Eating predatory fish linked to methylmercury in humans

I belong to an international network called International POPs Elimination Network which has obtained small grants to fund research for its global CSO members.  Their ambit widened to toxics which fall under the categories for all the UN conventions on Chemicals & Wastes, because of the recognized interlinkages among issues.

 While for Pacific Islands the emphasis is on improving management of chemicals and wastes rather than technical expertise with regard to industrial byproduts, there are still not many Pacific CSOs who follow these multilateral environmental agreements.

I was happy with the  emphasis during the Health Conference on research to gather data to support policy-making

First, there is the same issue mentioned by Dr Maoate in his keynote speech i.e. translating European terms into Cook Islands maori.  I tend to characterize bad chemicals as vairaku kino, that is “bad medicine”. We have  had advisory  fact sheets about mercury   translated into maori by former Parliamentary translator.  We decided to coin the phrase “mecurio” for mercury because the periodic table of elements has not been translated.

The second point I would like to reinforce  is the targeting specific populations with regard to interventions.

My third point is focus on minimizing risks to human health and environment from methlymercury

UN Environmental Program has an initiative called Strategic Approach to International chemicals Management (SAICM) which provides a forum for industry, academia, practitioners, government policymakers and negotiations; and civil society organisations or NGOs.   Under SAICM, one of the current emphases is to engage the health sector in effective, safe management of chemicals and waste, starting at international level with WHO and working successively down through regional, subregional and national levels. 

Brain damage resulting from methylmercury exposure in utero has similar social consequences to those characterized earlier in the Conference with regard to exposure to alcohol.  So the key message is about reducing exposure to toxics that will have lifelong impacts on a person’s life.

The  United States Geological Service or USGS carried out a ground-breaking study in 2009.  The aim was to find the origins of methylmercury in the North Pacific Ocean, and how it gets into fish.

It was estimated that 75% of human exposure to mercury globally was from fish or shellfish, but nobody knew how it got there.  It was further estimated that about 40% of U.S. exposure was from Pacific fish, but there were no research results available.

In 2009, the USGS published its findings in a report entitled “Mercury Sources, Distribution & Bioavailability in the North Pacific Ocean: Insights from Data & Models”.  The complex methylation process was explained

US Environmental Protection Authority (US EPA) commented that one unexpected finding was the significance of long-range transport by large ocean circulation currents from the west to the east.  Typically it was though that emissions were due to land-based combustion activity but this particular study concluded that emissions originated near Asia.

 

Some sceptics dispute this; and others have commented that radionucleoide technology can be used to determine from which continent the combustion source originated. 

 An important point for the Cook Islands is that “global deposition” explains why islands so far from the continents should be affected when there are no  nearby sources such industrial processes or coal-based power stations.

 In Europe, PRTRs (“pollutant release and transfer registers”) were set up to monitor pollutant releases under a regional convention called the Aarhus Convention.   Air quality monitoring is also carried outin the Arctic.  Perhaps the Pacific region could do with a similar monitoring system.

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FIRST MEETING OF I-O NET, 25-27MAY 2015 IN TOKHYO

25-26 May2015 Final ISACI Presentation I-O Net First Meeting, TokyoIslands and Oceans Net (IO Net) 1st General Meeting

Outcome Highlights

Islands and Oceans Net Secretariat

Ocean Policy Research Institute

Ocean Policy Research Institute, The Sasakawa Peace Foundation (OPRI, SPF) organized the Islands and Oceans Net (IO Net) 1st General Meeting with the Australian National Centre for Ocean Resources and Security (ANCORS), University of Wollongong and the University of Tokyo Ocean Alliance at the Ito International Research Center, University of Tokyo from 25 – 26 May 2015.

