Evaluation of the Social Impact Assessment of the Gunns Ltd Bell Bay Pulp Mill

This article contains an evaluation of the Social Impact Assessment (SIA) for the Bell Bay Pulp Mill proposed by logging and woodchipping company Gunns Ltd.

Description of project
Gunns Ltd is proposing to develop a bleached kraft pulp mill in George Town in North Tasmania. The project involves the construction of a pulp mill & its support infrastructure: a workers accommodation facility, a wharf facility, landfill, a water reservoir, a water supply pipeline & an effluent pipeline (GHD: 2006: p5).

The pulp mill is intended to produce kraft grade pulp for export & domestic markets.

Description of SIA methodology
GHD were commissioned by Gunns Ltd to conduct an SIA as part of the Integrated Impact Statement (IIS) of the proposed Bell Bay pulp mill.

The methodology adopted by this SIA used a range of techniques –
 * It developed a community profile on a local, regional & state level using Australian Bureau of Statistics (ABS) 2001 census data.
 * It conducted focused consultation interviews with key members of the community.
 * It conducted random interviews with community members.
 * It analysed potential social impacts, assessing key impacts associated with the pulp mill proposal & identifying potential mitigation methods.

Critique
In 1992, a group of social scientists formed the interorganisational committee on Guidelines & principles for SIA (ICPGSIA) (ICPGSIA: 2003: p231). They published an outline of principles & guidelines for SIA in 1993, with a revised edition in 2003. Although these guidelines are established according to the US policy framework, it is regarded as an international benchmark for SIA practice. As such, this set of guidelines will be used as the benchmark by which we shall compare the Bell Bay Pulp Mill SIA.

Public consultation
The first step in an SIA according to ICPGSIA is to develop public involvement, identifying all potential affected groups & interested parties, consulting them & determining potential areas of impact & concern (ICPGSIA: 2003: p244).

This SIA however only interviewed ‘key members of the community’ namely the Deputy Mayor of Georgetown, the General Manager of George Town Council & a team leader at a local employment agency (GHD: 2006: p26). Each of these parties shares the same development agenda as that advanced by the pulp mill proposal. This consultation process is hence only consulting stakeholders who will affirm the benefits of the pulp mill rather than providing the SIA with constructive criticism and a true representation of the views of the community.

The only attempt made to gauge public sentiment was a random interview process conducted by interviewing people on the streets in key retail & commercial districts. This form of random sampling fails any measure of scientific rigour. The process of interviewing people ‘randomly’ in a retail or commercial district doesn’t provide a random sample. It only provides a sample of a very specific demographic, namely those people who happen to be walking in a shopping district on a particular day at a particular time.

Furthermore, the selection process in this type of situation is far from random, interviewees have a tendency to interview a specific type of person with whom they can readily identify, these people will represent a specific demographic of society, not a random sample as it should.

An appropriate form of random sampling requires the selection of a sample of people which is proportionally representative to the ethnic, cultural, ideological & socio-economic make-up of a community. The sampling method adopted in this SIA however, doesn’t fulfil any such criteria.

The SIA consultants from GHD have been exposed to a diversity of concerns.

A consultation process has taken place between GHD & key environmental & community groups. They would have been aware of large environmental protests which attracted over 2500 people in Launceston in December 2005 (AAP: 2005). Nevertheless, there was no reference in the body of the SIA report to indicate the peoples’ concerns or to indicate the consultation process undertaken. The findings of the consultation process with NGO’s was published in a special report within the body of the broader 18 volumes of the IIS, but none of its content permeated into the SIA. The finding of the community group consultation process is hence lost within a mass of other evaluations.

This fails to provide the SIA with a comprehensive overview representative of the range of community concerns. Instead, only a selected perspective is articulated.

Community profile (Baseline study)
According to the guidelines for SIA, a community profile or baseline study is intended to give an outline of “existing conditions & past trends associated with the human environment in which a proposed action is to take place” (ICPGSIA: 2003: p245). This outline illustrates the baseline situation in which a project is to be implemented, it outlines current community dynamics, major economic trends & other aspect of the socio-political context.

The pulp mill SIA fails to develop an appropriate community profile. Rather than providing a comprehensive community profile, it develops a profile which is tailored to develop a particular impression of baseline conditions. In its summary of the community profile, it outlines “key issues & opportunities identified during profiling” such as high unemployment, an aging population problem, & low levels of qualifications (GHD: 2006: p24).

