. invertebrates (Oysters and clams etc.)
Capture methods:
Methods to catch these fish are also varied and include the following:
- Gillnet
- Beach seine
- Jigs
- Diving
- Spear
- Handline
- Traps
- Purse seine
Juvenile and Nursery Stages
Southern Rock Lobster larvae (phyllasoma) float freely in the water column for up to two years, moved solely by wave and current action. Any adverse impact on these juveniles would be devastating for the rock lobster industry. Nothing is known about the effect that electro-magnetic fields and higher than natural voltages may have on the larvae. Baseline scientific studies should be commissioned to research the effect of such unnatural influences on larvae prior to any thought of installing a cable that could impact on this and other very important fisheries.
The Baltic Sea has brackish water with a very low salinity. The negative impacts from electrode emissions, EMFs, potential voltage gradients and electrolytic processes identified for that region are very likely to be very much higher for the Bass Strait region due to the substantially higher salinity. The impact of the chlorine and chemicals produced at the positive anode on these freely drifting larvae is obvious from the first part of this document. All of these organisms contacting these unnaturally concentrated substances will die. TFIC is opposed to any installation that will cause any detrimental effect on larvae, commercially important or not.
Many scalefish species and invertebrates including the high value Blacklip abalone are broadcast spawners. This put simply is a situation where the males and females simultaneously release their eggs and sperm into the water column with fertilization taking place externally. Eggs and larvae are extremely vulnerable to changes in water quality and environmental perturbations. The effect of the chlorine and chemicals is obvious.
The effect from significant voltage gradients and electro-magnetic fields is completely unknown on spawning species in Bass Strait. This constitutes significant scientific uncertainty and as such the precautionary principle must be applied, specifying world’s best technology as the only possible alternative. It is obvious that any environmental interference will adversely impact upon any or all of these commercial species, and therefore have a detrimental effect on our commercial fishery members.
As the Basslink IIAS is deficient in quantifiable studies and scientific proof of no impact on eggs, larvae and juveniles of all species specific to the area, TFIC cannot support the monopole proposal in any way. Only industry’s ‘best practice’ for this project is acceptable.
Seagrass Beds
The IIAS (10-30) identifies the fact that there are seagrass beds in the vicinity and describes the process of ‘wet-jetting’ in such a way as to ensure minimal impact on these vitally important components of the marine environment.
The seagrass beds are diminishing at a substantial rate, and are very susceptible to sediment and other water borne influence that reduces the sunlight and photosynthesis. Once lost, seagrasses take decades to regenerate, if at all. Seagrass beds are a very important part of the nursery area for many fisheries and any threat to them is untenable. With the tidal action in Bass Strait, it is very likely that the sediment plume raised by wet jetting will negatively impact on these seagrasses, so mitigative processes should be clearly identified, such as plume density/settling distance and tidal direction being considered if wet-jetting near seagrass beds.
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The effect from electro-magnetic fields generated by both the power cable and electrode cables on vessel navigation equipment
The Basslink IIAS (10-65) is quite clear about the fact that some of the navigational equipment on vessels in the vicinity of the cable will be adversely affected by the magnetic fields generated by the cable. They indicate that the Global Positioning System (GPS) will not be affected at all neither will electronic equipment used for navigation. The magnetic compass is most certainly affected by the influence of the cable and because on many boats the autopilot is directed by the magnetic compass, the potential for a mishap remains.
On March 29 this year two ships collided in the Baltic Sea off the coast of Denmark, resulting in the worst oil spill Denmark has had to deal with. The virtually new oil tanker ‘Baltic Carrier’ collided with the cargo ship cargo ship ‘Tern’, spilling 2700 tons of fuel oil into the sea. The cause of the accident has not been established but for quite some period of time it was considered that the magnetic field from the Baltic Cable had influenced the autopilot on the Baltic Carrier causing a sudden turn and the collision in the narrow shipping lane.
As the vessel was new, the Korean builders sent inspectors immediately to investigate the cause. They declared the steering to be in good shape. For a period of time the press speculated as to whether the cause was the magnetic influence on the auto-pilot from the Baltic Cable that was underneath the Baltic Carrier went it suddenly turned from its course. Test readings were carried out over the cable with little being ascertained and no mention as to what power was going through the cable when the collision occurred or when the readings were taken of the magnetic fields.
