01-07-2008

July Newsletter

The Harvey Shire considered a planning application for the establishment

of a pilot desal plant at its Development Services Committee Planning

Committee of 15 July 2008. Marie Dilley and Tony France attended the

meeting and asked questions. The Committee recommended as follows:

DS-08/137. Adams/Godber

“That Council;

1. Grants approval under District Planning Scheme No. 1 for a temporary

Desalination Pilot Plant on Lot 33 Taranto Road and pipelines traversing Reserve

29628, subject to the following conditions;

a) Any necessary approvals under the Greater Bunbury Region Scheme being

obtained;

b) The applicant being advised of its obligations under the Environmental

Protection and Biodiversity Conservation Act, which has designated the

project as a “controlled action”;

c) All components of the proposed Pilot Plant being removed within two (2)

years of construction of the Pilot Plant, and any necessary site rehabilitation

being undertaken and maintained by the applicant, to the satisfaction of

Council including use of endemic species.

d) Suitable management measures being put in place to ensure sufficient notice is given of the pipeline construction

(and beach access), and that safety measures are taken to the satisfaction of Council;

e) The carparking areas being drained and sealed to the satisfaction of Council;

f) The Water Corporation providing regular updates on management and environmental compliance of the Pilot Plant to

the Council and the community.

2. Advises the Western Australian Planning Commission of its approval under the District Planning Scheme No. 1 and

that it has no object to the application for a Pilot Plant made under the Greater Bunbury Region Scheme.”

CARRIED 6-0

We have been in contact with Dr Andrew Weavers, Director Western Australia and South Australia Section

Environment Assessment Branch 1 Approvals and Wildlife Division Department of the Environment, Water,

Heritage and the Arts trying to find out when and where the decision under the EPBC Act will be published, as

there is a 20 day review period. We’ve received the following response:

This project is undergoing assessment under the Public Environment Report process and the

proponent is preparing information for the draft Public Environment Report. There is no imminent

decision required of us, but there will be a public comment process once we receive and then

approve publication of the draft PER. The proponent will be required to advertise this public

comment period including on their website.

We are currently discussing potential impacts of the proposed pilot plant as they relate to

significant impacts on matters of national environmental significance.

Michael Derry has been doing some great stuff and has had the issue of the renewable energy claims aired

before the ACCC.

The issue of energy sources to run the plant is an important point. The Kwinana Seawater Desalination Plant is

supposed to be powered by renewable energy and the Water Corporation has an arrangement with the operators

of the Emu Downs Wind Farm to purchase electricity from them. However the Water Corporation neglected to

purchase the Renewable Energy Certificates associated with this energy and they were sold to Synergy.

(Harries, 2008) Therefore the Water Corporation is not actually purchasing renewable energy, as it is not a

certified green power product. What they are using is essentially fossil-fuel power because Synergy owns the

greenhouse gas abatement from Emu Downs. This is a major concern because desalination is a highly energy

intensive process and the Kwinana desalination plant is responsible for 231,000 tonnes of greenhouse gases per

annum. (EPA, 2002, 2004)

The following is an extract from a letter from the ACCC to Michael

The issues raised in your letter regarding the possibly inaccurate or confusing statements made by the Water

Corporation in relation to the operation of the PSDP, concerning how it is powered, the source of that power and its

overall effect from an environmental perspective, has been raised with the ACCC by other concerned consumers. In

particular, the main claims raised are that the PSDP was powered by electricity produced by the Emu Downs Wind

Farm (Wind Farm) and that as a result of using electricity from the Wind Farm, the PSPD is carbon neutral.

Given the potential for these statements to cause confusion with members of the public, the ACCC has brought its

concerns to the attention of the Water Corporation with a view of ensuring that such statements are not made in the

future, and if any “green” claims are made, the statements are sufficiently qualified to minimise the risk of

misunderstanding.

As a result of our discussions with the Water Corporation, I am of the view that their conduct in publishing such claims,

were due to a large extent to a lack of appreciation by their staff of the issues associated with green claims, and how

these statements may be construed by the general public.

While I do not intend to go into specific details of the undertakings provided by the Water Corporation to the ACCC, I

can confirm that the Water Corporation will ensure that their employees will not make future representations to the

effect that the PRDP is powered directly by energy produced by the Wind Farm or that, in using the power supplied by

Synergy which it acquired from a renewable energy source, the PSDP’s operations are carbon neutral on the

environment.

You may be interested to know that the WC have published their peer review of the Social Impact Assessment that they

commissioned. It’s worth having a look on the WC website

http://www.watercorporation.com.au/_files/PublicationsRegister/15/SIA/Beckwith_Peer_Review_Comments_June_2008.p

df

However for those without the Internet this is the overview:

Jo Ann Beckwith PhD June 2008

Prepared for the Water Corporation of WA

In Western Australia, proponents are not required to assess the social impacts of their proposals beyond the very limited

aspects allowed as part of the EPA’s formal impact assessment process. As a result, too often proposals do not undergo

social impact assessment.

