|
|
Climate Change
|
|
5 April 2004 |
Alcan Gove Alumina
Refinery Expansion Project |
Draft Environmental
Impact Statement – Main Report
|
A Submission by the Environment
Centre NT: 5 April 2004
|
The Environment Centre
of the Northern Territory recommends against approval for the Alcan
expansion.
|
As indicated below we make
this recommendation for many reasons including the lack of clarity
as to what is actually being proposed and may be approved, and our
great concern over the route of the proposed new gas pipeline with
potentially serious impacts on high conservation value areas such
as the Daly River and the Arafura 'Swamp'.
|
»
|
It is difficult to assess the EIS in isolation
from the other components of the project i.e. the Trans Territory
pipeline and the Blacktip Gas processing installation at Wadeye
(which are currently at earlier stages of the environmental approvals
process). The cumulative impacts of all three related projects
should be assessed together before a final decision on approval
for the refinery expansion is made.
|
»
|
ECNT is concerned that environmental approvals
are being sought before a Definitive Feasibility Study is completed.
The DFS, due by mid-2004, will include a detailed examination
of the design, implementation, risk assessment and cost evaluation
of the expansion (ES-1). There is every reason to suppose that
significant changes to the project may occur as a result of the
DFS. It is therefore even more difficult to assess what is essentially
an interim EIS.
|
»
|
The EIS consistently maintains that the environmental
footprint of the expansion will not increase, as it will occur
within the existing lease area (apart from the construction of
the workers' accommodation).
|
|
Yet it is acknowledged
in the EIS that additional residue storage areas outside the existing
leases may be required in the future due to the increase in total
waste (the production of red mud waste, for instance, will climb
from 1,674,000 tonnes per annum to 2,691,000 tonnes per annum).
|
Furthermore, the existing
Residue Disposal Area has already had a significant impact upon vegetation
communities in the vicinity of Pond 5 (15.2.5.1) due to increases
in levels of salinity.
|
It is therefore not sufficient
for the proponents to say that separate environmental approvals will
be sought if additional storage areas are needed, then to use this
as a justification for not discussing the potential environmental
impacts in this EIS, as it appears more than likely that the additional
areas will be required.
|
Back to top |
»
|
No quantification of the amount of currently
lost and spilled product (bauxite, hydrate and alumina) is
made in Section 7.3.1.2. The EIS does say that modifications
to one conveyor reduced hydrate spillage by an estimated 2,500
tonnes per annum. This seems to suggest that the amount of
spillage is high. With increased throughput of materials in
the expanded refinery, will spillage increase? This question
is not addressed by the proponents.
|
»
|
There will be a significant increase in water
consumption by the expanded refinery requiring seven new bores
be drilled. Overall average water consumption is predicted
to increase by 25%. Predicted groundwater levels in Observation
Bore 1 will be 10.4 m MBHD (Melville Bay Height Datum), which
is not far above the critical threshold level of 10 m MBHD.
Any level below 10 m and the discharge of water to Yirrkala
Creek is below the permitted minimum rate of 50 L/s (5.1.8.2).
|
|
More information about the potential ecological
effects of lower discharge rates into Yirrkala Creek and Yirrkala
Lagoon is required. It is not sufficient to say that on the
previous two occasions that the level dropped below 11 m MBHD
no observable impacts were noted in Yirrkala Lagoon.
|
|
The increased groundwater extraction will be
continuous over a much longer time period. Moreover, groundwater
levels and discharge rates could well be affected by altered
rainfall conditions associated with climate change.
|
»
|
It is disappointing that Sulphur Dioxide emissions
from the refinery will increase under a fuel oil scenario (Table
8.5.1), whilst the incidence of small dust particles will remain
at similarly high levels at the Aboriginal community of Galupa
no matter whether fuel oil or gas is used (Table 8.7.1). Carbon
monoxide levels will also increase by a factor of three if
gas is adopted.
|
»
|
In Section 9.1. the EIS claims that Alcan
has reduced its company-wide greenhouse emissions by 1.1 million
tonnes CO2e, or 5% from 1999 levels on a 'growth adjusted basis',
without explaining what this term means. It is therefore hard
to evaluate Alcan's claims of greenhouse efficiency. ECNT has
concerns about the environmental impacts of the refinery expansion
if fuel oil continues to be the primary energy source for the
power station.
