The Draft Environmental Impact Statement for the Jabiluka proposal has attracted comment from a wide range of sources who, between them have queried most aspects of the document. of the 82 submissions, 79 were critical of the quality and scope of assessment performed. The following is a synopsis of what federal government departments, statutory authorities, industry bodies, land councils and non-governmental organisations have said about the quality of environmental assessment and the probable impacts the proposed mine would have.Each of the following comments refer to the Jabiluka Draft EIS and may be located in the Submissions to the Draft EIS. Copies of the full submissions may be obtained from Environment Australia or the Australian Conservation Foundation."The discussion on risks associated with radiation gives a false slant to the conventional view that there is no threshold, below which delayed adverse effects (carcinogenic or mutagenic) do not occur." Australian Radiation Laboratory
"the occupational radiation doses estimated may be up to a factor of two too low. This would lead to doses in excess of 20 mSv/year for some work categories..." (20 mSv/year is the maximum allowable dose for employees)
"In the early years of production the proposed monitoring programme may not be sufficient to ensure the necessary control of workplace conditions."
"Public and occupational doses should be kept well below the recommended dose limits......If the 30% of 20 mSv/year crtieria is used, then the proposals do not meet the requirement."
"The dose conversion convention for radon daughters is 10 mSv/WLM (Working Level Month), not 5 as used in the Draft EIS. This means that the dose contributions from radon daughters presented in the Draft EIS are low by a factor of 2."
"...the report implies that the risk of harm to the public is still acceptable at a dose of 1mSv/year. This is not consistent with ICRP." (International Commission for Radiological Protection)
"All these dose estimates seem to be predicated on the 20 mSv/year being an acceptable dose, but this is not correct.....Operational doses should be kept below approximately 6 mSv/year."
"The tipping of ore from mine haulers onto stockpiles is likely to generate significant quantities of dust, but no mention of this is made."
"Teh data.....suggest that the ore-grades will be higher in the first 8-9 years of production, so the average figure quoted is certain to be an underestimate for an empolyee who works only through the early years of operation."
"No regulator would be comfortable with a concept that annual exposures routinely approaching 20 mSv/year should be considered acceptable."
"ARPS is unable to confirm that the radiation exposures received by the public and persons occupationally exposed at the Jabiluka mine will comply with the recommended dose limits." Australian Radiation Protection Society
"At the design stage there is inadequate attention given to radiation exposure control."
"....no reason is given for ignoring Aboriginal camps which are closer to the mine site than the selected hypothetical group at Mudginberry."
"The ICRP and the IAEA (International Atomic Energy Agency) have both recommended that job rotation should not be used as a means of radiation exposure."
"ARPS concludes that ERA has not demonstrated that no worker will exceed the recommended dose limit."
"The statement that radioactive material taken in through the mouth 'passes through the body and is eliminated' is totall misleading."
"ARPS considers that the information provided on radiological protection is insufficient to confirm that public and occupational radiation exposures will be within recommended limits. It is not considered that the proponent has demonstrated that the project can be carried out in compliance with current radiation protection standards."
"I find it surprising that the proposal includes a threat that a redrafted Pan-Continental original proposal will be implemented if the Jabiluka project is not approved." Dr Stuart Pearson, Dept. of Geography, University of Newcastle
"The proposal does not adequately explain how the extra waste, processing and water will de disposed of...."
"The EIS demonstrates the the assessment of the biological and archaelogical significance is grossly inadequate and a decision based on such inadequate information would be irresponsible."
"...information about expected profits, expected tax schedules and tax concessions, expected royalties, foreign and corporate ownership structures, dividends, reinvestment strategies, commitments to provision of services and leakages to other regions and countries is lacking. This makes it impossible to make an assessment of the real economic value of the project relative to the copsts incurred."
"The risk of the mine becoming a liability to future Australians needs to be carefully considered and costed."
"The Committee is not satisfied that any community benefit will derive from the mine." Aboriginal Project Committee - Kakadu Region Social Impact Study
"I do not believe that the material published in the Draft EIS provides sufficient information for any informed judgement about this proposal and it's likely social effects." Dr Richard Howitt, School of Earth Sciences, Macquarie University
"ERA requires the consent of the relevant traditional Aboriginal owners to vary the approved design for mining at Jabiluka. That consent has not been given. Indeed, senior traditional Aboriginal owners have voiced their opposition to mining at Jabiluka. The Minister has also been advised of this fact. Yet the Commonwealth government has decided to proceed with an EIS for Jabiluka based on a proposal which is not approved by, and has not been negotiated with, traditional Aboriginal owners." Northern Land Council
"The traditional Aboriginal owners are so distressed by the notion of having a further uranium mine developed on their estate after their experiences of the last 15 years that they refuse to participate in consultations at least until their concerns have been addressed."
"The NLC finds it astounding that ERA and Government are undertaking an EIS on a number of proposals for which the proponent does not have the requisite consent of the traditional Aboriginal owners under the provisions of the Land Rights Act. In short, the EIS is predicated on proposals which cannot proceed without traditional Aboriginal owners' approval. This approval has not been given."
"As a State Party to the World Heritage Convention, Australia has obligations to identify, protect, conserve, present and transmit to future generations, the World heritage on it's territory. Australia's obligations under the Convention apply no only to actions which take place within areas inscribed on the World Heritage List but also to actions outside a listed property which have the potential to adversely affect World Heritage values. This is of particular relevance in this case given that the Jabiluka Mineral Lease is completely surrounded by land inscribed as World Heritage." The World Heritage Unit
"While the Draft EIS notes that adverse impacts on the ecology if the Magela Creek floodplain and associated waterbodies within the Park are 'unlikely', the World Heritage Unit recommends that because of the environmental sensitivity of the area surrounding the lease that there be no impact which in any way diminishes the World Heritage values of the surrounding area."
"It appears impossible to determine....whether the proposed mining operations will not have an adverse impact on cultural values, either within the lease area itself or the World Heritage Area. It is therefore recommended that a decision on whether the mine proceed be delayed until this issue is adequately resolved."
The Precautionary Principle states :
"Where there are threats of serious or irreversible environmental damage, lack of full scientific certainty should not be used as a reason for postponing measures to prevent environmental degradation."
Prepared by the Australian Conservation Foundation Anti-Uranium Campaign, March 1997.
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