*Please acknowledge this submission, and I reserve my right to be heard at the Panel Hearing
Channel Deepening S-EES Name John Willis
Department of Sustainability & Environment
Planning Panels Victoria Address PO Box 125, Patterson Lakes, Vic, 3197
8 Nicholson Street
VIC 3002 Date 4/5/2007Dear Chairperson
Re: Channel Deepening proposal
Firstly, I am furious at the little amount of time allowed for public scrutiny and consultation. The time period allowed for public scrutiny and submissions is totally inadequate for the task of independent analysis. In fact, the process in my opinion is restrictive to proper and fair democratic principles and reeks of bullying! Many members of my family have fought hard to maintain the freedom of democracy in this country, a freedom that in my opinion the Port Of Melbourne Corporation and indeed the current government of the State of Victoria obviously has little or no regard for in this SEES process.
To find out as late as TODAY that the PoMC continues to insult the concerned people of Victoria by after now spending two years and approximately $114 million on the project, that fully funded work is allowed to continue on the SEES by the proponent in the Notice To Mariners No 058(T)-07 describing the further gathering of information to support the SEES. This, in my opinion, is a total disgrace and typical of the flawed and insulting process of the EES and SEES to date.
I wish to state firmly and clearly my directive that I strongly oppose the proposed dredging of Port Phillip Bay as described by the PoMC Channel Deepening Project Supplementary Environmental Effects Statement.
I believe that the proposed project is highly detrimental to the ecology of the entire Port Phillip Bay, not just the species as targeted by amateur anglers.
I also believe that the proponent has not supplied a suitable economic argument to justify such expected damage.
I also believe that there are other suitable alternatives to this project, and that the overall scope of the project has limited any investigation into these alternatives.
The Supplementary EES reveals numerous remaining risks, increased costs and a largely unchanged project design from that so soundly rejected by the 2005 Independent Panel Report. The SEES acknowledges adverse impacts on dive and fishing charter businesses, and that fish stocks might be reduced for at least 2 years from project completion – this must affect linked industries such as boating, tackle and bait supplies, accommodation and tourism. In spite of this, if my or any business were to suffer loss as a result of the project, it would be at my expense to pursue compensation via civil action.
The recent “trial dredge” proved conclusively that the proponents and their contractors are not able to carry out the required dredging program in an acceptable manner, and that we hold the PoMC in disregard for allowing such damage to our Port Phillip Bay.
The means of dredging, transport and disposal are certainly not of an acceptable standard to ensure the health, welfare and safety to the bay, its flora and fauna, its mammals and the humans that rely on it for both recreational and commercial needs.
The scope of the SEES is misleading in that it does not include provision for any follow on costs such as maintenance of the channels, bunds or third party damage. I feel strongly that the PoMC has been using misleading and deceptive conduct in the SEES.
The prospect of dredging, transporting and dumping 3.87 million cubic metres of contaminated sediment into our Port Phillip Bay is preposterous!
The described method of containment in underwater “bunds” is even more preposterous and shows a total lack of understanding of the bay, its water movements and its ecology. If the material is too contaminated for landfall and ocean disposal then it is certainly not suitable for disposal in our bay.
It is my opinion that I would not mind the prospect of paying the infinitesimal amount extra for imported goods to support our bay, especially in the current economic climate where we have an imbalance of trade weighted heavily in favour of cheap imports which are destroying our local manufacturing sector.
I wish to call on the PoMC and indeed the State of Victoria to stop this highly destructive, ill-conceived and illogical project NOW!
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 quantitive 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 are impossible to calculate in dollars and cents assimilation.
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 mental health by the reduction of recreational opportunities such as fishing, diving, swimming and general beach going.
Possible effects to general public health.
The short and long term effects on bay related businesses;
Fishing Bait and Tackle Retailers.
Fishing, Sightseeing and diving charter activities.
Water-ski, water toy, dive shops and associated manufacturers and wholesalers.
Boating and accessories manufacturers, wholesalers and retailers.
General recreational retailing including sun care accessories, clothing, bathing costumes, footwear etc.
Hotels, motels, caravan parks and camping grounds.
General associated tourism outlets, take away shops, supermarkets, carnivals and attractions.