|
|
This will result in a much higher level of
greenhouse emissions, increasing by approximately 1.38 million
tonnes per year. Even if natural gas is used emissions will
rise by approximately 595,000 tonnes per year. It needs to
be pointed out that it is the total quantity of emissions that
this project should be assessed on, not the amount of emissions
per tonne of alumina produced. The atmosphere and climate system
is ultimately indifferent to alumina production efficiencies.
|
»
|
The EIS admits that Melville Bay in the vicinity
of the Residue Disposal Area and the refinery can be described
as a 'slightly to moderately disturbed ecosystem' (13.3.1).
Nabalco's 2001 Safety, Health and Environment Report indicates
that median vanadium levels in this area in 1999 exceeded the
ANZECC water quality guidelines and were only slightly below
guideline levels in 2000 (p26).
|
|
The expanded refinery, according to the EIS
modelling, will produce similar levels of vanadium and other
metal concentrations in its water discharges. ECNT's concern
is the cumulative impacts of these continued discharges on
the marine ecosystem and the species that inhabit it.
|
|
There is already an area of approximately 70
hectares where no macro-invertebrate fauna can be found (14.3.2.1).
The cautious wording in the EIS demonstrates that there is
still scientific uncertainty as to the factors which are causing
the dearth of macro-invertebrates.
|
»
|
The impact upon turtles, a threatened species,
is not assessed in sufficient detail. It is clear that no formal
turtle survey has been completed in the impact zone (14.3.2.3 & 14.5.3).
|
|
Moreover, there will be a much greater risk
of heavy fuel oil spills into the marine environment if gas
is delayed (14.5.1.2).
|
|
Back
to top
|
»
|
The discussion of the flora and fauna surveys
demonstrates that habitat quality within the refinery and residue
disposal areas has already been significantly degraded by human
activities and feral animals (15.3.7.1) and that the impacts
will continue.
|
|
It is perhaps a sad reflection upon the refinery's
current environmental impacts that a listed vulnerable species
like the northern hopping mouse has not yet been located in the
vicinity of the refinery (even though there is suitable habitat).
|
»
|
It is disappointing that in the account of Yolngu
history (20.2.1) there is no mention of the fact that the original
mine was imposed upon the Yolngu people against their wishes.
Nor is there any mention of significant protest events such as
the bark petition in 1963, or the 1971 Gove Land Rights case
heard by Justice Blackburn in the Federal Court.
|
»
|
The social impact assessment is very superficial
and one-sided, in our opinion. In Section 21.5 there is no mention
of any detrimental impacts of the existing mine, yet it is obvious
that the Aboriginal communities of the area have been impacted
by more than royalties and business opportunities. Along with
the mine came a large influx of non-Aboriginal people, a town,
additional access to alcohol and so on. It is clear to ECNT that
the community consultation processes have been deficient.
|
|
This is best illustrated by the fact that only
8 responses were received from the first feedback form and 6
from the second form sent out by the consultants to the wider
community. The EIS does not indicate how many members of the
public were interviewed aside from these written responses. There
is no attempt to distinguish between the feedback received from
Yolngu people and organisations and that of the non-Aboriginal
community.
|
|
There has been no direct consultation with Yolngu
apart from through the Reference Group. There is also insufficient
detail on the potential impacts on the nearby Galupa Aboriginal
community (apart from noise, air quality and lighting effects).
|
»
|
ECNT was also somewhat perplexed to discover
that Table 23.6.2 (23-15) indicates that we raised not one single
issue during the initial meeting with Alcan representatives in
April 2003. This is not an accurate reflection of the content
of the meeting and raises serious questions about both Alcan's
listening and note-taking ability and the usefulness of including
in the EIS such a broad-brush summary of issues raised during
stakeholder consultations.
|
|
In short, Table 23.6.2 smacks of tokenism. |
|
For more information on
Climate Change contact ECNT:
Phone: 08 8981 1984
Email: ecnt@octa4.net.au
|
|
Back to top
|
|
