Referral:
EPBC 2021/9128 — National Radioactive Waste Management Facility NRWMF, SA
Submission by Philip White, Friends of the Earth Adelaide
Introduction
In response to the question raised in the Minister for the Environment’s invitation for comments, the proposed action is a controlled action. It is acknowledged as such by the proponent, the Australian Radioactive Waste Agency (ARWA).
Establishing that fact may be the formal aim of this particular part of the assessment process, but, before the proposal can proceed, it must be subjected to a full public Environmental Impact Assessment under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act).
It should not be approved based solely on documentation provided by ARWA, or anything less than an Environmental Impact Assessment, for reasons including the following:
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The wastes that will be stored and/or disposed of need to be isolated from the environment for thousands of years. The long timescale greatly increases the opportunity for foreseen and unforeseen environmental impacts.
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The transport of radioactive waste over thousands of kilometres represents a serious environmental hazard. Besides problems related to mishandling, there is the potential for various types of transport accidents. Radioactive waste shipments are also potential targets of theft, terrorism, or even, as we are currently seeing in Ukraine, acts of war.
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The fact that the Barngarla traditional owners are opposed to the plan makes it even more important that aboriginal heritage issues are thoroughly addressed.
Recommendations
1. The referral should be rejected because (a) it is clearly opposed by the Barngarla people, the Traditional Custodians, and (b) there are better alternatives that have not been presented for consideration.
2. If, despite the arguments in recommendation 1 for rejecting the referral outright, the Minister decides not to reject the referral, it should not be accepted in its current form, based on s74A of the EPBC Act, which allows the Minister to not accept a referral if it is a component of a larger action. This proposal is clearly a component of a larger action, as is acknowledged by the proponent ARWA.
3. If, despite the arguments in recommendations 1 and 2 above, the Minister decides to consider the referral in its current form, there should be a full public Environmental Impact Statement under the EPBC Act. It is a controlled action with significant potential environmental and cultural impacts.
See the full report: PDF