Press reports quoted a study that indicates that it is quite possible for this speculation to fit reality. A substantial (Ph D) field study from the University of Lund in Sweden was conducted over the Kontiskan Cable which agreed with a computer simulation that had formed part of the work. The conclusion was made quite clear. "…show that a ship using a steering autopilot with a magnetic compass can be captured by a dc cable. That is, the ship tracks the cable, perhaps in an oscillatory fashion."
Despite the open finding from the investigation into the Baltic collision, it is mentioned here to illustrate that given the right set of circumstances, it is possible that a monopole cable could have a disastrous effect on vessel navigation. This sort of risk should not be accepted. A true ‘twinned’ bipolar cable negates the magnetic field problem if the return cable is incorporated within the same casing as the power cable. Both fields cancel each other out due to their proximity to each other.
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The corrosive effects from the potential gradient and stray electrical currents emanating from the electrode and the cable, both on land and within the marine environment.
National Geological Survey of Sweden (Sveriges Geologiska Undersökning)
It is illustrative to quote the Swedish Geological Survey (SGU), which is the central Swedish Government authority for the development, production and distribution of qualified reports about ‘mountain, earth and water’. (This is in regard to the investigation of the best natural resource handling, urban planning, environment, public health, wood production and farming and the national defence.)
The following excerpt is taken from their submission on the Swe-Pol-Link in its (then proposed) monopole/electrodes configuration.
23.4.96
"…it is well known that with monopolar electricity transmission, there is a risk of corrosion to metal constructions within the surroundings adjacent to the earth electrodes. It is therefore of outmost importance that these risks are reduced as much as possible, to minimize the potential gradients around the earth points." –
When it comes to the coordination of different national energy supply systems in the countries around the Baltic Sea and even within Sweden and to other countries, it is important to follow the recommendations of the CENELEC in Brussels (The European Committee for Electro-technical Standardization). This recommendation states that it is important (during the planning phases) to try to find solutions which minimize the produced potential gradients and corrosion risks. If a bipolar technique is available, this is of course to be preferred."
The Hydro-Electric Commission: Report 7612
"Experience with the Gotland scheme in Sweden showed that during the first year of operation corrosion damage was found in the armouring of a submarine power cable and in the sheath of a submarine telecommunication cable. Both cables had to be replaced. Many earth electrodes of low voltage networks were also damaged during the first year."
South African Consultant in Cathodic Protection; Neil Webb:
A personal communication with TFIC from South African corrosion expert Neil Webb was quite clear about the risks of corrosion from the monopole technique. The following is quoted directly from his email dated 28 May 2001:
"Earth electrodes in the sea will have significant potential gradients associated with them. Anything within this potential gradient will suffer interference corrosion. We experience stray current circuits operating over hundreds of kilometres between DC railways and pipelines. Stray current over tens of kilometres is commonplace. The original earth electrode of our HVDC powerline affected services well beyond 10km radius.
The consumption rate of steel under interference conditions is some 10kg/amp.year. This is a lot of metal. Vessels, services and infrastructure will all be affected by the stray current interference, depending on the geographical layout and spatial relationship between the various systems and the electrodes. I would certainly advise against going this route."
The issue here is not that corrosion ‘may’ happen, but that it will happen, with the degree of effect from this electrolytic process being discussed by experts. Basslink choose to trivialise or underestimate this destructive and far-reaching effect from their ‘cheapest but most suitable technology’ (McLelland, 2001. pers. comm.).
Basslink Development Board’s Michael Vertigan is on record as stating (regarding corrosion)… "All of these issues will be addressed by the three final bidders". Here he is referring to the three bidders to build the cable, with the Swedish company ABB being selected for this task (McLelland, 2001, pers. comm.). Postscript: ABB was originally mentioned by Mr McLelland (at a TFIC meeting) as the preferred cable supplier, however, the contract has since gone to Pirelli).
This is akin to passing the responsibility on to another entity, distancing the ownership of the problem away from Basslink. The corrosion issue is significant. The infrastructure at risk in the Tamar estuary is substantial and varied. The proposed Duke Energy Pipeline will be most at risk due to the proximity to the proposed Basslink cable, however the above communication from Neil Webb indicates that smaller structures both on land and in the marine environment will also be at risk. The stray currents from the sea electrode near Gothenburg (Sweden) the cause of serious tramline corrosion.
The fishing industry is one of a number of interests in the area. Vessels and equipment belonging to our members are obviously at risk. This includes marine farmers in the Tamar River who also have substantial investment and infrastructure at risk. Any risk (however small) to our members is unacceptable and because of this TFIC must vigorously oppose the proposed monopole/electrode cable configuration. Areas of concern include wharves and jetties, vessels, navigation equipment, moorings and fishing equipment.