IO Net is an international collaborative network for the organisations and individuals (called “Partners”) who support the Joint Policy Recommendations “For the Better Conservation and Management of Islands and Their Surrounding Ocean Areas” and collaborate and cooperate on a voluntary basis to implement it

190 participants including 27 from overseas attended the IO Net 1st General Meeting. At the opening session, Mr. Hiroshi Terashima, President, OPRI, SPF which serves as IO Net Secretariat underlined that the IO Net is an international collaborative network for the organisations and individuals that collaborate on a voluntary basis to promote the better conservation and management of islands and their surrounding oceans, and stated that this meeting was intended to facilitate the development of concrete projects to implement the Joint Policy Recommendations. Prof. Stuart Kaye, Director, ANCORS stated in his video message that he welcomed the launching and the operationalization of the IO Net. Prof. Toshiyuki Hibiya, Director, University of Tokyo Ocean Alliance affirmed his determination that the University of Tokyo Ocean Alliance will carry out advanced academic research and play a proactive role in promoting sustainability in the Pacific island countries.

Mr. Yohei Sasakawa, Chairman, The Nippon Foundation stated in his keynote speech that the alarming phenomena that threaten human existence have emerged in the ocean and been progressing silently and steadily and the time has come now for establishing an international organization that addresses  ocean issues comprehensively. As an honourable guest, H.E. Mr. Anote Tong, President, the Republic of Kiribati stated that the Pacific island countries have been greatly affected by climate change and variability and the fate of the island countries hinges upon the collaboration of international community and expressed his expectation to the activities to be carried out under the IO Net. Honourable Mr. Kazuyuki Nakane, Parliamentary Vice Minister for Foreign Affairs, Japan welcomed the undertaking of the IO Net that can forge the close long term relationship between Japan and the Pacific island countries.

At this Meeting, Mr. Hiroshi Terashima, President, OPRI, SPF, Prof. Alistair McIlgorm, Capacity Development Coordinator, ANCORS and Mr. David Sheppard, Director-General, Secretariat of the Pacific Regional Environment Programme (SPREP) presided the Meeting as Co-Chairs.

At the sessions, the participants had fruitful discussions on the challenges faced by the small island countries and the proposed future activities based on the presentations made by the participants from the Pacific island countries, Japan and international organisations under the agenda of the conservation and management of islands, management of islands’ surrounding oceans, responses to climate change and variability, and capacity development and institutional strengthening.

At the wrap-up session, the participants discussed the launching of concrete projects under the operational guidelines of the IO Net and affirmed the direction of future activities. They have also confirmed that the interested partners of IO Net will discuss and materialize various project proposals for their implementation and the IO Net Secretariat (OPRI, SPF) support partners to develop and implement the projects through collecting and sharing of related information and making and circulating a list of proposed projects.

The Meeting was a great success and highly fruitful as many participants have attested their enthusiasm and commitment to promote international collaboration for undertaking the proposed activities to implement our Joint Policy Recommendations “For the Better Conservation and Management of Island and Their Surrounding Ocean Areas”. The co-organisers would like to cordially express appreciation to those who attended and supported the Meeting and ask for continuous support to future activities of IO Net.

Further details of the future activities for the IO Net will be posted at http://blog.canpan.info/ionet-jpn. Please address any further inquiry to the IO Net Secretariat (ionet@spf.or.jp、Dr. Keita Furukawa, Senior Researcher k-furukawa@spf.or.jp and Mr. Masanori Kobayashi, Researcher, m-kobayashi@spf.or.jp、Ocean Policy Research Institute, The Sasakawa Peace Foundation)

Islands and Oceans Net Secretariat – Ocean Policy Research Institute, The Sasakawa Peace Foundation Attention: Dr.Keita Furukawa and Mr. Masanori Kobayashi

Address: Toranomon 35 Mori Bldg, 3-4-10, Toranomon, Minato-ku, Tokyo 105-0001 Japan

Tel: 81-3-5404-6855, Fax: 81-3-5404-6801

NEW NAIROBI CONVENTION ON WRECK REMOVAL COMES INTO FORzcE

;   The Nairobi International Convention on the Removal of Wrecks, adopted in 2007, entered into force on 14 April 2015. Under the Convention, for wrecks that are deemed to be a hazard by posing an impediment to navigation or expected to cause harm to the marine environment, liability is placed with the owners to locate, mark and remove wrecks.

