Submission: Channel Deepening SEES DSE Planning Panel 8 Nicholson St Melbourne

Questions for the SEES Panel that could not be answered from the Supplementary EES.

Costs

(A) What is the total cost of the Channel Deepening Project a) best case b) worst case?

What is the annual cost of maintenance after completion of the project over and above channel maintenance over and above existing annual (or annualised) maintenance costs.

What is the likely levy on shipping per standard container/per tonne of weight/other

a) best b) worst case?

(B) What is the value of the potential liability of the Port of Melbourne Authority, contractors and or State Government with and without the Port Facilitation Bill minimum and maximum exposure to claims for compensation following further opening of heads of increased tidal flow and change of currents from:

1)      Waterfront/estuary side property

2)      Beach front infra structure/property public and privately owned

3)      Sewerage/industrial waste water - and from prolonged  turbidity and the loss of seagrass beds from 2 years (PoMC consultants) to 10 years (commercial fishermen based on Geelong arm dredging affect experience) on:

4)      The loss of fish production in a) Recreational Fisheries b) Commercial Fisheries c) Aquaculture

5) Tourism including on beach recreation, yachting and general charter boat operations and diving charter

(C) What is the value of the potential exposure for liability to financial claims through litigation of the Port of Melbourne Authority, its contractors, members of the SEES Panel and/or State Government with and without the Port Facilitation Bill due to the impact of dredging Yarra River is if it generates smells and/or toxins that necessitate evacuation or blue green algal blooms 

1)      From the CBD and businesses along the Lower Yarra

2) the losses to businesses from the cancellation of public events normally staged on the Yarra River e.g. Moomba. - and due to spoilage of toxic spoil during excavation, transport to spoil grounds, at spoil grounds and in the event of the compromise of spoil holding structure of a wide range of toxins that can accumulate in edible marine life from:  

i/ The recreational fishing sector and supporting industries

ii/ The commercial fishing sector and supporting industries

iii/ Tourism operators along the bay including charter fishing and River

iv/ Victorian Tourism operators generally if the bay should become widely known the Port Phillip Bay or its eastern beaches had become contaminated by toxic spoil.

(D) What monitoring will there be of:

a)      stocks of commercial and recreational fish species before and after the projects completion, for how long after completion, and who will undertake the monitoring and how will the data be made available to the public?

b)      b) toxin levels in commercial and recreational fish and molluscan species before, during and after the completion of the project, by whom and how will the results of this testing be made available to the public

(E) What will be the net financial benefit of the project to Victorian consumers as measured by standard/average consumption /expenditure patterns?

Bob McDonald

Yanakie

7/5/07

VICTORIAN NATIONAL PARKS ASSOCIATION INC (VNPA) Submission on the SupplementaryEnvironment Effects Statement for the proposed Channel Deepening project in Port Phillip Bay Prepared by Jenny Barnett May 2007

WHY THIS PROJECT SHOULD NOT GO AHEAD

The Bay is too precious

As outlined in the EES and the SEES, the Bay has a vast array of important values including high biological diversity, complex ecosystems, Marine National Parks and Sanctuaries, internationally listed wetlands and sites of archeological and geomorphological significance. A large number of species in the bay are endemic to the region and most of the Bay’s species are found in the southern half of the bay where extensive dredging and dumping of the material is to take place.  There are threatened species such as sea-horses, snapping shrimp, ghost shrimp, giant seaweeds and unique ‘sponge gardens’ in the Rip. Thirty-three species are known to be ‘of conservation concern’ with much still unknown about the vast majority of species in the Bay. There are seals, dolphins, penguins and occasionally whales.  There are also important uses including a wide range of recreational and tourism activities, fishing industries, aquaculture and other marine-based industries.

The Bay also acts to help de-nitrify the runoff and treated sewage that is discharged into the Bay in large quantities. The sensitive benthic ecosystem is critical in this respect and irreversible damage of its ecosystems has been suggested as a possible outcome.   It is also possible that seagrass losses will be irreversible with long-term impacts on fisheries and the overall ecology of the Bay.   No matter how remote this possibility, it is a chance we should not be taking

The Bay is also of great economic importance for a wide range of reasons including ecological services (such as de-nitrification), fish resources, tourism, recreational and so-on.  The economic value of these, if put at risk, would far exceed claimed economic benefits of the proposal, and are also enjoyed far a far wider range of the general public.

Many impacts are certain or likely

The proposed dredging program is massive on a world scale and long in duration.  As outlined during the 2004 EES hearings it is four times the size of the next largest dredging operation anywhere.  It will affect large areas in the north and south of the Bay.  Port Phillip is the largest enclosed bay in the world, with complex and unique marine ecology.  It is no wonder that assessment of the proposal is complex and the project controversial.