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 and its relevance
In the late 1980’s and early 1990’s bayside user groups were fed up with the devastation of our Port Phillip Bay that was being caused by the commercial scallop industry. The economists and scientists at the time justified the process as an important economic industry with supposedly “minor” environmental impacts. The important decision to ban the process 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 also provides many follow on benefits to the community. These benefits cannot be counted in a profit and loss financial analysis, but must be recognized as an overriding element to the PoMC Channel Deepening Project.
Aquaculture, Commercial and Recreational Fishing Industry
The Executive Summary from the Aquaculture and Fisheries submission No. 77, December 2006 by Gregory P. Jenkins and Lachlan McKinnon published by Primary Industries research, Victoria (PIRVic) for the SEES provides an excellent overview of the size and value of the sector.
Some key points are as follows:
Port Phillip Bay Mussel farming industry returned an approximate value of $2.8 million during the 2004/05 financial 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 and with the rapid growth experienced by the industry during the last five years it would be estimated by Blue Wedges boating and fishing consultants that its current contribution could exceed this by double, if not triple that figure.
Of the visitors who had come to the bay in the last twelve months, 451,000 are anglers. (SKM 2007c, Technical appendix 58)
The annual worth of the boating industry in Victoria is $1.4 billion and recreational and commercial boating and fishing in Port Phillip Bay represent a huge proportion of that figure.
It is MY considered view that the CDP places a huge risk to the marine life of Port Phillip Bay and its flow on activities and amenities. After analysis of the SEES documents the Blue Wedges Coalition considers that the risk of the project is simply unacceptable.
The definitions of the risks are totally misleading. 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. In our analysis of these definitions an analogy of ten fishermen developing cancer and 100 fishermen becoming ill as a direct result of the project is considered a “minor” impact. We think not!
Statements such as quote “No long term effects on the health of the bay” (Main Volume 18-21) 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 will be able to shut the doors for a minimum of a two-year period and they magically reappear when the CDP is completed! Not so!
The SEES quotes in the Main Volume 5.2.3 Application of ESD Principles that the key principles of the project are:
Principle integration of economic, social and environmental considerations
Principle of equity
Principle of conservation of biological diversity and ecological integrity.
It is my opinion that the proposed CDP fails in all aspects in relation to these principles.
In particular I believe that 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 the Blue Wedges consider the intent to inflict such damage.
Trial Dredge and Rockfall
The “trial dredge” displayed such intentional and irresponsible damage to our unique marine environment. There is no doubt that the trial exceeded the requirements of the PoMC’s own EMP, and the delay in stopping the project when it exceeded its own Key Point Indicators (KPI’s) showed a wilful intent to inflict damage to our marine habitat at all costs. The PoMC’s original public statement declared a “minor” rockfall incident of less than 20 cubic metres over the 20 metre KPI. It was discovered by independent analysis that the rockfall at this point far exceeded the original declaration by the PoMC, and is in fact approximately 6,000 cubic metres. The immediate damage to the “Rip”, the “Canyons” and the sponge gardens, and the ensuing damage by the loose rubble in this sensitive environment are inexcusable and not acceptable to the whole bay user community.
The removal of complete marine habitat at the Nepean Bank and the ensuing rockfall into the Canyons is totally unacceptable. The further risk of mobilized rock precluding the regrowth only enhances the problem. There is simply no acceptable argument put forward by the entire project that justifies the damage to this world class marine environment. Any further damage to this environment I would consider unjustified, particularly for the pitiful economic benefit touted by the PoMC.
The vast amount of misinformation such as this has made it very hard indeed to gain any measure of trust in any of the presentations of the PoMC, and this /SEES document is no exception.
The SEES document has identified 3.87 million cubic metres of contaminated sediment (Table 7.2 Main Volume) from the Yarra River to be disposed into Port Phillip Bay. The Blue Wedges maintain that this material should be left exactly where it is! This contaminated material is only exposed to minimal disruption and dispersal into the main body of water by natural flow, limited wash from shipping and maintenance dredging to current levels.
I wish to express grave doubts about the proposed dredging, transport, dumping and containment processes and believe that the methods described in the SEES will have a major negative effect on the entire ecosystem.
Some of the doubts are as follows:
Removal of virtually all the sedimentary layer to the lower contaminated clay subsurface will alter the entire nature of the ecosystem.
