Protect the Northern Jarrah Forests

Alcoa is seeking approval to clear a further 11,458ha of the Northern Jarrah Forests.

If this goes ahead, the consequences for forests, water, climate, culture and communities will be unthinkable.

How to make a submission

Alcoa’s proposals are the most outrageous forest clearing plans WA has ever seen, and must be stopped.

Right now, we have a once in a generation opportunity to use EPA processes to achieve protections for the Northern Jarrah Forests.

The EPA is assessing two Alcoa proposals at the same time: 

• Assessment No 2385: Pinjarra Refinery Expansion
• Assessment No 2253: Mining Management Plan 2023-2027

INTRODUCTORY QUESTIONS

• Provide your name and email
• Select individual or organisation
  • If you are responding as an Individual for question 3, select "Other" for question 4.
• At question 5, select: "Both Assessment No 2385 and 2253"

COMMENTS ON THE PROPOSALS

• You have the option of commenting on one or both of the proposals. You cannot make two submissions.
• We recommend that you comment on both proposals in your submission.
• The headings below correspond to the sections set out in the EPA form. You don’t have to provide a response for every section.
• We’ve provided some information you can use, and we encourage you to elaborate using your own experience and knowledge. It’s best to refer to the EPA objective for each factor.
• The WA Forest Alliance has produced an excellent detailed guide that you might like to refer to for some or all sections.
• The Environmental Defenders Office has produced this informative overview of the Alcoa proposals and approach that the EPA will take.

Submissions can be made by filling in the form on the EPA’s website by midnight on Thursday the 21st of August. 

MAKE A SUBMISSION

Submission Writing Workshops

Whether you’re new to the issue or deeply involved, writing a submission to the EPA is a powerful way to take action.

Join Jess Beckerling MLC at the upcoming submission writing workshops, in Denmark and in Fremantle.
Both workshops are also available to join online.

You’ll get a clear briefing on what Alcoa is proposing and what's at risk, support to write your submission, and the opportunity to send your submission on the night.

Join the chorus of voices calling for the EPA to reject Alcoa’s expansion plans and protect the forests.

The EPA form is arranged in sections:

FLORA AND VEGETATION

EPA OBJECTIVE

To protect flora and vegetation so that biological diversity and ecological integrity are maintained. 

Alcoa is seeking to clear another 11,458ha of the Northern Jarrah Forests.

If approved, this will bring the total area of WA forest cleared by Alcoa to 45,524ha.

When combined with clearing by South32 and Newmont, the total cleared by 2045 would be 72,359 ha. 

While this is a vast area of clearing, the impacts are even further reaching. Fragmentation would affect up to four times the area cleared. Other major additional impacts would be from edge effects, dieback spread, reduced climate resilience and significant changes to hydrology. 

High conservation value forests that have been lightly logged and retain old growth structure and functions and high levels of biodiversity would be cleared with major impacts on biological diversity and ecological integrity across the region. 

Alcoa’s flora surveys have been completely inadequate and we can have no confidence that threatened flora species are being protected. 

The Intergovernmental Panel on Climate Change has found that the Northern Jarrah Forests are at risk of climate collapse and recommended we stop clearing to increase the forests’ resilience. 

The EPA’s objective for Flora and Vegetation cannot be achieved if Alcoa’s proposals are approved. 

RECOMMENDATIONS AND CONDITIONS

1. The proposals should be rejected due their unacceptable impacts on flora and vegetation.
    
2. If the proposals are not rejected outright, the EPA report and recommendations must at the very least include: 
   
   (i) Surveys to be conducted across all of the areas Alcoa proposes to clear.
   
   (ii) That there be no clearing and 2km buffers surrounding old-growth and other high conservation value forests including forests that retain old-growth structures and functions, critical habitat for wildlife, groundwater dependent ecosystems, threatened and priority flora, and threatened and priority ecological communities as urgent protections while we phase out forest mining.
   
   (iii) That large, contiguous areas of forest be securely protected across the Northern Jarrah Forests to safeguard biological diversity and ecological integrity; and
    
3. The EPA must acknowledge the IPCC finding that the Northern Jarrah Forests are at risk of climate collapse and require protections to improve climate resilience. 

