2 Reynolds Drive,

Crafers SA 5152,
Tel: (08) 8339 3972
Email: mountlofty@ozemail.com.au
7th August 2009

The Manager, Assessment Branch

Department of Planning and Local Government
RE: Proposed Olympic Dam Expansion
email to: OlympicDamEIS@state.sa.gov.au

Dear Sir,
Submission on the proposed Olympic Dam Expansion EIS

The role of Doctors for the Environment Australia is to examine and educate on the
links between human health and the environment. This submission details why the
Olympic Dam Expansion is not in keeping with the long-term health and wellbeing of
the population of South Australia. There will be direct adverse health impacts and also
impacts on future generations. Furthermore the Expansion will deplete basic
environmental resources of the State beyond the limits of sustainability. Health and the
environment are closely linked and environmental sustainability is increasingly
recognised as an important health issue.
Recognising that it is highly probable that the project will proceed for no discovery of
this size has yet avoided exploitation, our submission is intended to advise government
that the management of society must change radically in the 21st century; it has become
imperative that leadership focuses on creating a truly sustainable society without
untenable economic growth and population increases. It is vital that this focus becomes
a guiding principle in the governance of South Australia, to ensure survival and
longevity for South Australians and South Australia. If we had to select one project
which demonstrates most of the follies of our civilisation, this is it.

We will address the question, “Is the expansion of this mine in the future long-term
health interests of SA and indeed in the interests of Australia?” An important
recommendation is that this mine needs a detailed health impact study.
The expansion of the mine is to proceed at a time when South Australia will be increasingly
burdened by the constraints of accelerating climate change. The provision of water by the
State is a complex issue and one that governments have failed to solve with the consequences
that loss of land resources are already being witnessed. The call for a state of emergency to be
declared in the Lower Lakes region by Maude Barlow senior adviser on water to the President
of the United Nations General Assembly cannot be deflected. The predicted advent of a
further El Nino and the climate change predictions of permanently declining rainfall
emphasize the fundamental question: how many people can South Australia support? It would
seem that government has failed to recognize this issue for a number of years with an
unrealistic strategic plan, continuing calls for population expansion and most recently a plan
for Greater Adelaide.
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South Australia is also part of a World under increasing constraints from exploitation and
exhaustion of natural resources. Today society functions under the guidance of scientific fact
and consensus. We accept the findings of aerodynamics in establishing air safety, the findings
of microbiologists in discovering an antibiotic for an infection, and the role of computer
science in communications. Yet in 2005, The Millennium Ecosystem Assessment Synthesis
Report by 1,360 scientific experts from 95 countries was released which showed that
approximately 60 percent of the ecosystem services that support life on earth—such as fresh
water, fisheries, and the regulation of air, water, and climate—are being degraded or used
unsustainably. Since that report, these services have deteriorated further and this is related to
the footprint of consumption and pollution which, at South Australian levels applied to the
entire world, would require between 3 and 4 planets to live on. In its present form, the
Olympic Dam Expansion will add to this problem.

The global economy is nearly five times the size it was fifty years ago. Business cannot
continue as usual. The government has to assess whether this project is truly sustainable.
Sustainable development is recognised as a compromise between environmental, economic
and social goals. This permits society to ensure wellbeing for both present and future
generations without damaging the environment and jeopardising the ability of future
generations to meet their needs. A recent report outlined in 'Prosperity without growth:
lessons from the economic crisis' suggests that we need to redefine 'prosperity' in order to
avoid financial catastrophes in future and protect precious environmental resources. Scientists
increasingly recognise that proposals need to be examined in the light of this concept. We
recommend that government look at the proposed Olympic Dam Expansion in terms of the
study Source: Jackson, T.J. (2009). Prosperity without growth? The transition to a
sustainable economy. Sustainable Development Commission report. Downloadable from
www.sd-commission.org.uk/publications/downloads/prosperity_without_growth_report.pdf

The Justification for the proposed expansion at

http://www.bhpbilliton.com/bbContentRepository/docs//200947258289/odxEisChapter3Proje
ctJustification.pdf in our view summarises why the project is unsustainable.
The reasons are as follows:-
Population and water supply
Roxby will increase population as part of an overall government policy to increase
population:-
Table 3.1 aligns the proposed expansion to the SA Strategic plan of 2007.