The ensuing contaminated plume will certainly have a major negative effect on all of the marine life in the Yarra River and its surrounds
The contaminated plume modelling has only been carried out via computer modelling and is calculated with flow rates in times of drought. Aerial photographs of the top end of Port Phillip Bay during peak flow rates of the Yarra River (see attachment 1) certainly prove a much less localized toxic plume than displayed in the SEES. (Figure 10.4 main volume). It is insulting to any experienced fisherman to suggest that Yarra plumes will be contained and disperse in Hobson’s Bay and not be carried into the entire Port Phillip Bay ecosystem. This is particularly true of many of the bays most popular beaches from St. Kilda to Beaumaris where the old Yarra river bed is very close to shore. Prevailing westerly winds will certainly wash this contaminated plume into bayside swimming beaches, popular inshore fishing grounds and the Ricketts Point Marine Park.
The plume modelling is just that – computer modelling. Even though it was a requirement of the EES to test proposed equipment in the full range of operating conditions the Queen of the Netherlands never operated anywhere near the contaminated material in the Yarra River. All results in the SEES are therefore inconclusive, theoretical and unproven.
The Environmental Protection Authority has already issued warnings to the public warning of the risks involved with eating fish from the Yarra River. The SEES plume modelling certainly proves that those levels will rise considerably with the inclusion of the resuspension of sediments with the proposed CDP. This will obviously result in a much higher level of residual contaminants throughout the entire spectrum of marine life, and raises very important, unanswered questions regarding the public health issues for bay users, particularly fishermen and swimmers.
It states within the SEES that shellfish contamination modelling has been excluded due to regulation excluding amateurs from harvesting the various species. This is simply untrue and negligent. Shellfish including mussels, abalone and scallops may be collected from water deeper than the intertidal zone (2 metres) from the high tide mark. (Size, catch and species regulations apply. See page 23 Victorian Fishing Guide) The public consumption of contaminated shellfish is a major health consideration, particularly with the possibility of shellfish paralysis and heavy metal poisoning. Many people consume these shellfish on a regular basis.
Shellfish aquaculture is an important and growing industry in Port Phillip Bay which supports 140 jobs (SEES Technical Appendix 60, p10) The Victorian Department of Primary Industries report identified “risks associated with the release of nutrients and contaminants” as one of the greatest risks to this industry. The SEES Public Health Report in Technical Appendix 60 failed to consider shellfish as a public health issue.
The SEES fails to report on the presence of dioxins. Dioxins are of particular interest to both recreational and commercial fishers due to the recent closure of Sydney Harbour to all commercial fishing and recommendations that the public don’t eat any fish from the Sydney Harbour region.
It is totally flippant and irresponsible to make public statements in light of these facts such as “The potential impacts of dredging these materials on human health have been investigated. No significant concerns were identified for recreational swimmers or consumers of fish caught in the lower reaches of the Yarra River”
An unacceptable degree of uncertainty is highlighted in the SEES Public Health Report. In particular the researchers did not know:
- Who eats what fish
- Which fish species were eaten, nor which parts of the fish were eaten
- Important information in following the toxicants through the food chain to humans such as:
Site specific data about the sediments, water movements, fish movements and fish fat contents
Site specific biota-sediment accumulation factors (BSAF’s). These are values derived from the experiments and are important in calculating how much of the toxins will end up in animal tissue. The authors highlight that site-specific BSAF’s were not available for Port Phillip Bay (SEES Technical Appendix 60 p42)
Item 8.7 of the Main volume 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.”
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 plumes 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. I estimate an extra 20 million cubic metres of seawater will flow in and out of Port Phillip Bay, generally four times per day on each tide. This will certainly have an effect on marine life within the bay that migrates to its warmer waters to spawn. 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 have a negative effect on spawning activities.
Section 8.7.2 of the Main Volume supplies a very good overview of “Primary Production and Food Web” and section 9 provides a very good overview of the species of Port Phillip Bay. A simple read of these pages certainly describes the interaction within the species and the ability of detrimental cause and effect within the ecosystem.
