Submission on the Lancelin Extensions

by Denis Doherty for Australian Anti-Bases Campaign Coalition

Not confidential

Table of contents:

Introduction to the submission:

In light of the EIS for the Lancelin extension it is necessary to examine the experience of sites in the US and Australia where the militaries of these two countries have already done their damage. The beneficiaries of this land grab are these two flawed organisations.

Section 1- US experience

Introduction to the US experience.

The US military has the worst record of any environmental vandal ever seen in the world. It is able to achieve this rare distinction by being able to plant over 300 bases outside continental US and to deliberately in some cases contaminate with impunity because they know that the host country cannot do anything about it. Countries with weak environmental laws have been victim to gross contamination by the US military. In Philippines the toxic legacy left at Subic Bay and Clark Air Base were not cleaned up and were left in a horrific state. There are numerous other examples of this lack of care by the US military. I believe that a base in Puerto Rico has become such an embarrassment that it has been the subject of a major article in a recent "New Internationalist" magazine. Hawaii is also the subject of much US military exercising or contamination.

However, as the table below and the account of one base the Jefferson Proving Ground (JPG) prove the US military are no clean skins when it comes their own country. They are prepared to leave vast areas of valuable land fenced in as the author says like a person 'with a contagious disease' for an indefinite period.

Below are sections of the book noted for your information. The US experience as taken from: The Threat at Home - confronting the toxic legacy of the US Military by Seth Shulman. Pub 1992 by Beacon Press

Proving grounds and test sites * p 181

The Jefferson Proving Ground and the Aberdeen Proving Ground illustrate the scale and breadth of contamination found at the nation's proving grounds and test sites. Most frequently, as at JPG, these facilities have been used by the United States to test its weapons, leaving dangerous scattering of unexploded munitions buried in the soil. These munitions threaten to explode at any time, leaving the land unusable for other purposes and making cleanup dangerous and difficult. In addition, if left for long periods these munitions threaten to leach their contents into the soil and groundwater. The military's proving grounds have also been home to the testing of some of the military's most dangerous and exotic weapons, such as chemical and biological agents.


State Military installation Status Sites identified Sites cleaned

S=sites listed on EPA Superfund National Priorities List. *=Sites listed for closure

The point of this table is that there are an enormous number of sites that have been contaminated and there is little sign that they have been or can be cleaned up. Why would we want to produce another Jefferson Proving Ground? We must learn from this experience not be so insistent on military values when they do not leave the land they occupy in good shape. (Author)

The book that we are using lists about categories of bases and their toxic legacies, such as Naval, Air Force, Depots and so on. I have only included bases that approximate to the Lancelin extensions. The impact of this book is very savage as we are confronted by numerous instances of the US military's lack of care for the environment. For example the cover quotes Rear Admiral Gene R. LaRoque, US Navy (ret.) "As a military man, I am embarrassed to say that Seth Shulman's disclosures of the adverse impact of the military on our environment are accurate and very disturbing."

Jefferson Proving Ground - Minefield in the Heartland

Taken from "The threat at Home -confronting the toxic legacy of the US military" by Seth Shulman published by Beacon Press reprinted 1999. pp3-4

Madison, Indiana, has a problem. At the end of a long day, the town's mayor, Morris Wooden, leans back in his desk chair to explain. The federal government, after some consideration, has decided to close the Jefferson Proving Ground, a sprawling Army facility on the outskirts of town. The decision, says Wooden, is part of a fiscal belt-tightening measure mandated by Congress.

Jefferson Proving Ground-JPG, as everyone in Madison calls it-has been a good neighbor and has employed many Madison residents for over a half century. Today it remains one of the town's largest employers, so the economic impact of its planned shutdown is a serious concern, Wooden explains. Madison officials are fighting the congressional order to shut the facility because they want to keep the jobs in their town, and because they think that JPG was unwisely selected for closure.

But there is also another reason. After the military leaves, it is not at all clear what will become of JPG's 100 square miles of land in the lush southeastern corner of the state. The land, Wooden says, is uninhabitable, a minefield littered with unexploded bombs from decades of Army tests.

Cleaning up JPG, if it is undertaken, will be a mammoth, dangerous, and costly job. Wooden says the Army ignored the issue in its decision to close the base. Now, he reports, the Army admits that there aren't any funds set aside for the job and that none are anticipated. The cleanup costs are so high, in fact, and the work so dangerous, that the Army wants simply to abandon the site. And as things now stand, it is likely that this will happen: the vast installation may well be the first to be fenced off in perpetuity, permanently isolated from human contact, like a quarantined victim with a contagious and terminal disease. Mayor Wooden's office walls hold framed snapshots highlighting his political career. One shows him shaking hands with a former JPG base commander in happier times. Today the mayor remains on good terms with JPG personnel, but he is livid at the very idea that his town might be saddled forever with a huge abandoned minefield. He calls the prospect "immoral on economic and environmental grounds." The Army's handling of JPG's closure, Wooden says, "is the kind of thing that makes the Pentagon's $600 toilet seats look good."

