What The EIA Actually Says About Climate Risk

Rated
Extreme.

GHD’s own Climate Risk Scan assigns the highest possible risk rating — EXTREME — to both tropical cyclones and sea level rise at this site. Those risks are not modelled anywhere in the EIA. The comprehensive climate assessment GHD recommends does not exist. This page shows what their own document admits.

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Fiji sits in one of the world’s most climate-vulnerable regions. It faces rising seas, intensifying cyclones, and increasing extreme rainfall. Before a major coastal industrial facility can be approved, the developer must show regulators that the site can withstand these hazards — and that flooding will not turn a stockpile of hazardous ash into an environmental catastrophe.

TNG — the Australian company behind this incinerator — hired GHD to produce a Climate Risk Scan. That scan rates the three hazards most relevant to this coastal site — tropical cyclones, sea level rise, and flooding — as EXTREME or HIGH.

Those ratings are then ignored. In the same EIA package, submitted to the same regulator, the same consulting firm calls sea level rise “negligible” and does not model cyclones at all. The scan itself recommends that a comprehensive climate risk assessment be done. That assessment has not been done. It is not in the EIA.

Here is what GHD’s own document says — and what the rest of the EIA does with those findings.

All quotes below are taken directly from GHD’s Climate Risk Scan (Appendix G to the TNG EIA), prepared for The Next Generation Fiji by GHD Pty Ltd, dated 16 February 2026, and submitted to the Fiji Ministry of Environment and Climate Change as part of the TNG Environmental Impact Assessment, March 2026.
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Eight Critical Failures — One Climate Risk Scan

GHD’s Climate Risk Scan is contradicted, incomplete, and overridden by the very documents submitted alongside it. Each failure below is documented in GHD’s own words. Together, they describe an EIA with no credible assessment of the climate hazards facing this site.

01

GHD Rates Tropical Cyclones as Extreme — The Flood Study Doesn’t Model Them At All

The highest possible risk rating. Applied to the most dangerous weather event this region faces. Then not modelled anywhere.

The Climate Risk Scan’s conclusion (Section 7) is unambiguous. For the site under a very high emissions scenario in 2090:

GHD’s own report says — Section 7:
“Of the six climate hazards assessed, tropical cyclones and sea level rise were assessed as extreme and flood was assessed as high for the site under a very high emissions scenario for the 2090 timeframe.”

Table 17 of the Climate Risk Scan confirms the ratings:

Risk rating table — 2090 SSP5-8.5 scenario:
Tropical cyclones: EXTREME
Flood: HIGH
Sea Level Rise / Coastal Erosion: EXTREME

Now read the Flood Study (Appendix H) — submitted as part of the same EIA:

  • No cyclone scenario modelled
  • No storm surge modelled
  • No sea level rise in the rainfall input
  • One storm event only: the 100-year rainfall event

And the Hydrodynamic Modelling (Appendix K):

  • No cyclone modelled
  • Storm surge “assessed qualitatively” only
  • Sea level rise: “Impact is considered negligible.”
In plain language: GHD’s own risk scan rates the three climate hazards most relevant to this coastal industrial site as extreme or high. GHD’s own flood study and hydrodynamic modelling do not model any of them.
02

GHD Rates Sea Level Rise as Extreme — Then Calls It “Negligible” in the Same EIA

The most direct internal contradiction in the entire EIA. Two documents. Same firm. Same project. Opposite conclusions.

Appendix G rates sea level rise as EXTREME for the 2090 timeframe. That is GHD’s own finding, in the document submitted to the Fiji Government.

Now read Appendix K — the Hydrodynamic Modelling, also GHD, also submitted to the Fiji Government, in the same EIA package:

Appendix K, Table 6.2:
“Projected sea level rise causing marginal increases in water depths at the wharf and causeway. Impact is considered negligible.”

These two findings cannot both be true. The Climate Risk Scan also presents quantified sea level rise projections from NASA data: approximately 63.6 cm rise by 2090 under SSP5-8.5 at the 50th percentile. The Flood Study already documents baseline flooding of 2.44–2.69 mRL across the site in a 100-year rainfall event. Adding 63.6 cm to those figures — which the Flood Study acknowledges is necessary but never calculates — would render the current flood analysis meaningless.

In plain language: The same consulting firm, on the same project, in documents submitted to the same regulator in the same EIA package, concludes that sea level rise is simultaneously an extreme risk and a negligible impact. One of these conclusions is wrong. The EIA does not resolve the contradiction.
03

The Document Is Only a Qualitative Desktop Scan — And Says So Explicitly

Not a climate risk assessment. A preliminary screening exercise. The document states its own limitations clearly.