The "Burden Of Proof"
The potential exists for the Basslink generated corrosion to destroy property that belongs to other people.
- If this were to prove to be the case, where would the burden of proof lie?
- What baseline studies on existing rates of corrosion (of all structures) would be made by Basslink prior to installation of this potentially destructive monopole/electrode system?
- How would a fisherman who has had expensive equipment damaged or destroyed (thereby devaluing the capital investment and removing the capacity to earn an income) be able to prove that Basslink’s cable is the cause?
- How could that same fisherman with a limited budget and little legal assistance be able to challenge an international company of the size of National Grid International?
- What mechanism would be in place to provide compensation?
It is obvious that there must be substantially more work completed by Basslink on their corrosion assessment, as well as the need to address the issue of compensation and claims. This has to be calculated and seen in relation to the higher expense that a bipolar solution will inevitably cost. It is not enough to indicate that corrosion problems will be handled (inventory, measures to protect etc).
Corrosion must not be reduced to an economic equation to be solved after the event. It must not be allowed to occur in the first place, hence the vigorous opposition from TFIC and others to the monopole/electrode proposal. TFIC is seriously concerned about this issue and must insist on an agreement from Basslink that provides access to compensation in a timely and efficient manner for those affected by the side effects of the monopole system if it is unwisely allowed to be installed.
The Swedish Perspective
The SGU calculated the intensity of the corrosion risk to the metallic structures in the area surrounding the electrode proposed for the Swe-Pol-Link that they stated on 21.02.97 "…that it must be shown in a unquestionable way, that Svenska Kraftnät … will stand up for all claims and costs attributed to corrosion damage as a consequence of the cable. When calculations of damage are being made, the Svenska Kraftnät company has to collaborate with an independent authority and pay for the costs." Signed by Gunnar Svanfeldt (Director) and Leif Eriksson, (Chief State Geo Physicist)
Compensation and Claims for Fishing Industry Members
With regard to the fishing industry members who would be potentially at risk, TFIC is most adamant that it would have to be involved in the process of setting a mechanism in place for claiming compensation from Basslink. This would be in the form of a legal agreement that is able to be understood by the average layperson, providing simple and unambiguous access to adequate and fair compensation for any damage and loss of income caused by the Basslink installation.
There appears to be a significant problem in the concept of using the cheapest system available. It is important to add to this cost the probability of ongoing economic reparation. The relationship between the extra cost of a true bipolar system and the continued compensation claims from affected parties (from the cheapest alternative) must be fully included into the equation.
The Basslink Perspective
Basslink (10-42) indicates that the issue only places long metallic steel structures at risk, particularly those that pass through points of differences in the voltage equipotential contour. It is curious to consider the Basslink map (AW328_280501_A3_OSA_VoltagePotentials.Wor.) indicating the equipotential lines over Bass Strait and Tasmania. This map shows a drop from 14+ volts at the proposed anode at Stony Head to a 1 volt gradient predicted to be between Ross and Oatlands, some 100+ kilometres to the south.
These lines don’t appear to take into account the effect from the different land and water masses, such as the Flinders Island group and the mouth of the Tamar estuary. The circles radiating out from the anode would have to be far less concentric if the differences in resistance are taken into consideration. The sheer distance on land and in the water that will be affected by the placement of an anode in Bass Strait must give significant cause for concern. There is absolutely nothing natural or normal about inflicting a voltage gradient of this magnitude on a state that tries to maintain a ‘clean green’ image.
The correct interpretation of the map was pointed out by cathodic protection expert Mike Kirlew (Cathodic Protection Tasmania P/L; recommended for consideration as a consultant in the HEC Report No 7612)
August 17, 2001
"Obviously the equipotential lines would be quite meaningless when there is direct current flow. The gradients cannot possibly be uniform where there is a difference of conductivity between the sea and the shore. Similarly there will be distortion where there is an inlet such as the Tamar River. The curves can only be plotted after current is flowing. Idealistic curves can be dreamed up but are never found in practice. Any buried metal will distort the plot in a relationship to the conductivity of the metal related to the conductivity of the ground/seawater. Ohm's Law. Any dreamt up curves would have to allow for the known differences of conductivity between the land and the sea. For instance on the Vic side the drilling rigs and pipelines will distort the curves. The Duke pipeline will distort the whole scene as it will be a better conductor than the seawater and also the land at each end.