Target 1.21 “the proposed expansion would provide the impetus for expenditure on strategic
infrastructure, stimulated by business and population increases in both metropolitan and
regional South Australia.”

T 5.9 “The proposed expansion would increase the population of Roxby Downs up to 10.000
people. For the construction phase the expansion would also require a short-term increase of
an average 4000 people, peaking at 6000”.

In 2004 DEA made submissions to the Strategic Plan pointing out that there were no
sustainability studies to support the proposed economic growth and population policy. In
2009 we are not aware of any study of the population-carrying capacity of this State over the
next 30 years. The problem with the policy of population growth is further emphasized by the
ethos of the 2009 Plan for Greater Adelaide which will utilize productive farming land for
building. This displays ignorance of the likely trajectories for farm production under climate
change and the need to protect as far as possible one of our life support systems, food
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production. This is a prime example of the dichotomy between policy and scientific evidence
discussed below.
There is already evidence that South Australia will have difficulty providing water to its
existing population. Given current policy, it would be unable to service an expansion of
population. This problem could, in part, be solved by better water policy, but even if all
avenues such as storm water were efficiently pursued, there remains doubt about the future
adequacy of water supply. Increasing desalination is an unwanted course of action, as it not
only poses a significant financial cost, but also has significant environmental impacts, some
of which would cause permanent economic losses to the Gulf.
Water is a health issue. Its diminished supply already impacts on the health and wellbeing of
communities along the River Murray with stress, depression, social and family disruption and
yet we are only in the early stages of experiencing the effects of climate change.
In this light the original permission to draw around 37,000,000 litres per day from the Great
Artesian Basin (GAB) was a mistake for the GAB may become a necessary resource for a
sustainable South Australia. The current proposal is to increase this draw down. We oppose
this.
BHP uses population increase as a justification for the project, which in the short term may
provide economic benefits. As this project will last decades before the mine loses production,
we argue that the expansion of population supported by such a project is not sustainable.
Indeed the entire philosophy expressed in the Justification is based on continued economic
expansion which is untenable in its present form. Production is justified by rapid population
expansion in India and China. Population expansion is supported by cheap resources, the
costs of which are externalized (as with oil and other resources) and this exposes a
fundamental problem for humanity.

Greenhouse emissions
The World Health Organization has listed the health consequences of climate change as a
priority issue. The impacts on Australia have been researched by Doctors for the Environment
Australia and published at

http://www.dea.org.au/UserFiles/File/pdf_documents/Climate_Change_Health_Check_2020.
pdf In world terms, unless greenhouse emissions from this project are fully mitigated,
there will be an impact on health in all other countries and particularly in poor countries
which do not have funds for adaptation.

Target 3.5 of the proposal “Achieve the Kyoto target by limiting the State’s greenhouse
emissions to 108% of 1990 levels during 2008 to 2012 as a first step to reducing emissions by
60% (to 40% of 1998 levels) by 2050” and “For the Olympic Dam operation, BHP Billiton has
committed to applying a goal of reducing greenhouse gas emissions (reportable under the National
Greenhouse and Energy Reporting (Measurement) Determination 2008) to an amount equivalent to at
least a 60% (to an amount equal to or less than 40%) of 1990 emissions by 2050”

There are no plans to ensure this commitment is effected by BHP. Science indicates that a
reduction of 80% by 2050 is the likely need and this target is certainly being discussed
(though not yet agreed) internationally. BHP Billiton intends to source up to 650MW of electricity,
all from the current grid, or with an unknown percentage powered from gas. Current SA electricity
demand is between 1,650MW (base load) and 3,000 MW (peak). There is no commitment to mitigate
emissions from this usage. BHP Billiton will increase greenhouse gas emissions from the
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Olympic Dam mine from 1.2 Mt a year at present to up to 5.9 Mt a year CO2-e by 2020. This
would increase South Australia’s current total emissions of 33 Mt/yr by up to 14% by 2020.
This position makes the project untenable in its present form because:-
*South Australia will be unable to fulfil its stated commitments to reduce emissions.
*It will make it more difficult for Australia to comply with the increasing urgency to reduce
emissions before 2020.
*It is unacceptable and misleading to dismiss renewable energy sources---
“At present, no commercially viable solar or wind energy solution has been identified at the
base load scale required” (Executive Summary p.26); and