The SIA hence develops the impression that this community will need the proposed development to rejuvenate the community, providing it with new work opportunities, an influx of young workers & higher levels of education & training.

However, the analysis of the community profile leaves out many significant trends within the community:
 * It doesn’t provide an outline of one of the main economic activities in Tasmania, tourism.
 * It doesn’t provide a break down of the community according to gender.

These variables would provide a completely different illustration of potential impacts the pulp mill may have on the community. They provide us with a more comprehensive understanding of potential impacts upon social & economic dimension of the community.

Alternative formulation
The baseline study is supposed to give us a baseline understanding of the community in order to assess & compare the potential impact of a project with the alternative situation of the project not going ahead. The SIA process subsequently goes into exploring alternatives in a holistic & transparent fashion (ICPGSIA: 2003: p233).

The pulp mill SIA however never made any reference to alternatives, volume 1(a) of the IIS makes the only reference to alternatives stating: “The alternative to establishing a pulp mill is a ‘do nothing option, that is, continue to export woodchips to international pulp mills for processing”(GHD: 2006: p103).

This fails to provide an appropriate analysis of possible alternatives.

Tourism is a major industry in Tasmania currently employing 39,600 people either directly or indirectly, providing $1.6 billion to the Tasmanian economy. Tourism Tasmania plans to further develop the Tasmanian tourism industry, with a potential growth in employment to 54,000 people & a contribution of $2.5 billion to Tasmania’s economy in the next decade (Tourism Tasmania: 2003).

The development of tourism is therefore a distinct alternative.

The tourism industry hence has the potential to be a major source of growth & development for the state. However, tourism in Tasmania is based on Wilderness tourism. Tourism interests are hence in direct conflict with the interest of the pulp mill, the pulp mill proposal intends to continue the logging of native forest at the rate of a minimum of 5 million tonnes a year for the next 30 years (GHD: 2006: p103). These actions will have significant ramification on wilderness tourism in Tasmania, yet none of this was explored in the SIA.

Furthermore, they are many existing alternative conceptions relating to the future of forest management in Tasmania. Many environmentalists propose alternative forestry management regimes & hence maintaining current forestry practice at current rates is only one possible course of action among many.

The Bell Bay SIA nevertheless ignores all these possible alternatives.

Impact analysis
The consultation process, community profile & scoping exercises undertaken in this SIA have enabled most of the significant likely impacts of the proposed pulp mill to be disregarded. The impacts the proposed pulp mill would have on tourism, women & the natural environment have not been included into the frame of reference of this SIA.

According to GHD, the likely impact that this project may have on the future of Tasmanian tourism for instance is no longer relevant as tourism was not identified as a significant aspect of local community dynamics.

Meanwhile, the economic benefits that the pulp mill may have in terms of employment, education & training are described in considerable details. The pulp mill will create 2000 new jobs by 2030 & provide nearly $1 billion of tax revenue in the period between 2008-2030 (GHD: 2006: p54).

The cost to tourism however remains unappraised, there is no cost-benefit analysis, to compare the losses made in the tourism industry, to the gains made in forestry. Will there be a net gain in economic output & employment? These considerations are left unknown in GHD’s assessment.

The SIA does identify the some potential negative impacts, however these are understated in terms of their actual significance.

For instance, several aboriginal heritages sites were located on the pulp mill site, one of these sites is regarded as a site of state significance. However, according to the SIA, “none of these site will be directly impacted upon by the project” as they are to be incorporated into a reserve system within the pulp mill site (GHD: 2006: p52). The impact on aboriginal heritage values is hence regarded as being a minor negative impact (GHD: 2006: p55). The way in which the concerns of local aboriginal people are simply dismissed is both culturally insensitive & patronising. Local indigenous people have significant social, spiritual, and environmental concerns about their sacred sites being absorbed into the proposed pulp mill, yet these concerns are ignored.

In July 2005, the wilderness society issued a series of fact sheets outlining its concerns about the pulp mill, few of these concerns have be addressed in the SIA, there is no mention of problems relating to the excessive water supply needed for the pulp mill, the effluent outfall or the continued & intensified logging of Tasmania’s native forests (The wilderness society: 2005; The wilderness society: 2005; The wilderness society: 2005; The wilderness society: 2005).

Parts of the IIS refer to some of these potential impacts, however these reports are framed to dispel concerns of potential critics of the proposal rather than evaluating the actual potential impacts of an activity.

