Fishy business. The Social Impact of SST.pdf - Act Now!

Responses to Consent Condition ExceedencesIt is unclear what responses will be made to any exceedence of consent conditions. As notedabove, the consent conditions (in other words, what the monitoring procedures and protocolswill be, who will do the monitoring, how standards will be met and who will analyse the results)remain unclear. In addition, it is unclear what will happen if, for example:•odour levels exceed the expected guidelines;•local fisheries are shown to be depleted due to increased deep-ocean fishing;•marine water quality trigger-levels are exceeded;•noise levels are exceeded; or•there is an unacceptable pollution event (such as an oil spill from either the plant or anassociated fishing vessel).For all the above issues, a contingency plan could be prepared that clearly identifies what willhappen if any condition or set of conditions are exceeded. The contingency plan would include:•what the guideline has been set at•who does the monitoring and who checks the results•who should be contacted if the guideline/standard is exceeded•what the response should be if the guideline is exceeded•what the statutory and/or local remedies available should any guideline or standard beexceeded (for example, should operations cease until the situation is remedied; is there a fineinvolved); andIn many cases the preparation of a contingency plan will in itself help minimise the impositionof restrictive consent conditions, as the regulatory authorities and the community are clear aboutwhat steps the company will take in the event of something going wrong. The SSTC isestablishing an Environmental Monitoring and Management Plan (EM&MP) (Section 9.0). Thismay fulfill this function. Obviously in the case of the social impact issues, it is alwaysproblematic identifying to what extent the company may be responsible for undesirable impacts,and the extent to which it can address them. (In addition, the wisdom of imposing 'guidelines'or'standards' is debatable). However, a social monitoring and response system can be done inconsultation with experts in this field.Responsibilities of SSTCWhile recognising the limits on what SSTC can do regarding social/infrastructural issues, thecompany has identified Wewak as a good site for its factory partly because there is an available83