According to the International Maritime Organization (IMO), the Convention applies to wrecks located in a country’s exclusive economic zone (EEZ) or equivalent 200-nautical-mile zone. It makes State certification of insurance, or other forms of financial security for such liability, compulsory for ships of 300gt and above, and grants Parties a right to take direct action against insurers.

Parties to the treaty are: Antigua and Barbuda; Bulgaria; Congo; Cook Islands; Denmark; Germany; India; Iran; Liberia; Malaysia; Marshall Islands; Morocco; Nigeria; Palau; and the UK.

In addition, the Convention will come into force for Malta on 18 April 2015, and for Tuvalu on 17 May 2015.

Nairobi Wreck Removal Convention enters into force – IMO Press Release

The Nairobi International Convention on the Removal of Wrecks enters into force on Tuesday (14 April 2015). The Convention places strict liability on owners for locating, marking and removing wrecks deemed to be a hazard and makes State certification of insurance, or other form of financial security for such liability, compulsory for ships of 300 gt and above. It also provides States Parties with a right of direct action against insurers.

he Convention provides a legal basis for States Parties to remove, or have removed, wrecks that pose a danger or impediment to navigation or that may be expected to result in major harmful consequences to the marine environment, or damage to the coastline or related interests of one or more States. The Convention also applies to a ship that is about, or may reasonably be expected, to sink or to strand, where effective measures to assist the ship or any property in danger are not already being taken.

Provisions in the Convention include:

  • a duty on the ship’s master or operator to report to the “Affected State” a maritime casualty resulting in a wreck and a duty on the Affected State to warn mariners and the States concerned of the nature and location of the wreck, as well as a duty on the Affected State that all practicable steps are taken  to locate the wreck;
  • criteria for determining the hazard posed by wrecks, including depth of water above the wreck, proximity of shipping routes, traffic density and frequency, type of traffic and vulnerability of port facilities. Environmental criteria such as damage likely to result from the release into the marine environment of cargo or oil are also included;
  • measures to facilitate the removal of wrecks, including rights and obligations to remove hazardous wrecks, which set out when the shipowner is responsible for removing the wreck and when the Affected State may intervene;
  • liability of the owner for the costs of locating, marking and removing wrecks – the registered shipowner is required to maintain compulsory insurance or other financial security to cover liability under the convention;
  • settlement of disputes.

The Convention was adopted by a five-day International Conference at the United Nations Office at Nairobi (UNON), Kenya, in 2007.

The States Parties to the treaty as at 14 April 2015 are:  Antigua and Barbuda, Bulgaria, Congo, Cook Islands, Denmark, Germany, India, Iran (Islamic Republic of), Liberia, Malaysia, Marshall Islands, Morocco, Nigeria, Palau, and the United Kingdom.

The Convention will come into force for Malta on 18 April 2015 and for Tuvalu on 17 May 2015.​

___

IMO – the International Maritime Organization – is the United Nations specialized agency with responsibility for the safety and security of shipping and the prevention of marine pollution by ships.

Web site: www.imo.org

WHO Report – Glyphosate probably causes cancer

IARC MONOGRAPHS VOLUME 112: EVALUATION OF FIVE ORGANOPHOSPHATE INSECTICIDES AND HERBICIDES  

NOTE: Glyphosate is sold in the Pacific as “Round Up”

WHO International Agency for Research on Cancer

http://www.iarc.fr/en/media-centre/iarcnews/pdf/MonographVolume112.pdf 

Lyon, France, 20 March 2015 – The International Agency for Research on Cancer (IARC), the specialized cancer agency of the World Health Organization, has assessed the carcinogenicity of five organophosphate pesticides. A summary of the final evaluations together with a short rationale have now been published online in The Lancet Oncology, and the detailed assessments will be published as Volume 112 of the IARC Monographs.  

