Part 2 of 2

BLUE WEDGES COALITION

SUBMISSION TO THE

CHANNEL DEEPENING

SUPPLEMENTARY ENVIRONMENTAL EFFECTS STATEMENT

MAY 2007

Chapter 8 (continued)

FISH STOCKS

Economic assessment

The Supplementary Environmental Effects Statement (SEES) required the effects of the Channel Deepening Project (CDP) to consider the impacts of the project on Aquaculture and commercial and recreational fishing, commercial and recreational diving, effects on fish species and protected species including fish, reptiles and marine invertebrates.

The financial benefits of these elements are quantitative and relatively easy to estimate in financial terms. However, the possible short and long term effects of CDP on not only tangible effects; many of the flow on effects of the project are non-tangible and thus extremely difficult to calculate within the constraints of traditional financial assessment.

Many of these non-tangible items include:

• The value of Port Phillip Bay as a recreational amenity.
• The flow on effects of reduced recreational opportunities.
• The effects on general and mental health by the reduction of recreational opportunities such as fishing, diving, swimming and general beach going.
• The short and long term effects on bay related businesses:

1. Fishing Bait and Tackle Retailers.
2. Fishing, Sightseeing and diving charter activities.
3. Water-ski, water toy, dive shops and associated manufacturers and wholesalers.
4. Boating and accessories manufacturers, wholesalers and retailers.
5. General recreational retailing including sun care accessories, clothing, bathing costumes, footwear etc.
6. Hotels, motels, caravan parks and camping grounds.
7. General associated tourism outlets, take away shops, supermarkets, carnivals and attractions.
8. General amenities and their maintenance staff and supplies.

• The loss or heavy reduction in the supply of local seafood and follow on financial effects;
• The reduction in quality of fresh seafood as a community health issue, which will inevitably lead to a greater reliance on imported frozen substitutes of lesser quality.

The scope of the SEES places a high value on the costs and benefits ratio, but fails to rationalize the many long and short term intangible effects, and the value to not only the Victorian economy, but to the general well-being of its citizens and marine environment.

Scallop Industry history relevance

During the 1980’s and early 1990’s various bay user groups expressed considerable concern about a declining condition of Port Phillip Bay as a result of  the commercial scallop industry. Prevailing view until that time had been that the commercial scallop fishery was an important economic industry with minor environmental impacts. The decision to ban commercial scallop dredging in 1994 for the 1995 scallop-harvesting season was a benchmark for the life of Port Phillip Bay.

The condition of Port Phillip Bay today from the recreational and commercial viewpoint is that it is returning to a healthy resource that provides the necessary habitat for our diverse range of marine species, and a range of flow-on benefits to the community.  Many of these benefits cannot be measured in a traditional cost-benefit analysis but are intrinsic to the contribution that the Bay makes to our economy and community.  
Aquaculture, Commercial and Recreational Fishing Industry

The SEES advises²⁹ key residual risks of the CDP to Aquaculture and Fisheries (including protected marine species) are:

• Yarra River and Hobson’s Bay – Physical removal of the seabed and associated food for species such as black bream, and effects of suspended sediments on physiology and survival of larvae of fish species and listed freshwater fish
  
• South of the Bay – reduced visibility from suspended sediments affects migratory behaviour of species such as snapper, pilchards, Australian salmon and gummy shark, and also affects commercial abalone diving. Reduced light from increased suspended sediments impacts seagrass and associated species such as King George whiting and calamari and has a flow on effect upon fisheries
  
• The Entrance – Underwater noise causing lethal or sub-lethal affects on site attached species such as listed syngnathids and rock lobster, or changes to migratory behaviour of species such as snapper, pilchards, Australian salmon and gummy shark and has a flow on effect upon fisheries
  
• Berthworks – underwater noise causing changes to migratory behaviour of species such as listed freshwater fish, eels and black bream.

While it was claimed “These key residual risks had a “moderate” consequence, such that recovery of populations would occur in one to two years, and economic recovery for commercial fishing and aquaculture would occur in two to 10 years, following completion of Project construction” – this doesn’t take into account the significant on-going dredging maintenance, estimated elsewhere in the document at 570,000 cubic metres annually. The effects of maintenance dredging should be accounted for in assessments of risk to these industries.

PirVic consultants³⁰ also confirm the following:

• Blue Mussels: Bivalve molluscs are filter feeders and are dependent on phytoplankton, bacteria and particulate organic matter in the water column for their nutrition. Bivalves are ideally cultured in waters that contain relatively high nutrient levels and can sustain healthy phytoplankton populations.
  Mussels are farmed at Beaumaris, Dromana and Grassy Point with new farms in Kirk Point – Werribee, Mount Martha and Pinnace Channel expected to commence commercial operation in 2007.
  Mussels grown in contaminated areas can concentrate pollutants, particularly bacteria, heavy metals and other toxins and render mussels unsuitable for consumption. The concentration of bacteria, virus particles and toxins due to algal blooms in bivalve molluscs has particularly adverse implications for commercial bivalve culture.
  Victoria’s mussel farming industry is located in Port Phillip Bay and is the major Australian State for production of farmed mussels, with an approximate industry value of $2.8 million (2004/2005 fiscal year.)
  
