PLEASE TAKE ACTION IMMEDIATELY TO SAVE OUR NORTHERN JARRAH FORESTS.
This document is a resource for time-poor individuals to make a submission to the EPA regarding the Aluminium Company of America’s proposed mining activities in WA’s precious Jarrah forests. The categories below match the EPA feedback categories.
Do you have an extra 10 minutes to send your responses as a letter to your State and national MP's and the environmental minister? Ask them to speak up to save the NJF.
Contacts below:
Thank you, with BIG appreciation,
Jen Lowe
OVERVIEW
Alcoa (a US-owned company) is proposing to clear 11,457 hectares of our unique and irreplaceable Northern Jarrah Forest — much of it within Perth’s vital drinking water catchment.
For the first time in 60 years, the public can comment on Alcoa’s proposal. The Environmental Protection Authority is accepting submissions until 21 August 2025. This is our chance to speak up and protect forest,climate, biodiversity and our children’s future.
The links below provide further detailed reading for those who’d like to know more:
https://www.youtube.com/watch?v=86FpRJuxq2c
End Forest Mining– Rehabilitation failure
End Forest Mining– Water contamination
End Forest Mining– Bauxite Mining FAQ
End Forest Mining– A Thousand Cuts Report
End Forest Mining– A Thousand Cuts Report Summary
https://theleeuwingroup.org.au/_data/papers/Alcoa_Facts_at_a_Glance.pdf
https://theleeuwingroup.org.au/_data/papers/ALCOA_DESTROYING_OUR_FORESTS.pdf
Environmental Defenders Office – Submission Guide
EPA Fact Sheet– Public Review of Alcoa assessments
Alcoa– Pinjarra Alumina Refinery Revised Proposal
Alcoa– Bauxite mining on the Darling Range in the southwest of WA for the years 2023 to 2027 (Mining Management Plan)
SUBMISSION ANSWERS
FORM LINK HERE
1- 4: Your details
5: Both Assessments
Flora and Vegetation: Alcoa’s proposal to clear 11,447 hectares of Northern Jarrah Forest will permanently impact one of the most biodiverse temperate forest systems in the world. Studies (e.g. Standish et al., 2021) show that functional plant diversity does not recover after bauxite strip mining. Key ecological processes, such as pollination, seed dispersal, and nutrient cycling, are severely disrupted. Hollow-bearing trees that provide habitat for birds and mammals take 150–300 years to develop, and are not spared or replaced through rehabilitation.
To protect old growth forests bordering proposed mining and exploration areas from edge effects and other indirect impacts, no new clearing or exploration should occur within 2 km of these forests. This buffer is essential to safeguard them as critical future habitats.
Terrestrial Fauna: The NJF supports threatened species including the Carnaby’s, Baudin’s, and Forest Red-tailed Black Cockatoos, as well as quokkas and chuditch. Habitat loss from clearing, coupled with edge effects and reduced food sources, will exacerbate species decline. Faunal return to rehabilitated areas remains poor even after decades, according to long-term monitoring studies.
I believe that forest mining should be a thing of the past and mining should take place in areas previously cleared for other purposes. However, if any forest mining is to continue, no known or suitable Black Cockatoo nesting trees should be removed, and critical infrastructure should be rerouted to avoid them. The buffer zone around nesting trees must be clarified and expanded—at least 250 m for known and suitable nesting trees, and 50 m for potential nesting trees—in line with DBCA’s recommendations. Baudin’s Black Cockatoo is Critically Endangered, and protecting both current and future feeding and breeding habitat is essential for the species’ survival.
Terrestrial Environmental Quality: Mining removes up to 15m of topsoil and subsoil, severely disrupting microbial communities and soil structure. Research by Tibbett (2010), ‘Restoring mine soils in Australia: a progress report’ has shown that soil horizons essential for water retention and plant growth are not restored post-mining. Alcoa’s rehabilitation lacks the complexity of native systems.
Alcoa’s mining removes 4–6 m of bauxite and about 2 m of loamy soils, replacing them with stored topsoil, overburden, and clay, significantly altering soil structure and reducing water-holding capacity. Despite scientific evidence to the contrary, Alcoa claims this does not impair rehabilitation.
Rehabilitation slopes should be under 18° to reduce erosion, yet visual evidence shows this standard is not consistently met. Self-certification failures and limited inspections reveal a gap between commitments and on-ground compliance.This must be rectified.
Inland Waters: Bauxite mining poses the greatest threat to drinking water in Perth and the Southwest (Water Corporation 2022), with contamination deemed “certain” and potential treatment costs of $3.25 billion. Most disturbance from Alcoa’s expansion will occur in key dam catchments, with frequent drainage failures allowing sediment and turbidity to enter reservoirs, undermining pathogen control.
Mining within Reservoir Protection Zones (RPZs) directly contradicts water protection measures. Over 8,800 ha of exploration is planned in RPZs, along with infrastructure clearing. All mining and exploration in RPZs should be permanently banned, and mining in catchments phased out by 2028.
Alcoa does not consistently follow Water Corporation limits to reduce sediment risks, allowing clearing on steep slopes and in sensitive sub-catchments. The company also uses 17 billion L of water annually, adding pressure in a drying climate.
Significant knowledge gaps remain in groundwater analysis, contaminant modelling, and water quality monitoring. Without robust baseline data, risks to public drinking water and water-dependent ecosystems cannot be reliably assessed. The precautionary principle must apply.
Air Quality: Mining and associated haulage generate dust and airborne particulate matter (PM2.5, PM10), affecting nearby communities and ecosystems.The potential and current health impacts of long-term exposure are not sufficiently documented. This must occur before further mining operations are approved.
Vegetation clearing significantly reduces carbon sequestration capacity. Rehabilitation does not offset these emissions for at least 80 years (EPA WA 2023), ‘Greenhouse Gas Emissions Guidance for Environmental Impact Assessment’).
GHG Emissions: Net GHG emissions rest on assumptions. As such, the claimed long-term carbon neutrality of the Proposals is highly uncertain and cannot be relied on in environmental decision-making. With at least 1.4 billion t CO2-e GHG emissions over the next 20 years, the EPA has a clear mandate to either reject or significantly strengthen this proposal.
WA’s GHG emissions already exceed the level required to support the Paris Agreement. Hence, WA must cut its emissions more steeply than other States in the future. If the proposal is approved, Australia will not be heeding the science and meeting its international climate commitments, and the recognised environmental impacts from climate change will be severe.
Social Surroundings: Loss of recreational, educational, and cultural values occurs when forests are industrialised. Noise, light, and truck traffic impact nearby communities, while fire risk increases in fragmented landscapes.I have experienced the light and noise pollution first hand when walking on the bibblemun track. We were 5km from the Alcoa minesite and yet we heard works through the night under the glow of light spill.
