Letter 10 Re: Water over allocation threats from a Tasmanian pulp mill process

The Honourable Malcolm Turnbull
Minister for Water and Environment
c/- Parliament House, Canberra
18 February 2007

We are a complex systems consultancy working on behalf of a consortium of common interests about water including community based TAP and LEC a local environmental organisation, both concerned about the impacts of a mill approval. We write to ask that you intervene in the combined state/federal ‘approval’ process for a ‘world scale’ Tamar pulp mill in order to protect our water supplies that are in severe danger of being massively over-allocated for decades.

During our researches it has become evident that local industries need sensible protection from mill outputs and activities. They also need protection from a biased decision making process and a state government that appears to favour logging over all other industries without regard to the consequences. We write to you in order to try to get some rational intervention in the process and to ask you to obtain guarantees that our water will not be over-allocated in the RPDC process.

As rainfall continues to decline, our rivers and lakes are drying up (e.g. Great Lake down to 15%) indicating that demand for water in Tasmania already exceeds available supply from groundwater, dams and lakes. Despite this, demands for water are increasing. This is especially true for tree plantations that require water guarantees for decades and given the huge land areas involved together with their usual locations in upper catchments, their drain on our water supplies is enormous.The requirement for plantations to feed the proposed pulp mill and chip export markets is around 1,100 Gl/yr, more than double that used annually by the city of Melbourne (420 Gl/yr).

Committing to that amount of water every year for decades, at a time when demand already exceeds supply, could be disastrous. Unfortunately the actions and statements of the State government indicate that they want a pulp mill regardless of the impacts and critical issues of water needs in the areas of wood supply have been excluded from your consideration within the RPDC.

Water consumption in Tasmania's north and east 1975 to 2020

Diagram 1. Water consumption in Tasmania’s north and east from 1975 to 2020. (Data collated from Tasmanian Department of Primary Industry and Water reports, pulp mill proponent’s Integrated Impact Statement to the Resource Planning.

The diagram shows how the water hungry plantation estate, the highest percentage coverage of any State, has created a demand that Tasmania cannot now supply. The cross over point on the water supply & demand curve has already been passed as evidenced by existing water shortages across the State in the five driest months of 2006–2007.

Because water is used by plantations first (as evapo-transpiration), it is never available to downstream agriculture, industry and towns. Unlike urban residents and agricultural irrigators, plantation managers pay nothing for the water that they use which gives them another unfair advantage in any competition with other users of that same resource. The current pulp mill proposal is unsustainable without the promise of MIS subsidies and preferential and free access to water. Given the undisclosed price Tasmanians will receive for their timber resources, it is only prudent to do a complete accounting for the project, including costs of all impacts on rural areas affected by wood supply.

In this context, the recent decision to leave forestry MIS schemes in place is also highly questionable, especially given the impacts that MIS funded plantations are already having upon the sustainability of the overall water supply and those who rely upon it.

Decision making in the absence of a rational water budget presents serious threats to communities, other industries and river ecosystems. The mill will not only lock in a ‘world scale’ rate of logging, it will also lock in world scale water use at a time when we cannot afford it and may consequently ‘lock in’ decades of needless drought for Northern Tasmania. It will do these things based on an economic ‘justification’ that deliberately ignores opportunity costs of placing such a huge mill in a prime tourist, agricultural, fine food and wine region like the Tamar valley.

As signatory to the National Water Initiative, Tasmania’s water resources must be managed sustainably for the benefit of the State and the nation. In the context of climate change and increasing pressures on water resources in other states, the true value of Tasmania’s water resource will rise eg. for irrigated crops or direct water supplies. Simply put, ignoring the value of the State’s water resource puts our water at risk of being squandered and over-allocated.

As it stands, water consumed by plantations is unmetered, uncosted, unpaid and unavailable to downstream users. This extremely serious omission threatens the livelihood of thousands and the economy of the State. One effective way of correcting this would be to charge plantation and mill operators a commercial rate for water used.

As a consequence of the above factors, we ask:
1. that in the event of future water shortages, that the community, existing industries and agriculture, are guaranteed water priority over and above a pulp mill with its associated plantations; and
2. that you insist that complete water budgets, including in the (currently excluded) area of wood supply, be developed prior to any mill approval to assure that there is enough water available, and that you assure that any mill that may be approved is of a size commensurate with the size of Tasmania’s various resources.

If you, or your officers, would like more comprehensive information or a briefing from our consultancy, please let us know. We look forward to your reply and we hope sincerely that you can deal effectively with the distortions mentioned above in water use, priorities and budgets.
Yours truly,

Mike Bolan, Facilitator

Robert McMahon, TAP Chairperson

Gillian Marsden, LEC Chairperson

Update on Minister Turnbull's response

As of 20 August 2007 six months after posting the letter, no reply has been received by TAP.