What an incredible mess this is. Do the proponents know nothing or are they hoping any one reading the submission will not understand it?"
19 May 2001:
"Potential gradients (differences in voltage across an area)…There are records of the affect (sic) of these cables on the shark population. In Bass Strait it is known that in the non-breeding season the boys live at one end of the Strait and the girls the other. The cable will have the affect (sic) of forming an electric fence across the Strait. You could have a lot of frustrated sharks around the beaches.
…I strongly object to the use of the monopolar cable on the grounds that it will do acknowledged and understood damage to the environment and buried structures."
There is significant scientific uncertainty and as such the Precautionary Principle must be adhered to with worlds best practice being the only solution that TFIC can agree to.
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The effect of regular unnatural flushing of rivers and estuaries during Hydro operation
Economically speaking, the concept of being able to turn hydro-generated power on and off must be very attractive for the energy suppliers, transporters and brokers in the power market. If the lake levels are appropriate, the power demand can be fulfilled as the generators can be brought on line at short notice and be turned off equally quickly.
This creates problems of its own for the downstream environment and those that use it. Most estuarine environments have a crucial role in the fishing industry. The estuary works effectively to assimilate the chemicals and poisons that are washed downstream from terrestrial sources. Over the years, the sediments encapsulate these unnatural pollutants and seal them away under consecutive layers.
The estuarine system also has a crucial role providing a safe nursery environment for many marine species that rely on the seasonal regularity of water conditions such as salinity and temperature. Marine farmers in these systems rely on the same conditions. With power being available on demand to fulfill the requirements of the brokers who are trying to gain the best price for it on the energy spot market, the influx of fresh water into these systems will be unpredictable and disruptive.
The flushing effect of significant and sporadic water flows is likely to create elevated sediment plumes that will be flushed into the marine environment, as well as being disruptive to the nursery areas. Bed and bank erosion will contribute to this. The scouring influence of the extra water flow could well create a disturbance to encapsulated chemicals and poisons, which would in turn have the effect of redistributing these historically sealed but still viable chemicals back into the environment.
This type of activity cannot be described as environmentally friendly, neither can it be sustainable economically speaking. It does not appear to be taking into consideration the fact that nursery areas for marine species and marine farmers will be potentially paying an environmental cost for a situation that is a destructive externality. There is little equity involved here.
Macquarie Harbour
One factor that is not addressed in Basslink’s IIAS is the possibility of inundation in Macquarie Harbour. This is a very real possibility despite the size of the harbour. When the wind drives onto the Tasmanian coast from the west it can create significant wave action that has the effect of preventing the water in the harbour from moving through the narrow opening to the ocean. A combination of a high tide, extra water from power generation and strong westerly winds could create a water level that causes problems involving inundation.
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The need to use the Precautionary Principle due to any scientific uncertainty of possible effects once in operation
Dr. Westerberg from Sweden’s National Board of Fisheries delivered a lecture in Sweden in October 1999 where he made the situation quite clear about the lack of studies around HVDC cables.
Historically, a study was conducted at a test installation in 1949 using the relatively low voltage of 400 volts and very low amperage of 250 Amps. With this capacity and study it was concluded that the effect from the technology was localised to the area immediately adjacent to the electrode. In the following decades cables were installed around the Baltic region, but no further studies were made of the possible marine effects despite the significant increase in the capacity of the cables. It was not until the Swe-Pol-Link was proposed that questions were raised about the static magnetic field around the cable and the production of toxic chlorinated organic substances from the electrode were investigated (Westerberg,1999).
When using the term ‘uncertainty’, we are in this context referring to the definition made by Dovers (1995), where he defines ‘uncertainty’ as occurring "...when the direction of change and possible nature of outcomes are believed known, but processes cannot be quantified accurately."
Few Independent Field Studies Extant
One of the biggest difficulties involved in commenting on an IIAS such as this is the real lack of studies available world-wide that are specific to issues, as for example electro-magnetic fields generated by electrodes. Even Basslink acknowledges that fact in its IIAS (10-50). The propensity for the Basslink IIAS to refer to anecdotal personal communications (e.g. 10–50) and then claim that little or no adverse effect is expected can only be supposition. There is no science demonstrated in these situations and claims, therefore this is an example where scientific uncertainty is obvious.