  
• The abalone aquaculture industry in Victoria produced approximately $4.5 million of product in 2004/05.
  
  
• The commercial wild harvest fin-fishery produced approximately $2.8 million in the 2004/05 financial year
  
  
• Together the aquaculture and fin-fishery produced a total of 1908 tonnes of fresh seafood to the community in 2004/05.
  
  
• At least half of Victoria’s 500,000 marine anglers fish in Port Phillip Bay.
  
  
• Recreational fishing contributed $260 million to the Victorian economy in 2000/01 financial year. Using 5% annual growth as per the proponent’s calculations for the PoM, recreational fishing already contributes $350 million in 2007 and by 2035 will contribute $1.4 billion to the Victorian economy if not impeded in its growth.
  
  
• Of the visitors who had come to the bay in the last twelve months, 451,000 are anglers.³¹
  
  
• The annual worth of the boating industry in Victoria is $1.4 billion³² and recreational and commercial boating and fishing in Port Phillip Bay represent a huge proportion of that figure.

We contend that any increased in risks for these industries as a result of the project is unacceptable.

SEES risk definitions distort risk reality to individuals and individual sectors of the economy. A risk considered “minor” in nature to the SEES may well have the ability to wipe out many bayside businesses, or restrict the breeding seasons of many of our most valuable marine organisms for many years. 

Statements such as “No long term effects on the health of the bay”³³ are irresponsible and misleading, especially when followed by the statement quote “Some flow-on effects to social values and economic uses are expected during the dredging period”

This implies that bayside businesses would be able to suffer downturns in their business for several years (duration of project, and then the proponent’s predicted two years of post dredging impacts) , or even close down, and then magically reappear when the CDP is completed. No studies have been undertaken into how Bay related businesses might be to enduring a downturn of say 20-40% turnover for up to say 4 years. If they cannot survive that- they have lost their business, and its earning potential forever.

The SEES states³⁴  that the Ecologically Sustainable Development (ESD) key principles of the project are:

• Principle integration of economic, social and environmental considerations
• Precautionary principle
• Principle of equity
• Principle of conservation of biological diversity and ecological integrity.

We believe the proposed CDP fails in all aspects in relation to these principles.

The CDP fails to avoid “serious or irreversible damage to the environment” as required by the second element of the precautionary principle, and in fact the SEES documents actually describe what we consider to be the intent to inflict such damage.

Ecosystem drivers

• The SEES states “the fundamental drivers of the ecosystem are the availability of nutrients and light. There are other drivers of aquatic ecosystems such as temperature, salinity and pH, but these are not directly affected by CDP.”³⁵
• It is clear from all sources that nutrient levels will certainly be elevated and that light penetration will be reduced by CDP. The effects of these cannot be understated or underestimated. The possible effects of CDP such as eutrophication, algal blooms and the many other detrimental effects to marine life such as reduction in nursery areas, seagrass meadows, kelp forests, and indeed the health of the bay and its users have been grossly underestimated by the SEES. “Minor” impacts on these items can have truly major effects on the life of the bay.
• Anticipated changes to temperature and salinity have been dismissed by the SEES but they are indeed vital to the ecosystem. We estimate an extra 20 million cubic metres of seawater will flow in and out of Port Phillip Bay, on each tide – a lot of extra water moving four times per day. Although the proponent’s consultants hypothesise that this will have negligible effect, we expect marine life within the bay will be affected. Fishermen well know the effects of temperature changes to fish habits and many actually coincide holidays around the changes of water temperature, which bring in species such as the popular snapper. Minor changes in water temperature can have major effects on the habits of many species.

Similarly, salinity levels are another trigger for fish spawning. Extra flow throughout the Bay will certainly change the salinity levels, especially in times of drought, and will in turn impact on spawning activities.

Water levels and flows in Port Phillip Bay

The SEES states: “The marine biological communities of the bay are influenced by the shape of the bay, its enclosed nature, water movement patterns, its relative shallowness, the predominance of soft seabed over most of its area, the weather cycles, two major inputs of nutrient (the Yarra River and WTP) and the activities of a large human population around and on it.”³⁶

The SEES also concedes that “Dredging also has the potential to influence the marine ecology of the bay”³⁷ Any change in an ecosystem has the potential to render cascading effects throughout its structure.

Changes to the amount of water exchange and water levels in the Bay can have major effects on coastal erosion, underwater structure, coastal shape, sand bank stability, storm surge and wave height, and these changes will affect habitat.

Vital sand banks around the entrance of the bay assist in maintaining tide heights within the Bay to considerably lower excursions than that in Bass Strait. Changes to the water flows and subsequent changes to sand bank and coastal structure is expected to have an adverse effect on the ecology of the bay. A loss of sand banks can lead to losses in seagrass beds, leading to losses in fish sheltering and nursery areas, and so on to the highest predators in the bays food chain including humans. Aside from claiming no long term effects to the ecology of the Bay, the proponent also claims no responsibility for any changes to coastal erosion, communities or infrastructure. 

