Extracts from a Submission for EES on the Fingerboards Mineral Sands Mining project in East Gippsland*
10. The EES only considers Greenhouse Gas (GHG) emissions for the construction and operational stages of work at the Fingerboards site, plus emissions from the transportation of the concentrate to the shipping port. There is no mention of GHG emissions from shipping the concentrate from the Port of Melbourne to an overseas destination, nor of the GHG emissions from the further processing to refined products at destination.
Consideration of Scope 3 emissions in the EES has been limited to the off-site transport of the Heavy Metals Concentrate to the first delivery point. The proponent (Kalbar) has thus taken a very narrow view of the environmental impact of the project, and of their responsibilities. The proponent has put its collective head in the sand, pretending that these other Scope 3 emissions don’t exist.
11. The EES estimates that more than 1 million tonnes of CO2 equivalent will be discharged over 17 years. For a project commencing in 2021, this would take end-point to close to the year 2040. The EES gives no consideration to the scientifically recognised need to reduce global emissions CO2 as soon as practical, and to target zero emissions by 2050. There is no mention of any requirement, or indeed willingness, to possible mitigation and/or minimisation of the project’s GHG emissions over the life-time of the project.
12. At least 50% of the project’s predicted GHG emissions are expected to be sourced from operation of diesel generators and mining machinery. No consideration appears to have been given to any requirement that mining machinery could be electrical rather than diesel driven. Large-scale mining operations by the big iron ore miners in the Pilbara are already using electrically-driven haulage trucks, with the benefit of reduced usage of fossil fuels, reduced atmospheric emission of pollutants, and reduced ambient noise levels.
A sympathetic proponent would (and should) require the use of best available technology for its mining operations at the Fingerboards site, that would minimise fossil-fuel usage, minimise GHG emissions (including CO2 & N2O), and minimise noise emissions from the proposed 24-hour day operations. Further, with the switch to heavy electric vehicles, and combined with the other 50% of emissions from project electricity use, it is clear that the proponent should purchase clean & green electricity off-take from a large-scale solar/wind/battery electricity generating operation, preferably located in the Gippsland region. (Part 2 to follow)
*the author is a retired engineer, resident of Newlands Arm and lecturer on Environmental Sustainability at Bairnsdale U3A.