Details of MAZs and LDAs for both heritage, amenity and environmental values, must be provided and clarified to ensure they are aligned with recommendations from Noongar
people and corporations, and relevant experts and Government departments.
The buffer between mining and exploration and the Bibbulmun Track must be increased
from an inadequate 200 m to at least 1000 m and ideally 5km. Given its significance to the Jarrahdale community, the Balmoral Trail and Extension and POW Camp should all be placed in
an avoidance zone of at least 1000 m to safeguard their history, heritage, recreation and environmental values.
To protect its environmental, cultural and heritage amenity, Dwellingup Discovery
Forest should be removed from the Expansion Proposal.
Rehabilitation (Q7): Alcoa’s rehabilitation has not been formally completed or accepted after 60 years. Metrics focus on vegetation cover rather than functional ecosystem traits. Completion criteria should align with the Society for Ecological Restoration's standards, including species diversity, soil function, and faunal return.
Gaps in Alcoa’s self-certification process and the lack of effective regulatory oversight of rehabilitation must be addressed before any approval is considered. Alcoa should be held accountable without delay for breaches in its rehabilitation management.
Holistic Assessment (Q8): Alcoa has not adequately assessed the Proposals’ impacts on the ‘environment as a whole,’ omitting key interactions across systems, scales, and time. The assessment relies on assumptions, ignores many climate change effects, offers no new mitigation, and presents only best-case scenarios. Without a true holistic view, ongoing clearing, inadequate rehabilitation, emissions, and climate change will drive long-term forest degradation, species loss, and health risks.
I recommend the EPA undertake a Strategic Assessment under section 16(e) of the Environmental Protection Act for the entire NJF bioregion to fully assess cumulative impacts, address knowledge gaps, and guide long-term forest management.
Stakeholder Engagement (Q9): Communities have not been given full access to emissions data or long-term health monitoring, leaving them unable to properly assess potential risks. Before any approval is granted, the WA Government should commission independent assessments by specialists in toxicology, epidemiology, and hydrology to evaluate likely impacts on public health and the environment.
Evidence of meaningful involvement from independent scientists and Noongar Traditional Owners during the early planning stages is minimal. Engagement processes must be open, ongoing, and genuinely inclusive, giving local communities, Traditional Owners, and relevant experts a decisive role in shaping decisions that affect cultural heritage, environmental integrity, and community well-being.
Other (Q10): WA’s NJF is a globally unique ecological asset. The EPA has a responsibility to uphold rigorous, science-based protections that reflect the irreversible nature of biodiversity loss.
The EPA wants to hear what the Northern Jarrah Forests mean to people, so please include a personal perspective in question 10 on why this issue matters to you.
Flora and Vegetation: Alcoa’s proposals will contribute to climate-related vegetation decline, reinforcing existing threats in the NJF. Limited baseline surveys mean more conservation-significant flora may be unaccounted for, making impact assessments unreliable. The absence of adequate buffers around TECs, GDEs, and key communities fails conservation best practice. Precautionary buffers (50–100 m) should be applied, and Auditor General recommendations adopted to strengthen protection and accountability.
Alcoa downplays the biodiversity value of vegetation to be cleared, misrepresenting impacts as minor and short-term. In reality, mature forest structure takes over a century to develop, large Jarrah trees may not return, and climate change will likely transform forest composition. Rehabilitation cannot fully mitigate these losses, and cumulative clearing across the NJF makes further removal unjustifiable. Forest clearing delays ecological maturity, reducing resilience to fire and degrading fauna habitat—potentially permanently. No clearing or exploration should occur within 2 km of old growth forests.
Fauna: The Proposals will clear 11,458 ha of fauna habitat, much of it high-quality, contiguous forest connected to major conservation reserves. This is a substantial and lasting loss that cannot be justified by claims the forest is “well represented” elsewhere.
Impacts extend beyond clearing, including fragmentation, competition for habitat, and long-term rehabilitation failures, all worsened by climate change. Key habitat features like coarse woody debris and tree hollows—critical for species such as Chuditch—will be permanently reduced, while foraging quality for Black Cockatoos is lower in rehabilitated areas.
Avoidance measures are limited in scale and definition, and cannot offset the permanent loss of intact forest. Alcoa claims fauna deaths from clearing will be “low” due to staged clearing near unmined forest, yet provides no evidence animals can reliably survive or recolonise. Displacement increases competition for habitat and is not proven to lead to stable populations.
Rehabilitation claims are inconsistent: Alcoa says most vertebrate populations will recover in 10 years, yet key habitat features like coarse woody debris and nesting hollows take 100–200 years to form. No evidence shows this process achieves demographic stability.
Over 7,000 ha of high-value Black Cockatoo habitat will be cleared for the Expansion, including up to 300 known and 650 suitable nesting trees, with inconsistent and inadequate buffers far below DBCA’s recommendations. No known or suitable nesting trees should be cleared, and infrastructure must be rerouted if necessary.
Baudin’s Black Cockatoos must be assessed as Critically Endangered in line with IUCN listings to reflect true extinction risk and ensure accurate offsets.
Terrestrial Environmental Quality: Removal of topsoil severely damages soil carbon and microbial life. Tibbett (2010) 'Restoring mine soils in Australia: a progress report' shows these losses are not recovered post-mining. PFAS, hydrocarbons, and heavy metals have been detected in mining zones, threatening both environmental integrity and human health via dust, surface runoff, and leaching.
Alcoa’s mining removes 4–6 m of bauxite and around 2 m of loamy soils, replacing them with overburden and clay, permanently altering soil structure and reducing water-holding capacity. Despite scientific evidence to the contrary, Alcoa claims this does not impair rehabilitation.
Slopes should be under 18° to prevent erosion, yet visual evidence shows this is not consistently met, revealing a gap between commitments and on-ground compliance. Alcoa must be held accountable for breaches.
Inland Waters: Alcoa’s proposed use of 17 billion litres of water annually, including from protected drinking water catchments, poses serious risks. Spills of hydrocarbons and PFAS threaten Perth’s water security. These contaminants persist, bioaccumulate, and are linked to cancer, endocrine disruption, and developmental disorders. This must be adequately tracked and rectified before additional works are approved.
Air Quality and GHG Emissions: Dust and PM2.5 emissions from mining and haulage are linked to respiratory illness, cardiovascular stress, and increased hospitalisations.
In forests, tree loss reduces carbon sequestration. Modelling shows it takes at least 80 years for rehabilitated areas to begin offsetting these losses. In the meantime, increased fire risk contributes further emissions.
Social Surroundings: Public health includes mental health, cultural identity, and community wellbeing. The destruction of forests near towns erodes access to nature, reduces recreational opportunities, and causes distress about environmental change. The impacts are heightened for First Nations communities whose cultural ties are place-based and intergenerational.