What were the results of the IARC evaluations?  

The herbicide glyphosate and the insecticides malathion and diazinon were classified as probably carcinogenic to humans (Group 2A).    

The insecticides tetrachlorvinphos and parathion were classified as possibly carcinogenic to humans (Group 2B).    

What was the scientific basis of the IARC evaluations?  

The pesticides tetrachlorvinphos and parathion were classified as possibly carcinogenic to humans (Group 2B) based on convincing evidence that these agents cause cancer in laboratory animals.  

For the insecticide malathion, there is limited evidence of carcinogenicity in humans for non-Hodgkin lymphoma and prostate cancer. The evidence in humans is from studies of exposures, mostly agricultural, in the USA, Canada, and Sweden published since 2001. Malathion also caused tumours in rodent studies. Malathion caused DNA and chromosomal damage and also disrupted hormone pathways.  

For the insecticide diazinon, there was limited evidence of carcinogenicity in humans for non-Hodgkin lymphoma and lung cancer. The evidence in humans is from studies of agricultural exposures in the USA and Canada published since 2001. The classification of diazinon in Group 2A was also based on strong evidence that diazinon induced DNA or chromosomal damage.  

For the herbicide glyphosate, there was limited evidence of carcinogenicity in humans for non-Hodgkin lymphoma. The evidence in humans is from studies of exposures, mostly agricultural, in the USA, Canada, and Sweden published since 2001. In addition, there is convincing evidence that glyphosate also can cause cancer in laboratory animals. On the basis of tumours in mice, the United States Environmental Protection Agency (US EPA) originally classified glyphosate as possibly carcinogenic to humans (Group C) in 1985. After a re-evaluation of that mouse study, the US EPA changed its classification to evidence of non-carcinogenicity in humans (Group E) in 1991. The US EPA Scientific Advisory Panel noted that the re-evaluated glyphosate results were still significant using two statistical tests recommended in the IARC Preamble. The IARC Working Group that conducted the evaluation considered the significant findings from the US EPA report and several more recent positive results in concluding that there is sufficient evidence of carcinogenicity in experimental animals. Glyphosate also caused DNA and chromosomal damage in human cells, although it gave negative results in tests using bacteria. One study in community residents reported increases in blood markers of chromosomal damage (micronuclei) after glyphosate formulations were sprayed nearby.  

How are people exposed to these pesticides?  

Tetrachlorvinphos is banned in the European Union. In the USA, it continues to be used on livestock and companion animals, including in pet flea collars. No information was available on use in other countries.  

Parathion use has been severely restricted since the 1980s. All authorized uses were cancelled in the European Union and the USA by 2003. 

Malathion is currently used in agriculture, public health, and residential insect control. It continues to be produced in substantial volumes throughout the world. Workers may be exposed during the use and production of malathion. Exposure to the general population is low and occurs primarily through residence near sprayed areas, home use, and diet.  

Diazinon has been applied in agriculture and for control of home and garden insects. Production volumes have been relatively low and decreased further after 2006 due to restrictions in the USA and the European Union. Only limited information was available on the use of these pesticides in other countries.  

Glyphosate currently has the highest global production volume of all herbicides. The largest use worldwide is in agriculture. The agricultural use of glyphosate has increased sharply since the development of crops that have been genetically modified to make them resistant to glyphosate. Glyphosate is also used in forestry, urban, and home applications. Glyphosate has been detected in the air during spraying, in water, and in food. The general population is exposed primarily through residence near sprayed areas, home use, and diet, and the level that has been observed is generally low.  

What do Groups 2A and 2B mean?  