The SEES admits “Further information on the degree of certainty (e.g. confidence limits) associated with the hydrodynamic modelling and predictions is needed, including in relation to predictions of potential changes in tides, water levels as well as current, waves and other hydrodynamic conditions in affected parts of the bay” , a High degree of uncertainty for modelling currents in the Bay north of the Great Sands area, and a Medium to high level of uncertainly for modelling currents in the Yarra³⁹.

Marine Parks 
 
The Victorian Government declared four protected areas in Port Phillip Bay under the National Parks Act 2002 (Vic). These are Jawbone Marine Sanctuary, Point Cooke Marine sanctuary, Ricketts Point Marine Sanctuary and Port Phillip Heads Marine National Park. In his speech to launch the Marine Parks, Premier Bracks stated that these areas were chosen for their unique marine bio-diversity.

The creation of Marine Parks was controversial at the time however recreational and commercial users of the Bay now feel ownership of these protected areas and see them as important sanctuaries to a great variety of marine life.

We are concerned that these protected areas would be affected by the CDP. Plume modelling of the south of the bay⁴⁰ identifies a large plume within the Port Phillip Heads Marine Park. This poses unacceptable threats to a range of important species including our State marine emblem – the Common Sea Dragon along with many species of marine protected fauna including:

1. 24 species of syngnathids
2. four species of marine invertebrates
3. four species of marine mammals
4. two species of sharks
5. one species of reptile.

Ricketts Point Marine Park is also threatened by a turbid plume of what could be toxic sediment, during a co-incident storm and Yarra Dredging. It would seem that the PoMC should be held accountable for adverse impacts resulting from increased turbidity in our marine protected areas whilst the project is underway.

These are important areas for many recreational pursuits and indeed scientific evaluation, and. It is a criminal offence to intentionally cause harm to these areas and the bays user groups defend them as they would their own homes.

Noise

The effect of noise on the marine life in Port Phillip Bay seems totally understated in the SEES. Anglers well know of the effects of noise in scaring fish! The suggestion that migrating fish such as snapper will simply steer around the noise and plume created by the working dredge is not borne out by years of observation and experience. The noise and vibration caused by the Queen of the Netherlands was felt many kilometres away during the trial. Effects on migrating fish, larvae and fingerlings are given insufficient consideration in relation to longer term fish stocks and effects on the food chain.

The SEES reports “The operating THSD is predicted to generate noise above 145 dB within 200-400 m of the dredge”⁴¹. This is an extremely high noise level and would have a profound effect on any organisms within that range. It is expected that intensity of sound would form a barrier to the movement of fish especially in narrow spaces such as the Yarra River and The Rip.

We reject the assertions that fish will simply steer around the dredger when it is at work. Even if they were able to do this would they be able to reach their breeding ground given the other impediments posed by the dredging program?

Recovery after dredging the Yarra estuary

In some areas existing seabed will be all but removed to the clay sub-surface.

The SEES states:

“Dredging works in the Yarra and Williamstown channels will involve removal of 90% and 5% of the seabed in the lower Yarra and Hobson’s Bay respectively”⁴²

This describes a change in the estuarine environment which could be devastating to marine life.

We note the proponent predicts only short term displacement of fish stocks; “Dredging in the Yarra river will result in the removal of the seabed, which, as discussed in section 12.6.2 is predicted to result in the short term displacement of fish species with recovery expected within one year of project completion”⁴³ it is unclear how or why the previous fish stocks would return to former population levels within one year following such intensive alteration of the habitat.

The project effects do not end with the completion of the CDP. Maintenance dredging to ensure declared depths is ongoing throughout the life of the project – at least to 2035. Consultants admit that it is difficult to estimate future maintenance dredging requirements⁴⁴ but best guess maintenance dredging of 570,000 cubic metres annually. This is a large dredging program in itself, with the Yarra and approach channels alone estimated at 90,000 cubic metres. It seems unlikely then that marine life would return to its current, relatively healthy state with such volumes being removed on a regular basis. We contend that the proponent’s assertion that “The predicted effect on recreational fishing will be short term and localized”⁴⁵ is entirely unsupported by the facts.

Fish stocks and fish size

Snapper

The annual return of the snapper to Port Phillip Bay is a vital resource for the whole Victorian community. Since the elimination of scallop dredging in 1995 the return in the fish stock numbers has been heartening. Population growth has been predictable during the period. Several key issues have emerged:

• We have seen a dramatic rise in fish numbers in the 1.5 – 6 kg range which are generally fish up to 10 years old. The amounts of larger fish that are over 10 years old are negligible as a direct result of many years of poor recruitment in the days of scallop dredging.
• This contrasts with many other southern Australian snapper spawning areas such as the South Australian Gulfs particularly around Whyalla where the fish have not been as dramatically impacted by anthropogenic activities. Snapper over 6 – 8 kg abound in these waters, and older fish in the 10-14 kg range are quite common just as they once were in Port Phillip Bay.
• It is obvious that the effects of the (now relatively minor) scallop dredging in Port Phillip Bay did have a dramatically negative effect on our most precious snapper stocks.
• It is noteworthy that whilst we experienced a terrific rise in the numbers of snapper in our bay over recent years;  the 2005/06 spawning was referred to as a “failed spawn”⁴⁶ It is certainly no coincidence that this failed spawn occurred in the period when the trial dredge was in operation.