Rehabilitation (Q7): Alcoa’s rehabilitation lacks long-term success, with no sites formally completed or signed off after six decades. Rehabilitated areas typically exhibit simplified ecosystems, often resembling low-diversity monocultures lacking canopy structure, native understorey, and faunal return.
Holistic Assessment (Q8): The proposal separates rather than integrates risk factors. Health is affected by air, water, noise, land degradation, and cultural loss.
The lack of a comprehensive impact assessment underscores the need for the EPA to provide Strategic Advice under section 16e of the Environmental Protection Act for the entire NJF bioregion. Such a process could fill critical knowledge gaps, deliver a thorough cumulative impact assessment for the region, and guide the WA Government on its long-term management.
No doubt, if this were to occur, practices would be dramatically reduced in the NJF and relocated/ improved.
Stakeholder Engagement (Q9): The public has not been given access to comprehensive emissions data or long-term health surveillance. Independent experts in toxicology, epidemiology, and hydrology should be consulted before approvals proceed.
Other (Q10): Public health protection requires foresight. Once forests are gone, water is polluted, or soil is destabilised, the consequences ripple across generations. A precautionary approach is not only wise but essential.
The EPA wants to hear what the Northern Jarrah Forests mean to people, so please include a personal perspective in question 10 on why this issue matters to you.
Flora and Vegetation: Old-growth jarrah and marri trees are not just scenery — they are the scaffolding of a complex living system. These forests regulate temperature, store carbon, and support rich understorey communities. Standish et al. (2021) and McCrea (2023), ‘A Thousand Cuts: The state of the Northern Jarrah Forest’ show that post-mining rehabilitation fails to restore this diversity. Dominant species may return, but structure, function, and rare species do not. 60 years of failed restoration show a clear Alcoa legacy.
Fauna: Animals such as quokkas, cockatoos, possums, and honeyeaters require intact forest corridors and mature trees with hollows. Alcoa’s clearing will disrupt migratory pathways and nesting grounds, particularly for species already threatened. Craig et al. (2012), ‘Optimising fauna return in post-mining landscapes’ found that faunal return is minimal in rehabilitated areas, even decades post-mining.
The number of animals that can’t leave fast enough when these forests are cleared must be staggering. It is heartbreaking.
Terrestrial Environmental Quality: Removal of soil layers disrupts hydrology and nutrient cycling. Surface crusting and compaction reduce plant growth and increase runoff. Dust, noise, and light pollution make once-accessible areas unwelcoming for education and recreation. These effects are not temporary — they reshape the landscape.
Inland Waters: Our communities rely on the presence of healthy waterways and intact ecosystems. Contamination by PFAS and hydrocarbons is well documented in Alcoa's history. Impacts on Serpentine and Murray catchments need urgent scrutiny.
Alcoa’s proposed 17 billion litre annual water use risks depleting public supplies and degrading ecosystems.
Air Quality: Fine particulate pollution from blasting, haulage, and clearing affects not only those working or learning outdoors, but also residents in surrounding communities. These airborne particles, particularly PM2.5, are associated with respiratory and cardiovascular issues and disproportionately impact sensitive groups such as children, the elderly, and individuals with pre-existing health conditions. Long-term exposure has been linked to increased hospitalisations and reduced life expectancy. Despite these risks, monitoring and mitigation measures remain poorly defined in Alcoa’s documentation.
Social Surroundings: These forests are part of WA’s cultural and educational infrastructure. Schools, community groups, and outdoor programs rely on their accessibility, biodiversity, and tranquillity. Loss of these spaces reduces connection and community identity. For First Nations groups and many WA communities, these forests are cultural landscapes.
Disturbance avoidance zones must be clearly defined and aligned with recommendations from Noongar people, experts, and government agencies.
The Bibbulmun Track, including Mount Cooke, Vincent, Wells, and Boonering Hill, faces visible and audible mining impacts for up to 20 years. A 1,000 m buffer is needed to protect the walking experience.
The Balmoral Trail and heritage-listed POW Camp should be in 1,000 m avoidance zones to prevent closure, dust impacts, and visual intrusion.
The Dwellingup Discovery Forest, including the Murray Basin Wilderness Zone, should be excluded from the Expansion to safeguard its ecological, heritage, and recreational values.
Rehabilitation (Q7): Alcoa’s ‘rehabilitated’ areas often resemble monocultures with limited species diversity, underdeveloped soil profiles, and sparse canopy cover. These areas lack the diversity, structural complexity and ecological function of intact forests. They are silent and sad. Long-term studies have shown that faunal return, nutrient cycling, and native understory regeneration are severely limited even decades after rehabilitation. In addition to their reduced educational and ecological value, these areas can be more susceptible to fire, weed invasion, and erosion. Alcoa must be made accoutable to rectify the existing reforestation efforts prior to any further approvals.
Holistic Assessment (Q8): The impact is not just environmental — it’s generational. Once these forests are industrialised, they lose their capacity to teach, inspire, and restore.
Alcoa has failed to properly assess the Proposal’s impacts on the ‘environment as a whole,’ overlooking vital connections across systems, scales, and time. The assessment relies on best-case scenarios, lacks ecological depth, and assumes recovery in systems that science shows are slow, fragile, or irreversible. Mitigation should serve to protect nature, not to justify its degradation. The precautionary principle must be upheld.
Stakeholder Engagement (Q9): Educators, students, and community volunteers are not ‘stakeholders’ in the commercial sense — but our interests must be protected. Proper consultation with schools, outdoor education organisations, and cultural custodians is essential.
Other (Q10): We cannot teach sustainability in deforested landscapes. The EPA’s decision here is a signal to future generations about what kind of legacy they inherit.
The EPA wants to hear what the Northern Jarrah Forests mean to people, so please include a personal perspective in question 10 on why this issue matters to you.
Flora and Vegetation: Studies like Standish et al. (2021), 'Long-term ecological trajectories in rehabilitated jarrah forest', show that forest recovery after bauxite mining is incomplete and slow, with limited return of functional diversity, understorey complexity, and canopy height. Alcoa rehabilitate with a very limited number of species and poor ongoing management. Current restoration efforts need to be rectified proven on a large, replicable scale before any further approvals are granted.
Fauna: Forest fragmentation due to clearing has cascading effects on biodiversity. Species that are already under stress, such as the forest red-tailed black cockatoo, become more vulnerable to predation and food scarcity. Ecological corridors are severed, and without structural features like hollows and leaf litter, even rehabilitated areas fail to provide functional habitat.
Australia is leading the world in mammal extinction and the continued expansion of forest mining will continue this trajectory. Bauxite mining must be shifted to areas where clearing for other proposes has already occurred.