The Water Corporation’s decision to conduct a social impact assessment (SIA) of its proposed Southern Seawater

Desalination Project, including the use of a peer reviewer, is commendable.

However, having decided to embark on an SIA, it is essential that the SIA practitioners are equipped by the proponent

with sufficient technical outputs from associated studies (e.g. visual, noise, dust) to allow them to draw meaningful

conclusions regarding the significance of potential impacts and the most appropriate impact management measures in

response to the predicted impacts. Unfortunately, this has not occurred due to a mismatch in the timing of the technical

studies and the SIA resulting in needed technical study outputs being unavailable for the SIA.

By their own assessment (p.7), the SIA practitioners were unable to evaluate the following social impact issues they

identified:

 Impact on community Identity and Sense of Place

 Impact on community facilities and services

 Impact of power lines

 Impact of the construction of the plant on the visual amenity of the area

 Impact of the construction of the pipelines on the visual amenity of the area

 Impact of the construction of the tanks on the visual amenity of the area

 Increase in cost of labour for industries and businesses in the region

 Increased traffic in the area causing delays and increasing risk for local communities and commuters

The SIA practitioners attribute their inability to predict impacts to a combination of insufficient data inputs from the

technical studies (discussed above) and insufficient time for the SIA. While the peer reviewer empathises with the SIA

practitioners’ regarding the tight timetable for the assessment, the reviewer cannot apply available time, as a criterion, in

judging the quality of the SIA. In addition, the proponent defined the issue of impact on property values (potentially

positive or negative) as outside the scope of the SIA, although it was an issue of concern to some stakeholders.

It is the opinion of the peer reviewer, that despite the outputs of some technical studies not being available to the

practitioners, the SIA could have gone much further in informing decision makers and stakeholders about why certain

social impact issues are important. Use of the social science literature would have assisted in supporting why certain

social impact issues should be investigated and their potential effects.

There was also a missed opportunity to inform decision makers regarding the accommodation of construction workers. At

this point in time, no candidate sites have been identified for a construction camp, nor has the need for such a camp been

evaluated. This provided a valuable opportunity for the SIA to inform and influence decisions regarding how best to

address this important impact issue. It could provide the following information to decision makers:

 What can be learned from the social science literature about construction camps and their social impact issues?

 What considerations/factors should be included in the site selection process if a construction camp is needed?

the proposed plant site?

construction camp in their area?

However, the SIA did not take advantage of this opportunity. It deferred the assessment of facilities and services to after

the decision on the acceptability of the proposal and provided little guidance to decision makers regarding the siting of the

construction camp or whether it is desirable to have a camp at all.

BDAG have been busy asking questions of the Federal and State Environmental Authorities- re Controlled Action and the

implication of this action. We are now of the opinion, that perhaps they should have been asking/answering the same question with

the proponent- Water Corporation’s, Project Officers.

The “Controlled Action” resulted in an assessment level of “Public Environmental Report” being set, which is the second highest

level of assessment given by the Federal Environment and Biodiversity officers in Canberra. The “Controlled Action” was placed

over the “site” due to Federally protected Flora and Fauna and Marine species plus their habitat - which may be impacted by the

proposal.

According to Water Corporation’s Desalination proposal, the site covers Part lot 8, Lot 32,& 33 to the high tide mark. Therefore

resulting in “No Go” over any of the site, not without Federal Approval.

So the BDAG committee went into investigative mode on seeing the Shire of Harvey request for comment for the Pilot Plant planning

proposal, which is on the SITE of Controlled Action.

It seemed obvious to us, and other Binningup locals who asked, “How can the Water Corp propose any construction, no matter what

size, on a Federally protected site?” “Has the Shire of Harvey been informed?”

This has led to many frantic phone calls to and from BDAGERS. One of which was from Nicole Matthews, the EPBC officer based in

Perth asking “Is this Pilot Plant proposal on the same site??” “Yes” was our reply. She immediately contacted Canberra. Canberra

have requested a full assessment of the Pilot Plant Planning proposal, and politely informed Water Corp. (well we assume it was

polite)

Conversation with Nicole Matthews, confirmed the fact that the significance of the “Controlled Action” had not been fully understood

by the Water Corporation. BDAG may suggest “conveniently misunderstood” by Water Corp project team.- We believe Canberra

bods have straightened them out. But we ponder “What if we had not asked the question? Don’t the State Departments and Feds talk?

And isn’t that the proponents requirement before submitting to a Local Authority?

B-DAGGERS are not impressed!

The Water Corp have just published this on their website.

If you look at the scale provided and then at the process buildings – they’re all about 140m x 50m. Funny - I seem to remember that

we were told that there was to be one “Bunnings” shed on the site – now it looks like there are 9!!

Also - why aren’t they using the degraded limestone pit for anything.?