An extract from file notes is as follows:

“The day started with some scene setting speeches by Paul Worsteling, Trevor Hogan, Rod Barber and Murray MacDonald. By the time these four guys had spoken, it was very clear that everyone was singing out of the same hymn book. The main points made by these four were that the fishery is in very good condition due to the fishery experiencing strong spawning events in the 1995/96 and 1997/98 summers. Fisheries scientists have also recorded good spawning events for the fishery in recent years which will generate strong year classes in the fishery over the next few years. After this, the fishery is in the hands of nature. There was poor spawning recorded last year, even though there was a lot of fish.”⁴⁷

The trial dredge is heavily implicated in the failed spawn to an entire year class of snapper. PoMC reports that the trial dredge was only 6% of the overall proposed CDP volume. It should be expected that should the entire project proceed, we would not only lose at least two years spawning in the immediate CDP, but ongoing maintenance programs, changes in salinity, water flows, temperature, dredge plumes and suspended contaminants pose ongoing threats to future spawning ground viability.

Even the SEES admits there will be effects to snapper.

“The key effect on snapper is disruption to migration patterns within the bay, and effects on habitat and food supply. The plume, particularly in the south east corner of the bay, is predicted to interfere with snapper migration towards spawning areas off Frankston and Carrum. The plume may also affect the species ability to detect prey.”⁴⁸

It merely remains to properly quantify the extent of damage from the project and its ongoing legacy to the recreational and commercial snapper fishery in Port Phillip Bay should it proceed. The snapper fishery alone is a major recreational pastime generating many millions of dollars in revenue to the State and supports a healthy tourism industry.

Snapper anglers of Port Phillip Bay are a large segment of the population who have traditionally guarded their fishery from negative influence. It is foolhardy to ignore the consequences of any further intrusion into the snapper stocks of Port Phillip Bay.

Concerns for other fisheries

The proposal may also have a devastating effect on targeted commercial and amateur fish species such as anchovies, pilchards, garfish, flounder, snapper, King George Whiting, tailor, bream, snotty trevalla, mullet, trevally, gummy, mako, bronze whaler and school shark, flathead, gurnard, Australian salmon, red mullet, rock cod, ling, pike, barracouta, yellowtail kingfish, mulloway, trout, redfin and other freshwater species all of which are targeted in the area effected by the CDP.  Such widespread risk is not acceptable, and poses huge ramifications for both marine and terrestrial recreational and commercial interests.

We believe the stated risk to commercial fisheries as “low”⁴⁹ is grossly understated, whilst in the same Chapter (12.13.4) it is admitted that there is uncertainty in available data specific to Hobson’s Bay.

Toxic plume and increased suspended sediments dramatically increase the risk of physiological damage to commercial catches particularly shellfish, pilchard, garfish, flathead and anchovy.  

The south of the Bay would also experience adverse impacts on marine assemblages greater than is assessed by the proponents⁵⁰.

These include:

• Increased suspended sediments from the creation of dredging plume causing physiological effects to benthic invertebrates (including seapens).
• Smothering of the sea floor from placement of material affecting benthic invertebrates. Note that the proponent fails to list other marine species of flora and fauna which may be smothered
• Removal of MPB from dredging activities.
• Introduction of marine pests to SE DMG.

Reduced habitat for our second most favourite recreational species and highly valuable commercial species the King George Whiting is also evident⁵¹. The same is true for the increasingly popular Southern Calamari. Reduced habitat is also clearly predicted for many of our most treasured marine species for divers, namely the syngnathids including the Common (Weedy) Sea Dragon.

In fact it is possible that the CDP will interfere with the feeding and breeding behaviour of most marine organisms in Port Phillip Bay – not just in defined dredging areas⁵².

“Most fish species, including some pelagic species, filter feeders and syngnathids depend on vision as their main source of sensory information, and therefore the generation of plumes may affect their ability to find food and perform behaviours associated with breeding, such as schooling.”

It seems however that the SEES considers these facts as a low risk. “the effects on recreational fishing due to disruption of migration have been assessed as low risk”⁵³.  We do not agree, and find this totally unacceptable.

Independent polls of recreational anglers carried out on three separate recreational angling media outlets⁵⁴ returned results of a minimum of 86% of all fishermen DO NOT WANT THE CDP!

Algal Blooms

PIRVic notes⁵⁵ “there is no way of predicting if an algal bloom will occur.  Should an algal bloom occur, there is potential for the bloom to be moved to other areas of the bay by winds or currents …………. Algal blooms may be toxic and species such as mussels may be affected by the toxic algae.”

