Olympic Dam Expansion EIS - Where is the genuine commitment to biodiversity?

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We are extremely disappointed with the approach taken to biodiversity protection and management throughout the Olympic Dam Expansion Environmental Impact Statement – whilst some token efforts have been made to reduce impacts, there is no commitment to voluntarily create any non-compulsory environmental benefits to offset the monumental and far reaching impacts of the mine.  This is completely at odds with the biodiversity commitments made by BHPBilliton in 2007/08, including the commitment to: Manage our projects, operations and activities in a manner that supports and encourages positive biodiversity outcomes 

(http://www.bhpbilliton.com/bb/sustainableDevelopment/environmentalCommitment/biodiversityAndLand.jsp)  The scale and extent of negative environmental impacts imposed by this development is unparalleled, but the evidence provided in the EIS to describe, quantify and evaluate these impacts is weak and patchy as we have highlighted above.  It would be the height of irresponsibility to approve this development with an incomplete and erroneous understanding of the likely impacts.  This would effectively allow an unprecedented proportion of our environmental assets to be stolen and destroyed, and erode our capacity to secure fair compensation.

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The Nature Conservation Society of South Australia (NCSSA) is South Australia’s primary nature conservation advocacy body.  The primary objective of the Society is to “foster the conservation of the State’s wildlife and natural habitats”.  The NCSSA uses science to guide good conservation decision making.  The Society has taken action on many varied environmental issues since its formation in 1963.    The Society has reviewed the Olympic Dam Expansion EIS and wish to submit the following comments. We are extremely disappointed with the approach taken to biodiversity protection and management throughout this document – whilst some token efforts have been made to reduce impacts, there is no commitment to voluntarily create any non-compulsory environmental benefits to offset the monumental and far reaching impacts of the mine.  This is completely at odds with the biodiversity commitments made by BHPBilliton in 2007/08, including the commitment to: Manage our projects, operations and activities in a manner that supports and encourages positive biodiversity outcomes  (http://www.bhpbilliton.com/bb/sustainableDevelopment/environmentalCommitment/biodiversityAndLand.jsp) This lack of genuine commitment to biodiversity is most clearly reflected in the following areas: Significant Environmental Benefit offsets to compensate for Vegetation Clearance 17,267 hectares (Section 15.5.1) of vegetation will be cleared under the proposed expansion.  BHPB propose native vegetation offsets of 128,278 hectares, however no evidence is provided to demonstrate that this will result in a real environmental benefit. There is no detail provided of how these areas will be managed in perpetuity to deliver an SEB – indeed there are no details of how these offset areas are currently being managed. If these areas are not currently utilized for stock grazing, they are already protected from this use under legislation and therefore no SEB can be achieved without additional management commitments. The offset calculation is fundamentally flawed, as destruction of over 17,000 hectares should not be offset by simply trading an area that is less than 10 times the size and is already protected by legislation, and where improvements in condition or threat management are not expected to be substantial.   We request BHPB

  • release details of current land management in the proposed offset areas, to allow for an evidence based evaluation of the true environmental benefits that will be achieved in these areas

 A simple calculation of the number of animals that will be killed by this habitat destruction provides a more comprehensive understanding of the true impacts of the proposed expansion, and reveals the mediocrity of the current proposed offset.  Lizards in the Australian arid zone have been documented as occurring at a density of over 400 lizards per hectare[1].  Thus the number of lizards that will be lost due to habitat destruction through clearance of 17,267 hectares is approximately 7, 000, 000. Annual predation rates by feral foxes and cats accounts for approximately 1000 reptiles, 150 birds and 50 mammals per square kilometre[2].  Thus, using reptiles as the metric to calculate an environmental offset, the 17, 000 hectares of clearance could be offset by perpetual fox and cat removal within an area of 700, 000 hectares.  Current proposed offsets (that do not even commit BHPB to fox and cat control) are less than 20% of this area. We request BHPB:

  • take into account the figures provided above and commit to providing an offset that will guarantee a true environmental benefit.

  • commit to landscape scale management of threats in perpetuity to offset habitat loss as a result of vegetation clearance

 Proposed Tailings Retention System This EIS is the first time that quantitative data on the impact of the current Tailings Retention System (TRS) have been made publicly available.  Currently there are over 130 hectares of evaporation ponds (ie radioactive, acidic liquid waste only), plus an additional 400 hectares of tailings storage (incorporating solid and liquid waste).  In the last three years alone over 1400 water birds representing 28 different species have been found dead in the TRS. With the expansion of the Olympic Dam mine, the total tailings areas will be increased to just under 4000 hectares.  Whilst netting has been flagged as a primary mechanism to prevent access of birds to free liquor, no details are provided of the materials that will be used. The highly acidic environment of the tailings areas that will rapidly corrode most material and the distance that netting will need to span present huge challenges for the construction and maintenance of effective nets. The EIS does not demonstrate how these challenges will be overcome and does not provide any evidence of trials into the effectiveness of nets in the long term, nor are there any contingency plans listed if these nets prove to be ineffective. If netting is such a simple solution, then why have BHP Billiton not implemented netting on the much smaller TRS that exists now. The proposed TRS will include changes to its design that will reduce the amount of free liquor available, which may help mitigate impacts to some open-water species.  However, it is apparent that the expanded wetland surface will still attract noctural flying waterfowl.  There is no evidence that BHPB have investigated a more rigorous deterrent system. BHP Billiton also acknowledge that there are many limitations to their weekly monitoring counts (due to the huge area and inaccessibility of the tailings lakes) which make these numbers likely to be significant underestimates.  To effectively gauge the likely effects of the new TRS, BHPB should be undertaking modelling utilising all available data to predict the degree that the weekly sampling protocol underestimates true mortalities. These actions highlighted above are all to reduce impacts – there should be an onus on BHPB to do more than this, such as a genuine commitment to landscape scale biodiversity conservation in the region. BHBP must:

  • provide evidence of long term effectiveness of nets

  • commit to netting the existing TRS evaporation ponds

  • provide details of what monitoring is proposed, and how it will gain a more accurate estimate of bird losses

  • have independent scientists model the relative proportion of total bird deaths compared to bird deaths recorded in weekly visits to the TRS.