Section 1.4 of the Climate Risk Scan states its own limitations:

Section 1.4 — Scope and limitations:
“This climate change risk scan plan presents findings from a high-level desktop qualitative review of climate change risk. It considers physical risk only and was not informed by consultation with key stakeholders.”

“High-level desktop qualitative review.” This is a preliminary screening exercise — not a climate risk assessment. It tells the regulator that extreme-rated risks exist. It does not analyse what those risks mean for the facility design, does not model any climate scenario, does not assess whether the facility is adequate to withstand these risks, and does not recommend specific design responses.

In plain language: GHD produced a document that identifies extreme risks and then explicitly states it cannot be used to address those risks. This was submitted as the EIA’s climate risk evidence for a coastal industrial facility on a cyclone-exposed site in the Pacific.
04

GHD’s Own Conclusion Recommends a Comprehensive Assessment — That Assessment Has Not Been Done

The scan tells the regulator that the real climate risk work still needs to happen. It has not happened. It is not in the EIA.

Section 7 — the final conclusion of the document — ends with two recommendations:

GHD’s own conclusion — Section 7:
“It is recommended that a comprehensive climate risk assessment be undertaken during the design phase of the project to ensure that all potential hazards are thoroughly evaluated and appropriate mitigation actions are incorporated.”
“The completion of a more detailed climate risk assessment and adaptation strategy in accordance with AS 5334-2013 Climate Change Adaptation for Settlements and Infrastructure would identify specific climate change risks, control measures and adaptation responses for the project.”

That comprehensive assessment has not been done. No AS 5334-2013 climate risk assessment exists for this project. It is not referenced, summarised, or appended anywhere in the EIA.

In plain language: GHD is telling the regulator, in the document submitted to the regulator: the real climate risk work still needs to happen. The regulator is being asked to approve this project based on a preliminary scan that its own authors say is insufficient.
05

No Climate Risk to Ash Storage, Waste Handling, or Incinerator Operations Is Assessed

The scan covers roads, buildings, and workers. It says nothing about what cyclones do to a coastal stockpile of hazardous ash.

The Climate Risk Scan addresses how climate hazards affect physical infrastructure — roads, buildings, power supply, the workforce. At no point does it assess:

  • What happens to ash storage when a Category 4 cyclone strikes the facility
  • What happens to hazardous fly ash stockpiles during a compound storm surge and rainfall event
  • How increased rainfall frequency and intensity affects ash leachate contamination of the adjacent reef and ocean
  • Whether the ash export plan remains viable if the port is periodically inoperative due to cyclone damage
What GHD’s own documents confirm separately:
Table 8 of the Climate Risk Scan projects a 32.5% increase in extreme precipitation events by 2090. The Flood Study confirms ash stockpiles flood to over one metre in the current 100-year event. The Climate Risk Scan confirms that storm events will become more extreme and more frequent.
In plain language: No document in the EIA connects these three facts. The most dangerous physical output of this incinerator — tens of thousands of tonnes of hazardous ash stored beside the ocean — has no climate risk assessment at all.
06

The Facility’s Operating Life Is Assessed Against Only Two Time Snapshots — Neither Covers the Operating Period

The 2030 snapshot is the start of operations. The 2090 snapshot is 35 years after the facility closes. The operating period itself is not assessed.

The Climate Risk Scan assesses climate risks for two time periods: 2030 (range 2020–2039) and 2090 (range 2080–2099). The facility would operate from approximately 2028 to 2055.

This means:

  • The 2030 snapshot represents the very beginning of the facility’s operating life
  • The 2090 snapshot represents conditions 35 years after the facility is projected to close
  • The facility’s actual operating period — 2028 to 2055 — falls squarely between the two assessed snapshots
In plain language: There is no assessment of the operating period itself. The 25–30 years during which this facility would be burning waste, generating ash, and storing hazardous residue beside the ocean are the years not covered by either snapshot.
07

The Climate Risk Scan Does Not Account for Compound Events

The real existential risk to this facility is not a cyclone alone, or sea level rise alone. It is all three simultaneously, plus storm surge. This is never assessed.

The Climate Risk Scan assesses each hazard separately: cyclones, flooding, sea level rise, drought, temperature, bushfire. It does not assess compound events — the simultaneous occurrence of multiple hazards.