The potential for toxic algal blooms created by the resuspension of algal cysts is quite clearly identified by the SEES. The use of the precautionary principal must be applied to the CDP because of the risks to marine, terrestrial and especially human health. We consider any increase in risk of algal blooms occurring as an unacceptable risk.

Bund Design and Contaminants

The design of the bund for the containment of toxic material is of particular concern to our fishing membership. Concerns in particular are:

• The design will not protect the contaminated contents from all influences of water movements
• Many marine organisms would still be able to access the contaminated material by burrowing. Many of these organisms are the first vital link in the food chain.
• The clay bund will leach, erode and collapse.
• The proposed capping of soft contaminated silts with heavier coarser sands is predicted to fail in either the short or the long term
• Who will be responsible for the long term management and maintenance of the containment
• What are the cost estimates of such maintenance – why are these estimates not included in the SEES?

Equipment- Hydro hammer

The SEES documents regularly discuss the use of a “hydro hammer”. This item has not been trialled within either the EES or SEES process. We contend that an untested piece of equipment should not be used in a complex ecosystem setting such as Port Phillip Bay.

SPECIES OF CONSERVATION CONCERN

Chapter Five provides a discussion of species of concern as protected by the Flora and Fauna Guarantee Act (1998), the Environmental Protection and Biodiversity Conservation Act 1999 and the IUCN listing

Marine mammals and penguins

Dolphins:
 
The bottlenose dolphin population in the Bay is less than 100 individuals. Bay dolphins have a complex social ecology that can be simplified as large pods of mothers, related mature females and calves that occupy relatively small home ranges; and small groups (usually 2-3 individuals) of males that occupy larger home ranges. Bottlenose dolphin populations are considered to be female-limited, as their ability to breed depends on the number of surviving females in the large local pods.

The Bay is critical to this population because the female groups are almost confined to the Bay and the population appears to be genetically distinct and isolated from other coastal bottlenose dolphin populations elsewhere in Australia⁵⁶.

If female mortality was to rise (or birth rates drop) that would be more significant than general mortality.  Do we want to add Port Phillip Bay’s bottlenose dolphins to the endangered species list?

Penguins: There are two little penguin colonies that depend on the Bay. One is at St Kilda and numbers approximately 1,000 individuals. The other is on Phillip Island and numbers approximately 13,000 breeding pairs.

Approximately 14,500 little penguins were recorded during winter surveys for the EES
(Figure 8.10). This confirmed expectations from previous radio-tracking studies that between 40-70% of breeding birds from the Phillip Island colony winter in the Bay. The highest densities of birds during winter occur across the middle of the Bay with lower, though still significant densities, in Hobson’s Bay, along the eastern shores and from Corio Bay to Werribee River. Winter populations in Hobson’s Bay are significant because this is where all the birds from the St Kilda colony seem to feed.

During summer, little penguin numbers are much lower (~1,300 birds) and their distribution is very different (Figure 8.10). Their foraging range is across the Bay from Werribee River in the northwest to Dromana in the southeast. The highest densities are in the north of this range are thought to comprise mainly birds from the St Kilda colony which do not feed at all in Hobson’s Bay in the summer months. Only a very small number of birds from Phillip Island are present at any one time during this season and from radio tracking studies, these are thought to reside mainly in the southeast corner north of Hovell Pile.

A major threat is posed by the project to little penguins is the impact of dredging on the spawning of their prey species. Due to their small surface to
volume ratio, little penguins have high energy requirements and consume approximately their own body weight in prey every three days. Hobson’s Bay is an area of particular concern all year due to the fact that it is a major spawning area for anchovy in spring and summer.

Dredging in the Yarra and Hobsons Bay during the anchovy spawning season could be disastrous for the St Kilda Penguin colony and also impact on the large numbers of Phillip Island penguins that come to Port Phillip Bay during winter. 

White Shark: Listed as Vulnerable
Act: EPBC listed as threatened species
Protected species under State Fisheries Act and Flora and Fauna Guarantee. Red List Species under International Union for the Conservation of Nature and Natural Resources 2003.
Distribution: Northern & Southern hemisphere, southern Australia
Abundance: Continued decline
Habitat: Rocky reef
Movement: Baywide and Bass Strait

Grey Nurse: Critically endangered
Distribution: sub-tropical to cool temperate waters – Australia all states except Tas.
Abundance: Continued decline
Habitat: Reef, sandy substrate
Movement: Baywide and Bass Strait

School Shark: Red List species under IUCN.
Distribution: Australia occurs from Moreton Bay QLD to Perth WA
Abundance: Continued decline
Habitat: Soft muddy
Movement: Baywide and Bass Strait
Breeding: Spring, summer

Marine Invertebrates
Sea cucumber: Protected species under FFG.
Distribution: Port Phillip Bay
Abundance: Rare
Habitat: Seagrass
Movement: <1km
Breeding: unknown

