This submission is made on my own behalf.
I have no special interest in any likely outcome of the project.
I do not wish to make an oral presentation at the hearings.


RE THE EXTENT OF THE PROBLEM

The Executive Summary to the SEES says (ES3) that ships of draft above 11.6 m cannot access the Port fully laden – or can do so only with tidal assistance.

It also says “Vessels with draught exceeding 12.1 m cannot enter Port Phillip Bay at all”. This must mis-state the case. Surely such vessels could enter and leave if not fully laden.

The ES makes no reference to the fact that Melbourne is a port at the end of a very long line.  How many ships – even if they could – want to arrive at or leave Melbourne fully-laden?

There seems to be an answer in the SEES (at 6- 28), where we read that  27% of vessels arriving in the year ending June 2006 exceeded 11.6m, but that only 4.7% of these larger vessels required tidal assistance on arrival and only 3.0% of them used the tide on leaving.

I deduce from this that the proportion of vessels that choose to arrive at and/or leave Melbourne fully-laden is about 4%. And I suppose this proportion will continue to 2035.

This puts the idea of unloading goods at other ports and using rail to bring them to Melbourne in perspective. While the suggestion has been mocked (causing one to wonder  why various railway lines – especially the one from Darwin to Adelaide – were ever laid) it makes much more sense if we are talking about doing it for only 4% of all freight.

In fact, the cost of doing it has been built into the SEES calculation of net benefits. The logic chart at 16-6 includes the step of “estimating costs of adapting to limited depth by landbridging top-up cargo or adding second calls to other ports.” So the idea is taken seriously in the SEES itself, and stands or falls with the cost/benefit calculation (discussed below).

Again, if we are thinking as far ahead as 2035, is it really just a black joke to suggest that we might by then see the ice sliding off of Greenland and raising sea levels by an amount that will reduce our debate about channel deepening to an amusing memory of better days? Or to suggest that our desperate efforts to reduce consumption of fossil fuels will see international sea trade shrinking to a fraction of its present volume?

And again, why has there been so little interest shown in the Melbourne invention of a system which reduces the safety tolerances of ships in shallow waterways? On the face of it, this could at least buy us some time to better understand our future options. As well as rewarding an inventive Melbourne enterprise.


RE THE ECONOMIC BENEFIT

The $ figures of cost and benefit in the ES do not represent – as claimed - “a benefit/cost ratio of 3.3”.

A return of $1936m over the next 28 years – most of it to be received in the later years – cannot be simply compared in that manner with an up-front cost of $590 m.

Rather, it represents a return of about 10% simple interest on the $590m – or $60m pa.

Again, does the cost of $590m:

• Take into account the costs of suspending dredging – or alternatively suspending electricity generation at Newport – when the two activities clash?
• take into account the costs of suspending dredging when turbidity levels exceed set standards?
• take into account the costs of “physical protection or decommissioning” of pipelines and conduits for sewage, oil, gas, telecommunications and electricity under the bed of the Yarra? (ES8)
• include costs of rearranging on-shore transport links around the Port of Melbourne?
• include costs of moving the Footscray Market? ($300m+ has been mentioned)
• take any account of likely damages claims by divers, fishers, tourism operators etc?
  (The PoMC claims that these are included – ES23-24. However I note that a Portsea lawyer dismisses the PoMC estimate of $14.6m losses in favour of an estimate of $200m.)

Again who is to bear the costs and who will get the benefits? Given the confusion and vagueness of public statements on this point, it seems to be a fair question.

RE THE SCALE OF DREDGING

The argument is made that we have been dredging the Bay for 150 years – so what's the problem?

And the first point in response is that past dredging has not been harmless – something relevant authorities seem to implicitly accept and reinforce. In April 2005, the State Government threw the book at Mr Dennis More – who had built himself an unauthorised marina which opened on the Bay near Geelong. And the CSIRO's Port Phillip Bay Environmental Study of 1996 included the observation that:

“To protect the biodiversity of the benthos and its key role in ecosystem function, habitat destruction must be reduced to a minimum. The effects of fishing, dredging and coastal engineering on seagrasses and the benthos must be minimized and should be closely monitored. The disposal of dredged spoil must be confined to as small an area as possible.”
(my emphasis).

The Panel should also take note of the observations made by the previous Panel about the sheer scale and intensity of this project. Observing that the proposal was to dredge around 32 million cubic metres over two years - followed by a further 11 million cubic metres to maintain the channel through to the year 2030 - it asked the PoMC for examples of projects elsewhere in the world of a similar scale and nature. The largest the PoMC could come up with involved dredging 11.5 million cubic metres.

That Panel also observed that the job was the equivalent of digging a ditch 4 metres deep and 15 metres wide from Melbourne to Sydney, and that the spoil - if dumped on the Melbourne CBD - would cover it to a depth of eight storeys.

The volumes have been reduced by about 14% in the SEES. So the ditch would now be only 13 metres wide, and the CBD would be buried to only about seven storeys.

The Panel also pointed out that the dredging over two years would be dealing with 30 times the annual average volume of normal dredging with disposal to the Bay.

This intensity is one of the main worries. To even contemplate it is to pour contempt on the  advice of the CSIRO - a body whose expertise is second to none and which, unlike the PoMC, has no vested interest in any particular decision.


RE TOXIC SPOIL

Approximately 2.07 million cubic metres of the spoil will be toxic mud from the bed of the Yarra. It is proposed that this should be moved to a dredged material ground out in the Bay and covered with uncontaminated material.

I understand that the material is relatively safe so long as it remains undisturbed. The problem is the amount of it that will be mobilised - and ingested by fish and eels etc - during the year or so of its excavation and removal and placement and eventual covering.

A letter to the Editor of The Age made what I thought was a rather arresting observation:- that if the author had a one ton truckload of this stuff he would have the greatest difficulty finding anywhere in Victoria where he could legally dump it – on land.

Yet the same government that would prevent him from doing that is proposing to allow the PoMC to dump some two million such truckloads in Port Phillip Bay.

But the PoMC assures us that “contaminant concentrations in the water are not predicted to cause adverse ecological or human health effects.” (ES22)

So I guess that must be alright.


PROPOSED WORK AT THE HEADS

During the trial dredging they removed 27,000 tonnes of rock – causing extensive damage.

They only have another 500,000 tonnes to go.

According to some people who know the heads, may of the loose rocks will continue cannoning around in the strong currents, smashing things and gathering no moss.

And bringing ever larger ships with deeper drafts through the cross-currents in that narrow channel is surely courting eventual disaster.


CONCLUSION

I was one of the UnVictorians who opposed the Grand Prix in Albert Park – an arrangement whereby we pay a foreign billionaire to abuse our parklands at our expense.

And it is just now becoming apparent to all and sundry that we were dead right about that.

I'm afraid this looks like a similar case – except that the consequences for Melbourne are likely to be far worse. It seems to me that we need this project like a self-inflicted hole in the head. I find the alleged benefits profoundly unconvincing and the risks appalling.

I just hope that this time I am wrong.



Colin Smith
St Kilda
4 May 2007

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