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Submission to ACCC in relation to the review of possible acquisition by Incitec Pivot Ltd of interests in Burrup Holdings Ltd, Burrup Fertilisers Pty Ltd and/or interests in Burrup Nitrates Pty Ltd

Submission on behalf of Friends of Australian Rock Art

By
Dr John L Black AM FTSE FAIAST, PhD, BAgricSci, DipEd.
PO Box 4021
WARRIMOO NSW 2774
Email: jblack@pnc.com.au
16 May 2011
Summary

Our concerns relate to National Heritage and particularly to the petroglyphs (rock art) and other aboriginal heritage sites located on the Burrup Peninsula and Dampier Archipelago.

Our submission relates to:

0 Unacceptability of Incitec Pivot Ltd acquiring an interest in Burrup Nitrates Pty Ltd, through Burrup Holdings Ltd, with the intention of producing ammonium nitrate within an area of unprecedented national and world heritage significance. The company already has announced plans to build a 100,000 tonne/year ammonium nitrate plant at Port Headland (The West Australian, 10 May 2011) and have submitted plans to the Western Australian government to build a 350,000 tonnes/year plant through Dampier Nitrogen Pty Ltd on the west side of Burrup Fertilisers (Dampier Nitrogen Pty Ltd, 2010).

o Inadequate scientific evidence that the emissions from the proposed ammonium nitrate facilities will not significantly affect the rock art.

o Stated Corporate Social Responsibility of the company that should ensure they follow the lead from other major companies (BHP Billiton, Chevron and Apache Energy) who have relocated developments from the Burrup Peninsula because they were unable to guarantee there would not be damage to rock art or the immense heritage value of the area.

Our suggested outcomes are:

o Incitec Pivot Ltd not be granted an approval to obtain an interest in Burrup Nitrates and to consolidate their production on ammonium nitrate in Western Australia at the newly announced plant at Port Headland.

Background

The Burrup Peninsula is unique in the world for its ancient petroglyphs and long record of human history. Bird and Hallam (2006) wrote: 'The Dampier Archipelago contains the largest concentration of rock art in the world, estimated at perhaps a million petroglyphs. The art is extraordinary in its range and diversity. Associated with the art is a rich archaeological record, including camp sites, quarries, shell middens and stone features. Many motifs and some stone features are connected to the beliefs and ceremonial practices of Aboriginal people in the Pilbara region today. The entire Archipelago is a continuous cultural landscape providing a detailed record of both sacred and secular life reaching from the present back into the past, perhaps to the first settlement of Australia.'

The petroglyphs on the Burrup Peninsula contain the oldest depiction of the human face known anywhere in the world (Ken Mulvaney, pers com). They also contain numerous depictions of the Tasmanian tiger (thylacine) and the fat-tailed kangaroo which are both thought to have become extinct on the Australian mainland at least 3000 years ago (Anna Salleh, 2004).

'Although the outstanding heritage values of the area have been recognised for more than a quarter of a century, the industrial development that began in the 1960s has continued unabated' (Bird and Hallam, 2006). In 2007, a portion of the Burrup Peninsula and Dampier Archipelago were included in the Australian National Heritage list. The proclaimed National Heritage Place covers some of the areas previously designated for industrial development by the Western Australian state government, including Area D, King Bay-Hearson Cove. The Burrup Fertilisers facility and the two ammonium nitrate plants proposed by Burrup Nitrates and Dampier Nitrogen are within an area that divides major sections of rock art and other aboriginal heritage sites.

Friends of Australian Rock Art (FARA) are a voluntary organization dedicated to the protection, preservation and promotion of Australian rock art. We wish to preserve rock art, particularly on the Burrup Peninsula and Dampier Archipelago because it is the world's most significant and continuous record of human culture, going back 30,000 years, well before the last ice age. The area is an unique record of human culture adapting to changes in climate and land form. The Burrup rock art is far older than the Lascaux cave paintings in the south of France, Stonehenge in England and the pyramids of Egypt.

FARA understands the importance of industrial development for Australia, but believes it is totally inappropriate for large industrial plants, such as ammonium nitrate production facilities to be placed in the centre of such a culturally significant National Heritage listed Place. The Burrup Peninsula has on three occasions been listed in the World Monuments Fund's '100 most endangered sites'.