The actual risk scenario that would threaten a coastal ash storage facility is not a cyclone alone, or sea level rise alone, or extreme rainfall alone. It is all three simultaneously, plus storm surge. A Category 4 cyclone making landfall at Vuda Point during a high astronomical tide would produce:

  • Extreme rainfall (rated HIGH individually)
  • Storm surge of 2–4 metres above mean sea level
  • Ocean wave heights far exceeding normal coastal conditions
  • All on top of a baseline sea level that is already rising
What the hydrodynamic modelling confirms:
The Hydrodynamic Modelling (Appendix K) acknowledges storm surge at Lautoka can reach 1.67 metres. The Climate Risk Scan rates cyclones as “extreme.” The Flood Study models a 100-year rainfall event in isolation.
In plain language: No document assesses what happens when all of these occur simultaneously — the actual scenario that would threaten a coastal ash storage facility. Three separate documents cover overlapping hazards in isolation. None of them speak to each other.
08

Extreme Rainfall Projections in the Climate Scan Directly Contradict the Flood Study’s Inputs

By 2090, the 100-year storm event becomes the 4-year event. The Flood Study explicitly excluded this from its calculations.

Table 8 of the Climate Risk Scan projects that extreme precipitation events will increase by 32.5% by 2090 under SSP5-8.5. The document also notes:

Climate Risk Scan — Table 8 and accompanying text:
“Extreme daily rainfall events in Fiji are expected to increase in both frequency and intensity. It is estimated that the current 1 in 20-year daily rainfall events will become more frequent under all future global emissions scenarios. By 2090, these events are anticipated to happen on average every 1 in 9 years under a very low emissions scenario, and as often as once every 4 years under a very high emissions scenario.”

Now read the Flood Study (Appendix H):

Flood Study — on its own rainfall inputs:
The Flood Study used a rainfall input of 588 mm described as being “without the consideration of future climate change allowances.” It explicitly excluded climate change from its rainfall depth.
In plain language: If the 100-year rainfall event becomes the 20-year or 4-year event by 2090, the facility’s flood design — already inadequate because it excludes sea level rise, cyclones, and storm surge — becomes catastrophically inadequate before the facility’s operating life ends. The Climate Risk Scan and the Flood Study are the same EIA. They contradict each other on the most fundamental input.

Three Documents. Three Drafts. Three Different Conclusions.

All three documents were prepared by GHD. All three were submitted in the same EIA package. All three are stamped “draft — must not be relied upon.”

Issue Appendix G
Climate Risk Scan		 Appendix H
Flood Study		 Appendix K
Hydrodynamic Modelling
Tropical cyclone risk EXTREME Not modelled Not modelled
Flooding risk HIGH 100-year event only Not relevant
Sea level rise risk EXTREME Excluded from inputs “Negligible”
Assessment type Qualitative desktop scan Desktop only, no site visits Model calibrated 1 month, 1 location
Document status Draft — must not be relied upon Draft — must not be relied upon Draft — must not be relied upon

“It is recommended that a comprehensive climate risk assessment be undertaken during the design phase of the project to ensure that all potential hazards are thoroughly evaluated and appropriate mitigation actions are incorporated.”

— GHD Pty Ltd, Section 7, Climate Risk Scan. Prepared for The Next Generation Fiji. Submitted to the Fiji Ministry of Environment and Climate Change, March 2026.

GHD wrote this recommendation into the document. TNG filed the document. The comprehensive assessment was never done. It is not in the EIA. The regulator has been given a preliminary screening exercise — which says it must not be relied upon — and asked to treat it as a completed climate risk assessment.

Summary of Failures

What the Climate Risk Scan Does and Does Not Establish

Issue Status
Cyclone risk rated EXTREME — not modelled in Flood Study or Hydrodynamic Modelling
Sea level rise rated EXTREME — called “negligible” in Appendix K
Flooding rated HIGH — only 100-year event modelled, no climate factors
Comprehensive climate risk assessment completed Not done — “recommended” only
AS 5334-2013 assessment completed No
Compound event (cyclone + surge + rain) assessed No — each hazard assessed separately only
Ash storage climate risk assessed Not mentioned anywhere in the Climate Risk Scan
Extreme rainfall projections incorporated into Flood Study No — explicitly excluded
Climate projections cover facility operating period (2028–2055) No — 2030 and 2090 snapshots only
Document status Draft — must not be relied upon
GHD liability Disclaimed in full

One More Thing

Every page of this report carries this warning:

“This document is in draft form and contains information that is confidential and/or proprietary. It must not be relied upon or used in place of appropriate professional advice. GHD reserves the right, at any time, without notice, to modify or retract any part or all of the draft document.”

Cyclone risk rated EXTREME. Sea level rise rated EXTREME. Flood risk rated HIGH. And every page of the document that contains those ratings carries a disclaimer saying it must not be relied upon. This is TNG’s climate risk submission to the Fiji Government. A draft. One that can be modified or retracted at any time, without notice.

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