Heading north a few miles Outside of Madison's historic downtown, U.S. Highway 421 begins to hug the fence of the Army's Jefferson Proving Ground. It is beautiful American heartland, this corner of Indiana near I the Ohio and Kentucky borders, with miles of rolling pastures and cornfields.

Arriving at this spot by car, the first thing a visitor notices is the fence. It seems normal enough at first for a military facility, an eight-foot-tall rusting chain link topped with barbed wire. But as it clings unbroken to the road's edge for mile after mile, toward Ripley County, through Belle- view and Bryantsville, the fence's length-and the size of the facility it surrounds-begins to sink in. Enclosed behind this uninviting 48-mile perimeter are the 100 square miles of Indiana that Mayor Wooden fears t will remain quarantined forever: an area larger than Manhattan and the District of Columbia combined. It is an area that Indiana's Senator Dan Coats has described, probably accurately, as the "largest contiguous contaminated area in the US"

Here at Jefferson Proving Ground the Army has tested huge quantities h of conventional munitions since World War II. Over the span of fifty a years, Army personnel have shot off some 23 million rounds of ordnance, littering the land with more than a million unexploded bombs, mines, and artillery shells which lie on the surface or are buried as deep as thirty feet underground. Some of the buried munitions are white phosphorus shells that JPG officials say are certain to ignite if they are dug up and CI exposed to air. Other bombs explode unexpectedly from time to time; ~ many more surely would if the Army tried to remove them.

Conclusion to the US military section

The proponents of this extension must have serious problems if they are going to invite such an organisation as the US military into the Lancelin area. We are looking at repeating the experience of the JPG above. We are far more culpable as we know what can happen to such an area if it is allowed to be treated as proposed. We can look forward to the permanent loss of that huge area to the people of WA and Australia and the permanent maintenance of two-metre fence to keep people out.

Section 2- Australian Experience

Introduction to the Australian Experience

As far as we know the nearest example of the proposed extensions to Lancelin are similar to Shoalwater Bay Training area( SWBTA). This area of rainforest and semi tropical landforms with a significant component of coast area seems almost to match Lancelin. The experience of this area with huge exercises such as the Kangaroos and the US-Australian exercise shows that despite the best efforts of bureaucrats and Defence chiefs' serious flaws are permitted. These lead to the unmistakeable conclusion that Defence does what it wants and when and where it wants.

There have been scandals with these exercises such as significant amounts of ammunition spilling into the sea or US marines killing an emu for 'fun'. But the problem is much deeper than that. The inquiry alludes to these attitudes of defence, which makes the area of Shoalwater Bay open to much environmental damage.

At its core is Defence saying that it needs training areas and much of the Australian public would agree with them. This is then coupled with the idea that 'Defence' has to be secret and frank and open discussion cannot be had with the nearby public.

Again there is another reason we should stop and ask, "Does Defence really need this when it already has SWBTA?" The answer lies in the participation of foreign forces in Australian training areas sometimes for nothing and sometimes for money. We need to ask should we open our land to the contamination of Foreign Forces? Is our precious land to be spoiled to assist our Defence chiefs to get friendly with other national militaries? My answer is that Australian land can be used by Australian forces for training and not for the goodwill of the US and others in the region. In other words the ADF already has enough training facilities and the shameless land grab by our military is just a knee jerk reaction to September 11, 2001 or a way of making hay 'while the sun shines'. The ADF are hoping that this land grab can be squeezed through because of all the hysteria surrounding the so-called 'war on terror'.

Shoalwater Bay Qld Experience

Lancelin is not an entirely new to Australia operation. The nearest thing in our experience to this extraordinary move by the military is the Shoalwater Bay, Queensland experience. In 1994 an inquiry was held into the uses of Shoalwater Bay where there were several stakeholders in using the area. The stakeholders were the Aboriginal people, Mining interests, Tourism and the military. The inquiry came down on the side of the military but it was not totally in favour of the defence department. I have included excerpts of the report delivered in 1994.

The inquiry was called: Commonwealth Commission of Inquiry Shoalwater Bay, Capricornia Coast, Queensland.

Final Report; Report No 3. May 1994. Recommendations and key findings.

