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Below is a template submission to the EPA on the
Public Environmental Review for the Biomass Power Plant.

 

Submissions can be made to the EPA either by post or email or fax (6364 6522).

 

The submission can be made by email to submissions.eia@dec.wa.gov.au after adding the submitters address at the top and name at signature point below. It may also assist to rename the attached file Word doc to add name of person (eg SubmissionToEPA_BiomassPowerPlant_JanBrown.doc), but this isn’t essential. When submitting by email, please add a short note to body of email advising who you are, which will also go on record.

 

The template assists people make their own submission; that is, it can be amended as you wish, or you can simply add your details and submit.

 

ALSO below is a one page short submission based on the Recommendations, which may be more suitable in some circumstances.

 

It is vital as many submissions as possible are made URGENTLY. Multiple but individual submissions from family members and teams at workplaces are important, because numbers count.

Environmental Protection Authority

Locked Bag 33, Cloisters Square
Perth Western Australia 6850

Attention: Ms I-Lyn Loo

 

SUBMISSION ON PUBLIC ENVIRONMENTAL REVIEW FOR BIOMASS POWER PLANT, DIAMOND MILL, MANJIMUP

 

This submission on the Public Environmental Review for the Biomass Power Plant, Diamond Mill, Manjimup (January 2008) addresses:

 

  1. Impacts of 380,000 tonnes of wood heavy-haulage on road safety
  2. Impacts of air pollution on public health
  3. Impacts of air pollution on agribusiness
  4. Impacts on the local economy
  5. Impacts of expansion at Diamond Mill based on wood fuel from Karri forest
  6. Shire of Manjimup processes and submission to the EPA

 

1.       Impacts of 380,000 tonnes of wood heavy-haulage on road safety

 

The Environmental Protection Authority (EPA) is considering a Public Environmental Review for a Biomass Power Plant to be located at Diamond Mill. 380,000 tonnes of Tasmanian bluegum and pine fuel for the Plant will be transported up to 100 kilometres to the Diamond Mill site south of Manjimup, including from north of Bridgetown. An additional up to 34 heavy-haulage trucks (60 tonnes when loaded, and 68 truck movements) will traverse the South West Highway daily between 7am and 7pm, increasing the already major presence of similar woodchip heavy-haulage trucks, and road user conflicts, since the Diamond Mill (Lambert siding) to Bunbury rail line closed. The Public Environmental Review presents estimates for increased percentage of vehicular traffic on relevant roads (pages 206 to 208), but this fails to acknowledge the heavy-haulage trucks are 40 times the mass of a typical sedan (1500kg), which is relevant to their dominance of the roadway and daunting presence for drivers of sedans (especially women), and damage to roadways because of their mass. There is no attempt in the Public Environmental Review to evaluate the impact of additional heavy-haulage trucks on the safety of school buses, the routes of which coincide on all of the public roads proposed to be used for wood fuel heavy haulage.

 

An independent study report by the RAC WA in January 2008 says the South West Highway between Bridgetown and Manjimup is the State’s Worst”. The Public Environmental Review states that 30% of the wood heavy haulage joining the South West Highway will be via Muir Highway, which the RAC ranked as eighth worst in WA. In State Parliament on 25 May 2005, Paul Omodei MLA, Member for Warren Blackwood, moved “That this house condemns the Labor government for its failure to resolve problems with the Lambert to Bunbury railway line, which has resulted in the closure of the line and a dangerous increase in the number of heavy haulage trucks using the South Western Highway”, and he said in his speech “People dread the trip to Bunbury for medical treatment for themselves or their loved ones. I have now been using the road for most of my life, and on a more regular basis over the past 20 years or so. I am not saying that I am any rally driver or whatever, but I consider the road to be dangerous, even to me. We see near misses all the time.”  When referring to the death of a truck driver in a collision with a heavy-haulage truck on the South West Highway, Mr Omodei said in his speech "The highway is also a school bus route. If the truck had hit a school bus, it would have killed 20 or 30 children." (Hansard, Legislative Assembly, 25 May 2005). Clearly, both the RAC WA and the experienced Member for Warren Blackwood are warning that the present condition of, and heavy-haulage on, the South West Highway are unacceptable and dangerous, and that the risks should be reduced, not increased.