“Solar and wind energy technologies are at an early stage of market development and are
unable to supply base load power on a continuous basis. Accordingly, they are unsuited to
steady state power supply…” (Ch.4 Project Alternatives, 4.11.2 Reasons for rejecting other
options)

----for review of the world literature will demonstrate rapid progress in dealing with base-load
power and the use of renewable energy in other large projects. Firstly there is increasing
evidence that both wind and geothermal are poised to become more economical that fossil
fuels within a short time frame (e.g. Report from the New York University Stern Business
School 2009), and especially so if the true cost of fossil fuels is computed by including
subsidies, and secondly base-load problems are being increasingly circumvented by a mix of
renewable energy sources. Furthermore geothermal projects are already nearing completion
in the north of SA.

Our concerns extend to the sourcing of electricity for the desalination plant. Only 63% of the
required energy will be from renewable energy. We note that this usage of renewable energy
contradicts the BHP position on the suitability of renewable energy for the main project.

Let us be realistic about this unacceptable situation. Like all constituted companies, BHP is
committed to profit and will use the cheapest subsidised source of energy, fossil fuel. It is for
the government to have the public interest and guts to indicate otherwise.

Health Hazards to South Australians

The tailing dams are a health hazard- or more strictly we have to assume that they are a
health hazard until a full health risk assessment study is completed. We understand that there
will be 9 new dams which will increase the present 400 hectares to 4000 hectares. The dams
will be clay capped on completion of usage. The capped tailings dams will hold 1.25 to 5.5
million tonnes of acid; the acid water will have a pH of ~ 1.5, will have a high metal content
of metals toxic to humans, including arsenic, mercury and uranium and it will take 150-200
years for it to seep into groundwater. The track record of most mines suggests that there will
be leaks. It will take thousands of years for the radioactivity to decay. There will also be a
waste heap of 242 million tons of mined materials which will also seep. The proposals for
dust remediation create further problems with seepage of sprayed water and chemicals.

To use a non-medical term, these proposals are mind-blowing in the potential risks to this and
to future generations.

1. Contamination of water supplies has to remain a potential health hazard for a project of this
size. The science of aquifers that might be accessed is complex. This risk has to be considered
in the light of the future use of the water of the underground water of the region in a State
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which might need to utilise this source. It also has to be considered in the light of increasing
data showing long delays in the appearance of surface toxics in ground and aquifer water.

2. Air quality compliance needs to recognise the volume of toxic material and the prevalence
of dust storms which can transport thousands of tons of material into the atmosphere. There is
a local impact because particulates are formed which cause lung disease. The world cannot
contain the metals in the dust; they are having health impacts from accumulation. Their
containment during the life of the mine will be difficult but who will be responsible for the
containment and monitoring for hundreds of years?
As consequence of the above statements we make the following comment:-
Review of process
That governments over-ride existing laws to promote such developments indicates a profound
ignorance of the ecological crisis facing the world as a result of human activity. In many
instances the ignorance is understandable for throughout the world, governments are trying to
cope with increasingly complex issues, the crisis in the rivers of many countries provides but
one example. The most striking feature of government performance is the increasing
dichotomy between policy and scientific evidence. In South Australia, this relates to the oft
expressed ‘leadership on climate issues’ despite incompatible policy actions that will worsen
the effect of climate change. Nowhere is this more evident than the proposed Olympic Dam
Expansion.
Accessibility of scientific understanding to policy makers has been identified as a contributor
to the dichotomy between policy development and science. As a result of these concerns,
detailed studies are being made on how understanding and performance can be improved. An
EU-supported report, conducted by the SKEP-ERA-NET network www.skep-era.net,
compares processes for planning, managing and communicating research to advise
environmental policy making and regulation. The conclusions relate to planning,
collaboration and communication including the use of intermediaries.
http://www.naturvardsverket.se/sv/Nedre-meny/Webbokhandeln/ISBN/5900/978-91-620-
5958-3/ The conclusions drawn in this study can be summarised simply in two points.
Firstly, scientists are typically poor communicators and need to become better
communicators, such that policy makers and the general public are better informed. Secondly,
there is a similar responsibility for members of governments to make informed decisions,
which requires a thorough understanding of sometimes complex concepts. To give one
example, in the preparation of the IPCC reports, experts from many disciplines participated,
from economics, health, agriculture, forestry and dozens more. Each expert will relate that it
took several months to get their head around the problem so that they could understand how
the picture fitted together. As doctors, we are required to inform our patients, so that they can
decide what treatments are appropriate for them. We must provide our patients with unbiased,
scientifically based information and inform them of the risks and potential consequences.
What does this mean for a government Minister? Is their department capable of telling them
what they need to know and are they being thoroughly informed, or is there information
missing? It is not too late to demonstrate leadership and review the Olympic Dam project by
criteria that consider all aspects and impacts, direct and indirect, short and long-term of the
Olympic Dam Expansion.