Southern Hooded shrimp:  Protected species under FFG.
Distribution: Port Phillip Bay and Bridgewater Bay
Abundance: Rare
Habitat: Sandy and muddy substrates, reef
Movement: <1km
Breeding: unknown

Ghost Shrimp: Protected species under FFG.
Distribution: Port Phillip Bay and Western Port Bay (Vic)
Abundance: Rare
Habitat: Fine sand
Movement: <100km
Breeding: unknown

Chiton: Protected species under FFG.
Distribution: Port Phillip Bay and Flinders (Vic)
Abundance: Rare
Habitat: Reef, Sandy substrate
Movement: <100km
Breeding: unknown

Marine Reptiles
Leatherback turtle: Vulnerable.
Act: EPBC Threatened species and marine species. Protected species under FFG. Red List species under IUCN and listed as an endangered species under CITES.
Distribution: In Australia, found in the waters offshore from NSW, Vic, Tas and WA. May migrate between Australia and neighbouring countries.
Abundance: Globally declining
Habitat: Pelagic
Movement: Reproductive migrations from foraging areas to nesting beaches.
Breeding: Dec-Jan

Freshwater Fish
Australian grayling: Vulnerable
Act EPBC: Listed as threatened species. Protected species under FFG. Listed as a Red List Species under the IUCN.
Distribution: Grose River (NSW) to Hopkins River (Vic), Tas. King Island and SA.
Abundance: Common (sporadic)
Habitat: Soft Juveniles probably pelagic, adults freshwater
Movement: Larvae to sea in autumn; juveniles upstream in spring
Breeding: Late summer, autumn

Australian mudfish: Vulnerable.
Act EPBC: Listed as threatened species. Protected species under FFG.
Distribution: Vic, Flinders Island, Tas.
Abundance: Common (localised, less common in Vic)
Habitat: Juveniles probably pelagic, adults freshwater
Movement: Larvae to sea in autumn; juveniles upstream in spring
Breeding: Winter

EPBC Act
Division 4—Listed marine species
Subdivision A—Listing
248 Listed marine species
(1) The Minister must, by instrument published in the Gazette,
establish a list of marine species for the purposes of this Part.
(2) The list, as first established, must contain only the following:
(a) all species in the Family Hydrophiidae (sea-snakes);
(b) all species in the Family Laticaudidae (sea-snakes);
(c) all species in the Family Otariidae (eared seals);
(d) all species in the Family Phocidae (“true” seals);
(e) all species in the Genus Crocodylus (crocodiles);
(f) all species in the Genus Dugong (dugong);
(g) all species in the Family Cheloniidae (marine turtles);
(h) the species Dermochelys coriacea (leatherback turtles);
(i) all species in the Family Syngnathidae (seahorses,
sea-dragons and pipefish);
(j) all species in the Family Solenostomidae (ghost pipefish);
(k) all species in the Class Aves (birds) that occur naturally in
Commonwealth marine areas.


Page 4187 4.2.3.1 Pelagic
Most fish use the water column for spawning. Eggs and sperm are released into the water column where fertilisation and the subsequent development of planktonic eggs and larvae occur. Fish eggs and larvae constitute a recognised component of the planktonic fauna, which are dispersed by currents. These early life stages of fishes are particularly sensitive to changes in water quality …

While some fish species inhabit the pelagic habitat only during their egg and larval stages (e.g. flounder and flathead), other fishes (e.g. pilchards and anchovies) spend their entire lives in this habitat. The pelagic fishes are directly reliant on the pelagic habitat for food … Zooplankton and phytoplankton constitute an important food source for larval, juvenile and adult fin-fish species that use Port Phillip Bay.
…changes to the physical and chemical nature of pelagic habitat (i.e. changes in nutrients, light levels etc) can influence the structure and productivity of the phytoplankton communities and can therefore indirectly alter the availability of food to pelagic fish…

The quality of the pelagic habitat can also affect life stages of fish species not directly reliant on it. Since water links all aquatic habitats within bays and inlets, deterioration in the quality of the pelagic habitat has the potential to fundamentally affect every habitat that fish use. In this sense, the pelagic habitat is critical as either a primary or secondary habitat for fishes in Victoria’s bays …


In numerous studies seagrass have been shown to be an important habitat for many species of fish including commercial and recreational species.
It has been found that fish diversity and fish assemblages is higher in seagrass meadows than in unvegetated areas.


3.3.6 Areas of Conservation Significance
Areas within the northern Port Phillip region that are of conservation significance include:
The Ramsar wetlands sites at Point Cook and Point Wilson
The Ricketts Point Marine Sanctuary, Jawbone (Altona) Marine Sanctuary and Point Cook Marine Sanctuary; and
Seagrass beds

… the introduction of exotic marine species is listed as a threatening process and such species are known to cause substantial environmental impacts. Listed noxious marine species in northern Port Phillip Bay are: the European fan worm Sabella spallanzanii; northern Pacific seastar Asteria amurensis; and Northern Pacific kelp Undaria pinnatifida. Further discussion of these species is outside the scope of this report.