Terrestrial Environmental Quality: Alcoa’s topsoil removal and site reshaping leads to soil compaction, reduced permeability, and erosion risk. Tibbett (2010), 'Restoring mine soils in Australia: a progress report', highlights that mining-impacted soils in WA often take decades to regain basic functionality, and nutrient cycling remains impaired. In the case of the NJF, which has developed over millions of years to thrive in some of the world's poorest soils, the removal of the bauxite and natural soil composition hinders any hope for real forest restoration. Paired with the spread of dieback closely linked with Alcoa’s works, it is a death sentence for biodiversity.
In the words of Professor Kingsley Dixon ‘The scientific community is clear: it is not a lack of knowledge but a lack of ecological fabric to create a Jarrah forest that is the issue.’ The Jarrah forests cannot thrive without the bauxite in the soil.
Inland Waters: Mining in and around Priority 1 Drinking Water Source catchment areas risks contaminating both surface and groundwater. PFAS, hydrocarbons, and heavy metals accumulate and persist.
Alcoa’s proposed use of 17 billion litres of water annually threatens both ecological flow regimes and human consumption needs. An immediate and permanent ban must be placed on all mining and exploration activities except rehabilitation in RPZs to minimize the risk to drinking water. Planned infrastructure corridors in RPZs must find alternative routes.
In addition, all mining in drinking water catchments should be phased out by 2028, at the end of the window of the currently approved 2024-2028 MMP. In line with Water Corporation’s (2022, 8)
recommendations, there should be no exceptions to the 30% clearing limit in a sub catchment and to the mining prohibition in areas of greater than 16% slope.
Air Quality: Vegetation loss leads to increased temperatures, lower humidity, and greater dust generation. Mining, haulage, and diesel combustion release PM2.5 and PM10 particles. According to the World Health Organization and environmental health literature, these fine particulate emissions are common byproducts of heavy machinery operation and surface disturbance, with documented links to respiratory and cardiovascular impacts.
At a talk last week, I heard from the Peel Environmental Protection Alliance who sited evidence of higher instances (30% increases) of respiratory and other diseasse in the Pinjarra region surrounding Alcoa’s refinery. These were taken from the census. The true health implications of Bauxite mining and the subsequent Aluminium produciton in our urban adjacent areas must be researched and the methods improved before further works continue.
Greenhouse Gases:Carbon emissions from land clearing, soil oxidation, haulage, and equipment operation are substantial. According to EPA WA (2023), 'Greenhouse Gas Emissions Guidance for Environmental Impact Assessment', carbon offsets from rehabilitation may not accrue for 80+ years. Surely, areas that have already been degraded are where mining efforts must be focused. In the current environmental climate we must be protecting our existing forests and using the precautionary priciple. Rainfall has depleted 20% since since the 70’s and is projected to continue depleting. Forest clearing is a key reason for the reduction in rainfall.
Social Surroundings: Changes to forest structure and landform reduce access to traditional, educational, and recreational forest uses. Loss of canopy cover and the intrusion of mining infrastructure diminish the experience of place for communities and visitors. Noise and light pollution travel for many kilometres, disturbing communities.
I believe that forest mining should come to an end by 2028 and areas previously cleared should be the focus for future bauxite mining. If any forest mining continues, then at a minimum the below amendments must take place.
Details of Mining Avoidance Zones (MAZs) and Limited Disturbance Areas (LDAs) for heritage, amenity, and environmental values must be clearly provided and aligned with recommendations from Noongar people and corporations, relevant experts, and government agencies.
The buffer between mining or exploration and the Bibbulmun Track should be increased from the inadequate 200 m to between 1 and 5 km. The Balmoral Trail, its extension, and the heritage-listed POW Camp should be placed in a minimum 1,000 m avoidance zone to protect their historical, cultural, recreational, and environmental values.
The Dwellingup Discovery Forest, with its high environmental, cultural, and heritage significance, should be excluded from the Expansion Proposal.
Rehabilitation (Q7): Alcoa’s rehabilitation is not a reliable way to repair the serious, irreversible environmental damage caused by mining and cannot be accepted as mitigation. After 60 years, no rehabilitation areas have been officially completed, and removal of the bauxite layer permanently prevents full restoration of Jarrah forest ecosystems.
Independent reviews (Stantec 2023; Campbell et al. 2024) show Alcoa’s success claims are misleading: species composition differs greatly from unmined forest, key species are missing from targets, understorey cover and functional diversity remain low after decades, Marri regeneration is failing, and biodiversity indicators do not reflect ecological integrity.
Approval should not proceed without:
Until these issues are resolved, the Proposals must not proceed under any conditions.
Holistic Assessment (Q8): Climate vulnerability, biodiversity collapse, and water insecurity are compounding crises. Alcoa’s project adds pressure to already strained systems. A holistic approach must weigh cumulative and long-term impacts, not isolated metrics.
Alcoa’s assessment omits key interactions across systems, scales, and time, relying on assumptions, overlooking climate change, and presenting only best-case scenarios. Without this broader view, cumulative effects from clearing, poor rehabilitation, emissions, and climate change will lead to long-term forest degradation, species loss, and health risks.
The EPA should reject this assessment and undertake a Strategic Assessment under section 16(e) of the Environmental Protection Act for the entire NJF bioregion to address knowledge gaps, assess cumulative impacts, and guide long-term forest management.
Stakeholder Engagement (Q9): The public has not been given full access to emissions data or long-term health monitoring, leaving communities without the information needed to understand potential risks. Before approvals proceed, the WA Government should require independent reviews by experts in toxicology, epidemiology, and hydrology to assess impacts on local health and the environment.
There is also little evidence that independent scientists or Noongar Traditional Owners were meaningfully engaged during early planning. Engagement must be transparent, ongoing, and inclusive, ensuring that local communities, Traditional Owners, and relevant experts have a genuine role in shaping decisions that affect public health, cultural heritage, and environmental integrity.
Other (Q10): A warming climate demands strong decision-making. This proposal undermines the ecological infrastructure that will buffer our communities in the decades ahead.
The EPA wants to hear what the Northern Jarrah Forests mean to people, so please include a personal perspective in question 10 on why this issue matters to you.
Flora and Vegetation: Forest cover stabilises climate, supports tourism, and provides mental and physical health benefits for local communities and regional economies. Clearing more than 11,000 hectares risks undermining all three. Standish et al. (2021) and McCrea (2023), 'A Thousand Cuts: The state of the Northern Jarrah Forest', document the slow and partial recovery of native vegetation in post-mining areas.
Alcoa’s proposal to clear Jarrah–Marri forest will permanently damage areas of high biodiversity and ecological value, including forests still recovering from past logging. The company downplays the loss by citing regional abundance, ignoring that local plant diversity, structure, and resilience will be degraded — with impacts worsened by climate change. Mature Jarrah forest takes over a century to recover, large trees may never return, and rehabilitation cannot fully restore ecosystem integrity.