TERRESTRIAL FAUNA

EPA OBJECTIVE

To protect terrestrial fauna so that biological diversity and ecological integrity are maintained.

Multiple threatened wildlife species, including Federally listed Matters of National Environmental Significance will be profoundly impacted if Alcoa’s plans go ahead.

This includes:

• Baudin’s, Carnaby’s and Red-tailed Black Cockatoos
• Quokkas
• Chuditch
• Carter’s Freshwater Mussel 

Alcoa expects its plans to impact up to 144,500 potential nesting trees for Black Cockatoos (see page 151)

Potential breeding trees are mature trees that have the potential to produce nesting hollows in coming years. They are the vital next cohort of critical habitat that must be protected for the survival and recovery of all three Black Cockatoo species. 

Baudin’s Cockatoos have suffered a 90% decline in their population.

This proposal could be the final nail in the coffin for this beloved bird species. 

A shortage of nesting hollows is a primary threat to these birds – all habitat is considered critical for their survival, and it takes up to 200 years for hollows to form. It is unacceptable for tens of thousands of potential nesting trees to be lost, and this loss cannot be mitigated with offsets.

Alcoa acknowledges that its proposals are likely to cause significant impacts to Black Cockatoos.

It says it will avoid known nesting hollows where possible, but has not provided survey results or numbers of trees it intends to protect or destroy for peer review or consultation, saying they will be identified in pre-clearing surveys.

Alcoa acknowledges that Numbats, Woylies and critically endangered Western Ringtail Possums are also likely, or have the potential to be within areas it proposes to impact, but does not acknowledge the significant impact the proposal would have on these species, or set out a mitigation plan for them.

The loss of thousands of hectares of critical habitat for threatened species is completely unacceptable and will push wildlife closer to extinction. 

No amount of offsets or rehabilitation can mitigate the threat posed by this plan. 

Alcoa has used the wrong classification for Baudin’s Cockatoos in its proposals, dramatically underestimating the mitigation measures required. 

The EPA’s objective cannot be achieved if Alcoa’s proposals are accepted. 

RECOMMENDATIONS AND CONDITIONS

1. The proposals should be rejected due to their unacceptable impacts on threatened fauna, including Matters of National Environmental Significance. 
    
2. If the proposals are not rejected outright, the EPA report and recommendations must at the very least include that:
   
   (i) There be no clearing whatsoever of critical habitat for threatened species
   
   (ii) Baudin’s Cockatoos be recognised as Critically Endangered (IUCN classification) 
   
   (iii) Large, contiguous areas of habitat be protected, not just individual trees or small patches of vegetation, which is not sufficient for the maintenance of biological diversity and ecological integrity
   
   (iv) Immediate protections of critical habitat must be put in place while we work towards a phase out of forest mining; and
    
3. (c) Offsets cannot be considered an acceptable method for protection of endangered wildlife when all remaining habitat is required, along with rehabilitation, for their recovery. If offsets are used then they must be calculated on the basis of the highest level of threat for all species.

TERRESTRIAL ENVIRONMENTAL QUALITY

EPA OBJECTIVE

To maintain quality of land and soils so that environmental values are protected.

The clearing of 11,458ha of forest and removal of 4-6m of soil would dramatically reduce the quality of land and soils. 

Bauxite plays a key role in the hydrological function of the jarrah forest and its complete and permanent removal has irreversible effects on the environmental values of the Northern Jarrah Forests. 

Alcoa does not have sufficient top soil for rehabilitation and is using thin layers of soil that do not provide the hydrological, fertility or other values of good quality forest soils. 

Clearing steep slopes causes erosion and mitigation efforts routinely fail to prevent erosion. 

Hydrocarbon spills and other contamination events are common, with significant impacts on quality of land and soils and flow on effects for environmental values.

The EPA’s objective cannot be achieved if this proposal goes ahead.

RECOMMENDATIONS AND CONDITIONS

1. The proposals should be rejected due to their unacceptable impacts on terrestrial environmental quality. 
    
2. If the proposals are not rejected outright, the EPA report and recommendations must at the very least: 
   
   (i) Acknowledge Alcoa’s history of poor soil management and failing rehabilitation.
   
   (ii) Require that Alcoa remediate all soils contaminated through its operations. 
   
