Mr Norm McIlfatrick
Department of Economic Development
GPO Box 646
Hobart TAS 7001
Mr Robert McMahon
Chairman of TAP Inc.
22 – 8 - 2006
Dear Mr McIlfatrick
Re: request for funding [$143 000] from TAP Inc. to the Department of Economic Development for a community based independent assessment and risk analysis of the Gunns proposed pulpmill at Long Reach.
Tasmanians Against the Pulpmill Inc. [TAP] is a community based, non-politically aligned group of residents from throughout Tasmania who share a common concern over the scale of impacts of the proposed Gunns pulp mill on livelihood, amenity, life- supporting capacity of our environment and of the needs of future generations.
Aims of the assessment and analysis
The State Government is relying heavily on the RPDC process to make careful reasoned judgements on the pulp mill proposal and on any necessary conditions that need to be imposed. An independent assessment and analysis coordinated by TAP Inc. aims to facilitate the ability of the community to usefully contribute critical analysis of claims made by the proponent in the IIS.
The independent assessment and analysis coordinated by TAP Inc. will collate and review data on the scale, impacts and risks arising from the proposed pulp mill from the perspective of sustainable development in Tasmania. We need to access independent expert information in areas such as eco toxicology, hydrology, air pollution, monitoring, modelling etc and make findings available to the public in digestible form.
A key issue is the impact of the scale of the proposed pulp mill on our natural resource industry, agriculture, small business and rural communities. We believe that the scale of the proposed pulp mill may detract value rather than add value.
We aim to identify key limits that should be placed on the pulp mill operation including the scale of the project eg:
- the maximum area of farmland in Tasmania that should be given over to plantations for wood supply;
- the maximum concentration of poisons used that may impact on other users in eg. forests and waterways, farms;
- the maximum level of air pollution;
- the maximum pollution of the marine environment;
- the impact on the value of water arising from plantation evapo-transpiration and direct consumption by the mill particularly given the changing long term rainfall patterns in relevant catchments.
The study will also:
- identify Tasmania’s at-risk communities and industries eg vineyards, fisheries, and tourism;
- include a risk assessment with identification and quantification of risks as well as the probability and scale of the hazards, and mitigation strategies;
- identify areas of uncertainty including assumptions made in models and how they relate to validity of claims made by the proponent;
- establish criteria for regular and event monitoring and evaluation of pulp mill impacts;
- identify regulatory mechanisms that should apply when limits are exceeded and associated penalties and compensation arrangements for aggrieved parties.
The findings will be presented in a Risk Management Report focussing on the sustainability of the Tasmanian environment, our communities and business that depend on a clean green image for continued profitability. Communities and businesses will then have an independent assessment of their exposure to various risks arising from the mill. They will be better able to contribute a realistic critique to the RPDC hearings as it relates to their individual circumstances.
Justification for this request
There is a heavy bias in publicly available information in favour of the proposal from the proponent, government Pulp Mill Task Force and industry lobby groups. Gunns have run closed meetings with selected guests to promote the findings of their IIS. In addition we as taxpayers have twice paid for the government to support the proposal viz. by providing a budget to the Pulpmill Task Force and through favourable taxation treatment for Gunns (as for all businesses), by being able to write off costs as a business expense.
To date, the government has not provided any assistance to support community responses to the Gunns draft integrated assessment report. The expectation is that members of the community who wish to provide a response to the IIS will do so at their expense and without the benefit of independent data.
This request seeks to redress that inequality by funding an independent assessment to inform the community of risks, encourage public involvement in resource management and planning and assist the RPDC to fulfill its obligations under the State Policies and Resource Planning and Development Commission Projects Act 1993. It will promote rigorous debate and significantly improve the quality of government decisions that will affect Tasmania’s future for decades to come.
State Government policies and objectives relevant to this request
Our request is consistent with the State Government policies and objectives listed below.
1. The Mission Statement of Department of Economic Development is to advance the sustainable development of Tasmania by increasing the capacity of individuals, enterprises and communities to contribute to the Tasmanian economy.
2. The Tasmania Development and Resources was established under the provisions of the Tasmanian Development Act 1983 to encourage and promote the balanced economic development of Tasmania.
3. The Environmental Industries Council aims to reposition the environment to become an essential contributor to the future of all Tasmanians by among other things strengthening Tasmania's clean, green and clever image.
4. The objectives of the legislative framework of RPDC are:
- to promote the sustainable development of natural and physical resources and the maintenance of ecological processes and genetic diversity; and
- to provide for the fair, orderly and sustainable use and development of air, land and water; and
- to encourage public involvement in resource management and planning; and
- to facilitate economic development in accordance with the objectives set out in the above paragraphs; and
- to promote the sharing of responsibility for resource management and planning between the different spheres of government, the community and industry in the State.
The RPDC objectives relate in particular to:
- sustaining the potential of natural and physical resources to meet the reasonably foreseeable needs of future generations; and
- safeguarding the life-supporting capacity of air, water, soil and ecosystems; and
- avoiding, remedying or mitigating any adverse effects of activities on the environment
5. This request assists the RPDC to meet the requirements of Schedule 1 of the State Policies and Projects Act 1993.
6. State policies on agricultural land and water quality management set out to achieve sustainable management of resources in accordance with the objectives of Tasmania’s RMPS.
Budget and deliverables
Membership of TAP Inc. includes professional accountants and project officers who have regularly handled budgets well in excess of this amount. A sum of $143 000 will be used to procure the services of independent consultants, for data collation and information presentations to the public and RPDC. Project deliverables are a Risk Management Report, public information documents viz. brochure and CDs for public use summarising the report and public seminars in major centres.
Closing date for a response
Given the very short time frame and immense importance of the task ahead, we respectfully wish to receive notification regarding the success of our submission by the close of business on 30 – 8 - 2006.
We are looking forward to your considered response.
Mr Robert McMahon
On behalf of TAP Inc. membership