Group 2A means that the agent is probably carcinogenic to humans. This category is used when there is limited evidence of carcinogenicity in humans and sufficient evidence of carcinogenicity in experimental animals. Limited evidence means that a positive association has been observed between exposure to the agent and cancer but that other explanations for the observations (called chance, bias, or confounding) could not be ruled out. This category is also used when there is limited evidence of carcinogenicity in humans and strong data on how the agent causes cancer.  

Group 2B means that the agent is possibly carcinogenic to humans. A categorization in Group 2B often means that there is convincing evidence that the agent causes cancer in experimental animals but little or no information about whether it causes cancer in humans.   Why did IARC evaluate these pesticides? The IARC Monographs Programme has evaluated numerous pesticides, some as recently as 2012 (anthraquinone, arsenic and arsenic compounds). However, substantial new data are available on many pesticides that have widespread exposures. In 2014, an international Advisory Group of senior scientists and government officials recommended dozens of pesticides for evaluation. Consistent with the advice of the Advisory Group, the recent IARC meeting provided new or updated evaluations on five organophosphate pesticides.   

How were the evaluations conducted?  

The established procedure for Monographs evaluations is described in the Programme’s Preamble. Evaluations are performed by panels of international experts, selected on the basis of their expertise and the absence of real or apparent conflicts of interest. For Volume 112, a Working Group of 17 experts from 11 countries met at IARC on 3–10 March 2015 to assess the carcinogenicity of tetrachlorvinphos, parathion, malathion, diazinon, and glyphosate. The in-person meeting followed nearly a year of review and preparation by the IARC secretariat and the Working Group, including a comprehensive review of the latest available scientific evidence. According to published procedures, the Working Group considered “reports that have been published or accepted for publication in the openly available scientific literature” as well as “data from governmental reports that are publicly available”. The Working Group did not consider summary tables in online supplements to published articles, which did not provide enough detail for independent assessment.  

What are the implications of the IARC evaluations?  

The Monographs Programme provides scientific evaluations based on a comprehensive review of the scientific literature, but it remains the responsibility of individual governments and other international organizations to recommend regulations, legislation, or public health intervention.  

Media inquiries: please write to com@iarc.fr. Thank you.

 

Objection to EIA Petrocean Submersible Fuel Line – Rarotonga, Cook Islands

DATE: 4 MARCH 2015

OBJECTION BY IMOGEN P. INGRAM

TO PETROCEAN – SUBMERSIBLE FUEL PIPELINE & OFFSHORE MOORING SYSTEM FOR THE DISCHARGE OF PETROLEUM PRODUCTS, RAROTONGA COOK ISLANDS (hereinafter referred to as “the proposed project”)

___________________________________________________________________________

Applicant/Proponent: TransAm throughMr Oki Apera (hereinafter referrred to as “the proponent”)

Consultant: Mr Daryl Rairi

Reviewer: Fereti Filipe of Envirocare & Engineering Consult Ltd, Christchurch

GENERAL COMMENTS

Unfair Foreign Company Competition with Locally-Owned Companies

A Bloomberg overview of Pacific Energy Southwest Pacific Limited indicates the parent company is Pacific Petroleum Company SA, formed in 2006 by residents of French Polynesia i.e. a foreign company (since French Polynesia is still a territory of France). In a press release in the Cook Islands Herald about the 2010 sale of the former Cook Islands company JUHI to Pacific Energy Southwest Pacific SA, a company spokesman stated “With this acquisition, our group is now bigger than any of our competitors in this region.”1 The news item went further to say that the PPC Group are now operating in are French Polynesia, New Caledonia, Fiji, Tonga, American Samoa, Vanuatu, Cook Islands (JUHI) and Tuvalu.

I believe that JUHI was set up in the 1980s to supply aviation fuel to the airport, and that TOA (formerly Mobil) and Triad were to supply retail fuel to local consumers. These local local companies had to bear the expense of installing pipelines to supply their fuel depots.