Relatively small changes to any part of the ecosystem have a pronounced ability to affect the entire food chain. It is with this understanding of the entire network that the hazards of the CDP are too great to allow the CDP to proceed further. The knowledge of cause and effect is blatantly obvious and the risk too high for a minimal financial return. I would consider it criminal negligence for the CDP to proceed with its stated knowledge as demonstrated in the SEES.
Water levels and flows in PPB
- Item 9.2 of the Main Volume 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.”
These biological communities are also very much influenced by the water flows throughout the bay and relatively small changes in structure can have long lasting effect. A change in the amount of water exchange in the Bay can also have major effects on many items such as coastal erosion, underwater structure, coastal shape, sand bank stability, storm surge and wave height etc
When directly related to the marine and terrestrial inhabitants these changes may well cause huge changes in habitat as admitted in the SEES under item 9.2 “Dredging also has the potential to influence the marine ecology of the bay”
The structure of vital sand banks around the entrance of the bay, both inside and out keep the higher water levels of Bass Straight from allowing the Bay to rise to outside levels. The Blue Wedges believes that the possible changes to the water flows and subsequent changes to sand bank and coastal structure is expected to have a most adverse effect to the ecology of the bay. A loss of sand banks, can lead to losses in seagrass beds, which in turn lead to losses in fish sheltering and nursery areas, and so the food chain goes on to reach the highest predators in the bay’s food chain including humans. The SEES investigations do not adequately guarantee to the people of Victoria that the changes in structure of the Bay due to CDP are minimal, and in fact there seems to be no real responsibility, or contingency, or ongoing management plan for the ensuing changes which may well have extreme negative effects.
The SEES admits in Section 6.1 of the Main Volume that “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.”
It is further evidenced to note a “Medium to High” degree of level of uncertainty expressed in the table in the Main Volume 10-14.
- 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.
The issue was highly divisive at the time of proposal, however all recreational and commercial users of the Bay now feel a certain ownership of these protected areas and see them as important sanctuaries to a great variety of marine life.
I believe that all of these protected areas will be affected by the CDP. The plume modelling of the south of the bay ( Figure 10-20, 21) clearly identifies a large amount of plume and ensuing sediment in the Port Phillip Heads Marine Park. This is simply not acceptable! The risks to the entire marine ecosystem in these areas are critical. We might add that this is also the habitat of our State’s unique marine emblem – the Weedy Sea Dragon along with many species of marine protected fauna including:
- 24 species of syngnathids
- four species of marine invertebrates
- four species of marine mammals
- two species of sharks
- one species of reptile.
Ricketts Point Marine Park also has the potential to succumb to massive toxic plume in periods of high flow from the Yarra River. I consider the PoMC has the knowledge for such potential from the EES and subsequent SEES and will hold the PoMC and its officers responsible for any subsequent damage.
These are important areas for many recreational pursuits and indeed scientific evaluation, and were originally chosen for their unique marine bio-diversity (refer Premier Bracks speech at the opening). It is a criminal offence to intentionally cause harm to these areas and the bay’s user groups defend them as they would their own homes.
- 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 inference that the migrating fish such as snapper will simply steer around the noise and plume created by the working dredge is ludicrous.
The noise and vibration caused by the Queen of the Netherlands was felt many miles away during the trial. In fact from my own personal experience, I experienced the thunder like rumblings of the working dredge from inside a private residence at Dromana when the dredge was working at the Hovell Pile. This is a distance of some 9 kilometres!
According to the SEES (Main Volume item 12.5.2) “The operating THSD is predicted to generate noise above 145 dB within 200-400 m of the dredge. (CMST 2006, Technical Appendix 64)" It must be noted that these noise levels are huge and certainly will have a profound effect on any marine (and terrestrial) life in the area. This sound will form a barrier to the movement of fish when working in narrow spaces such as the Yarra River and “The Rip” area.
Given that fish and marine mammals are particularly sensitive to sound we completely reject any assertions made regarding the fish being unaffected as they can simply steer around the noise of the dredger at work. Can they still steer themselves to their feeding or breeding grounds? Another unanswered question.
Recovery after dredging the Yarra estuary
- Item 12.9.2 Impact Assessment (Reduced fish population affects recreational fishing) quote “ 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”
This is impossible to predict! This is a complete removal of the existing seabed to the clay subsurface. (See Item 12.4.2 Main Volume which 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”) This describes a total change in the estuary environment and the effects are devastating to all marine life. This proposal completely changes the habitat and has the potential to completely change the ecological composition for the long term.