Surveys for conservation-significant flora are inadequate, leaving many species unaccounted for. Fragmentation from mining will isolate patches of forest, multiplying the total area affected and threatening long-term ecological function. These impacts extend to key local assets such as old growth forests, Priority flora, and Threatened Ecological Communities, all of which require enforceable buffers (e.g., 2 km for old growth, 50–100 m for peatlands).
The WA Government and EPA should require clear avoidance strategies, climate adaptation measures, independent monitoring, and enforceable remediation triggers before any approval. Given Alcoa’s compliance record, strong regulatory oversight is essential to protect both local values and the long-term health of the Northern Jarrah Forest.
Fauna: Loss of forest habitat places further pressure on already vulnerable native fauna. These impacts extend beyond the mine site, affecting community spaces, nature corridors, and local reserves that are now increasingly isolated.
The Proposals would clear 11,458 ha of fauna habitat, much of it high-quality, contiguous forest linked to key conservation reserves. This is a significant and permanent loss, undermined by Alcoa’s claims it is “limited” regionally. Impacts extend beyond direct clearing to fragmentation, competition for habitat, and reduced foraging quality, especially for species like the Chuditch and Black Cockatoos. Rehabilitation cannot replicate critical features such as coarse woody debris and nesting hollows, which take over a century to form.
Avoidance measures are small-scale and lack clear definition or oversight. Claims that fauna deaths will be “low” lack supporting evidence, and assumptions about recolonisation are unproven. Over 7,000 ha of high-value Black Cockatoo breeding and feeding habitat would be cleared, including hundreds of known nesting trees, with inadequate buffers far below DBCA recommendations.
For credible protection, the EPA and WA Government must require: no clearing of known or suitable nesting trees, rerouting of infrastructure, accurate threat classifications (including listing Baudin’s Black Cockatoo as Critically Endangered), and enforceable avoidance zones supported by independent monitoring.
Terrestrial Environmental Quality: Poor rehabilitation outcomes create long-term legacy issues. Degraded soils can become weed-prone, fire-prone, and structurally unstable. These risks ultimately fall to local government for ongoing management.
Alcoa’s mining removes 4–6 m of bauxite and around 2 m of loamy soils, replacing them with overburden and clay. This permanently alters soil structure, reduces water-holding capacity, and risks long-term impacts on forest regeneration—despite scientific evidence disproving Alcoa’s claims that rehabilitation is unaffected.
Slopes over 18° increase erosion risk, yet visual evidence shows Alcoa is not consistently meeting this standard, breaching its own commitments. Given the importance of healthy soils for local water quality, biodiversity, and forest recovery, the WA Government must enforce strict compliance, mandate independent monitoring, and hold Alcoa accountable for any failures.
Inland Waters: The Water Corporation identifies bauxite mining as the single greatest threat to drinking water in the Perth and Southwest catchments, with contamination from Alcoa’s operations considered “certain” and potential treatment costs estimated at $3.25 billion. Most disturbance from the Expansion and MMP will occur in the Serpentine, South Dandalup, and Murray River catchments—critical sources for local communities.
Mining and infrastructure clearing are planned within Reservoir Protection Zones (RPZs), despite their role as 2 km public exclusion buffers to safeguard water quality. Over 8,800 ha of exploration is also planned in RPZs, directly contradicting state water protection policy. A permanent ban on all mining and exploration in RPZs is needed, along with a phase-out of mining in drinking water catchments by 2028.
Alcoa’s plans do not fully comply with Water Corporation guidelines on clearing limits, increasing sediment and turbidity risks. Its annual use of 17 billion litres of water adds further pressure in a drying climate, demanding close government scrutiny in supply negotiations. Critical data gaps—such as groundwater analysis and contaminant modelling—must be addressed before approvals proceed. The precautionary principle should guide EPA and government decision-making.
Air Quality: Community members routinely raise concerns about dust, diesel fumes, and degraded air quality. Particulate matter from mining activities, including PM2.5 and PM10, has been linked to respiratory issues, cardiovascular disease, and reduced lung function. These pollutants can travel long distances and accumulate in populated areas, especially affecting vulnerable populations such as children and the elderly. Additionally, diesel exhaust from haulage and machinery contains carcinogenic compounds. Local health services and planning authorities must account for these impacts when forecasting community growth and future health infrastructure needs. Without adequate air quality controls and emissions mitigation, the long-term burden of these pollutants is likely to fall on future ratepayers through increased healthcare costs and regulatory remediation.
Greenhouse Gases:
Social Surroundings: Community identity in our region is closely tied to the landscape. The forests are not remote; they are neighbours, classrooms, and spiritual places. Once they are cleared, these values are diminished and difficult to restore.
Rehabilitation (Q7): Long-term rehabilitation places significant expectations on future councils and land managers. Current rehabilitation outcomes are underwhelming: after more than six decades of mining, not a single Alcoa site in the Northern Jarrah Forest has been formally signed off by regulators. Rehabilitated areas typically exhibit simplified ecosystems, often resembling low-diversity monocultures lacking canopy structure, native understorey, and faunal return. Soil health is compromised, with limited nutrient cycling and poor water retention. Fire risks increase due to homogeneous vegetation and fuel accumulation. Without clear accountability and independently verified standards, the cost of ecological failure, fire mitigation, and land management falls on local communities and future ratepayers.
Holistic Assessment (Q8): We must consider the full picture: climate change, demographic pressure, fire, water stress, and biodiversity loss. Projects of this scale must be assessed within these intersecting realities.
Stakeholder Engagement (Q9): Local governments were not adequately consulted early in the process, despite being responsible for managing many of the long-term consequences of land use decisions. Given the scale and legacy impacts of this proposal, local authorities must be actively involved in decision-making from the outset. Ongoing collaboration must include formal partnerships, transparent reporting on rehabilitation benchmarks, and access to independently verified environmental data to ensure accountability and informed regional planning.
Other (Q10): Local government bears the brunt of poorly regulated large-scale development. We ask the EPA to apply the highest standards of precaution and intergenerational responsibility.
The EPA wants to hear what the Northern Jarrah Forests mean to people, so please include a personal perspective in question 10 on why this issue matters to you.
Flora and Vegetation: The Northern Jarrah Forest is not just trees; it is a layered, interdependent system of fungi, moss, birdsong, leaf litter, and canopy. Alcoa’s proposal would clear over 11,000 hectares of this ecosystem, including areas with old-growth characteristics. Research by Standish et al. (2021) shows that even after decades, rehabilitated jarrah forest lacks the species richness, canopy structure, and ecological functionality of the original. Once the bauxite layer that sustains these forests is removed, full restoration is unlikely—perhaps impossible—within a human lifetime.