As a Cook Islander, I think that there should be a level playing field in that the same legislation should apply to all fuel suppliers. I think is unsound economic policy to give an unfair advantage to a transnational company and instead all I call on the Cook Islands Government, through the National Environment Service, to reconsider this inequality. The proponent should replace the existing pipeline as set out in page 12 Section 2.4 Alternatives Considered.

Cook Islands Government Policy Switch to Clean Renewable Energy

In the EIA, it is asserted that the proposed project to install the submersible fuel pipeline and offshore mooring system will result in the reduction of fuel costs to consumers. However, at the Third Small Islands Developing States Conference in August 2014 the Cook Islands Government publicly committed to switch to 100% renewable energy by the year 2025. At the University of South Pacific 3rd Forum on Climate Change, held on 17th February 2015, a government spokesman indicated that the Cook Islands government project to achieve this was progressing well. Logic therefore dictates that in the next 10 years, demand for fuel will decrease rather than increase. Changing the arrangements of fuel importation in order to increase supply by using bigger tankers is therefore inconsistent with Cook Islands Government current policy to reduce dependence on fossil fuels and substitute clean, renewable energy and therefore I object to the proposed project and suggest that the proponent instead replaces the existing pipeline as set out on page 12 Section 2.4 Alternatives Considered.

Public Consultations

The Appendix to Version 2 refers to the need to record and add as appendix any public consultation with the landowners of Areanu in the Nikao Tapere. Typically at a public consultation in Rarotonga, a meeting is advertised and interested parties who attend are given copies of the proposal by way of information while the project applicant/client makes explanations and answers questions. But the public consultations should have been open to the wider public because the impact of any accident resulting in oil leakage will be much wider than on the landowners of Areanu, Nikao. Furthermore, the landowners do not own the waters where the proposed mooring would be sited; instead ownership below 30 metres from the Mean High-Water Mark is vested in the Crown. It is the duty of the Crown to protect all its citizens from any impacts from this project, not just the landowners of Areanu and I call upon the Cook Islands Government, through its National Environment Service, to protect human health and the environment by ensuring prior, informed consent of the wider Te-Au-o-Tonga community.

Containment of Any Oil Leaks During Proposed Operations

The proponent’s EIA at page 6 mentions that there was a pipeline installed by Mobil in the 1960’s which was removed in the 1980’s after the Avatiu Port was upgraded. They did not specify the reason why this old pipeline was discontinued, but I believe it was considered an unnecessary risk, since after the upgrade tankers could berth at Avatiu Harbour. If there were an accidental leak from a tanker berthed at Avatiu Harbour, it would be easier to contain it and I can remember practice runs to deal with a spill emergencyh using deployment of woollen “booms” . The offshore mooring proposal means that any leakage spread easily over a wide area, reducing the efficacy of so called “booms” to contain any such leakage. A picture from the grounding of the container ship “MV Rena” in the Bay of Plenty, NZ is an example of what could happen in Rarotonga.

Oil slick MV Rena – 2011, NZ

Risk Assessment vs. Hazard Assessment

My understanding is that any consideration of risk has to be linked to a probability and direct consequences as a result of that probability. While one could argue that the probability of an accident resulting in an oil spill could be calculated as low, if such a spill then occurred the the hazard would widespread and a great burden on a Small Island Developing State.

If the 1992 Rio Earth Summit principles are considered in the Environment Impact Assessment then a number of principles come into play e.g. a precautionary approach to potential hazards; polluter pays for remediation; full internalization of costs if an accident lshould arise. If the proponent and the consultant that prepared the EIA take these principles into consideration, then it is clearly cheaper for them to replace the existing pipeline than to proceed with the proposed project.

Extent of toxic oil sludge from MV Rena – 2011, NZ

The photograph above shows how far along the coast the pollution from the container ship MV Rena spread. Three years later, NZ authorities are counting the cost of clean-up – given the length of time that other merchant ships have remained on the reef at Avatiu after grounding because of human error, I think that Cook Islanders and their environment will be exposed to a needless degree of hazard, which could be avoided if this proposed project did not go ahead.