It is difficult to see how the Victorian public can be assured that all relevant information that has been carefully scrutinised, considered and weighted if key experts cannot even discuss the full range of data available and the true impacts?
Perhaps the impact of the project on the species “outside the scope of this report” will suffer the adverse effects that this project tries to hide.


3.5.5 Species of Conservation Significance
Page 1572 SEES Tech Appendices 37-67 pdf
Species and habitats listed under protective legislation or noted for specific conservation measures are:
All fishes of the Syngnathiadae family, including pipefishes, seahorses and sea dragons
Great white shark – Carcharodon carcharias;
Southern bluefin tuna – Thunnus maccoyii
Leatherback turtle – Dermochelys coriacea;
Snapper Shrimp – Athanopsis australis;
Chiton Bassethullia glypta; and
Sea water-mat Lepilaena marina

Weedy sea dragons Phyllopteryz taeniolatus are commonly associated with Amphibolis antartica habitats in the Entrance region of Port Phillip Bay. There are several large A. antartica patches around Nepean Bay and Lonsdale Bay. Phyllopteryz taeniolatus are susceptible to decline and destruction of A. antartica patches.
Further discussions of Phyllopteryz taeniolatus and the above species of conservation significance is outside the scope of this report.

RED ALERT!!!! RED ALERT!!!!

Comment: Again, why are Species of Conservation Significance outside the scope of this report? Alarm bells are ringing.
The Mud Islands support a distinctive community of animals that live in the sand. This is an important habitat for numerous invertebrate species, including small crustaceans and segmented worms. These invertebrates provide an important source of food for many fish and birds. Dense sea grass beds, growing over the sand, and mudflats provide vital breeding, foraging and nursery areas for many fish such as King George Whiting. These sandy soft sediments also provide habitat for scallops, mussels, oysters and many bottom dwelling fish. Many bottom dwelling fish species including yank, sand flathead and snapper also rely on animals that live in the soft sediment habitat for food. All at risk from this major project!
Flounder and other fish flourish in the shallow sandy habitats and a number of shark species use these areas for basking. During summer months, Bronze Whaler Sharks also use the warm waters around Mud Islands as an area in which to give birth to their young.
In addition, the micro fauna of the sands and mud within this and other areas of the bay are important in maintaining water quality within the whole of the Bays waters. The denitrification processes occurring in the soft sediments within the bay are primarily responsible for removing nitrates from the water preventing massive algal blooms..

Threatened and protected Bird Species:

Migratory Waders

Port Phillip Bay renowned for its diversity of migratory wader birds and includes a number of sites listed under a number of treaties to protect migratory bird habitat including International Convention on Wetlands of International Importance (the Ramsar Convention).

Swan Bay is an important site for migratory waders that will be under pressure from dredging, if nothing else it is in direct line with the Heads and is the first point of contact with any turbid plume coming from the Heads, and not as PoMC see it as negligible impact area. In fact, in the PoMC Summary Brochure, the PoMC see the CDP as having no effect or “Negligible Effect” on either the Marine Parks or everything that lives within them.

Orange-bellied Parrots

Like many birds in Tasmania the Orange-bellied Parrot migrates to mainland Australia each year. However, the saltmarshes and dunes where they spend the winter have been cleared and degraded by human activities over the past two hundred years. This degradation is generally thought to have been the main cause of decline in the bird's population.
The Mud Islands component of the Port Phillip Heads Marine National Park is located in the southeastern part of Port Phillip approximately 6 km NE of Portsea. The Mud Islands are an exposed section of the Great Sands, the most extensive sandbank in the Bay, which is continually changing in shape due to storms and sand movement. At an increase of 8mm, predicted by the PoMC, there is solid evidence that these sand islands formed on bird guano has every chance of going under and dissolving due mainly to increased height of wave activity and storm surge! Thus losing one of the few bird breeding habitats where birds are not vulnerable to terrestrial predators and disturbance associated with human visitation.

The Mud Islands are listed as part of the Port Phillip Bay (Western Shoreline) and Bellarine Peninsula Ramsar site as well as being listed on the Register of the National Estate. The fine sand and muddy sediments exposed between tides within the Mud Islands component of the Marine National Park provide excellent habitat for many birds, including endangered and long distance migratory species.

Some 70 species of birds have been recorded on the islands. Vegetation on the low-lying islands consists of saltmarsh and dune shrubland surrounding a sheltered lagoon.

Popes Eye is an important breeding site for Australasian Gannets which nest on the platform and rocks above the water, one of the few known sites where Gannets breed on a human made structure in the world.

Australian Fur Seals are often seen in the area. Because of its unique shape and protection from tidal currents Popes Eye is one of the most accessible snorkelling and dive sites in the Bay with many people learning to SCUBA dive having this site as there first open water dive.

We must not let increased sea levels in the bay and increased currents, that are both predicted from PoMC disturb this most pristine region and it’s amenity for use by the natural world as well as by the numerous Dive companies that use it and enjoy it’s unique qualities. It is an area that is extremely close to the “Heads” and would be prone to increased pressures coming from this area e.g. wave height and currents. Popes Eye has also been the only fully protected marine environment within Port Philip for the last twenty years and as a consequence there are large numbers of animals present, particularly fish.

