01 August 2002
The Hon. Jim Bacon MHA,
Premier of Tasmania
Executive Building, 15 Murray Street,
Hobart, Tas. 7000
Dear Premier,
Tasmanian fishing industry concerns about Basslink
The Tasmanian Fishing Industry Council (TFIC) has taken an active role in the community scrutiny of the proposed Basslink HVDC interconnector, investing significant time and money into evaluating the potential threats that the proposal would pose to the marine environment in Bass Strait.
TFIC does not oppose the Basslink proposal as such, but has had to seriously question the justification of the proposed technology. We have strenuously opposed the fact that economic factors rather than environmental factors have driven the choice of technology and right from the outset have recommend strongly that worlds best technology be used for this significant project.
It is gratifying to see that common sense has prevailed with the adoption of the metallic return technology. This has effectively removed the two most serious threats (toxic electrode emissions and stray current corrosion) that we identified in our research and demonstrated to the community (including Duke Energy) prior to our representation to the Joint Advisory Panel.
However, we are not convinced that the metallic return eliminates all threats to the Southern Shark Fishery in Bass Strait.
TFIC members have a substantial interest in the marine environment within Bass Strait. As you will be well aware, the Southern Shark Fishery is worth around $13 million annually. Any unnecessary threat to this valuable fishery needs to be immediately evaluated and mitigated.
We wish to draw your attention to one of the Joint Advisory Panel's final recommendations.
Basslink Joint Advisory Panel
Final Panel Report
6.4.7
Notwithstanding the elimination of electric fields by replacing the sea/earth return by a metallic return, the Panel considers particular attention should be paid to the analysis of existing industry data for the shark fishery and other cartilaginous fish, and future monitoring requirements to ensure that no adverse effects are experienced… … Section 6 of the Strategic EMP should be amended to allow for preconstruction monitoring of shark migration.
6.6.3
DPIWE (T121), referring to the proponent’s conclusion that ‘no adverse impacts are predicted on cartilaginous fish or their migrating behaviour,’ states:
"It would be more accurate to state an impact is expected but the degree of the impact will be species specific and difficult to predict."
Further, DPIWE states that:
"...it is noted that BPL consultants have indicated in conversation an intention to undertake monitoring of sharks (in conjunction with CSIRO). Their written comments acknowledge that they cannot definitely answer the question but suggest that sharks should be able to cross the cable based on the long history of cable use world-wide without report of adverse impacts."
DPIWE regards the evidence to support these conclusions as inadequate and recommends requiring pre- and post-operation monitoring of sharks.
6.6.8
BPL’s submission T*7.2 states that:
"The magnetic fields of the bundled main and return conductors provide substantial cancellation. In other words, the magnetic fields that would have been generated by the sea/earth return configuration initially proposed by BPL will be virtually eliminated" (p. 5) and "At 600 MW transfer, maximum predicted combined MF at 1 m above north-south aligned HVDC cable is 67.6 µT compared to background geomagnetic intensity of 61.0 µT." (p. 8)
6.14.2
Panel commentary
… While the Panel accepts that predicted impacts from the proposal are significantly reduced with the change to a metallic return the Panel does not agree with BPL’s view that pre-construction monitoring and surveys, and long term monitoring are not necessary. The Panel is of the view that a more comprehensive approach to monitoring of changes to the marine environment along the bundled cables is required. Accordingly, the Panel recommends that the Strategic EMP be modified to incorporate a pre- and post-construction and operation monitoring program to provide an overview of ecological change. The Bass Strait Environment Review Committee will review the results of the monitoring program (see Chapter 5 for recommendation on establishing a Bass Strait Environment Review Committee). The Panel considers that monitoring post-operation of Basslink should continue for a minimum of two years, and then be reviewed by the Review Committee.
The monitoring program should be developed to the satisfaction of Environment Australia, Commonwealth Department of Agriculture Fisheries and Forestry – Australia, the Victorian Department of Natural Resources and Environment and the Tasmanian Department of Primary Industries, Water and Environment.
The attitude exhibited by Basslink P/L towards this recommendation is quite clear.
Basslink Appendix E: Marine impact assessment
7.3 (Page 47, Para. 2)
However, the adoption of the revised Basslink Metallic Return proposal and the evidence from other cables without any magnetic cancellation… … now means that shark monitoring is not needed and none is proposed.
With the Panel obviously not being convinced that there is no threat to the Southern Shark Fishery, TFIC must insist that monitoring of the shark fishery be initiated as the Panel has recommended.
This of course brings us to the next question. There appears to be a significant difference of opinions regarding the effect of the minimised electro-magnetic fields (due to the cable bundling technique), with the world's foremost shark expert Professor Kalmijn indicating possible problems may still exist.
If the monitoring proves that there is an effect (caused by Basslink) that impacts negatively upon this valuable fishery, what protocol will be in place for compensation or mitigation? We believe that this is an issue that should be dealt with before the event rather than after it has occurred.
Plastic Strapping
While the 'bundling technique' for the three cables is innovative, it is noticed with some concern that the polypropylene rope used for this bundling will be supplemented with plastic strapping.
Basslink Appendix E: Marine impact assessment
2.2 (Page 11)
…The cables will be bundled together continuously with polypropylene rope with plastic or stainless steel straps at intervals.
2.4 (Page 13)
…The cables will be bundled together continuously with polypropylene rope with plastic straps at intervals.
5.1 (Page 39)
Mitigation Measures:
The Basslink cables will be bundled together continuously with propylene rope with plastic straps at intervals.
These three statements seem to indicate a preference for plastic strapping rather than stainless steel strapping. There is no statement to what type of strap is actually going to be used, neither is there any attempt to indicate dimensions of the strapping, whether it is expected to come loose during installation, or whether it is robust enough to retain its integrity for the duration of the cable installation.
TFIC has to also seriously question whether plastic strapping will be robust enough to retain its integrity after decommissioning, especially if the cable is retrieved.
We would point out that under the Tasmanian Pollution of Waters by Oil or Noxious Substances Act 1987 it is illegal for fishermen to dispose of bait box strapping at sea within 3 nautical miles. From 3 nautical miles, to 200 nautical miles the MARPOL Convention prohibits the discharge of plastics.
The prospect of plastic strapping coming loose during or after installation and subsequently escaping into the marine environment is not acceptable. This is an issue that is not adequately addressed in Basslink's Final IIAS and needs to be clarified.
TFIC would be more at ease with the thought of the strapping being made from stainless steel, as it will remain negatively buoyant and does not pose a threat to vessels or marine creatures if it breaks loose from the bundled cable.
Exclusion Zones
Despite claims from Basslink that there will be no exclusion zones over the cables after the construction of Basslink, TFIC's interpretation of the 'Regulation of Submarine Telecommunications Cables' tends to raise significant concern.
We feel that the laying of the optic fibre cable with the power cables will give the leverage needed to apply a protection or exclusion zone over the cables. If this is the case, this will preclude a substantial amount of Bass Strait from fishing activities.
It was significant also that the JAP indicated (that the possibility of the telecommunications cable having an exclusion zone) was outside of their scope and that they were unwilling to comment about it.
TFIC is on record as vigorously opposing any exclusion zone apart from those needed during construction. We remain vigorously opposed to the application of any such zone and feel that there should be a designated corridor for all telecommunication connectors between Tasmania and the mainland.
We thank you for your consideration of our concerns prior to sanctioning the Basslink project on behalf of Tasmania. We would ask that you communicate any action that you consider appropriate to us at your earliest convenience.
Yours faithfully
Ralph Mitchell
Executive Officer