   (iii) Require that Alcoa fully rehabilitate all existing cleared sites to internationally acceptable standards prior to any further clearing being permitted; and 
    
3. Rehabilitation must not be considered an adequate mitigation mechanism.

INLAND WATERS

EPA OBJECTIVE

To maintain the hydrological systems and quality of groundwater and surface water so that environmental values are protected.

The Water Corporation rejected Alcoa’s Mining Management Plan (MMP) in its entirety because of the risk it poses to drinking water. 

Alcoa is still not agreeing to fully comply with the Water Corporation’s risk management criterion. 

According to the drinking water assessment conducted for the Pinjarra expansion:

"The pathogen, hydrocarbon and turbidity hazards for the Proposal (Myara North, Holyoake and O’Neil mine DEs) are assessed as a High Risk."

Alcoa’s plans do not comply with preventative risk management criteria for drinking water and the EPA can have no confidence that the proposals adhere to the EPA objective for Inland Waters. As such the proposals must be rejected.

Alcoa is seeking to take approximately 17 billion litres of ground and surface water every year for use in its Pinjarra Refinery and mine sites. This is more than a third of the total amount of water that will be produced by the Alkimos desalination plant (50gl/an). 

In a drying climate, with significant reductions in availability of potable water and the need for expensive, energy intensive desalination, as well as ecosystems struggling with lower water availability, we cannot afford to give Alcoa this huge quantity of water every year. 

Alcoa has an appalling track record of threatening our drinking water with PFAS and other contaminants and cannot be trusted to operate in drinking water catchments. 

The Peel Yalgorup Ramsar listed wetland will be impacted by clearing and potential contamination if the proposals are approved. 

Mine site rehabilitation is twice as thirsty as mature forest. It draws and transpires double the groundwater of surrounding mature forests, reducing available groundwater across the region. 

There are major knowledge and data gaps in both proposals that must be addressed.

The EPA objective for Inland Waters cannot be met if Alcoa’s plans are allowed to proceed. 

RECOMMENDATIONS AND CONDITIONS

1. The proposals should be rejected due to their unacceptable impacts on Inland Waters. 
    
2. In the proposals are not rejected outright, the EPA report and recommendations must at the very least: 
   
   (i) Require Alcoa to fully comply with Water Corporation preventative risk management criteria in drinking water catchments
   
   (ii) Require that Alcoa remediate all water contaminated through its operations.
   
   (iii) Reject Alcoa’s proposals to increase water use due to unacceptable impacts on environmental values. 
   
   (iv) Immediately and permanently exclude Alcoa from any activities in Reservoir Protection Zones. 
   
   (v) Rapidly phase out all mining and related activities in drinking water catchments. 
   
   (vi) Require all knowledge gaps to be filled, and the precautionary principle applied. 
   
   (vii) Reject Alcoa’s proposal to build a pipeline through the RPZ; and 
    
3. Alcoa must be held to account for all historic breaches of regulation concerning water quality protection. 

AIR QUALITY

EPA OBJECTIVE

To maintain air quality and minimise emissions so that environmental values are protected.

The two major air quality issues are:

• Toxic emissions from the Pinjarra Refinery
• Dust from mine sites and transport routes

The Pinjarra community has raised serious concerns about the human health impacts of the refinery that have gone unheeded and no cumulative impact of the increased production Alcoa is proposing has been conducted. 

Dust from mine sites, haulage routes and conveyor belts is impacting local farms, visibility on roads, vegetation, social amenity and inland waters. 

Major exceedances of air quality levels are predicted, but Alcoa minimises the impacts and fails to provide any assurances that it will maintain air quality so that environmental values are protected.

The EPA objective for Air Quality cannot be met if the proposal goes ahead.

RECOMMENDATIONS AND CONDITIONS

1. The proposals should be rejected due to their unacceptable impacts on Air Quality.

2. If the proposals are not rejected outright, the EPA report and recommendations must, at the very least: 
   
   (i) Reject Alcoa’s proposed increase in annual production at the Pinjarra Refinery.
   
   (ii) Require Alcoa to acknowledge the full impacts of refinery emissions and dust. 
   
   (iii) Require the necessary independent surveys and studies to quantify impacts. 
   
   (iii) Employ best practice techniques, including reducing water use for dust suppression, to reduce refinery emissions and dust. 