International Standards & Best Industry Practices

The New Zealand Transport Accident Inquiry Commission2 or “TAIC” concluded in its report on the grounding of the MV Rena in 2011 that a key finding was that “ship’s crews should comply with mandatory requirements and recommended best industry practices for passage planning, navigation and watchkeeping if similar groundings and other equally catastrophic maritime casualties are to be avoided”. I am concerned that the Environmental Management Program (“EMP”) does not make reference to “best industry practices” but merely refers to relevant NZ and Australian standards.

A further finding by the TAIC was that “countries’ maritime education, training and certification systems must be capable of meeting the standards required by the STCW Convention3 to ensure that seafarers emerging from the system are trained to an appropriate standard.” . These training and operational standards are important, particularly when transnational companies are involved, because in the absence of local standards then the international standards under the International Maritime Organization can be used. I noticed that Fuel Committee established in September 2013 after Cabinet consideration did not include a representative from Maritime Cook Islands. In the 1980s’, it was the Waterfront Commission (later renamed Maritime Cook Islands) that undertook the training and response measures through simulated emergencies, so the omission is very noticeable.

SPECIFIC COMMENTS:

Petrocean Environmental Management Plan Submitted After Approval by Reviewer

It is concerning that the EIA appears to have been reviewed by the same person who prepare the the Petrocean Environmental Management Plan (“EMP”). The Petrocean EMP was submitted in August 2014, AFTER approval by the reviewer (Mr Fereti Felipe) in July 2014. This means that the reviewer was not independent, but instead prepared both the approval to submit the project AND the EMP.

Further reason for concern is that Mr Felipe is a former employer of Mobil Oil, who has set up a company in New Zealand called Envirocare & Engineering Consult Limited (“EECL”). There appear to be only two shareholders, himself and his wife. It is very unusual for a professional engineer to try to limit their liability by operating a limited company i.e. EECL.

Typically a professional engineer (including environmental engineers) belongs to a professional organization of engineers, and acts in their personal capcity, citing their professional qualifications and professional membership after their name. While they often set up a limited company for the day-to-day running of their business, it is understood that they are personally liable if their professional advice is relied upon which results in harm or damage. This usually means that any evaluations or assessments produced are carefully-considered, and point out any gaps in the Terms of Reference that a professional might be expected to recognize as a way to limit the scope of their considerations.

Applicable Standards during Construction, Commissioning & Operation:

The EMP seems to shift the onus of enforcement during construction and commissioning to the Cook Islands National Environment Service – and yet as a transnational corporation it should be aware of the requirements of international law.

At page 10 of the EMP, Section 6.1 there is a checklist of Environmental Issues and Impacts.

It is very noticeable that there are no references to impacts on the marine life, or in reference to possible oil spills during the commissioning or during operations. In 2006, the USEPA acknowledged that oil spills and other contamination from onshore sources can pollute and harm coral and marine life, and that “delicate coral reef ecosystems and all marine species are easily harmed by oil spills that could be prevented with the proper containment.”4. The American Samoa Port Authority was required to develop “comprehensive oil spill prevention and control plans”.

CONCLUSION:

In the interests of time, I have kept my objections to what I consider to be the more obvious gaps and deficiencies in the EIA for this proposed project. I believe that, at the very least, the Cook Islands Government, through the National Environment Service, should seek a proper independent evaluation of the Environmental Impact Assessment from a mainstream consultant. Tourism provides more than 50% of our GNP, and it is hoped that more cruise ships will call at Rarotonga . The objective of the bringing low fossil-fuel prices to consumers in the short-term may come at enormous long-term cost to tourism. Imagine the fall in revenues if an oil spill caused massive degradation of the coastline, at the very spot where most tourist cruises land.