Legislative and Policy considerations p xv

This report was based on these laws and these laws must be again consulted if we are to have some reasonable discussion of this huge takeover of land. (Author notes)

Defence values and use p xvii

The administrative procedures used to assess potential environmental impacts of works, projects and activities carried out by the Department of Defence in the Area are inadequate. (Author emphasis) The current process for considering the environmental effects of Department of Defence proposals, works, projects and other activities within the area lacks open public scrutiny and accountability and does not adequately reflect the statutory responsibilities of the Department with respect to several COMMONWEALTH STATUTES. Also, the Department of Defence 's environmental management performance in the Area should be open to a process of public and professional scrutiny.

In particular, the list of exclusion areas in the Plan [which are those sites in the Area where defence activities are prohibited] is adequate, and sites on the list are ill defined in terms of sector identification, areal extent, vulnerability and temporal sensitivity.

Future defence use of the Area should be predicated on the principle that defence use and conservation use should be concurrent and equally significant uses. p. xviii

The procedures of Defence in relation to the big exercises are inadequate still! Defence run Public Relations exercises in the local area Rockhampton and Yepoon. They specialise in getting the chamber of commerce types to say what an economic boon such an exercise will bring to the area. They engage in filibustering at Public meetings where they rarely tell the truth and they engage like-minded environmentalists from Commonwealth departments who rarely object to anything. They definitely do not allow independent environmentalists to inspect the damage of Tandem Thrust etc.

Socially the US service personnel have not reached the depths of their behaviour on Okinawa but there are incidents of rape and child abuse in the local area. This is so with the visits of US personnel from warships.

Military training and other defence requirements [term of reference] pxxv

The Commission recommends:

[12] That as there is no alternative area to which the Department of Defence has access which will produce the substantial benefits which defence use of the Area produces at the national, State and regional level, the Department of Defence continue to use the whole Area, subject to the implementation of the findings of the Commission for the conservation of the whole Area.

The department is running this argument again with Lancelin, we have no other training area, and we must have this huge area no matter what! We urge all those with oversight to check what they have and whether it is adequate. We believe that the ADF already has enough training areas and is already doing them damage so why give them more space to pollute?

Quality and quantity of information about the Area [term of reference 3(i)] pxxix

The Commission recommends:

That for the future management purposes permanent scientific reference areas of the range of the Area's community types be established as benchmark sites and then be used to monitor the impacts of uses and activities; and that priority is given to the collection of data in the following areas:

It is our belief but we have not had time to check this that this has never been done. Our case is that the DoD is a bad steward of the environment and does not deserve or need more land to poison. We have checked with James Patrick O'Brien who was an author of a submission to the original inquiry and he informed us verbally that things had not improved.

Chpt 9 Effect of defence use and management on the Area's values p159

Description of use

9.02 The Commission received virtually no submissions on specific defence force activities within the Area other then from the Department of Defence itself. This is understandable, given the lack of public access to the Area and appropriate levels of secrecy regarding defence matters and national security. The description of the use of the Area is therefore based primarily on submissions received from the Department of Defence.

This is our point because of secrecy and there is difficulty in being objective about defence does and we are wholly reliant on the word of DOD, which has proved to be a bad tenant in numerous places. We are of the opinion that if Defence is being secretive then it has something to hide.

9.34 Future administrative arrangements p166

The Commission considers the current arrangements in respect of environmental assessment of the impact of works and activities carried out by the Department of Defence in the Area are unsatisfactory.

Although defence-training activities were a use of the Area before Environment Protection [Impact of Proposals] Act 1974 came into force, Department of Defence has statutory responsibilities with respect to matters, which fall, under section 5 of the Act. The Department also has responsibility under the 5A of the Act regarding listed native species, as well as responsibilities under the Endangered Species Protection Act 1992. Because the Area is listed in the Register of the National Estate, the Minister for Defence is obliged to comply with section30 of the Australian Heritage Commission Act 1975.

Further evidence of what we are saying. The situation has not improved for nearby residents of SWBTA and we contend that without fully independent environmentalists to inspect the 'work' of DOD then no one will know what they are doing and they do not have to answer to anyone.

Impacts on the terrestrial environment p169

Many parties to the Inquiry praise the efforts of the Department of Defence for its management of the Area, [35] although because of restricted access to the Area, the majority of these views would be based on limited information. There is currently no process for assessing the environmental management performance of the Department of Defence against objective criteria.

The Clinton Lowland Joint Venture puts the view that:
It is quite clear that Defence impacts on the environment of the Area, as well as impacts inherited from times of pre-Defence ownership, are, and have been, quite adverse and quite significant. [36]

9.50 Dr Hynes' report demonstrates that there are transient impacts, which are repaired by a combination of natural processes and intervention: for example, back filling and regressing of disturbance. Some of these transient disturbances in sites such as the Townshead Island target area cannot be rehabilitated for reasons of safety and redisturbance. There are also permanent impacts such as the construction and use of airstrips and Scale A camps and airstrips. Table 9.4 sets out Department of Defence's estimates of the area of temporary and permanent impacts. (We have not included the table author)

One of the parties who praised the DOD was the Shoalwater and Byfield Environment group, however when we ventured into Rockhampton in 1997 to protest about Tandem Thrust 97 this group were our staunchest supporters. Apparently they no longer held happy views of the DOD.