These proposals will accelerate climate-related vegetation decline and compound existing threats. Limited baseline surveys mean more conservation-significant flora may be missing from impact assessments. The absence of adequate buffers around Threatened Ecological Communities (TECs), groundwater-dependent ecosystems (GDEs), and key communities breaches conservation best practice. Precautionary buffers of 50–100 m should be applied, and Auditor General recommendations adopted to strengthen protection and accountability.
Alcoa downplays the biodiversity value of vegetation to be cleared, framing impacts as minor and short-term. In reality, mature forest structure takes more than a century to develop, large jarrah trees may never return, and climate change will likely alter forest composition permanently. Rehabilitation cannot fully offset these losses, and cumulative clearing across the NJF makes further removal unjustifiable. Clearing delays ecological maturity, weakens fire resilience, and degrades fauna habitat—potentially forever. No clearing or exploration should occur within 2 km of old-growth forests.
Fauna: The animals that live here don’t just need trees; they need old trees, with hollows and interwoven roots. Quokkas, bandicoots, and cockatoos can’t relocate to a paddock of young saplings. Forests are homes built over centuries, and once lost, the wildlife will perish with it. WA is a world leader in mammal extinction - we must change this statistic by protecting our precious intact environments.
The Proposals would clear 11,458 ha of high-quality, ecologically connected forest, much of it rated “good” to “excellent” habitat and forming part of a continuous network with major conservation reserves. Such large-scale clearing undermines the integrity of the Northern Jarrah Forest, fragmenting ecosystems, reducing connectivity, and eroding the long-term resilience of threatened species. Forest-dependent fauna like the Chuditch and Black Cockatoos rely on large, connected tracts for breeding, foraging, and survival—values that rehabilitation cannot fully restore. Key features such as coarse woody debris and nesting hollows take over a century to form, meaning habitat quality is permanently diminished.
Avoidance measures are limited in scale, lack enforceable conditions, and fail to prevent the loss of irreplaceable forest. The planned removal of over 7,000 ha of high-value Black Cockatoo breeding and feeding habitat, including hundreds of known nesting trees, is incompatible with conservation best practice. Buffers are far below DBCA recommendations, further jeopardising breeding success.
To safeguard the ecological integrity of the Northern Jarrah Forest, the EPA and WA Government must prohibit the clearing of known and suitable nesting trees, reroute infrastructure to avoid high-value habitat, accurately classify species at risk (including listing Baudin’s Black Cockatoo as Critically Endangered), and implement robust, independently monitored avoidance zones.
Terrestrial Environmental Quality: Alcoa excavates to depths of 10 to 15 metres, removing the lateritic bauxite layer and the entire soil profile that took millennia to form. This process disrupts nutrient cycling, soil microbiota, and hydrological balance. According to Tibbett (2010), Restoring mine soils in Australia: a progress report, rehabilitated soils following bauxite mining in WA often remain compacted, nutrient-poor, and structurally unstable for decades. These altered soils are prone to erosion, invasive weed colonisation, and poor native plant establishment. They frequently lack a functioning topsoil horizon, and their microbial and mycorrhizal networks are largely absent. Simplified post-mining vegetation increases the risk of intense and uncontrolled fires due to fuel continuity and absence of understorey diversity. Without full soil profile restoration and ecological complexity, the land remains fragile and vulnerable to long-term degradation.
Inland Waters: Water is life. These forests feed the creeks and dams our communities depend on. Alcoa’s massive water use, and the risk of chemical contamination, threatens more than just bushland. It puts our drinking water and farming land at risk. PFAS and hydrocarbons in the soil don’t stay put and the spills already made by Alcoa will have effects for generations to come.
Air Quality Alcoa admits it has difficulty determining dust levels from its mining operations, yet claims air quality in the Myara North and O’Neil regions is typical of rural areas. Its own data shows the Huntly Mine can produce high dust levels under certain weather conditions, and modelling indicates serious breaches of air quality limits. While Alcoa dismisses these as minor, its own consultants describe them as “major exceedances.” These uncertainties weaken Alcoa’s conclusions and require independent review by qualified experts.
Dust control relies heavily on distance from sources and large-scale water use, rather than reducing emissions at their origin. This approach is unsustainable and less effective in dry or high-traffic conditions. Alcoa’s assertion that its Refinery Air Quality Management Plan is effective is unsupported by evidence, highlighting the need for stronger, proven dust reduction measures.
Alcoa acknowledges dust can harm plants by reducing photosynthesis and growth, yet plays down the risk during dry seasons without robust evidence. It also recognises that water-based dust suppression can damage vegetation but continues to rely on it as the primary method. The potential impacts on animals have not been assessed, despite their known sensitivity. A thorough evaluation of these effects and the development of alternative, long-term dust management strategies are essential.
GHG Emissions: Every tree cut releases stored carbon, and soil disturbance contributes further emissions through oxidation and loss of organic matter. Heavy machinery, including trucks and bulldozers, emit additional greenhouse gases through diesel combustion, while also stirring up toxic dust. Clearing forest canopy also increases land surface temperatures and reduces local humidity, altering microclimates and exacerbating heat stress. In this context, large-scale clearing is not just a physical loss—it initiates a chain of ecological, atmospheric, and health consequences that are difficult to reverse and will contribute to climate instability for generations. Bauxite must be mined in areas already cleared and degraded, and forests must be retained.
Social Surroundings: These forests raised me. I take my children walking here, teach them how to spot insects and orchids. That kind of knowledge is rooted in place. Once the forest is gone, so is the learning.
Changes to forest structure and landform reduce access for traditional, educational, and recreational uses, while loss of canopy and the presence of mining infrastructure diminish the sense of place for communities and visitors. Noise and light from operations can travel for kilometres, affecting surrounding areas.
Forest mining should end by 2028, with any future bauxite extraction focused on previously cleared land. If mining continues, strict measures are essential. MAZs and LDAs for heritage, amenity, and environmental values must be clearly defined in consultation with Noongar people, relevant experts, and government agencies.
The Bibbulmun Track buffer should increase from 200 m to between 1–5 km, and the Balmoral Trail, its extension, and the heritage-listed POW Camp should have at least a 1,000 m avoidance zone to safeguard cultural, recreational, and environmental values. The Dwellingup Discovery Forest, recognised for its environmental, cultural, and heritage significance, should be excluded from the Expansion Proposal.
Rehabilitation (Q7): After 60 years, there is not one signed-off site. That should tell us something. Real rehabilitation in the northern jarrah forests is not currently possible. We need independent monitoring and full transparency. We need to stop forest mining and mine agricultural areas that have already been degraded. No new areas should be approved for mining unless rehabilitation can be proven at a replicable scale. As you and I both know, this is unlikely to be possible whilst the strip mining method continues at scale.
