Why the EES is a flawed process
The EES process was originally a process that assessed the environmental effects of a proposal to ascertain whether it should proceed or not. This EES is designed to minimize or mitigate the environmental effects regardless of their severity. This is a puzzling course for a modern, democratic government. The project potentially threatens our environment for present and future generations but was announced as a fait accompli without the environmental effects being understood. The specific areas that should concern all Victorians are as follows.
1. Discussion of more cost effective or environmentally sustainable options is excluded. The evidence that desalination is the worst solution for Melbourne’s water problems is overwhelming and yet this cannot be included in the EES Panel discussions. (See Supply and Demand Analysis – Melbourne’s Water, YWYS for more information).
2. Does not include the government’s justification of the need for the project.
3. The scoping document suggests that the panel will only have the authority to set guidelines for the project to proceed and not decide whether or not it should proceed.
4. Discussion of alternative sites is excluded. Desalination plants around the world, where necessary, are predominantly in industrial areas. Not unspoiled coastal areas.
5. Time span – Nominal time span for a serious EES is a minimum of 18 months. This is the biggest infrastructure project in the history of Victoria and has a 4 month EES.
6. The Evaluation Objectives and Criteria are predominantly drafted in language that only requires the Panel to avoid or minimise to the extent practicable adverse effects. This enables the EES process to provide a positive finding for desalination provided the environmental or other effects of the plant are minimised to extent practicable. For example, does the destruction of one, two or more square kilometres of rich marine ocean floor by the outfall diffusers equate to minimising to the extent practicable? If the government wanted a transparent process then we would have objectives that sought to identify adverse effects and make informed judgements.
7. Scientific Method The government has failed to present any rigorous scientific investigation to assess of the impact the desalination processes will have on the marine environment. They are relying on people to submit to the panel and no one group or expert could, with any validity, assess this in four months.
In particular
• No detailed documentation of the existing marine species and their seasonal movements i.e., no baseline data
• No information about the effect of increased salt levels and waste chemicals on marine flora and fauna.
• No information on the effect of destroying microscopic sea life in the seawater intake process and how this will impact on food sources for larger animals e.g., penguins, whales.
• Little understanding of how salt and waste discharges will disperse into the local environment.
8. The Economic Effects section of the EES avoids any discussion of the modelling that established the decision to build a desalination factory with a capacity of 200 GL. It also avoids any analysis of future costs of desalinated water especially considering the predicted rise in energy costs due to the measures to reduce greenhouse gases and the inevitable increase in building costs. A further consideration should be the loss of tourism, the difficulty of recruiting professionals i.e. teachers, doctors to an area that has become industrialised and the loss of current ratepayers who do not wish to live on an industrial coastline.