Industry ‘best practice’ is recommended in situations such as this by international agreements that relate to the environment. Australia is a signatory to a number of these agreements. Diesendorf and Hamilton (1997) define the precautionary principle as follows:
"The Australian Intergovernmental Agreement on the Environment defines the precautionary principle as:
Where there are threats of serious or irreversible environmental damage, lack of full scientific certainty should not be used as a reason for postponing measures to prevent environmental degradation. In the application of the precautionary principle, public and private decisions should be guided by:
- Careful evaluation to avoid, wherever practicable, serious or irreversible damage to the environment; and
- An assessment of the risk-weighted consequences.
Another stronger version of the principle is that in considering new policies and economic projects, the onus of proof should be shifted from the opponents to the proponents, who must demonstrate that, to a very high degree of probability, the project will not cause significant harm to the environment.
Due to the obvious lack of real scientific certainty, TFIC must strenuously insist on the ‘mandatory use of the best technology’ to be applied to this project. This is regardless of Basslink’s economic considerations and preferences as this is Tasmania’s environment and it is irreplaceable!
In fifty years Basslink will have made their profit from Tasmania’s resources while Tasmania picks up the bill for the social and environmental costs. It is vital that the precautionary principle be applied to this project before it starts, with the proviso being that only the best technology is suitable for this application. It cannot be driven from a ‘budget’ perspective, as this is environmentally short-sighted.
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Best Technology is required regardless of NGI’s preferences
Economy and Technique
A very strong and valid point must be repeated here. The solution to the negative effect of corrosion and other problems must be built into the design at the start, not attended to economically after the fact. There is no doubt that there will be corrosion coupled with the other serious effects described above. There is little doubt that it will have long term ramifications both on the marine environment, on land and on the economical values of individuals and companies.
To address the negative effects after the cable is installed is poor economy. In addition to that here will always be both a social and environmental cost that is unable to be compensated for or even calculated if economics drive this proposal instead of environmental factors.
- Social cost: In this case, this is the economic impost on other entities who are affected by corrosion or negative side effects from a source that has nothing to do with them. But they will be forced to endure the penalty simply because they are in the area that is affected by the installation of worlds worst practice because it is the cheapest.
- Environmental cost: The long term cost to the environment due to chemical emissions, electro-magnetic fields affecting migratory species and possibly larvae, eggs etc, and corrosion effects requiring sacrificial aluminium/zinc anodes that will also concentrate dissolved metals into localised areas of the marine environment.
Why should Tasmania bear this cost while a foreign owned company makes a profit without respecting the Tasmanian intergenerational responsibility that is affected by environmental and social factors? The solution is available by using ‘world’s best practice’ despite the extra cost to the company. It defies rational decision-making to consider anything else.
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According to international standards as described by Professor Lars Emmelin (an expert in Environmental Impact Statement (EIS) Assessment) in his report on EIS of the (then proposed monopolar/electrode configuration) Swe-Pol-Link cable, the analysis of the Basslink should be:
"…based upon the ‘best international practice’ rather than formal guidelines. The demands that are given in the EU directive about EIS (85/337) should (for example) be used as a form of minimum standard when it comes to international standards…".
The primary point to be made here is that because of the obvious scientific uncertainty, the precautionary principle should be applied to this situation. The Basslink IIAS appears to be deficient in a number of areas. The lack of the assessment of the effect from the placement of the anode on the seabed is another example that has been noticed by TFIC. How many other issues of significance have been ignored?
Due to these deficiencies the use of this IIAS document in the decision-making process may give the company some form of advantageous position, especially if these issues are not identified and addressed.
Soft phrases and rhetoric that is difficult to verify
One of the major problems with the IIAS is the difficulty to gain any clear proof that the soft comments and rhetoric are quantifiable or even based on a scientifically proven fact. The poor reasoning is peppered through the IIAS, especially chapter 10 with the use of phrases such as those below in a multitude of places, leaving the reader no clue on how to check the veracity of the comment or claim.
The number of "personal communication" comments that are supposed to back up an argument that should have been proven by science in the first place is alarming. If these HVDC cables are so prevalent and environmentally sound, why are the comments and opinions so soft? Why can’t there be strong statements that say what the result of an action will be? The constant uses of phrases such as those below most certainly reduce the confidence that one should have in a supposedly thorough IIAS such as this.
A meeting was arranged with Mr Mitchell and Professor Emmelin during the TFIC visit to Sweden. Professor Emmelin is an internationally acknowledged authority on the assessment of Environmental Impact Statements, lecturing and teaching the subject at the Blekinge Institute of Technology in Sweden. The Basslink IIAS was considered to be so poor by international standards that he asked for an electronic copy to be forwarded to him so that he could put it on the Institute’s server for students to access as an exemplar of "how not to do an EIS".