 

It would be dangerous to add another 380,000 tonnes of wood heavy-haulage to the South West Highway. We all have to share the roads, but the 380,000 tonnes increase in haulage for wood is massive compared to, for example, present annual haulage of 25,000 tonnes of potatoes and 10,000 tonnes of apples from the Manjimup and Pemberton region. Since closure of the railway line, private woodchip and timber transport is increasingly dominant at the expense of the public interest, and other industry, particularly tourism which is important to the Manjimup and Pemberton region. Tourists experiencing cracked windscreens and near misses will not return, they will travel elsewhere for their next holiday. The risk of serious and fatal injury on the narrow South West Highway will increase. One such event involving temperate climate holidaying tourists from Singapore or Malaysia, then reported in those countries, could take Manjimup and Pemberton off their tourism map.

 

The Public Environmental Review (page 43) refers to the proponent investigating ‘backload’ of some of the trucks presently transporting woodchip from Diamond Mill to Bunbury. However, even if this proves practicable, it will only reduce a minority of the haulage which will converge on the South West Highway near Manjimup. One of the joint-venture companies proposing the Biomass Power Plant controls the Bunbury to Lambert (Diamond Mill) railway line asset and should re-open the railway line to transport the wood fuel if the project proceeds.

 

Recommendation 1: The level of wood heavy-haulage on the South West Highway must be decreased to improve road safety. If the Biomass Power Plant proceeds, wood fuel must be transported by rail, and where rail is not possible, the proponents must pay for road improvements for public safety.

 

2.       Impacts of air pollution on public health

 

The Minister for Health says the proponent has misrepresented and misquoted the Department of Health’s Principal Toxicologist (letter from Minister of 7 February 2008). This brings into question the credibility of statements on health impacts made by the proponents in the Public Environmental Review.

 

The proposed Biomass Power Plant burning 380,000 tonnes of wood will be the biggest ‘point source’ of air pollution in the Shire of Manjimup. The National Pollution Inventory (www.npi.gov.au) publishes data for pollution emissions from businesses throughout Australia, including the Gunns Ltd Manjimup Processing Centre. This enables comparing ‘business with business’ in regard to ‘point source’ pollution emissions, where pollution emissions from a specific business activity can be compared with another. This is where the pollution facts count. Beyond this, pollution modeling based on local climatic conditions and topography is a relatively inexact science.

 

Below is the comparison of ‘point source’ primary pollution emissions estimated for the Biomass Power Plant at Diamond Mill (Public Environmental Review page 153) versus the Gunns Ltd Manjimup Processing Centre (National Pollution Inventory):

 

Pollutant (kg/year)

Biomass Plant

Gunns Manjimup

Biomass v Gunns

Nitrogen Oxides

850,00

8,000

120 x pollution

Particulates 10um

56,700

26,000

4 x pollution

Sulphur Dioxide

53,400

40

1335 x pollution

Volatile Organics

58,700

720

82 x pollution

Carbon Monoxide

360,000

5,600

64 x pollution

Lead

800

4.4

182 x pollution

P A Hydrocarbons

1,000

15

67 x pollution

 

The above pollutant emission profile for the Biomass Power Plant at Diamond Mill is for primary pollutants only. Levels of secondary pollutant load (eg Dioxin, Ozone) that may form in the stack and in the immediate plume will only be known once the Plant is in operation. Since publication of the Public Environmental Review, the proponents have claimed the tabulated data in Table 13.18 on page 153 isn’t estimated emissions from the proposed Biomass Power Plant! Further, the information in Table 13.18 is different to that in the table on page 39 of the Development Application for the Biomass Power Plant, Diamond Mill, Manjimup (December 2007). If the proponent wishes to put alternative emissions data forward it should be done in a supplement to the Public Environmental Review, and be subject to additional public comment.

 

The effect of this air pollution load will be to shift the air quality from that normally experienced in a non-industrial rural area to approximate what would be found in a mixed urban/industrial area. For example, the levels of Sulphur Dioxide in the notional 7 kilometre radius of pollution emitted from the proposed Biomass Power Plant at Diamond Mill will be 120x the level from diffuse sources in the Shire of Manjimup. While this pollution load may be within current standards for a normal population, the actual effects on public health of this pollution load will not be known until the Plant has been in operation for considerable time (perhaps up to 5 years).  Two obvious public health impacts are:

·         negating use of rainwater tanks for drinking water. Pollutants of specific concern are Nitrogen Oxides, Sulphur Dioxide, Volatile Organic Compounds, Lead compounds and Polycyclic Aromatic Hydrocarbons. Public health government agencies throughout Australia (including Department of Health, Western Australia) advise against the use of rainwater tanks for drinking water when the storage is collected in an urban/industrial area, because of air pollution. Some agencies specifically advise against drinking water from rainwater tanks in proximity to incinerators, which have emissions similar to biomass power plants burning wood. There are approximately 120 families dependent on drinking rainwater within a 7 kilometre radius of pollution emitted from the proposed Biomass Power Plant at Diamond Mill; and

·         exacerbation of asthma and other respiratory disorders. Pollutants of specific concern are Particulates 10um, Sulphur Dioxide, Nitrogen Oxides and Ozone (secondary pollutant). The extent of this impact will not be known until the Plant has been in operation for considerable time, as it will be dependent on actual emissions and plume behaviour. There is also increasing evidence that these pollutants may have a role in causation of asthma and other respiratory disorders at levels of exposure considerably less than prevailing standards.

 

The EPA should disregard submission from the Shire of Manjimup based on a ‘study tour’ to NSW and Qld. The Shire of Manjimup’s ‘Biomass Power Plant Study Tour’ report of January 2008 says on page 1 “The mandate of the delegation was to form an impartial view of the effects of power plants on communities...”. However, the ‘study tour’ was not impartial; two of the three Councillors on the tour have since declared interests relating to impartiality (associated with supplier of wood fuel to biomass power plant interest and transport industry interest, on 24 January 2008 when the Study Tour report was presented to Council), and the proposed Biomass Power Plant burning 380,000 tonnes of wood at Diamond Mill is estimated to emit many times more pollution on most substances than the power plants visited in Qld and NSW by the Shire’s ‘study tour’ and thus the ‘study tour’ report is not valid for prediction of effects on the communities of Middlesex, Eastbrook, Jardee and Seven Day Road between Manjimup and Pemberton.

 

Recommendation 2:  The location of the proposed Biomass Power Plant at Diamond Mill is unacceptable because atmospheric pollution from the Plant will negate use of rainwater tanks for drinking water, on which approximately 120 families nearby are dependent, and exacerbate asthma and other respiratory disorders.

 

3.       Impacts of air pollution on agribusinesses

 

The Public Environmental Review at pages 151 and 152 states some pollutants will be at maximum levels 7 kilometres from the Diamond Mill site, both west and east. Assigning a notional pollution impact zone with a 7km radius includes the rural communities of Middlesex, Eastbrook, Jardee and Seven Day Road. The traditional private land use in these rural communities has been agriculture for approximately 80 years, for vegetables, fruit and cattle, and more recently viticulture, truffles and marron aquaculture. Reflecting the significance of the agricultural production in these communities is the Department of Agriculture and Food Horticultural Research Institute in Jardee, where new agribusiness opportunities such as green tea are trialed.

 

The agricultural produce within the 154 square km zone of pollution has varying sensitivities to the primary and secondary pollutants associated with the Biomass Power Plant. The Public Environmental Review doesn’t address impacts of atmospheric pollutants on agriculture. The tenor of the Public Environmental Review is a simple transposition of the impacts estimated for Bridgetown to the materially different land use location and area between Manjimup and Pemberton. This is a fatal flaw in the Public Environmental Review and the EPA must request the proponent address direct and indirect impacts of pollution on agriculture.

 

A further impact not addressed in the Public Environmental Review is the impact of air pollutants on surface water quality. Most of the agriculture in the Middlesex, Eastbrook, Jardee and Seven Day Road area is dependent on high quality water allocated in approximately 100 surface water licences (under the Rights in Water and Irrigation Act 1914) in the catchments of Smith Brook, East Brook and Lefroy Brook. There are grounds to be concerned that both primary and secondary pollutants associated with the Biomass Power Plant may be detrimental to surface water quality, and some of the pollutants may have cumulative impacts. While the proponents have compared some of the ‘point source’ pollutants estimated for the Biomass Power Plant with pollutants from diffuse sources such as burning of State Forest, the diffuse sources occur during drier months whereas maximum ground level concentrations of some of the above point source emissions occur during winter and rainfall periods when the pollutants are most likely to enter water resources. There may also be surface water resource quality implications of disposal of ash from the Biomass Power Plant if it were to be disposed on land in local water catchments. These matters were raised by the submitter and others at a meeting of the State Government Warren Water Management Area Advisory Committee on 11 February 2008, and members of the Committee were assured by the Department of Water that the Department of Water would make a submission to the EPA on the Public Environmental Review.

