Below is the preface by Oceanographer, Dr. John Luick from the recently released report ‘Physical Oceanographic Assessment of the Nautilus Environmental Impact Statement for the Solwara 1 Project – An Independent Review’
As I prepared this review of the Nautilus Environmental Impact Statement (EIS), what struck me the most was how nothing seems to have been learned in the two decades since the original Ramu Nickel EIS was written. My critique of the Ramu EIS (on behalf of the Mineral Policy Institute in 2001) could be summarised as “great data set, shame about the analysis”. And pretty much the same describes my response to the Nautilus EIS.
Ramu Nickel Limited and it partners wanted to discharge the mine tailings into the coastal ocean. Local Madang landowners opposed the plan, and it led to a case before the National Court. The landowner’s case was largely based on scientific evidence that my colleagues and I provided. My testimony was that the oceanographic consultants had done the field work well, but their analysis of it was weak. For example, they presented plots which implied that the bottom currents at the shallow dumping site were onshore, and that upwelling currents would quickly sweep the dissolved fraction up into surface waters. Despite these plots indicating worrying risks to local communities, they were presented without analysis – in fact, without comment.
The Nautilus EIS shows much the same pattern. In fact, the same company (Coffey Natural Systems, then known as NSR) did the physical oceanography for both, so perhaps it should not come as a surprise. The physical oceanography and hydrodynamic components of the EIS are, to put it kindly, second-rate. The modelling is completely unacceptable by scientific standards. Moreover, every error and every omission in the analysis downplays the risk. This is also what I saw in the Ramu Nickel EIS. For example, in the Nautilus EIS, an instrument was deployed to monitor surface currents, but the data was not presented.
Most of my work as an oceanographer has been in so-called “marginal seas” similar to the Bismarck Sea, as well as in the deep Pacific Ocean and on the shallower waters of the continental shelf. But the real point is that one does not have to be a “deep-sea” or “marginal-sea” or any other oceanographic specialist to pick out the shortcomings in the oceanographic elements of the Solwara 1 EIS. They are so basic that I could have written the same review 27 years ago while still a student.
While working on this review, I contacted Nautilus and the modellers to seek further details. This led to three important pieces of information. Firstly, Nautilus confirmed that surface current data existed, but did not consider it to be relevant to an environmental impact statement, hence had deliberately omitted it. (The implications of this are described in Section 3 of this report.) Secondly, the modellers (APASA) claim to have done sensitivity studies and other analysis that would have lent their results some credibility, but had chosen not to mention them in their report. Thirdly, the sediment deposition and plume data (the subjects of sections 4 and 5 of this review) were reviewed by an independent consultant to the PNG Government. It has not been possible to obtain a copy of the reviewer’s report. Thus it is not known whether or not this review led to changes to the predicted impacts. According to Nautilus and the consultants responsible for the EIS’s oceanographic modeling, the reviewer ran their own model with the same inputs and obtained the same results as in the EIS. So perhaps this does address concerns about the accuracy of the models. However, this approach fails to address the findings that data inputs to the modeling were flawed (see Sections 4 and 5 below). By inputting the wrong data, the reviewer could well have made same wrong predictions about impact.
In regards to the modelling, I decided to base my review only on what is included in the EIS, because this is what was submitted to the PNG government. As far as the public can tell, the EIS was the basis on which the PNG Government granted the 20 years operating licence to Nautilus. I accept that the modelling validation may have been more comprehensive than was reported, and that there may be additional work that supports the results in the EIS. However, that remains to be seen, and it does not lend support to the PNG Governments’ decision to issue the operating licence
The people of PNG deserve better. They should be able to feel confident that the approvals process is open and based on the best available science. The EIS fails to provide the basic information needed to assess the risk of pollution of the environment or the risk to local communities.
As time goes by, the people of PNG seem to be increasingly concerned that government agencies are letting them down. Hopefully, companies like Nautilus will also come to see that ramming through an EIS based on second-rate science is not in their own best interest.
I conclude with three suggestions for future development proposals:
- Companies need to make it clear to the consultants that they are not looking for “greenwash”. The purpose of the EIS is to aggressively look for every potential source of risk, to properly evaluate it, and to spell it out clearly.
- It should be ensured that EISs are subject to strong independent review by third party experts completely dissociated from the local approvals process and that the results of such reviews be made publicly available. Such people can be found in many countries.
- If mining work then commences, the original EIS consultants should have nothing to do with the environmental monitoring.
Finally, lest it be thought that I am anti-mining, I have worked for mining, gas and oil companies in Australia, Papua New Guinea, Saudi Arabia, California and Alaska, and continue to do so. If I am against anything, it is against incompetence, especially in environmental impact studies.