This sort of evaluation by an expert does not give very much reassurance that the IIAS is designed with the environment or public in mind.
An example of the rhetoric in the IIAS is found in Chapter 10, page 61:
"…annual salmon runs have continued unabated to the rich coastal salmon fishing grounds of south Sweden (e.g., Blekinge coast) and then upriver to Sweden’s famous salmon rivers, such as the Mörrum River."
To verify whether the statement was true or simply ‘writers licence’ Mr Mitchell questioned the owner of a large fish retailing business that has been established in the area for two generations. The answer was quite simple. There is virtually no wildfish catch available, with catches declining over a similar period to the recent cable installations.
They now rely upon imported and farmed fish and were happy to put the statement to that effect in writing. However, there is little to say that the cables are to blame for a reduction in numbers, due to there being no prior studies to compare with.
Mr Mitchell travelled to question people at the Mörrum River, Sweden’s most famous trout fjord where the salmon return to reproduce. He gained anecdotal opinions that the fish stocks were certainly declining, but without accurate records, the veracity of the comment was impossible to quantify. The lack of fish could well be due to other factors. However the point is made here because it clearly indicates that the Basslink IIAS statement is relying upon no-one actually checking out their creative claims that try to make it appear as if there is nothing for Tasmania to be concerned about, despite the lack of verifiable knowledge.
Soft phrases and unquantifiable rhetoric do not encourage any credibility in this IIAS nor in the proposal in its current state. Without sound scientific factual evidence, the IIAS is indicating that despite significant experience overseas this still includes a proportion of guesswork, something that should have been totally eliminated considering the decades that this technology has been developed over.
Where are the alternatives?
The scope guidelines published by the Joint Advisory Panel were very clear about the fact that the IIAS was to fully evaluate the alternatives.
By presenting Australia with the cheapest design and only evaluating that alternative is not appropriate for the decision-making process. This will ensure that the efforts to prove the viability of this alternative are extremely high.
The assessment of the environmental impacts is not for the proponent to do in comparison with their economic requirements. This is for the decision-making authority and as such all of the alternatives should be clearly and fully evaluated to the fullest extent. This has not been done adequately and until such time as it is completed, TFIC must oppose the monopole alternative that Basslink has proposed.
The ‘zero’ alternative
These alternatives should by definition include the ‘zero alternative’ which describes what happens if nothing is actually done. The evaluation should consider whether this is in actual fact a better option over the time period of the proposed project, taking account environmental, social and capital costs as well as the projected profit.
The monopole configuration with metallic return cables alternative
This is the next cheapest option to the monopole/electrode system that has already been chosen by Basslink as ‘most appropriate’ technology due to it being the cheapest. This system removes the problems with chlorine emissions and corrosion, but still has problems with EMFs unless the cables are all buried in the same trench.
The bipolar configuration with two separate cables alternative
This technology is significantly better and more expensive due to the extra converter stations required for the extra cable. It can still have problems with EMFs if the cables are separate, as well as limited chlorine and corrosion problems from the standby electrodes that are needed.
The bipolar system with both the power cable and return cable built into the same casing
This technology is acknowledged as worlds best, with very little effect on the environment. The Norwegians have used a special coaxial style of cable from the Danish cable builder NTK Cables. This technology builds the return cable into the outer periphery of the main power cable casing.
There are other styles of cable available that are ‘twinned’ cables. This type of cable is in use and has virtually no side effects on the environment and marine users. By burying the cable into the sediment, it would be virtually undetectable.
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Despite comments that indicate the Basslink philosophy moves away from enforcing exclusion zones over the cable and adjacent area, TFIC wishes it to go on record that it will vigorously oppose any exclusion zone should there be any proposal to create such a zone.
The chances of a fishing industry member having an interaction with the cable are extremely low, especially if it has self buried or been wet-jetted into the substrate. Any move to create a ‘no fishing’ zone in the area of a substantial shark fishery will be strenuously opposed.
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It is totally irrelevant and unimportant which technology the proponent wishes to use especially if it is based on an economic evaluation excluding negative environmental side effects. This decision should be driven primarily by the environmental factors, not the economic factors alone. If the cheapest technology has harsh side effects on the Tasmanian marine environment as described by many experts, then TFIC must vigorously oppose it. There should be no risk, however small, to the marine environment, neither will TFIC tolerate any risk to its members who may be affected by this proposed project.