GREENHOUSE GAS EMISSIONS

EPA OBJECTIVE

To minimise the risk of environmental harm associated with climate change by reducing greenhouse gas emissions as far as practicable.

Alcoa’s proposals would result in approximately 1.4 billion tonnes of GHG emissions according to the documents Alcoa has provided. This is a staggering volume. 

At peak operation, the proposals will result in approximately 70 million tonnes of GHG emissions every year. This is equal to more than 18 coal fired power stations (based on Muja power station emissions).

In the midst of a climate emergency, while the world works to decarbonise as quickly as possible, it would be unconscionable to approve a project that would emit this volume of carbon. 

The clearing of forests associated with this proposal on its own will result in an estimated 9.3 million tonnes of carbon being released into the atmosphere, and dramatically reduce the sequestration capacity of the forests. 

Forests are essential allies in our efforts to avert catastrophic climate change. The older and more biodiverse they are, the more carbon they draw down, and the more resilient they are to climate change. Young, less diverse rehabilitation draws down less carbon and is more likely to collapse from drought stress, becoming a carbon source rather than sink.

We must protect forests as a part of our climate efforts. 

Alcoa claims that the net loss from forest clearing will be an estimated 6.6 million tonnes, down from the gross emissions of 9.3 million tonnes after the rehabilitation has grown and drawn down carbon. It admits this wouldn’t be the case until 2075, and the truth is that this is a best case scenario given the warming climate that the proposal would add to. 

We need climate action now, and the impacts from this proposal make it unacceptable. 

The EPA’s objective for Greenhouse Gas Emissions cannot be achieved if Alcoa’s proposals are approved.

RECOMMENDATIONS AND CONDITIONS

1. The proposals should be rejected due to the unacceptable risks of environmental harm associated with climate change that they pose.

2. Given the very high volume of emissions and significant environmental harm that would result, the EPA should not accept carbon offsets as a way to mitigate the climate impacts of this proposal. The emissions must be avoided in the first instance. 

SOCIAL SURROUNDINGS

EPA OBJECTIVE

To protect social surroundings from significant harm.

The proposals would have profound impacts on Aboriginal and European heritage and on community values and amenity.
 
Alcoa’s heritage survey methodologies have been entirely inadequate, relying on desktop studies and limited existing registered sites rather than scientifically robust on-ground surveys. There are no doubt far greater numbers of sites that require protection than Alcoa has acknowledged. 

The 10m buffers that Alcoa has agreed to retain around heritage areas are far too narrow and do not conform with the recommendations of the report produced for the proposal. 

There are multiple Aboriginal heritage sites in the areas Alcoa proposes to clear that have not been reported to the Department. Alcoa categorises them as ‘internally protected’ and it appears that there is no independent oversight to ensure their protection. 

The Northern Jarrah Forests have been occupied by First Nations people for tens of thousands of years, and by European communities for 200 years and are dense with cultural and heritage values. 

Alcoa acknowledges that:

"The physical cultural heritage places across Noongar booja are not just comprised of objects with archaeological interest they exist within a broader living cultural landscape, connecting Noongar people to their ancestors, to lore, to kaartijin (knowledge) and to deep-time cultural heritage.”

In spite of this acknowledgement, and the particular significance of rivers and riparian areas, Alcoa proposes to clear vast areas of these culturally significant forests, and says:

“The Proposal is not expected to cause cumulative impacts to Aboriginal cultural values associated with Inland Waters, which will remain substantially impacted by agriculture, water supply reservoirs, climate change and introduced aquatic fauna and weeds.” 

Alcoa has not adequately surveyed, understood or recognised the true significance of the heritage values of the forests it proposes to clear, or presented a meaningful plan to avoid impacts to these values. 

The EPA objective for Social Surroundings cannot be met if Alcoa’s plans are allowed to proceed. 

RECOMMENDATIONS AND CONDITIONS

1. The proposals should be rejected due to their unacceptable impacts on social surroundings.

2. If the proposals are not rejected outright, the EPA report and recommendations must, at the very least:
   
   (i) Require that Alcoa conduct thorough on-ground surveys of all areas likely to be impacted by the proposal and protect recognised heritage values
   
   (ii) Require that Alcoa engage appropriate Aboriginal organisations and resource them adequately to carry out extensive consultation with all Aboriginal people and groups who may be affected by the proposal with a view to protecting cultural and heritage values.
   