Holistic Assessment (Q8): This isn’t just a mining project—it reflects a broader pattern of land degradation across biodiverse and climate-critical ecosystems. Decades of mining, logging, and clearing have already pushed many of Australia’s native ecosystems beyond ecological tipping points. The Northern Jarrah Forest, identified in the WA Forest Alliance's synthesis and the report A Thousand Cuts (McCrea, 2023), is suffering cumulative losses in canopy cover, biodiversity, soil structure, and hydrological integrity. These impacts are not isolated; they interact with broader climate challenges such as fire, drought, and invasive species. We must move beyond short-term economic metrics and begin valuing long-term ecosystem stability, water security, and public health. Continuing on the current trajectory risks irreversible damage to landscapes that cannot be reassembled once dismantled.
Stakeholder Engagement (Q9): Real engagement means listening, and letting the science and community voices lead. Feedback must be sought from those qualified to independently verify ecosystem health. This includes human health and the increases in disease already evedent in areas surrounding Alcoas works.
Other (Q10): The forests of the Northern Jarrah are living classrooms. Diverse vegetation supports learning across science, culture, and wellbeing. Losing 11,000 hectares means future generations will not experience these landscapes. Rehabilitated areas do not support the same diversity or function.
Nature education relies on presence—of animals, tracks, sounds, cycles. With every hectare lost, so too is an opportunity for connection. Fauna-dependent lessons about interdependence, resilience, and adaptation vanish when landscapes are stripped bare.
We owe it to the next generation to leave more than scars. The EPA has a chance to stand up for the forests that protect our resilience and well-being.
The EPA wants to hear what the Northern Jarrah Forests mean to people, so please include a personal perspective in question 10 on why this issue matters to you.
Flora and Vegetation: Vegetation plays a crucial role in moderating air quality, regulating climate, and filtering contaminants from the environment. The planned clearing of over 11,000 hectares of the Northern Jarrah Forest will significantly reduce canopy cover, understorey complexity, and microhabitat availability. According to Standish et al. (2021), 'Long-term ecological trajectories of post-mining restoration in the jarrah forest', rehabilitation efforts have not achieved functional or compositional recovery. The proposal area includes 29 vegetation complexes, 14 of which are considered to have less than 30% of their pre-European extent remaining—below thresholds of concern under the EPA's own guidance. Several threatened plant communities occur within the proposed mining zones, including unique assemblages of banksia and jarrah-marri forests that are poorly represented in protected areas. The removal of such communities cannot be offset through rehabilitation. The loss of plant diversity and structural layers also reduces essential ecological functions such as erosion control, seed dispersal, and moisture regulation, all of which support human and ecosystem health. Without the intact vegetative matrix, the forest’s ability to provide essential health-protective services such as shade, cooling, and filtration is severely compromised. Vegetation plays a crucial role in moderating air quality, regulating climate, and filtering contaminants from the environment.
Fauna: Habitat loss affects more than threatened species—it undermines ecosystem services that support health. Fauna, particularly species that pollinate, control pests, and cycle nutrients, are vital to human well-being. Their decline can lead to increased disease vectors and ecosystem imbalances. WA’s status as a hotspot for mammal extinction is directly linked to land clearing patterns like those proposed.
Terrestrial Environmental Quality: Alcoa’s removal of deep soils disrupts soil biota essential for nutrient cycling. According to Tibbett (2010), 'Challenges in Ecological Restoration: Lessons from Bauxite Mining in Western Australia', mine-affected soils in WA remain nutrient-poor, compacted, and functionally impaired even after decades. This degradation contributes to dust generation and reduces the natural buffering capacity of the landscape.
Inland Waters: Alcoa’s proposed 17 billion litre annual water use combined with the risk of PFAS and hydrocarbon contamination, presents a direct public health risk. These substances are persistent, bioaccumulative, and potentially carcinogenic. Proximity to Priority 1 drinking water catchments amplifies this concern. Long-term exposure to contaminated water sources can have neurological, endocrine, and developmental impacts.
Air Quality: Diesel combustion and land clearing release PM2.5 and PM10, both linked to respiratory illness, cardiovascular disease, and developmental issues in children. Research by the WHO and Australian environmental health bodies confirms these risks.
Loss of vegetative complexity directly affects natural pollutant filtration and moisture regulation, increasing the vulnerability of surrounding populations to heat and airborne toxins. Adequate assessment of the damage already being caused by the dudts from Alcoa’s works must be completed independently before further mines are approved.
Greenhouse Gases:Greenhouse gas emissions from clearing, haulage, and soil disturbance add to the burden of climate change, which itself presents increasing health threats via extreme heat, food insecurity, and air pollution.
Alcoa’s Proposals are expected to produce more than 1.4 billion t CO₂-e by 2045—almost 2.5 times Australia’s annual emissions and exceeding the savings required to meet the 2030 national target. This scale of impact warrants the EPA rejecting the proposals or applying much stronger conditions.
These estimates depend on rapid forest regrowth offsetting carbon from clearing, despite rehabilitation backlogs and uncertain success. Even by Alcoa’s figures, net-zero from clearing would not occur until 2075–76, excluding wildfire losses. Independent review is essential.
With WA’s emissions already too high to meet Paris Agreement targets, the state will need deeper cuts than others. Approving the proposals would undermine climate science, breach Australia’s commitments, and lock in severe environmental damage.
Social Surroundings: Changes to forest structure and landform reduce opportunities for traditional, educational, and recreational use, while the loss of canopy and the intrusion of mining infrastructure erode the sense of place for communities and visitors. Noise and light from operations can travel for kilometres, disturbing surrounding areas. Public health is closely tied to a healthy environment—the destruction of forests removes places for physical activity, stress reduction, and cultural practice, all of which are proven protective factors against disease.
Forest mining should end by 2028, with future bauxite extraction focused on previously cleared land. If any mining continues, strict safeguards are essential. MAZs and LDAs for heritage, amenity, and environmental values must be clearly defined in consultation with Noongar people, relevant experts, and government agencies.
The buffer between mining or exploration and the Bibbulmun Track should be increased from 200 m to between 1–5 km. The Balmoral Trail, its extension, and the heritage-listed POW Camp should have at least a 1,000 m avoidance zone to protect cultural, recreational, and environmental values. The Dwellingup Discovery Forest, with its high environmental, cultural, and heritage importance, should be excluded from the Expansion Proposal.
Rehabilitation (Q7): No site has yet been signed off. Rehabilitation efforts fail to deliver the ecological services needed for air and water filtration. Without those services, human health suffers. Reports such as Standish et al. (2021) and WA Forest Alliance (2023), 'A Thousand Cuts: Mining and the Decline of the Northern Jarrah Forest' show that previously rehabilitated areas remain biologically simplified, with poor canopy structure, low plant diversity, and minimal ground cover. Many areas are dominated by a few fast-growing species and show little sign of supporting the complex interactions found in native ecosystems. This reduces their capacity to manage erosion, fire spread, and moisture retention. Some rehabilitated sites are prone to weed invasion and exhibit persistent soil instability. Standards must be independently verified and monitored, with long-term ecological outcomes—rather than superficial vegetation targets—at the core of assessment.