There is little point in the proponent being economical with the truth, as the suite of problems that will inevitably follow will cost the company dearly. These costs are unable to be estimated due to the uncertainty that surrounds this proposal, but would include further expensive and time consuming studies, legal costs, compensation, and media and public consultation costs. These costs could still culminate in the very real potential for the system to be forced to change to the better technology as has happened in the Baltic region. These points alone could jeopardise the economic viability of the project.
This pattern of an energy company insisting on cheapest technology, no real baseline environmental studies and urgent installation has been clearly demonstrated in the Baltic. Basslink appears to be repeating this pattern in Australia. This will have the potential for the consequences to be a repeat of all the problems that have been experienced in Europe. It is therefore hard to understand why this can be seriously considered as an environmentally sustainable proposal.
The question that must be asked in the decision-making process is to clearly define whether this project is more trade or includes a strategy of sound development? There must be a process of examination that evaluates whether this proposal is simply about transport or about a desired development for Tasmania. If it is trade, then it may well not be sustainable. Development on the other hand will contribute in a positive way to further sustainability (Nordberg, 2000).
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- Due to the scientific uncertainty, the precautionary principle must apply and world’s ‘best practice’ is the only method acceptable for Tasmania and Bass Strait.
- Only a true bipolar power cable with the return cable built into the same casing is acceptable. Anything less than this is environmentally irresponsible as far as Bass Strait is concerned.
- Before that is adopted, the deficiencies in the IIAS must be addressed including the full evaluation of the zero "do nothing" alternative.
- Full baseline studies must be taken of existing infrastructure and equipment.
- Full-scale studies of fish reaction to a HVDC cable EMFs specific to Bass Strait
- Full assessment of the effect of decommissioning the cable prior to it going in, not when it is decommissioned.
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Appendices (Copies available from the TFIC Office):
Appendix 1: Vattenfall/SvenskaKraftnät, (1996). Application for permission to install the Swe-Pol-Link cable in
monopole configuration. Pages 25, 26 and 27 (Original Swedish and English translation).
Appendix 2: Johansson, O., (1997). ‘Biased argument in favour of the Poland cable’.
Published in the Blekinge Länstidning, BLT (Blekinge newspaper, Sweden) (Original Swedish and English translation).
Appendix 3: Karlshamn Kommun Kommunledningsförvaltningen, (1997). Authoritative declaration to NUTEK
(Swedish National Board for Industrial and Technical Development, 117 86 Stockholm, Sweden) from Karlshamn Community Mayor Torsten Magnusson, denying permission for a monopole system with electrodes to be installed.
Appendix 4: Ronneby Kommun, Office for Environment and Public Health, (1997),
Authoritative declaration from Thomas Gummesson, Environmental Chief, denying permission for the project due to undesirable environmental impacts.
Appendix 5: Press Release: Ronneby Office of Environment and Public Health declaration that
any activity that involves the production of chlorine gas is forbidden, based on Environmental Law.
Appendix 6: Boverket (National Board of Housing, Building and Planning), (1998).
Authoritative declaration from the board denying permission for the installation of the Swe-Pol-Link monopole cable due to environmental impacts being in contravention of the Environmental Law in Sweden.
Appendix 7: Sandström, O., (1996). Fennoscan Cable Electrode Fish Assessment, Swedish National Board of
Fisheries. (Rough English translation of abstract).
Appendix 8: Document AB 441 at the Nutek: Submission from Professor Bengt Holmberg (Dr. Med. Ph D) Lund
University. Questions the significance of studies undertaken for the Sweden (Blekinge) to Poland cable.
Appendix 9: Notes from a meeting between TFIC representative Ralph Mitchell and Ms Dagmar Nordberg with
Professor Bengt Holmberg.
Appendix 10: Swe-Pol-Link document by Per-Anders Bergqvist, Origo Hb and University of Umeå. (1997). Project to
study the presence of halogenated substances around the grounding point of a submarine cable (HVDC).
Appendix 11: Danish Fishermen’s Union Press Release: 1994.
Appendix 12: Notes from a meeting between TFIC representative Ralph Mitchell and Ms Dagmar Nordberg with the
President and Managing Director of the Danish Fishermen’s Union in Copenhagen on July 4: 2001.
