Unfortunately it is my view that the problems with the project description
document are so extensive that it is beyond redemption. You should therefore
understand my concern that if I were to go to the trouble of submitting comments
on the present document, it would give it credibility that is not deserved.
As previously stated, I believe that a completely new project documentation
process needs to be instituted. For starters the project site needs to be
properly assessed in terms of its biodiversity, hydrology, socio-economic
and cultural value, as well as its potential for, and the projected cost
of, restoration to its pre-project state should the alien pine tree plantations
become diseased or burned, and are then abandoned or removed in the future.
I
would go so far as to say that in my view it would be irresponsible to proceed
further with the present flawed document. It is my opinion that to do so
could be construed as a deliberate attempt to misrepresent the nature and
impacts of the project as benefiting biodiversity and local communities,
while the opposite could just as likely be true.
I therefore suggest that
you convey to the project proponent my request for a new independent process
to be launched, as well as to suspend all land preparation and tree planting
pending the project being determined acceptable. A comprehensive new site
description process that focuses on the grassland habitat that could be eliminated
due to the proposed project, and that estimates localised and downstream
hydrological changes that could occur if the plantations are established,
will need to be completed. Together with a professional estimation of opportunity
costs (over the 60 year plus project period), the information derived through
this process would help inform a full environmental impact assessment, and
a proper cost-benefit analysis.
The alternative would be for an independently funded organisation to investigate
the project and to produce a detailed public report based on analysis of
the information contained in the existing PDD and related documentation.
Such a report could have a significant effect on public attitudes towards
this and other similar projects.
Comment 1
Unfortunately it is my view that the problems with the project description document are so extensive that it is beyond redemption. You should therefore understand my concern that if I were to go to the trouble of submitting comments on the present document, it would give it credibility that is not deserved.
As previously stated, I believe that a completely new project documentation process needs to be instituted. For starters the project site needs to be properly assessed in terms of its biodiversity, hydrology, socio-economic and cultural value, as well as its potential for, and the projected cost of, restoration to its pre-project state should the alien pine tree plantations become diseased or burned, and are then abandoned or removed in the future.
I would go so far as to say that in my view it would be irresponsible to proceed further with the present flawed document. It is my opinion that to do so could be construed as a deliberate attempt to misrepresent the nature and impacts of the project as benefiting biodiversity and local communities, while the opposite could just as likely be true.
I therefore suggest that you convey to the project proponent my request for a new independent process to be launched, as well as to suspend all land preparation and tree planting pending the project being determined acceptable. A comprehensive new site description process that focuses on the grassland habitat that could be eliminated due to the proposed project, and that estimates localised and downstream hydrological changes that could occur if the plantations are established, will need to be completed. Together with a professional estimation of opportunity costs (over the 60 year plus project period), the information derived through this process would help inform a full environmental impact assessment, and a proper cost-benefit analysis.
The alternative would be for an independently funded organisation to investigate the project and to produce a detailed public report based on analysis of the information contained in the existing PDD and related documentation. Such a report could have a significant effect on public attitudes towards this and other similar projects.
Wally Menne, 2 June 09.