  • provide a genuine offset to the number of birds that modelling demonstrates will be killed by the TRS by committing to perpetual landscape scale conservation programs

 Tailings Leakage from the TRS Tailings leakage will ultimately represent a moderate residual impact (12.7) on groundwater.  This is unacceptable.   BHPB must:

  • commit to a program for which tailings leakage has negligible residual impact on groundwater

 Dam pit at the end of Mining The open pit left at the completion of mining will act as a regional groundwater sink, capturing all seepage from the TSF and RSF.  Given the effect of highly acidic tailings dams on birds and other animals as noted above for the TRS, this will undoubtedly be a threat to regional fauna, particularly waterbirds.  There is no information in the EIS on the acidity and toxicity of water that will be in this pit.  This is a crucial omission. BHPB must: ·        Provide data on the toxicity of water that will be in the pit upon completion of mining activities·        Model the effects on fauna to allow for informed debate and decision making·        Provide alternatives to minimise effects on fauna·        Offset the biodiversity cost of residual impacts (such as the pit in this case) by committing to perpetual programs that have demonstrable environmental benefit Water Extraction from the Great Artesian Basin In order to achieve their stated aim of “[managing] our projects, operations and activities in a manner that supports and encourages positive biodiversity outcomes” BHPB need to decrease groundwater uptake from the Great Artesian Basin to zero, rather than increase uptake as is the current plan.  The statement (12.7) that “no groundwater will be extracted from the GAB outside of approval of the South Australian Government, resulting in no residual impact” is deplorable: residual impact is independent of government approvals. BHPB should:

  • cease extraction of water from the Great Artesian Basin

 Location of desalination plant The expansion proposes another 200 million litres of water per day will be sourced from a desalination plant at Point Lowly.  The EIS provides a good summary of the great diversity of habitats and species found in this area.   However the EIS appears fundamentally flawed as only one of potentially six chemicals that are likely to be used in the desalination process and returned to the water was tested in vitro (16.4.2).  This is unacceptable for assessing impacts. The interactive effects of this chemical cocktail in combination with raised salinity also needs to be tested (as the combination of raised salinity and chemical load is likely to have a far greater effect than any one chemical or raised salinity alone).  We would also question how a zone of impact (quoted as 3.9km south-west 2.1 km north-east of the outfall) could even be calculated without these data.  We request BHBP:·        conduct in vitro testing of the effect on local sea species of all six chemicals that are likely to be released into seawater at Point Lowly.·        ensure this in vitro testing considers the interactive effects of these six chemicals and heightened salinity·        re-evaluate the zone of impact following this in vitro testing Within Section 16.7 Accumulation of Salt in Spencer Gulf there is a statement:  Entire Gulf flushes over an annual cycle, with salt removal via the hypersaline bottom current on the east coast”.  The statement “entire gulf flushes” is contradictory to 16.3.2 which states 78% of water north of Pt Lowly is exchanged from below each year.  It is also apparent that hypersaline, pollutant rich seawater will thus traverse the entire coastline of Spencer Gulf, including “slugs” of hypersaline seawater that will move along the east coast of Spencer Gulf.  This water will include chemicals that will be released by the Desalination Plant that have not even been tested for toxicity.   There are clearly risks involved in locating a desalination plant in a gulf which only partially flushes each year.  Associate Professor John Middleton, has raised serious concerns about the data used to justify claims of minimal risk[3].   We thus call upon BHPB to:

  • minimise risk to the marine environment by moving the desalination plant to an area where discharge can be undertaken in deep ocean rather than in a gulf

 A monitoring program is flagged (16.6.5, 16.6.7), but no response actions or their trigger points are identified to address impacts outside of the predicted range. These are necessary to demonstrate that BHPB will commit to managing the risks associated with this desalination plant. We request that BHPB:

  • not only implement monitoring as described in 16.6.5 and 16.6.7, but detail trigger values relating to this monitoring that will be used to change the mode of operation of the desalination plant

  The scale and extent of negative environmental impacts imposed by this development is unparalleled, but the evidence provided in the EIS to describe, quantify and evaluate these impacts is weak and patchy as we have highlighted above.  It would be the height of irresponsibility to approve this development with an incomplete and erroneous understanding of the likely impacts.  This would effectively allow an unprecedented proportion of our environmental assets to be stolen and destroyed, and erode our capacity to secure fair compensation.


[1] Morton, S.R. and James, C.D. (1988).  The diversity and abundance of lizards in arid Australia: A new hypothesis.  American Naturalist 132: 237-256.

[2] Read, J. and Bowen, Z. (2001).  Population dynamics, diet and aspects of the biology of feral cats and foxes in arid South Australia.  Wildlife Research 28 (2) 195-203.

[3] Middleton, J. (2009).  Submission to SA Parliament ERD Committee South Australian Research and Development Institute.