The sheer volume of material to be removed (about 25 million m³ initially and 17 million m³ for maintenance in the next 30 years), and the multiple and difficult to control problems associated with moving it, mean some impact is inevitable.  The SEES admits this but claims such impacts will be ‘short-term’ or ‘limited’ with most impacts lasting only 1-2 years. Where, after 100 years of dredging in the Bay (at a much lesser scale), are the comprehensive studies of the impacts of past dredging that provide the basis for these risk assessments?  The physical change to the Bay will also mean some permanent changes in the Bay’s physical environment which again are described as ‘limited’.

Impacts which particularly concern the VNPA include:

These impacts are outlined below.  To match the layout of the SEES, issues are largely dealt with area by area except where some issues overlap.

Some of these impacts and risks on their own may seem ‘minor’ or ‘medium’ (but see comment on risk analysis below). However, taken in total, and especially if all does not go as predicted, there is a cumulative risk of some serious losses in the medium or long-term, especially if the system is periodically re-disturbed with not-so-small maintenance dredging.

In addition, some possible scenarios such as oil spills and widespread denitrification and algal blooms could result in catastrophic outcomes.  While these may be unlikely, they nonetheless represent a real gamble.

Bias In The Risk Analysis

The risk analysis employed, and the SEES in general, play down the risk to the environment. Different standards and criteria are applied to economic considerations than to the environment and social considerations.  If the shipping industry suffers more than one month’s stoppage this is rated as an ‘extreme’ consequence (p5-54) and as ‘moderate’ when it is for only one week. 

In contrast, for the various aspects of the environment and tourism permanent loss is required to get an extreme rating and effects that last for years are only rated as ‘moderate’.  Over 10 fatalities or major health impacts on over 1000 individuals are required to be assessed as ‘extreme’ while 1 fatality and/or 100 persons suffering major illnesses or injuries is considered ‘moderate’.

YARRA RIVER/HOBSONS BAY

Ninety percent of the river bed in the Yarra for 6 km from the mouth, up to (and including) Appleton Dock, will be removed (3.37 million m3) together with 5% of the seabed in Hobsons Bay (2 million m³).  Impacts will include gross removal of habitat, increased turbidity, re-suspension of contaminants, noise and vibration and possible stimulation of algal blooms.

Recovery of various invertebrate and microscopic biota in the river and seabed will take up to one year, if the SEES is correct in its predictions.  Fish and other fauna dependant on these such as Black Bream will be affected for at least this period.

Seahorses and pipefish

The SEES notes that a number of EPBC protected seahorses, seadragons and pipefish (syngnathids) are found in seagrass and reef algal habitat in Hobsons Bay and some are in the Yarra River estuary (p12-30 – 12-35).  Twenty-four species are found on the wider Bay, however, the SEES main report is vague about numbers of species in each area.  Impacts from turbidity and high noise percussion are dismissed as ‘minor’ on the grounds that the various species are found elsewhere in the Bay or Australia.  Australia has about a third of the world’s syngnathid species with this group being sparse or absent in many other parts of the world.  Protection of our exceptionally diverse fauna is important even if individual species are found elsewhere.

Fish in the Yarra

Estuaries are usually more diverse than rivers. In addition to the above syngnathids, the lower Yarra has records of 32 native species between East Melbourne and the mouth (see table below) including at least 10 species of freshwater fish from further up the Yarra that are diandromous, (species that pass between freshwater to marine/estuarine systems and back, in either direction, as part of their lifecycle).  They include 4 species of gallaxids, one of which is the Mudfish.  There are also five mainly freshwater species that frequent lower stretches, 3 species that frequent both freshwater and estuaries, 8 species confined largely to estuaries, and 6 largely marine species.  These were detailed in one of our earlier submission to the 2004 EES.  But, in spite of our provision of this information, the SEES ignores the overall fish diversity and only considers those fish that are listed as threatened, or are of commercial value.

In spite of this diversity, there has never been a fish survey between Melbourne and the sea save for one day with gill nets (at Spencer St Bridge, Victoria dock, Westgate Bridge, Newport power station) plus one dip net near Newport power station.  In contrast Dights Falls in Kew has been intensely surveyed.  Most lower Yarra fish records are either opportunistic or are very old, dating back to the 19th century.  For those fish with only old records, it should not be concluded they are no longer there, especially smaller non-commercial/recreational fishing species.  For instance, the single dip net survey at Newport in 1989 revealed the only record for the Bridled Goby and only the second record for the Blue-Spot Goby (previously recorded in 1935).

We are disappointed that the SEES has still not conducted base-line surveys for the smaller fish such as the gobies, gudgeons, hardyheads and smelt in the lower Yarra, although at least the invertebrates have now undergone some limited sampling.