Cinders

I am familiar with "Guidelines." They are unenforceable and not worth the paper they are written on.

The exception is when "guidelines" are incorporated into the company licence under "Conditions of Licence." They are then enforceable and open to prosecution from breaching that condition, though, in my state, prosecutions rarely occur anyway.

You did not address my assumption that NOx emissions from the Gunns' proposal will exceed "guidelines." Can you confirm that for me please?

Just for Dickie, Sweco Pic, the Government’s independent consultants found 8 areas of non compliance out of 100 assessments made against the 2004 emission guidelines.
Guidelines that must be addressed prior to the Parliamentary approval of the pulp mill, a pulp mill that will only use pulp wood from the integrated and sustainable harvesting of regrowth native forest or specifically grown plantations.

There is no need to assume what these areas are as they are laid out in the report published by the State Government in a completely open and transparent manner.

One area of non compliance is the in- stack (chimney) level of NO2 emission being 1.5 kg per air dried tonne of pulp rather than the Tasmania guideline of 1.3 kg per ADt.

However the ambient levels in the general environment for NOx will be met.

The reason for the increase that now equals the guidelines of the World Bank, EU and US EPA is the selection of gas firing of the lime kiln rather than oil firing.

Sweco Pic concluded that the “Proposed emission rates are considered to represent accepted international best practice for a project of this nature and scale and ambient NOx values are predicted to be well within guideline design criteria.”

Of the remaining seven areas of non compliance, one has been actioned by selecting a chemical processing option that now meets the Guidelines, five will be the subject of regulated conditions of the licences and another one, stack height, was regarded as not significant by SWECO Pic.

For those interested the Sweco Pic report and its reasoning is available from the Tasmanian Government web site.

The regulatory authorities in Australia have a practice of manipulating stack emission levels to "ambient" or "ground" level estimates by their "you beaut" computer modelling.

Should the stack emissions for NOx or any other chemical be in breach of the licence, the manipulation to "ambient" levels will always favour the polluter.

Regulators appear to be oblivious to the fact that there is an upper troposphere. Reducing stack emissions levels to ambient levels will baffle those who object to the pollution (unless they have a degree in chemistry!) and this is a totally irresponsible method by authorities who are captured by the industries they regulate.

It reveals an authority which has no respect for the atmospheric releases of pollutants or the damage to the environment.

An example is an appeal where the appellant objected to the release of dioxins which was 0.38ng/m3, far in excess of the international guidelines of 0.1ng/m3. It was also revealed from emission reports they had previously emitted dioxin levels at 0.9ng/m3. "No worries" says the department - it's not a licence condition!

However, the department, under pressure, chose to manipulate the 0.38ng/m3 of dioxins to ground level readings which resulted in a reading of 0.014 pg/m3. End of story.

This is ridiculous since dioxins are bioaccumulative and transboundary which means that the emission could have landed thousands of miles from the source invading eco-systems and even someone's dinner plate! Who knows where they ended up? You cannot reduce dioxins!

So when a condition of licence places a limit on "stack emissions", it should mean just that - and not reduced to "ambient" or "ground" levels to shut appellants up, unless ground levels are stipulated in the licence - which they never are!

It is reassuring to find Taswegians insisting on transparency prior to the final approval for this proposal. It will be too late after the horse has bolted!

Ill-informed governments and their environmental agencies have continued to dupe most of the people most of the time but I believe that's no longer sufficient!