Again there is evidence of lack of information and with the Lancelin venture there will be similar lack of information. What is most worrying about this study was the complete absence of any toxic examination of the soil of SWBTA, which will have a big bearing on the Lancelin application.

Floral and Fauna Conservation

9.58 Under the Endangered Species Protection Act 1992, the Commonwealth is required to prepare and implement a 'recovery plan' for each 'native species and ecological community' listed under the Act, within five years of the commencement of the Act [which was 30 April 1993] for Endangered species and within ten years for vulnerable species. Such plans while they are overseen by the Australian Nature Conservation Agency are not necessarily prepared by that agency. The Act prevents Commonwealth agencies from actions, which contravene an approved/adapted recovery plan. The Act [section 165,part 7] also places an obligation on Commonwealth agencies - in this instance the Department of Defence- to provide reasonable assistance to the Australian Nature Conservation Agency in preparing inventories of rare threatened species.

9.59 No recovery plans have been prepared for the Area. The Commission is aware that the Act has only been in force for a year and the presence of listed species has not been fully determined to date. Substantial information has been obtained as a result of the Inquiry and is now available to the Department of Defence for this purpose. P173

The inquiry gives a rap on the knuckles to the DOD for its tardiness in protecting endangered species. We have here a growing picture of Defence lack of regard for the environment and they must not be allowed to acquire land for the sake of some glorified notion of doing their bit for the 'world'.

Effects on Aboriginal values p176

9.78 No evidence was presented to the Inquiry of impacts of defence use on archaeological sites in the Area. The Clinton Lowland Joint Venture notes that 'no-go' areas set out in Defence Land Management Plan for the Area do not include any archaeological sites [72]. Mr A. Border and DR P. Memmott, consultants to the Commission, note that the Land Management Plan contains a cultural and heritage sites component, which is intended to promote the conservation of Aboriginal sites in the Area [73]. Mr Border notes the potential impacts of military activities on archaeological sites and suggests methods by which these impacts could be avoided. [74] DR Memmott observes that the Department's archaeological site protection strategies are weakened by the absence of any involvement of Aboriginal people. [75] The Commission supports this view.

The environment is one thing but to engage in a laissez faire approach to our indigenous people and their sensitivities is outrageous but not limited to SWBTA or Lancelin.

9.3 Findings

9.84 p 177

The administrative procedures used to assess potential environmental impacts of works, projects and activities carried out by the Department of Defence in the Area are inadequate and must be changed. The current process lacks open public scrutiny and accountability and does not adequately reflect the statutory responsibilities of the Department of Defence with respect to several Commonwealth statutes.


The prescriptions in the Land Management Plan for the conservation of the natural values of the Area do not contain adequate measures to protect the bio-diversity values of the Area. Major aspects of concern in this respect are the current measures for fire management, feral animal management [including goats on Townshend Island] and the protection of fragile and biologically significant ecosystems. In particular, the list of exclusion areas in the Plan [which are those sites in the Area where defence uses are prohibited] is inadequate and sites on the list are ill defined in terms of sector identification, areal extent, vulnerability and temporal sensitivity.


In addition, many of the prescriptions for the conservation of the natural and cultural heritage values of the Area contained in the Land Management Plan are not effectively and consistently implemented in the Area. For example, lack of compliance with the Plan in relation to tree clearing suggests that either the communication of the requirements of the Land Management Plan to users is inadequate, or users do not consider the requirements of the Plan to be binding; and there are also inadequacies in the management and use of chemicals/herbicides.


The plan does not specify management for the maintenance of wilderness qualities in either the terrestrial or marine environments as an objective. Nor does it provide procedures for consultation with Aboriginal people to determine the significance and protection of Aboriginal sites.

Chapter 9 was titled:

Effects of defence use and management on the Area's values. This last section has some of the findings. We are saying that the DOD is not a good manager because their agenda is to blow up things using nasty chemicals and instruments. We reiterate there is already sufficient facilities for training in Australia and this extension should not go ahead.

The table below indicates what pressure Lancelin will be under, however the figures are 1991-3. The use is much larger nowadays with the advent of Tandem Thrust exercises and the increasing use of the SWBTA by other regional forces.

Australian experience as taken from: Commonwealth Comission of Inquiry Shoalwater Bay, Capricornia Coast. Queensland 1994