The bottom line is that the Cook Islands is on a path to cleaner, renewable energy and will in the future be importing less carbon-based fuels. It seems to be only commonsense that we do not expose ourselves to the hazards of this mode of importation, but instead require the proponent to replace its existing oil supply pipeline.

Submitted by: Imogen P. INGRAM

1Cook Islands Herald, 4th June 2010 “Pacific Petroleum take over JUHI”

2Marine Inquiry 11-204 Container Ship MV Rena grounding on Astrolabe Reef, 5 October 2011” – Report November 2014 by NZ Transport Accident Inquiry Commission (see http://www.taic.org.nz)

3The International Convention on Standards of Training, Certification and Watchkeeping for Seafarers (or STCW), 1978 under the International Maritime Organization (“IMO”) sets qualification standards for masters, officers and watch personnel on seagoing merchant ships STCW was adopted in 1978 by conference at the International Maritime Organization (IMO) in London, and entered into force in 1984. By 2014, the STCW accounted for 99% of global shipping tonnage.

4American Samoa settles violations of oil spill prevention law” USEPA Report 15th May 2006

Oceans Intervention – Feb 2013, Open Working Group on Sustainable Development Goals

Thank you, sir. My name is Imogen Ingram and I am from Island Sustainability Alliance CIS Inc. I speak on behalf of the Indigenous Peoples Major Group.

Speakers on yesterday afternoon’s panel spoke eloquently about major issues confronting Indigenous Peoples, particularly in the Amazon which are relevant to Indigenous peoples and we support a stand-alone SDG within a rights-based framework to deal with Oceans, Biodiversity and Forests. Yesterday, one speaker explained how in Iceland, a rights-based approach to fisheries has been in place since the early 1900’s. His view was that although it was a difficult process, it was achievable, and fair. We believe that such workable governance could be used as a guidance to resolve social and environmental issues impacting on Indigenous Peoples, in compliance with the principle of Prior Informed Consent.

In 2012, the UN Forum on Business and Human Rights under the Office of the High Commission on Human Rights commenced and in its Report A/68/279 it mentions that the objective is to 1 “identify gaps identified in implementation and challenges with regard to the State duty to protect against business-related human rights abuses, the corporate responsibility to respect human rights and the corresponding obligations relating to access to effective remedy”. This concerns many Indigenous Peoples who have been left with legacy contaminants in abandoned mines in their territories, as well as the pollutants from new mines, both artisanal and large-scale, which currently affect their drinking water and traditional foods. In our view, the Rio Principles of polluter pays should apply, and those who created the problem should pay to clean it up. Where those entities for legacy pollution have disappeared, the burden falls upon the State.

With regard to food sovereignty, it was the alarm raised by Indigenous Peoples of the Arctic that resulted in the Stockholm Convention, after biomonitoring results showed contamination of the human food web by Persistent Organic Pollutants produced many thousands of miles away,. With their dependence on seafoods, Arctic Peoples have again become aware of contamination by persistent toxic substances in their water and foods, with damaging effects on the health of their communities. The most cruel aspect is that they only contribute negligible amounts of these contaminants. And they may not leave their territories to which they are bound by culture and tenure.

A further issue discussed by expert panels yesterday was that forest lands of indigenous peoples are often taken for development, often resulting in displacement of those who have thousands of years of residence but no formal tenure over their territories. This development often takes the form of hydroelectric power projects, where the power generated is for the benefit of others far away. Again, Indigenous Peoples feel that a rights-based SDG would assist in the process of redress or avoidance of such alienation of their territories.

In conclusion, yesterday afternoon a question was asked about how to obtain data from widely dispersed Indigenous Peoples. We believe that data can come from Indigenous Peoples themselves, in cooperation with global monitoring agencies so that the information is presented in a suitable and useful manner.

Thank you sir.

1Report on Transnational Corporations to the 2nd UN Forum on Business and Human Rights