From example, GHD commissioned a report entitled Comment on Bell Bay effluent & potential impact on nearby seal colonies. The scope for this report was defined in the following statement:

‘The scope of the commentary was restricted to potential bioaccumulative effects of substances in the effluent in order to address concerns articulated by a community member during consultation about the impacts of the Bell Bay mill’ (Drew and Frangos: 2006: p5).

This impact assessment process doesn’t attempt to investigate all potential impacts which may arise from the project but rather acts as a means to respond to potential criticisms.

Mitigation measures
Mitigation procedures are intended to be a way of identifying potential impacts & avoiding them by modifying the project through the redesign of specific aspects of a project. The process of developing mitigation procedures usually works in conjunction with the public consultation process, people identify prospective issues & in response, the SIA consultants redesign the proposed project in order to incorporate these concerns into a new improved project proposal. This process of redesign is repeated, until an acceptable proposal in created, providing maximum utility to all parties through improved design.

The mitigation methods outlined in this SIA however, do not include any major changes to the initial proposal. Technical suggestions made by the Wilderness society in 2005 have been ignored.

Other mitigation measures are outlined but most are tokenistic & provide no real changes to the initial proposal. Examples of this include:
 * The creation of a reserve system within the boundaries of the pulp mill to preserve aboriginal heritage sites.
 * The development of “a sympathetic colour scheme’ to minimise the visual impact of the project (GHD: 2006: Appendix B: p5).

Furthermore, many of the mitigation measures in this SIA can be seen as ways of containing criticism, rather than embracing them as a means of improvement. There is a range of mitigation methods which focus solely on channelling criticism to a variety of different community liaison meetings, committees & complaint hotlines (GHD: 2006: Appendix B). These mitigation procedures are devised to minimise the impacts of likely complainants by incorporating them into a bureaucratic framework in which the communities’ criticism can be contained.

Summary of contrasts with benchmark principles & guidelines of SIA
The Bell Bay pulp mill SIA is consistently at odds with SIA principles & guidelines:

Principle 1& 2
 * Achieve extensive understanding of local & regional settings
 * Focus on key elements of the human environment relating to the project

This SIA fails to include all local patterns in its community profile, it fails to mention the economic potential of tourism in the region & also overlooks women in its demographic analysis of the area. Instead, it provides an illustration of baseline conditions which reflect the need for the pulp mill to go ahead.

Principal 3& 4
 * Must be based on sound & replicable scientific methods
 * Provide quality information for use in decision-making

These principals require the collection of data which is representative of all issues & perspectives relating to a project, providing a holistic & transparent analysis of information & alternatives (ICPGSIA: 2003: p233). The consultants in this SIA have blatantly disregarded this principle, systematically leaving out specific issues, perspectives & alternatives in order to promote a single course of action.

Furthermore, sampling methods, which were supposedly from a random sample of community opinions, have no sound statistical scientific basis.

Principal 5 – Ensure that any environmental justice issues are fully described & analysed. This principal refers to the need to identify disadvantaged & underrepresented groups, insuring that their views & opinions are adequately represented in an SIA & that they are not adversely effected by a proposal due to lack of exposure to the consultation process.

This project makes no attempt to identify vulnerable & disadvantaged parties. No consultation process has occurred with women from the community, to assess their concerns at a large influx of male construction workers. Nor has any consultation taken place with local aboriginal people to assess their concerns with the fact that the proposed pull mill is to be developed in an area that has several sites of regional & state significance to aboriginal people.

The consultation process that did take place focused almost exclusively on key stakeholders & parties within the bureaucratic elites.

Conclusion
The Bell Bay pulp mill SIA conducted by GHD Pty Ltd disregards all principles & guidelines relating to SIA. In each stage of the SIA, GHD leaves out specific considerations relating to the project in order to create an SIA which portrays the project as a positive development for Tasmania.

The SIA fails to provide a comprehensive account of all perspectives & concerns, glossing over a significant amount of its consultation data & impact assessment.

As such, this SIA cannot be regarded as an appropriate appraisal of the pulp mill proposal.

This is largely due to the fact this was never an ‘independent’ SIA, as the report claims to be, but rather should be regarded as a public relations paper, commissioned by Gunns Ltd in order to gain permission to build the pulp mill.

It is therefore important, for an independent SIA to be commissioned, evaluating all potential impacts of the Bell Bay pulp mill & developing a clear understanding of its ramifications.