The inference that the affected species will recover within one year of completion of the project is totally misleading. The project does not end with the completion of the CDP. The continued dredging is ongoing throughout the life of the port to maintain the deeper draft that will be gained by the CDP. The effect on all marine life is that it is therefore never going to be given the opportunity to return to its current, relatively healthy state. The declaration of item 12.9.4 that “The predicted effect on recreational fishing will be short term and localized” is therefore a complete falsity.
- It is clearly identified that the CDP will have a detrimental effect on protected marine species such Australian Grayling and Australian Mudfish as well as to a number of protected marine mammals, seabirds, Syngnathids etc, for many of whom we still lack a complete understanding of their migration schedules, requirements and methods. Of particular concern are the effects on penguins, dolphins, snapper and seals by the predicted losses of pilchard and anchovy biomass due to CDP.
Snapper and fish size
- The annual return of the snapper to Port Phillip Bay is a vital resource for the whole Victorian community. Thankfully, since the elimination of the scallop dredges in 1995 the return in the fish stock numbers has been heartening. The growth has been predictable during the period and the effects of early dredging still lingering
- 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 is a stark contrast 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. Snapper over 6 – 8 kg abound in these waters, and in fact older fish in the 10-14 kg range are quite common just as they once were in Port Phillip Bay.
- It is therefore blatantly obvious that the effects of any dredging in our Port Phillip Bay do have a dramatically negative effect on our most precious snapper stocks. It is interesting to note that whilst we have experienced a terrific rise in the numbers of snapper in our bay over recent years that the 2005/06 spawning was referred to as a “failed spawn” by Paul Hamer from PIRVic at the recent snapper forum. (Frankston 30/11/06) and again on radio station 3SER 97.7FM Fishing Show on 4/5/07. It is certainly no coincidence that this failed spawn occurred in the period when the trial dredge was in operation.
An extract from the 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.” (www.reelaction.com.au/snapper discussion_paper.pdf)
The trial dredge was only a minor part of the entire operation and has already caused a failed spawn to an entire year class of snapper. This is simply not acceptable. The trial dredge is quoted by PoMC to have been only 6% of the overall CDP. It must therefore be expected that we will not only lose at least two years spawning in the immediate CDP, but the overall effects of ongoing maintenance programs, changes in salinity, water flows, temperature, dredge plumes, suspended contaminates and spawning ground structure are untold by the SEES.
Quote Item 13.8 Main Volume:
“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.”
The threatened effect of the CDP is catastrophic to the recreational and commercial snapper fishery in Port Phillip Bay. This fishery is a major recreational pastime that generates many millions of dollars in revenue to the State, but also supplies a tourism destination keeping our money within our State.
The proposed dredging methods will certainly 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. This is simply not acceptable, and poses huge ramifications for both marine and terrestrial recreational and commercial interests.
The management regimes under the Fisheries Act 1995 (Vic) (Fisheries Act) “ which provides a legislative framework for the regulation, management and conservation of Victorian Fisheries including aquatic habitat” (Main Volume 5-16) are simply not suitably considered or enforced.
The human value of the recreational benefits of our Port Phillip Bay snapper fishery is unquantifiable in dollars and cents, and certainly cannot be lightly dismissed as attempted in the SEES with statements such as “The consequence of this predicted effect considered to be minor” (Main Volume 12.6.2, PIRVic2006a, Technical Appendix 57)
It must also be realized that the 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.
Table 12.13 lists the risk factor for commercial fishing as ‘low”. In my opinion this is a gross underestimation of the risk factor. Item 12.13.4 admits 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.
Table 13.5 Main Volume lists predicted effects and risk events which may occur as a result of CDP in Project Area 3 South of the Bay. 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 – fails to list other marine species of flaura and fauna which may be smothered.)
- Removal of MPB from dredging activities.
- Introduction of marine pests to SE DMG.
Table 13.9 clearly predicts reduced habitat for our second most favorite recreational species, and highly valuable commercial species, the King George Whiting. The same is true for the increasingly popular Southern Calamari. Reduced habitat is also clearly predicted for many of our most treasured visual marine species for divers, namely the syngnathids including the Weedy Sea Dragon.