 

The continued competitiveness of agricultural produce from the Shire of Manjimup is dependent on food quality certification from Food Standards Australia and New Zealand and similar national and international certification organisations. In general, the technical requirements to achieve food quality certification are becoming more rather than less demanding on producers. Standards required to be achieved increasingly turn upon ‘worlds best practice’. Shift in air quality in the notional 7km radius pollution zone from that normally expected in a non-industrial rural area to approximate what would be found in a mixed urban/industrial area will increase risks associated with both maintaining and achieving food quality certification. Agricultural producers are being asked to accept these risks with no benefit in return for them from the proposed Biomass Power Plant.

 

While the above are potential direct negative impacts of the Biomass Power Plant, an indirect impact may be damage to the ‘clean and green’ image of agribusinesses. The Shire of Manjimup’s strategic plan review in 2001 identified a promotional objective of “…a clean and green image – air and water quality…”. Identified ‘strengths’ in the same review were “Clean Air and Water”. While these are somewhat subjective values when compared with the objectivity of satisfying food quality standard certification, they are important values when associated with agriculture and promotion of produce into new markets and when attracting new investment in agribusiness (eg green tea). The ‘clean and green’ image is also important for agriculture-related tourism, such as wine tourism and, more recently truffle-related tourism. The proposed Biomass Power Plant will be the most significant ‘point source’ of pollution in the Shire of Manjimup; its presence will damage a ‘clean and green image’, the degree to which will remain uncertain for some time. The most significant damage will be to agribusinesses and agriculture related tourism in the Middlesex, Eastbrook, Jardee and Seven Day Road areas, but collateral damage to ‘regions’, such as the Pemberton and Manjimup Wine Regions is reasonably foreseeable.

 

The location of the proposed Biomass Power Plant at Diamond Mill in a mixed forest and rural environs heightens concerns regarding both direct and indirect (‘clean and green’) impacts on surrounding agribusinesses. The proposed location at Diamond Mill is also surrounded by farming residents dependent on rainwater tanks for drinking water (see 2 above). Location of the Biomass Power Plant in the Manjimup Industrial Park should be considered as an alternative. Operating the proposed industrial activity within an established Industrial Park in an urban and industrial location doesn’t raise the spectre of impacts on traditional rural land use to the same degree, and the township of Manjimup is supplied by ‘scheme’ water administered by the Water Corporation which is competent to both monitor and manage water quality. There would remain justifiable concern regarding air pollution from the Biomass Power Plant; however, if approval was limited to 20MW generating capacity for a trial period of five years that impact could be managed, monitored and reviewed. There may be additional costs for the proponent to be located in the Manjimup Industrial Park (for water and power transmission); however, under the current proposal the ‘traditional’ rural land users of Middlesex, Eastbrook, Jardee and Seven Day Road are being expected to carry the costs and risks.

 

Recommendation 3:  The EPA must request the proponent address direct and indirect impacts of air pollution on agriculture in a supplement to the Public Environmental Review, and make the supplement available for public comment.

 

Recommendation 4:  In giving consideration to the Public Environmental Review, the EPA must give priority attention to the pre-existing interests of ‘traditional’ rural land use and users, ahead of the new and conflicting interests of the proponents of the Biomass Power Plant.

 

Recommendation 5:  If the pre-existing interests of ‘traditional’ rural land use and users are likely to be significantly harmed, then the Biomass Power Plant proponents should be redirected to the Manjimup Industrial Park, and, if necessary because of air pollution, be approved for a lower generation capacity (perhaps 20MW, rather than 40MW) at the Manjimup Industrial Park.

 

4.       Impacts on the local economy

 

A project of the nature of the proposed Biomass Power Plant at Diamond Mill, with substantial impacts on public interests and private interests beyond the commercial interests of the proponent, must be evaluated in full context, which isn't done in the Public Environmental Review. There is no attempt to put the 20 jobs at the Biomass Power Plant in the context of, for example, a recent study by the Pemberton Wine Region Association showing 600 persons employed in viticulture and the wine industry alone. Manjimup and Pemberton virtually have full employment now, and rely upon residents of Bridgetown to fill many employment positions. Other employment of a more temporary nature relies upon visiting contractors and others, including 'backpackers', often linked to ecotourism. Below, some of the immediate impacts on jobs and the regional economy are hypothesised in scenarios that can be reasonably foreseen.