Threatened and protected Mammals of Port Phillip Bay:

Australian Fur Seals

The seal molts, breeds and rests on rocky platforms, reefs or pebbly beaches. It also utilises artificial structures such as beacons and oil platforms as in Port Phillip Bay.

Although the overall Australian Fur Seal population (around  60 000) is secure, the local Port Phillip Bay population needs to be properly monitored and managed if we are to retain this valuable ecotourism asset.

The public desire to interact with marine mammals has resulted in the development of a billion dollar tourism industry around Australia that includes activities such as humans swimming with free-ranging dolphins and seals. As with Dolphin Eco Tours, studies have been conducted and legislation has been enacted to secure the long term opportunities of both seal and dolphin tourism to be conducted in a humane and beneficial manner.

By having these types of mammals living in the bay, not only does it show a very healthy environment but also gives our universities opportunity to study them up close and understand more of the natural world in which they/us live. As with dolphins they too are apart of a very complex food chain in which we as humans are a part and which is still under investigation by academic scholars.

Yet despite the popularity of the fur seals, the SEES has not addressed the adverse impacts the CDP will have on the Port Phillip Bay community. Check

Threatened and Protected Invertebrates in Port Phillip Bay:

The Mud Islands support a distinctive community of animals that live in the sand. This is an important habitat for numerous invertebrate species, including small crustaceans and segmented worms. These invertebrates provide an important source of food for many fish and birds.

Dense seagrass beds, growing over the sand, and mudflats provide vital breeding, foraging and nursery areas for many fish such as King George Whiting. These sandy soft sediments also provide habitat for scallops, mussels, oysters and many bottom dwelling fish. Many bottom dwelling fish species including yank, sand flathead and snapper also rely on animals that live in the soft sediment habitat for food.

Sea cucumber, chiton and shrimp are quoted by the PoMC as not being “significantly affected” by the dredging. As far as we can see no real investigation or research has gone into the affects on these animals as they are seen as insignificant to the PoMC. What does the PoMC mean when they say “not significantly affected”, what loss do they anticipate? Naturally, any loss of these animals would have an affect due to the link in the food chain without which many of the higher order animals will be “significantly” affected.  

Threatened and Protected Sharks:

The Mud Islands component of the Port Phillip Heads Marine National Park is located in the southeastern part of Port Phillip approximately 6 km NE of Portsea. The Mud Islands are an exposed section of the Great Sands, the most extensive sandbank in the Bay, which is continually changing in shape due to storms and sand movement. Flounder and other fish flourish in the shallow sandy habitats and a number of shark species use these areas for basking.

During summer months, Bronze Whaler Sharks also use the warm waters around Mud Islands as an area in which to give birth to their young. Hammer Head shark and Bronze Whalers have made Mud Islands there home for as long as our history of Melbourne goes back. They are renowned for interacting with and feeding off the various marine mammals living in the bay and move in and out of the bay via the “Heads”. They then complete the food cycle/food chain as being the high order feeders. They also act as the scavengers of the bay and are very useful in this role to retain clarity of the bay.

The Summary Report (p. 28, Table 2) of states that the Grey Nurse Shark (protected under State and Federal Environmental law) has never been reported in Port Phillip Bay. Visitors to Melbourne Museum however can see a set of Grey Nurse Shark jaws labelled as coming from Port Phillip Bay. (refer to appendix 57 of PIRVIC – Primary Industry Research Vic document for further info on grey nurse shark. In main report there’s unverified report to grey nurse sharks in Port Phillip Bay.)

Sea Grass Beds:

The Swan Bay component of the Port Phillip Heads Marine National Park contains the best representative sample of seagrass beds within the park. The importance of Swan Bay as a fish nursery area has long been recognised by Queenscliff fishermen and was protected unofficially for nearly 100 years, before being officially protected under legislation from net fishers in 1970. Forty-four fish species have been recorded in Swan Bay.

Two species (Heterozostera tasmanica, Zostera muelleri) occur here in high densities, their distributions dependent on water depth and exposure at low tide. Heterozostera tasmanica or Eel Grass is the dominant species in the deeper channels but is replaced by Zostera muelleri or Swan Grass in the intertidal areas.

The seagrass habitat acts as an important feeding area and nursery ground for numerous fish species including leather jackets, flounder, King George Whiting, Black Bream, garfish and flathead. In addition, the seagrass habitat is important for black swans, which feed on the seagrass, as well as providing resting and breeding ground for spoonbills, cormorants and egrets. The area is also part of the Port Phillip Bay (Western Shoreline) and Bellarine Peninsula Ramsar site and is used by species listed in international agreements such as the Japan - Australia Migratory Birds Agreement (JAMBA) and the China Australia Migratory Birds Agreement (CAMBA) for the protection of migratory birds. The rare and endangered Orange-Bellied Parrot uses the saltmarshes fringing Swan Bay as a winter refuge and feeding ground.

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