5 July, 2004
Resource Planning and Development Commission
GPO Box 1691
Hobart
TAS 7000
To Whom It May Concern:
Re: Draft Report on the Development of Environmental Guidelines for New Bleached Kraft Pulp Mills in Tasmania
Thank you for the opportunity to comment on the above Draft Report.
While not having any significant expertise in the field of pulp production, it must be stated at the outset that from a Tasmanian seafood industry perspective, any additional loading of pollutants and chemicals into the Tasmanian marine environment is unacceptable.
There are also two key factors that are imperative to any pulp mill proposal. The first factor is the mill feed-source for pulp. From the perspective of community responsibility, the use of clearfelled native and/or old growth forest resources is untenable and should not be considered for pulp production under any circumstances.
This leads to the second factor, that of plantation timber that will be sourced/grown to supply the raw material to any proposed pulp mill. Water resources in Tasmania are crucial to the multi-million dollar Tasmanian seafood industry. To be more specific, water quality and quantity are absolutely paramount for the maintenance of the environmental flows and ecosystem processes that our industry relies upon 100% for marine primary production.
The prospect upper-catchment eucalypt plantations being established without full stakeholder consultation or due regard for downstream environmental/industry water needs is alarming. A 'whole of catchment' consultation process must be
integrated into any environmental impact assessment (EIS) for proposed eucalypt plantations. This EIS must be available to the wider community, and address water needs of industry and environment in the lower catchment. It must also address the use of chemicals/poisons used in the plantation that may leach and have an adverse impact on eco-system processes and marine farmers downstream.
I note with interest that the Draft Report reiterates in all three volumes (e.g., Volume 2, B.16)
'…"Closed-cycle technologies are not yet technically or commercially proven". While significant progress has been made in closed-cycle technology, it appears that those conclusions remain valid….
Not necessarily contrary to the thrust of your report, it is worthy of mention that there appears to be technology available (internationally) that is now operating, economically producing pulp with no effluent discharge.
The question that should be asked is why Tasmania insists on limiting pulp production to the Kraft process when other Totally Chlorine Free (TCF) mills are operating successfully overseas?
I quote:
"In May 2003 a Technical Bulletin written by Stratton and Gleadow titled Pulp Mill Process Closure: A Review of Global Technology Developments and Mill Experiences in the 1990s was released by the National Council for Air and Stream Improvement. It can be found at the following weblink http://www.ncasi.org/publications/tb860.pdf.
4.1.1 Millar Western Pulp (Meadow Lake) Ltd. – Meadow Lake, Saskatchewan, Canada
The Millar Western Pulp (Meadow Lake) Ltd. mill has been the most successful zero effluent discharge market pulp mill operation to date. It is a totally chlorine-free, alkaline peroxide pulp/bleached chemi-thermo-mechanical pulp (APP/BCTMP) mill, with a current production capacity of 300,000 metric tons per year of market pulp made from 100% aspen. Pulp produced per mass of wood consumed by this high-yield mill ranges from 85 to 95%.
A groundbreaking wastewater treatment and recycling system implemented by Millar Western at the mill allows the manufacture of pulp with no discharge of liquid effluent, eliminating water pollution concerns for the mill."
And…
"4.1.2 Tembec (formerly Louisiana-Pacific) – Chetwynd, BC, Canada
Louisiana-Pacific constructed a new BCTMP mill in Chetwynd, British Columbia, in the early 1990s. The factors which weighed in the decision to go zero discharge at Chetwynd included: a corporate vision for efficient resource use and to meet and exceed current and future environmental regulations; concerns over regulatory delays for permitting an effluent discharge; progress in CTMP technology which made operation at low water and effluent flows possible; anticipated demographic changes; and market trends. The zero discharge technologies Louisiana-Pacific considered included freeze crystallization, evaporation, conventional water treatment, and membrane technologies (Rogers and Arac 1997; Arac 1998)."
To summarise:
The Tasmanian Fishing Industry Council submits that the Draft Report should reflect the following:
- Any added pollutant load on the Tasmanian marine environment is unacceptable.
- Any prospect of feeding any proposed pulp mill with clearfelled native or old-growth forest is irresponsible and unacceptable.
- Any eucalypt plantations proposed for mill-feed must include the development of an environmental impact assessment (EIS) that is readily available to the wider community; that addresses lower catchment water quality and quantity (including possible leachate from plantation sprays and chemicals).
- Alternative technologies should not be eliminated from any proposal to build a pulp mill in Tasmania.
It should also be made quite clear here that the Tasmanian Fishing Industry Council is neither endorsing nor opposing a pulp mill in Tasmania. 12w Tasmania's environment deserves the best technology available and should not be totally constrained by dollar values. (Then) Deputy Premier Lennon's media statement "We will not accept second best…"demanding no less than 'world's best practice' should become the key criteria for any proposal.
Yours sincerely,
Ralph Mitchell
Executive Officer