Immediate impacts on jobs and the economy of Manjimup and Pemberton while Biomass Power Plant development awaits approval (until approximately June 2008) and impact of a ‘wait and see’ response.

Positive: It is unlikely there will be any immediate new Biomass Power Plant related jobs in the region while the project is under consideration by the Shire of Manjimup and State Government agencies, with the exception of a project community liaison person.
Negative: Landowners in Middlesex, Eastbrook, Jardee and Seven Day Road will withdraw from further investment in development of their agribusinesses, prudently adopting a 'wait and see' attitude in regard to whether the project will be approved by the Minister for the Environment and the Shire. This will be significant and will immediately impact suppliers to this sector, especially in the town of Manjimup. Potential purchasers of properties in the Middlesex, Eastbrook, Jardee and Seven Day Road areas will 'wait and see', and perhaps be lost as new investors and residents. This appropriately cautious 'wait and see' may also extend to potential investors and new residents beyond the area of the four communities. This could especially apply to tourism-related investment, and to new 'tree change' settlers previously attracted by the ‘clean and green’ image. Bridgetown, having rejected the proposed biomass power plant will be keen to fill this gap, attracting new residents to Bridgetown and investors in retail services. Confident investors in new retail businesses in Bridgetown will intelligently foresee that 380,000 tonnes of additional heavy-haulage on the South West Highway for the Biomass Power Plant at Diamond Mill will deter Bridgetown residents from traveling to Manjimup to shop. It will be safer for them to shop in Bridgetown. As the controversy surrounding the proposed Biomass Power Plant increases, especially in response to foreseeable impacts on State Forests (using Karri, Marri and Jarrah as fuel for expansion), invoking involvement of state and possibly national conservation groups, relevant parties may need to increase expenditure in 2008/2009 on promotions of Karri forest related tourism, or might withdraw from such expenditure promoting the region, foreseeing what lies ahead. Some people in Perth, picking up the news stories, may think the 380,000 tonne increase in heavy-haulage is already on the South West Highway, and the power plant is already running, and opt to holiday elsewhere. A view by Ministers and Government agencies, perhaps some may regard as cynical, but certainly plausible, is that the Shire of Manjimup has failed to move ahead after the Gallop Government restrained the notorious 'Marri Woodchip Project', returning to its old ways influenced by those who see the Karri, Jarrah and Marri forest only as wood! This view damages prospects of establishing the Donnelly River Slide tourism icon with State and Commonwealth funds, and prospects of State Government funding for other projects. The controversy surrounding the biomass power project divides the communities of Manjimup and Pemberton, with those businesses offering petitions in favour of the project noted by families and other businesses concerned about the effects on their health, safety on the South West Highway, agriculture and tourism. A divided community and local economy loses productivity as the controversy rages.

While the immediate negative economic impact period may run for six months, it could extend beyond June 2008 with appeals, injunctions and other actions taken by families and businesses protecting their pre-existing and future interests. The 'wait and see' attitude in regard to further investment in agriculture, land/homes and tourism will persist during and well past the approximately two year duration intermediate phase for construction and commissioning of the Biomass Power Plant. Aspects of the ‘wait and see’ attitude will persist for up to five years until impacts on road safety, public health, agribusiness and the areas ‘clean and green’ image can be evaluated by those concerned with present and future investment in agribusiness, tourism and lifestyle related real estate.

No comfort in regard to negative impacts of the proposed Biomass Power Plant on jobs and the economy in the Shire of Manjimup can be drawn from the Shire’s ‘Biomass Power Plant Study Tour’ report of January 2008, as the study tour was not impartial as claimed and the comparisons with effects on other communities are invalid.

Recommendation 6:  The EPA not approve the Biomass Power Plant at Diamond Mill, because, in that rural location, the net impacts on jobs and the local economy are likely to be negative, and thus there will be no benefits to the local and State economy to offset environmental costs.