In conclusion the issue of the dichotomy between policy and scientific reality which should
determine policy in complex issues is one of increasing concern to scientists. Together
government and the scientific community need to develop mechanisms to address this
problem.
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A simple question-- What is the true cost benefit of the proposal to the people of SA?

It should be possible to determine whether annual royalties to the State will be greater or less
than the costs to the State which are likely to be:-
(1) Greenhouse abatement will be increasingly costly as international agreements come to
grips with the problem. What is the cost of government providing renewable sources to cover
this?
(2) The increasing costs of water provision. These will result from more potential draw down
from the Great Artesian Basin water, a source that may become necessary for the
sustainability of this State. Economic damage to gulf fisheries from the proposed desalination
plant at a time when the upper Gulf which has poor tidal flows will be harmed by climate
change.

(3) The costs and maintenance of population expansion resulting from the project.
(4) The costs of monitoring for hundreds of years.
(5) Uncharted health costs—no health impact study.
Apart from the shareholders of BHP, it is possible that the Australian nation will incur a
financial loss on this project. Against possible royalties of 200m, we must balance diesel
subsidies of $70m, and the cost of providing renewable energy development which is
essential if South Australia is to fulfil its commitments, and generations of health and site
monitoring.
Will the Royalties be used for mitigation?
The question of how the government will use the royalties is not part of the EIS. However if
we accept that emissions must be fully mitigated if the project is to be truly viable, then either
the company or government must mitigate. The company makes a commitment, but without
stringent legislation there is little to ensure that this commitment is met. Companies are driven
by market forces and shareholders to do the least possible, as was highlighted by the response
of James Hardie to the compensation of asbestos users.
If the government is to mitigate, then the concept of Dutch disease applies to the royalties. It
is well recognised that over-reliance on resource extraction is a sure prescription for poor
countries to become poorer and there is evidence to suggest other adverse consequences in
developed countries. The reason for this is that large royalties obviate the need for raising
taxes for necessary development but the royalties are not used for necessary development,
they are put into general revenue. The occasional prudent government e.g. Norway, has
created future funds which have had and will continue to have a favourable outcome for the
wellbeing of its citizens.

If then prudent environmental accounting is not to be used for this project which is unlikely as
it would increase the cost of the product, then the project will be made more sustainable by
the creation of a Futures Fund. This would allow South Australia to use the added revenue
from the expansion of the mine to advance its place in the world as a centre for renewable
energy production and innovation. To this end, the first call on the fund would be
infrastructure for renewable energy and, should further funds be available after this priority,
funds should be made available to the rural sector to secure one of South Australia’s most
important life support systems.
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Conclusions

The project should not proceed but could be re-evaluated after health impact studies and
independent economic analysis which takes into account all externalities present and future.
If the government decides to proceed it should be under the conditions that:-
1. All greenhouse emissions are remitted by renewable energy developed by them. It is
unreasonable for the community to shoulder this development of renewable energy at a time
of financial crisis when commercial banks are not lending for such projects.

2. The size of expansion is reduced commensurate with concerns about the viability of the Gulf
and the usage of GAB water.
3. Full health impacts and risk assessments are made.
4. That a Futures Fund is created for the majority of royalties that will be used to adapt SA to
the impacts of climate change. In particular it would be used to develop renewable energy
industries and for adaptation in the rural sector

5. That BHP put aside funds, in public control, for potential health consequences over 50 years
and for air and ground water toxic monitoring over centuries.

Yours sincerely

David Shearman
Hon Secretary, Doctors for the Environment Australia