Source document: https://docs-lawep.s3.us-east-2.amazonaws.com/1697640151188.pdf (Australia)
Science inadequate to prove industrial emissions on the Burrup Peninsula will not damage rock art Dr John Black AM FTSE FAIAST - February 2013  Formation and maintenance of the rock surface patina (desert varnish) is crucial to preservation of the unique rock art on the Burrup Peninsula.

The rock art is up to 30,000 years old and contains the oldest known representation of the human face.
The million plus piece rock art 'gallery' on the Burrup Peninsula is a depiction of continuous human cultural and environmental change over 30,000 years from before the last ice age.

There is nothing like it anywhere else in the world.

 The science conducted to date is inadequate to prove that emissions from industry currently located and planned for the Burrup Peninsula will not damage the rock art.
The Burrup Rock Art Monitoring Management Committee was established in 2002 to conduct scientific studies to investigate the effects of industrial emissions on Burrup rock art.

Summary of Study Reports1 from the Committee concludes “There are no known impact assessment criteria for the impact of air quality to rocks of the type that exist on the Burrup and that contain rock art.” Nowhere in the reports does it state that emissions from industry will not adversely affect rock art.
However, industry and government submissions2 make claims such as "... it is unlikely that the relatively small quantities of NO2 and NH3 that would be emitted from the TANPF (Technical Ammonium Nitrate Production Facility) would have a significant impact on rock art in the surrounding areas."
Thorough analysis of the scientific studies conducted show that these claims cannot be justified, particularly when no consideration has been given to the release of small particles of ammonium nitrate into the atmosphere.

 The 2007 CSIRO3 study concludes that desert varnish is formed by precipitation of dissolved trace metal components from dust particles in fog and rain.
The study concludes that the elevated level of 24 different airborne pollutants from industrial development "will play a vital role in predicting outcomes for the rock art on the Burrup Peninsula".

This statement appears to have been ignored by industry and government.
 A study by Dr Ian MacLeod from the Western Australian Maritime Museum4 showed that mobilisation of metallic ions on the surfaces of rocks from the Burrup Peninsula increased Environment Protection and Biodiversity Conservation Amendment (Standing) Bill 2015Submission 36 - Attachment 1 with acidity.

Nitrate ions increased both acidity and microbial activity on the rock surfaces.
Microbiological activity, particularly bacteria, yeasts, moulds and fungi of the type found on rocks from the Burrup are known to damage rapidly the surface of rocks.

A comparison of rocks on the Burrup Peninsula in 2003 and 2004 with rocks held at the museum and collected from the Burrup before industrial development showed a significant increase in surface acidity.
This change in acidity was observed when industrial pollution was relatively low and before the fertiliser plant producing ammonia and urea was present.

The recently approved TANPF, which will be constructed in the first half of 2013 within 1.6 km of significant rock art, is to release into the atmosphere 25.2 tonnes/year of ammonium nitrate particles with a diameter of around 10 micrometers.

The potential damage to the rock art patina from these emissions may be considerable.
 The CSIRO3 2007 study examined the effect on colour and mineral structure of concentrated solvents (benzene, toluene, xylene), acids and alkalis (nitric acid, sulphuric acid and ammonia) individually in vials at room temperature and at 50ºC.

The material used in these studies was iron ore (largely hematite) and not rock surface with desert varnish.

Thus, the study has no relevance to preservation of rock art.
However, this study showed that sulphuric acid, which is formed from the sulphur emissions from ships burning high sulphur fuels, significantly changed the colour and composition of iron ore.  The CSIRO3 study also involved fumigation of rock fragments with mixtures of gaseous pollutants for cyclic 1 hour periods under harsh conditions of humidity and temperature.

The studies continued for only 30 days.


The highest concentrations of NO2 and NH3 used in the experiments were 50 ppb and 40 ppb, respectively.

These concentrations were assumed to be ten times greater than estimated future industrial emissions on the Burrup Peninsula.

However, predicted2 cumulative concentrations from all approved industry are 62.6 ppb and 77 ppb for NO2 when the TANPF is operating under normal and upset conditions.
Thus, the CSIRO study did not cover the concentrations likely to occur on the Burrup Peninsula in areas where rock art is located.

 A further major limitation to the CSIRO3 study is that statistical information is not presented.

There are large variations in the values for the same treatments with no indication of variation between measurements.

This evidence suggests that there were insufficient measurements made to determine whether there were significant differences between treatments.
Conclusions from the study suggesting no significant effect of treatments on rock colour are therefore dubious.

 Further properly designed scientific studies must be undertaken to prove which levels of emissions from industry will affect rock art.

This research must be properly designed and undertaken before more approvals are provided by government for industrial development on the Burrup Peninsula 1SKM 2009.
Burrup Rock Art Monitoring Program – Summary of Study Reports: A report to the Burrup Rock Art Monitoring Management Committee.

2Technical Ammonium Nitrate Production Facility, Burrup Peninsula.

Burrup Nitrates Pty Ltd. Environmental Protection Authority.

Perth, Western Australia.

Report 1379.

January 2011.

3C4CSIRO 2007: Field studies of rock art appearance – Final Report: Fumigation & dust deposition – Progress Report: Colour change & Spectral mineralogy.
4I.D.MacLeod 2005: Effect of moisture, micronutrient supply and microbiological activity on the surface pH of rocks in the Burrup Peninsula.

Environment Protection and Biodiversity Conservation Amendment (Standing) Bill 2015Submission 36 - Attachment 1 Environment Protection and Biodiversity Conservation Amendment (Standing) Bill 2015Submission 36 - Attachment 1