5.    Impacts of expansion at Diamond Mill based on wood fuel from Karri forest

 

There are grounds for concern the Karri forest will be used as fuel for biomass power generation at Diamond Mill:

·         the Minister for Forestry on 29 November 2007 in answer to Parliamentary Question 5603 said Karri, Jarrah and Marri will be offered by tender to energy markets;

·         in a 25 January 2008 letter responding to private questions on this, the Minister for Forestry said “I understand that the Manjimup biomass plant in question does not intend, under its current application process, to utilise fuel from native forest residues. Should the project ever reach a stage where it wished to expand its operation, that expansion would be subject of a further assessment process.”;

·         it is reasonably foreseeable that such energy generation using Karri, Jarrah and Marri will be conducted within the Diamond Mill precinct near Manjimup, taking advantage of the extensive network of roads previously used for the ‘Marri Woodchip Project’, for transport cost savings; and

·         it is reasonably foreseeable that Karri, Jarrah and Marri will be burnt in the proposed Biomass Power Plant at Diamond Mill, as a commercially advantageous variation to the 380,000 tonnes per annum wood fuel mix for the 40MW capacity, and for expansion beyond 40MW output.

 

In the Minister for Forestry’s answer to Parliamentary Question 5603 he said Karri, Jarrah and Marri ‘forest residue’ and ‘forest waste’ will be used for energy markets. These ‘forest residue’ and ‘forest waste’ terms are precisely the same terms that were used to justify the notorious 'Marri Woodchip Project', where Marri was described as residue and waste from clear felling, and millions of tonnes were squandered as woodchips. Now, Marri is in demand for furniture and flooring; exemplifying 'forest residue’ and ‘forest waste' is misused terminology.

 

The language of the Minister for Forestry of 25 January 2008 re “Should the project ever reach a stage where it wished to expand its operation, that expansion would be subject of a further assessment process.” is reminiscent of the ‘staged’ development of the Wagerup Alumina Refinery which has devastated the previously rural township of Yarloop. Neither the EPA nor a ‘community reference group’ (Public Environmental Review page 203) saved Yarloop. The negative impacts on public health (2 above), on agribusiness (3 above) and the local agribusiness and tourism economies (4 above) will compound if biomass power generation expands at Diamond Mill. 

 

The Forest Products Commission 2006-2007 Annual Report at page 21 states:

"Bioenergy development

The Commission is actively working with a number of parties to develop and promote renewable energy opportunities."

"Tender process for residues

The Commission continues to work actively to finalise markets for native forest derived residues. Due to increasing enquiries particularly from bioenergy companies, the Commission decided to call for tenders. It is expected that tenders will be requested late in 2007."

 

The Forest Products Commission doesn’t appear to have offered the tender for Karri, Jarrah and Marri ‘residues’ yet. It is possible they will hold that until the Biomass Power Plant at Diamond Mill has approval of its Public Environmental Review based on Tasmanian bluegum and pine, and then the tender could be offered for a shift in fuel resource mix and/or expansion beyond 40MW generation capacity.

 

In addition to exacerbation of impacts from pollution, expansion at Diamond Mill based on fuel from native forest will evoke massive controversy similar to that which surrounded the notorious ‘Marri Woodchip Project’. Such controversy will further discourage tourism and eco-tourism based on the Karri forest, and also discourage new residents seeking ‘lifestyle’ based on the Karri forest, for which there are several developments progressing in the Shire of Manjimup.

Recommendation 7:  The EPA should ask the proponent of the Biomass Power Plant at Diamond Mill if it has intentions of expanding beyond 40MW generation capacity at Diamond Mill, and if it does, the EPA should request a supplement to the Public Environmental Review providing preliminary information on environmental impacts and management of impacts beyond 40MW capacity.  

Recommendation 8:  The EPA should ask the proponent of the Biomass Power Plant at Diamond Mill if it or associated companies have approached the Forest Products Commission enquiring about access to native forest derived fuel, and if so, whether the proponent envisages use of native forest derived fuel within the wood fuel mix for up to 40MW generation capacity, and/or for expansion beyond 40MW capacity. The EPA should verify the proponent’s response with the Forest Products Commission.

Recommendation 9:  The EPA oppose use of Karri, Jarrah and Marri from native forests as fuel for biomass power generation at Diamond Mill and elsewhere in WA.