Incitec Pivot Ltd interests in Burrup Nitrates Pty Ltd

FARA believes that it is unacceptable for Incitec Pivot Ltd to acquire an interest in Burrup Nitrates Pty Ltd, through Burrup Holdings Ltd, with the intention of producing ammonium nitrate within an area of enormous national and world heritage significance, when the company already has announced plans to build a 100,000 tonne/year ammonium nitrate plant at Port Headland (The West Australian, 10 May 2011) and have submitted plans to the Western Australian government to build a 350,000 tonnes/year plant through Dampier Nitrogen Pty Ltd on the west side of Burrup Fertilisers (Dampier Nitrogen Pty Ltd, 2010). Incitec Pivot Ltd also has a major ammonium nitrate production facility at Moranbah in Queensland.

Inadequate scientific evidence that emissions will not damage rock art

FARA and several of its members have made submissions to the Western Australian and Federal government environmental authorities providing evidence to show that emissions from the proposed ammonium nitrate plants and other industries on the Burrup Peninsula cannot be guaranteed to cause long-term damage to the rock art. Three of these documents are provided with this submission.

The major points from these submissions are:

o The cumulative nitrogen emissions from industries proposed for the Burrup Peninsula is 2.6 kg/ha/yr or 260 meq/m2/yr, which is well above the value of 200 meq/m2/yr considered to be the highest critical load and for the least sensitive environments.

o The proposed cumulative NO2 emissions of 137 ppb is almost three times the concentration tested in fumigation studies undertaken by the Burrup Rock Art Monitoring management Committee of 50 ppb.

o The fumigation studies were conducted for only 30 days.

o Over the proposed 25 year life time of the proposed ammonium nitrate plants over 30,000 tonnes of emissions will have been produced. The emissions will include over 2,000 tonnes of ammonium nitrate deposited as PM10 particles.

Corporate Social Responsibility

James Fazzino, Managing Director and Chief Executive Officer of Incitec Pivot Limited wrote on page 2 of the 2010 Sustainability Report (Incitec Pivot Limited 2010): "Our approach to Sustainability is a product of our Culture which is based upon our seven Values. Our Values have been adopted across the whole company and are integral to the day-to-day decision-making process of everyone in the IPL Group. Several of our Values are relevant to our Sustainability commitment, including Care of the Community &our Environment..." On page 7 of the Report, it states: "Zero Harm is a critical organisational Value and it reflects our commitment to conduct our business operations in a manner that maximises safety and minimises health and environmental impacts." On page 9: "The company has a long history of environmental management at each of our manufacturing sites."

Incitec Pivot should consider the large impact they will have on world heritage and recorded history of mankind back to 30,000 years if they produce ammonium nitrate on the Burrup Peninsula. This consideration is particularly important when it has been stated in submissions to the Western Australian EPA that the ammonium nitrate facilities will have only a limited lifespan. The heritage value of the area can never be regained through any decommissioning plan.

FARA believes that Incitec Pivot Limited and other companies considering acquisition of interests in Burrup Holdings Ltd follow the lead from several other large international corporate enterprises including BHP Billiton, Chevron and Apache Energy who have relocated developments from the Burrup Peninsula because they were unable to guarantee there would not be damage to rock art or the immense heritage value of the area (Bednarik, 2007; Sonti, 2009).

References

Bednarik, R.G. (2007). Orientation: Good progress at Dampier. Rock Art Research. 24:267-271.

Bird, C. And Hallam, S.J. (2006). Archaeology and rock art in the Dampier Archipelago. A Report prepared for the National Trust of Australia (WA). National Trust Australia.

Dampier Nitrogen Pty Ltd (2010). Public Environmental Review, December 2010. WA EPA.

Fazzino, J. (2010). Incitec Pivot Limited Sustainability Report 2010. Incitec Pivot Limited.

Salleh, A. (2004). Rock art shows attempts to save thylacine. News in Science. ABC Science Online. 15 December 2004.

Soni, C. (2009). Barnett a 'hypocrite' on rock art. WA Today. February 11, 2009.

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