Archived page, Submissions PER Commercial HISmelt Plant - Kwinana - April 2002

Introduction

Recfishwest is very concerned at the impact of individual industrial and residential development proposals on the waters of Cockburn Sound and Owen Anchorage, as well as the cumulative impacts arising from the ongoing 'rollout' of such projects. In this regard, we are concerned that the HIsmelt proposal will add to the already overstressed ecology of the Sound in the context of all the other extant environmental impacts (see EPA Bulletin 907 for a discussion on this matter).

Nevertheless, Recfishwest also recognises that the proposal is for an industry development in an area long since having been designated for heavy industrial use, and, in the context of the specific site chosen, is for a use compatible with previous usage for steel rolling and pig iron production.

We do not oppose the proposal in principle. However we believe that the proponent has not yet properly provided sufficient information in the PER, or made a satisfactory set of environmentally responsible commitments, as would allow our organization to not oppose the proposal in its current form.

Please note that Recfishwest's charter encompasses ensuring that marine and freshwater systems are only exploited in such a manner as to allow sustainable use of their resources. We are not generally inclined to comment on proposals for terrestrially based developments, as that here being commented on, except as they do or may impact on these systems.

With the above in mind Recfishwest would like to make the following observations and comments:

Proponent's Commitments

The proponent's commitments are manifestly deficient in providing reassurance that key potential environmental impacts will be well managed. For instance Commitments 1.2, 1.3, 2.1, 11.1,13.1, 16.1, relating to the eventual preparation of: an environmental management plan; an environmental management system; a construction phase EMP; a dust management plan; a surface water management plan; and a waste management plan respectively, are simply inadequate.

The lack of these plans in the PER does not allow any assessment to be made as to how effectively and diligently the proponent will manage these critical environmental management processes and issues. This situation is most unsatisfactory, and on this issue alone, the proponent should not be allowed to proceed further until such time as the community is given sufficient information as to allow informed judgments to be made.

Pollution of Sound Waters through Groundwater

Recfishwest considers the proponent's description of its intentions (p7-55) to provide an impermeable layer under stockpiles of bulk materials to be insufficient, as are its Commitments re this issue, as observed above, to eventually "prepare a surface water management plan".

Quite simply, we consider this issue to be of primary importance. There must be NO additional groundwater pollution impacts on the Sound arising from new development. The proponent should be made to fully commit to, and technically specify, at the 'front end', how it intends to meet a ZERO groundwater pollutants discharge target.

Dust Control

Recfishwest is very concerned that the proponent has not adequately described potential dust impacts. At a minimum, some description should have been provided as to the extent of any dust plume which may arise from unloading operations of bulk raw material of in the order of 1.3 million tonnes annually. The visual amenity of the Sound has already suffered greatly from coastal infrastructure development and to potentially add a dust plume to the existing level of visual pollution without describing, at the community assessment stage, what that might consist of, is a major omission.

In addition, Recfishwest contends that the proponent should be made to commit to a fully enclosed system of bulk unloading operation such as that pertaining to material handling at the Port of Esperance.

Spillage of Bulk Materials

The proponent's commitment is inadequate. A zero spillages target together with a fully specified management plan produced PRIOR to approvals is required.

Marine Environmental Impacts via Increased Shipping Levels

Recfishwest notes that there will only be a marginal increase in overall metropolitan area shipping resulting from this proposal, and also notes existing State plans for ballast water discharge and tributyltin management. However, if this project is to proceed the proponent should be asked to undertake some baseline research in order to determine, in the future, any impacts of the development on TBT in particular, and in a broader context, changes in future ecology of marine organisms at the site.

Conclusion

Recfishwest is strongly of the view that this proposal should not be assessed until the proponent provides sufficient further information, together with the making of more rigorous commitments, so as to enable a further round of community consultation.



This page last updated on 30 December 2003.