6.    Shire of Manjimup processes and submission to the EPA

 

There are grounds for serious concern regarding the Shire of Manjimup’s required impartial, objective and thorough consideration of the Biomass Power Plant, Diamond Mill, which include:

·         the Shire attracted the specific proponent to the Diamond Mill site, and thus there is concern the Shire’s comment on the Public Environmental Review may not be as impartial as expected if the Shire had not actively attracted the specific project;

·         despite the demonstrable controversy surrounding a proposal for a biomass power plant in the adjacent Shire of Bridgetown-Greenbushes, officers and Councillors of the Shire of Manjimup spent seven weeks through to the end of October 2007 attracting the proponent, without any apparent consultation with agribusiness and tourism related associations representing businesses that could be negatively impacted by the project;

·         the Shire made no submission to the EPA on the scoping document published by the proponents of the Biomass Power Plant at Diamond Mill in November 2007 for the then forthcoming Public Environmental Review. This is a serious omission by the Shire, as input from relevant local government is crucial to the EPA, based in Perth, appreciating detail of potential impacts on road safety, public health and the economy within the jurisdiction of the local government (Shire of Manjimup, in this instance); and

·         the Shire dispatched a ‘study tour’ to power plants in Qld and NSW, at ratepayers expense,  without giving sufficient consideration to matters relating to impartiality and validity of comparisons of effects of power plants on communities.

 

Recommendation 10:  The EPA note the Shire of Manjimup attracted the controversial Biomass Power Plant to the Shire and thus the Shire may not be impartial in it’s submission on the Public Environmental Review.

 

I trust this submission is of interest to the EPA and I urge adoption of the recommendations herein.

 

Yours sincerely

(download submission)

Environmental Protection Authority

Locked Bag 33, Cloisters Square
Perth Western Australia 6850

Attention: Ms I-Lyn Loo

 

SUBMISSION ON PUBLIC ENVIRONMENTAL REVIEW FOR BIOMASS POWER PLANT, DIAMOND MILL, MANJIMUP

 

This is a submission on the Public Environmental Review for the Biomass Power Plant, Diamond Mill, Manjimup (January 2008). After due consideration, I make the following recommendations to the EPA:

 

Recommendation 1: The level of wood heavy-haulage on the South West Highway must be decreased to improve road safety. If the Biomass Power Plant proceeds, wood fuel must be transported by rail, and where rail is not possible, the proponents must pay for road improvements for public safety.

 

Recommendation 2: The location of the proposed Biomass Power Plant at Diamond Mill is unacceptable because atmospheric pollution from the Plant will negate use of rainwater tanks for drinking water, on which approximately 120 families nearby are dependent, and exacerbate asthma and other respiratory disorders.

 

Recommendation 3: The EPA must request the proponent address direct and indirect impacts of air pollution on agriculture in a supplement to the Public Environmental Review, and make the supplement available for public comment.

 

Recommendation 4: In giving consideration to the Public Environmental Review, the EPA must give priority attention to the pre-existing interests of ‘traditional’ rural land use and users, ahead of the new and conflicting interests of the proponents of the Biomass Power Plant.

 

Recommendation 5: If the pre-existing interests of ‘traditional’ rural land use and users are likely to be significantly harmed, then the Biomass Power Plant proponents should be redirected to the Manjimup Industrial Park, and, if necessary because of air pollution, be approved for a lower generation capacity (perhaps 20MW, rather than 40MW) at the Manjimup Industrial Park.

Recommendation 6: The EPA not approve the Biomass Power Plant at Diamond Mill, because, in that rural location, the net impacts on jobs and the local economy are likely to be negative, and thus there will be no benefits to the local and State economy to offset environmental costs.

Recommendation 7: The EPA should ask the proponent of the Biomass Power Plant at Diamond Mill if it has intentions of expanding beyond 40MW generation capacity at Diamond Mill, and if it does, the EPA should request a supplement to the Public Environmental Review providing preliminary information on environmental impacts and management of impacts beyond 40MW capacity.

Recommendation 8: The EPA should ask the proponent of the Biomass Power Plant at Diamond Mill if it or associated companies have approached the Forest Products Commission enquiring about access to native forest derived fuel, and if so, whether the proponent envisages use of native forest derived fuel within the wood fuel mix for up to 40MW generation capacity, and/or for expansion beyond 40MW capacity. The EPA should verify the proponent’s response with the Forest Products Commission.

Recommendation 9: The EPA oppose use of Karri, Jarrah and Marri from native forests as fuel for biomass power generation at Diamond Mill and elsewhere in WA.

Recommendation 10: The EPA note the Shire of Manjimup attracted the controversial Biomass Power Plant to the Shire and thus the Shire may not be impartial in it’s submission on the Public Environmental Review.

 

Yours sincerely
 

(download submission)
Please email contact@nobiomass.com to assist this campaign for safe roads, and a healthy, prosperous, clean and green Manjimup and Pemberton. The Biomass Action Group, formed on 12 January 2008, has an informal organising committee, and new helpers are very welcome.