Holistic Assessment (Q8): The proposal’s cumulative effects—on air, water, climate, and ecological stability—translate directly into public health burdens. These must be central to the EPA’s assessment.
Stakeholder Engagement (Q9): The public health sector must be engaged in impact assessments. Medical professionals, environmental health researchers, and affected community members must be consulted meaningfully.
Other (Q10): A degraded environment becomes a health crisis. Prevention is the best investment.
The EPA wants to hear what the Northern Jarrah Forests mean to people, so please include a personal perspective in question 10 on why this issue matters to you.
Flora and Vegetation: Forests serve as climate stabilisers, mitigating heat extremes and slowing storm runoff. Removal of vegetation across 11,000+ hectares increases exposure to climate-related risks including fire, drought, and flooding. Post-mining landscapes lack the structural diversity and moisture buffering of intact forests. Species such as Banksia grandis, Macrozamia riedlei, and Dryandra species—key to providing food and habitat for fauna—do not reliably return in post-mining rehabilitation. These species play essential roles in the microclimate stability, and their absence further diminishes landscape resilience.
Fauna: Fauna are not just part of ecology—they are indicators of resilience. Declines in key species weaken ecosystem response to disruption. Recovery is uncertain in fragmented, degraded landscapes. Among the many species under threat from habitat destruction are iconic and ecologically significant birds such as Baudin’s Black Cockatoo, Carnaby’s Cockatoo, and the Red-tailed Black Cockatoo. These species rely on mature jarrah and marri trees for nesting hollows and foraging, both of which are significantly reduced in post-mining landscapes. Marsupials such as the Western Ringtail Possum, Woylie (Brush-tailed Bettong), and Chuditch (Western Quoll) also face declining habitat availability and increased exposure to predation and environmental stress. These losses signal not only ecological imbalance but also long-term declines in biodiversity resilience.
Terrestrial Environmental Quality: Alcoa’s removal of soil profiles weakens land integrity and increases susceptibility to fire spread. According to Tibbett (2010), 'Challenges in Ecological Restoration: Lessons from Bauxite Mining in Western Australia', post-mining soils remain prone to erosion, poor infiltration, and instability. The removal of topsoil and subsoil disrupts microbial communities, reduces organic matter, and compacts the remaining substrate, all of which limit water retention and vegetation re-establishment. These altered landscapes are more flammable, less permeable, and less capable of supporting diverse native flora. As erosion progresses, sedimentation also impacts downstream aquatic ecosystems, compounding the degradation of surrounding environments.
Inland Waters: Reduced vegetation decreases groundwater recharge and elevates runoff contamination. Well-documented and regular chemical spills (hydrocarbons, PFAS) threaten water sources vital to emergency preparedness and long-term resilience.
Air Quality Fire danger is compounded by dry, degraded landscapes and dust generation. Dust accumulation from mining and haulage can reduce visibility, aggravate respiratory conditions, and create secondary ignition risks.
Greenhouse Gases: Alcoa’s Proposals are projected to generate over 1.4 billion t CO₂-e by 2045—almost 2.5 times Australia’s annual emissions and greater than the savings needed to meet the 2030 national target. This scale of impact demands that the EPA either reject the proposals or impose far stronger conditions.
Emissions estimates rely on the assumption that forest regrowth will quickly offset carbon from clearing, despite existing rehabilitation backlogs and uncertainty over success. Even by Alcoa’s figures, net-zero from clearing wouldn’t be reached until 2075–76, not accounting for wildfire losses. Independent verification is essential.
WA’s emissions are already too high to meet Paris Agreement targets, requiring steeper cuts than other states. Approving this proposal would undermine climate science, breach Australia’s international commitments, and lock in severe environmental consequences.
Social Surroundings: Community preparedness relies on natural buffers. Forest loss removes the first line of defence, diminishing the landscape’s natural ability to moderate local temperatures, slow water runoff, and filter air. This leads to increased exposure to heatwaves, water contamination, and poor air quality. In the long term, communities may experience reduced liveability, increased health burdens, and mounting infrastructure costs related to environmental degradation. Forest mining must end by 2028 and be limited to previously cleared areas and regulation and research into the adverse health and enviromental effects of Alcoa’s works must be ramped up.
Rehabilitation (Q7): After more than six decades of mining in the Northern Jarrah Forest, not a single Alcoa rehabilitation site has been formally signed off by regulators. Current rehabilitation fails to restore the ecological services—such as air and water filtration—that underpin both environmental and human health. Research by Standish et al. (2021) and WA Forest Alliance (2023) shows these areas remain biologically simplified, with poor canopy structure, low plant diversity, and minimal ground cover. Many are dominated by a few fast-growing species, offering little of the complex interactions found in native forests, and lacking resilience to erosion, fire spread, and moisture loss.
Soil instability, weed invasion, and compromised nutrient cycling are common, while homogeneous vegetation increases fire risk. Biodiversity return is slow and uncertain, with little evidence of restored fauna habitat. Climate change impacts are not factored into current standards, making rehabilitation an unreliable risk-reduction strategy. Without independent verification, clear accountability, and a focus on long-term ecological outcomes—not superficial vegetation targets—the costs of ecological failure, fire mitigation, and land management will fall on local communities and future ratepayers.
Alcoa must not be allowed to continue forest mining until they have proven rehabilitation sites on a large, replicable scale.
Holistic Assessment (Q8): Risk compounds across systems—fire, water, heat, pollution. These impacts interact and amplify one another: for example, degraded soils contribute to runoff, which pollutes waterways and heightens flood risk; forest loss increases both heat exposure and fire danger; and poor air quality worsens health outcomes already stressed by climate change. The EPA must consider these overlaps holistically and not isolate assessment categories, as a siloed approach underestimates the full scope of environmental and social consequences of the destruction of the northern jarrah forests.
Stakeholder Engagement (Q9): Water contamination is a serious and well-documented risk in Alcoa’s operations. Repeated chemical spills—including hydrocarbons and PFAS—pose a threat to both surface and groundwater systems, particularly those in Priority 1 drinking water catchments. Despite the high stakes for regional water security, the proponent's mitigation and monitoring strategies remain inadequately defined. Ongoing engagement must include independent hydrological experts, health agencies, and community water stewards to ensure transparent assessment of contamination and enforceable safeguards for public water supplies.
Other (Q10): This proposal increases hazard exposure while reducing our capacity to respond. That is not resilience—it’s risk transfer
The EPA wants to hear what the Northern Jarrah Forests mean to people, so please include a personal perspective in question 10 on why this issue matters to you.