Appendix 13: Communication from Mr Michael Andersen (Danish Fishermen’s Union) to TFIC (30.08.01)
Appendix 14: Diary Number 9323-96-6991 at the Nutek: Submission from the Swedish Fishermen’s Union (17.02.97)
strongly opposing the proposal for the Sweden to Poland cable in monopole configuration.
Appendix 15: Communication from Dr Håkan Westerberg (Swedish National Board of Fisheries) to TFIC (27.08.01)
Appendix 16: The Coastal Laboratory of the Swedish National Board of Fisheries: (1997). Radio Antenna Experiments
with Eels at the HVDC Cable 1997: (Selected paragraphs translated into English)
Appendix 17: South Coast Fishermen’s Union (Subdivision of Sweden’s Fishermen’s Union) Submission (15.10.98) to
the Swedish Government Department of Trade and Industry commenting on the Vattenfall/SvenskaKraftnät EIS for the Swe-Pol-Link HVDC cable proposal.
Appendix 18: The Swedish National Board of Fisheries, Submission for Swe-Pol-cable 05081996,
Diary-no: 339- 1883-96
Appendix 19: Westerberg, H., Begout-Anras, (2000). Orientation of silver eel (Anguilla anguilla) in a disturbed
magnetic field. Swedish National Board of Fisheries, Institute of Coastal Research, Sweden.
Appendix 20: Notes from a meeting between TFIC representative Ralph Mitchell and Ms Dagmar Nordberg with the
Swedish National Board of Fisheries Senior Scientist Dr Håkan Westerberg and Marine Biologist Dr Susan Hope Smith, in Gothenburg Sweden, July 9: 2001.
Appendix 21: Souza, J. J., Poluhowich J. J., & Guerra, R. J., (1988). Orientation Responses of American eels Anguilla
rostrata to varying magnetic fields. Departments of Biology and Physics, University of Bridgeport, Bridgeport, CT, USA. Published in: Comp. Biochem. Physiol. Vol. 90A, No.1, pp 57 – 61, 1988.
Appendix 22: Translated Danish press article by Birgette Marfelt og Stig Dall: "The ship turned to port".
Appendix 23: Akke, M., & Lampe, K. H., (1995). Nonlinear Interaction of dc Cables and Magnetically Controlled
Ship-Steering Autopilots. IEEE Transactions on Control Systems Technology. Vol. 3, No. 4, December 1995.
Appendix 24: Swedish Geological Survey (SGU) Report: 23.04.96.
Appendix 25: Neil Webb, B. Sc., Corrosion Engineer; (South Africa). Email communication to TFIC re effects of
monopole electrode technique.
Appendix 26: Swedish Geological Survey (SGU) Report to Nutek: 21.02.97
Appendix 27: Basslink map of equipotential lines for anoda and cathode locations:
AW328_280501_A3_OSA_VoltagePotential.Wor
Appendix 28: Westerberg, H., (1999). Effects of HVDC cables on eel orientation.
Swedish National Board of Fisheries, Institute of Coastal Research, Sweden
Appendix 29: Professor Lars Emmelin, Professor of Environmental Law (EIS Assessment), Department Of Spatial
`Planning, Blekinge Institute of Technology. Submission to Nutek, the permission giving authority for the Swe-Pol-cable NUTEK (Swedish National Board for Industrial and Technical Development)
Appendix 30: Letter from Wägga Fisk & Delikatessrökeri, Karlshamn, Sweden
References:
Diesendorf, M., & Hamilton, C., (1997). Human Ecology, Human Economy. Allen and Unwin,
St Leonards, NSW, Australia.
Dovers, S., (1995). A framework for scaling and framing policy problems in sustainability.
Ecological Economies, vol. 12, pp. 93-106). In: Diesendorf, M., and Hamilton, C., (1997). Human Ecology, Human Economy. Allen and Unwin, St Leonards, NSW, 1590, Australia.
McEwan, W. J., (1992). Report No. 7612: Tasmanian Hydro-Electric Commissions Engineering and Scientific
Nordberg, D. B., Dipl Des BA Architect BDIA.
- Lecturer in Environmental Communication
- ‘Citizen of the Year’ in the County of Blekinge (Sweden) in 1998.
- Awarded the ‘Environmental Award of the Region of Blekinge 1999’, (regional government award), and the prestigious ‘ICA Award 2000’ (Sweden’s highest environmental award)
Nordberg, D. B., (2000). Lecture held at Uppsala University, Dec. 2000, Inst. For Urban
Readers Digest, (1986). Sharks. ISBN 086438 0413