   (iii) Increase the buffers surrounding heritage to meet best practice standards
   
   (iv) Increase buffers between the Bibbulmun Track and mining disturbance to at least 1km.
   
   (v) Much greater transparency surrounding the Mining Avoidance Zones and Limited Disturbance Areas to ensure they are in line with First Nations people’s expectations and relevant expert recommendations. 

REHABILITATION

INFORMATION

Alcoa has been dishonest about rehabilitation, stating that 75% of the area it has cleared has been rehabilitated. The fact is that rehabilitation has commenced over 75% of the area it has cleared since the 1960s, but none has been completed. 

Rehabilitation has been proven to be unsuccessful and is likely impossible. Jarrah forests are complex, ancient ecosystems that cannot be returned following clearing and removal of 4-6m of soil and the spongy bauxite layer that plays a crucial hydrological function. 

The EPA must not accept rehabilitation as a mitigation measure for the purposes of approving additional clearing. 

Even if rehabilitation were successful, some habitat elements, such as nesting hollows in mature trees, require 200 years to form. Endangered species who rely on these nesting hollows do not have 200 years to wait for trees to reach maturity. 

Alcoa is using insufficient seed per hectare, at a rate of approximately half or less of the industry standard. It is also unable to source sufficient seed for recalcitrant species and is planting a mix that does not reflect the biodiversity of the forest. 

The completion criteria is currently under review so it is impossible to meaningfully comment on the extent to which Alcoa’s practices or proposal complies with the future criteria. This prevents adequate community engagement. 

The current criteria lack goals and monitoring protocols for ecological function and focus on overstorey density, fundamentally missing the point of aiming to achieve, and demonstrating achievement of returning biological diversity and ecological integrity. 

Rehabilitation is already failing, and there is no recognition in the proposal of the impacts a drying climate will have on future rehabilitation success.

HOLISTIC IMPACT ASSESSMENT

INFORMATION

Alcoa’s holistic impact assessment is entirely inadequate.

This assessment should provide meaningful information on the ways that impacts interact and how they cumulatively impact environmental and social values.

Instead, the assessment simply lists impacts as data points without providing the analysis and information. 

We know that over 70,000 ha of the Northern Jarrah Forests will have been cleared by Alcoa, South32 and Newmont by 2045 if this proposal goes ahead, and over 300,000 ha will have been impacted by fragmentation and edge effects. 

We also know that the forests’ resilience to climate change will have been substantially reduced, the hydrological function of the forest will have been altered with deleterious consequences for ecological integrity, and that fauna and flora will have been impacted.

However, Alcoa does not provide information on these interacting impacts or acknowledge the role its proposal will cause. 

STAKEHOLDER ENGAGEMENT STRATEGY

INFORMATION

Alcoa’s stakeholder engagement registers demonstrate that Alcoa has not meaningfully responded to issues raised, simply noting issues it disagrees with.

Many stakeholders have expressed dissatisfaction with insufficient consultation. 

Overall, the strategy is weak, short and ineffective. 

OTHER: OFFSETS

INFORMATION

Alcoa’s offset plan for cockatoos is woefully inadequate.

The plan focuses on monitoring and research and provision of watering points and upkeep of existing hollows - none of which comes close to offsetting the loss of thousands of hectares of habitat - and makes an unsubstantiated reference to investigating unquantified and unqualified areas for inclusion in the conservation system, but says it cannot commit that the areas will have a change in conservation tenure. 

It categorically fails to identify the number of hectares of suitable habitat that will be protected, and fails to set out a plan that will increase habitat and recovery outcomes for Black Cockatoos. 

Alcoa’s claim that the plan has a high likelihood of providing a net benefit to black cockatoos within 20 years is entirely unsupported and does not acknowledge the profound net loss of habitat that the project would result in.

Thank you for taking the time to join the chorus of voices calling for the EPA to reject Alcoa’s expansion plans and protect the forests.
 

This is our best chance in a generation to protect the Northern Jarrah Forests and every submission counts.

Please share this web page with your networks and ask them to get their submissions in by the 21st of August.

MAKE A SUBMISSION