These factors are clear recognition of the cause and affects of CDP that I consider as unacceptable.
The smothering of seabeds will effect our entire marine habitat as shown clearly by the SEES dredging plume diagrams. The inshore areas in particular are of great social importance to Victoria for all bay users. The decline in quality of these areas as described by the SEES is unacceptable.
Item 13-75 Main Volume clearly demonstrates that the CDP will interfere with the feeding and breeding behaviour of most marine organisms in Port Phillip Bay – not just in defined dredging areas.
Quote: “Most fish species, including some pelagic species, filter feeders and syngathids 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 that the SEES consider these facts as a “low risk”. I consider this interference with feeding ability to be “inevitable” and totally unacceptable.
Overall it is stated that the SEES considers “the effects on recreational fishing due to disruption of migration have been assessed as low risk. (SKM 2007a, Technical Appendix 59).
I totally refute these claims as underestimated, uninformed and totally misguided.
Independent polls of recreational anglers carried out on three separate recreational angling media outlets (Fishnet, 97.7 3 SER and 94.7 Pulse FM) returned results of a minimum of 86% of all fishermen DO NOT WANT THE CDP!
- Quote PIRVic 2006b, Technical Appendix 43 “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 principle must be applied to the CDP because of the risks to marine, terrestrial and especially human health. I personally consider the inevitable algal blooms as totally unacceptable risk. The proponents clearly have identified cause and effect and will be held accountable should the project proceed and toxic algal blooms occur.
Bund Design and Contaminants
- The designs for the bunds for the containment of toxic material are simply ludicrous. I have no confidence in the construction of underwater bunds, or their ability to contain contaminated material. The design and construction of these bunds are temporary in nature and certainly will not secure the material from contaminating the whole marine environment in either the short or long term.
It is certainly worrying that such a preposterous method of containment even be suggested. It shows a complete lack of understanding about water movements in the bay. Many marine organisms will 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 sides of the bund will undoubtedly leach, erode and collapse. The idea of capping with heavy materials over the soft Yarra silt is farcical.
The impact of the inevitable breakdown of these bunds is tumultuous. It is not revealed who will be responsible for the long term management and maintenance of the containment, nor are estimates for the costs of such maintenance included in the scope of this SEES.
The fact remains that the contaminated material is too toxic for terrestrial disposal and similarly for disposal in Bass Strait. It is my hard and fast opinion that it is certainly not then acceptable for disposal into Port Phillip Bay.
Equipment- Hydro hammer
The SEES documents regularly discuss the use of a “hydro hammer”. This mythical being has never been tested by the SEES or EES and hence cannot be considered as a tool for the CDP. Highly modified and untested equipment should not be used by any contractor in the CDP.
Similarly, the trial dredge was the PoMC and Boskalis’ chance to prove that they can undertake the project with the proposed machinery. The damage that was caused is well documented and the contractor’s inability to work within the guidelines of the EMP are definitive proof that the project cannot be suitably undertaken without huge, unacceptable risk factors to both our marine environment, public amenity and health.
There are unsuitable strains placed on marine and terrestrial flaura and fauna, particularly the strains placed on recreational and commercial target species. The effects on protected wildlife and Marine Protected Areas are and unacceptable and perhaps outside lawful boundaries.
Public opinion is clearly against the CDP and the majority of the public would not mind paying the miniscule cost to individual consumer’s difference in transport costs to save one of our nation’s most precious marine environments, its users and its residents.
The terminology used in the SEES to understate risk is a disgraceful attempt to disguise the huge potential for extremely negative outcomes as a result of CDP.
The response period to the SEES is simply inadequate, unfair, and certainly shuns the spirit of our Australian Democratic Society.
My submission has been made in haste due to the insufficient time allowed for proper scrutiny and investigation. Should clarification of any detail, or indeed any further contact be required I would be pleased to offer my contact telephone number of 0407053484.
On closing, I ask all persons reviewing this SEES to consider the long term human effects that this proposal inflicts. The risks are certainly not worth the pittance in anticipated economic gain.
The value of Port Phillip Bay cannot be expressed in sheer economic terms, neither can its recreational value be traded or destroyed at the whim of the PoMC.
There has been a huge effort by many, myself included, to restore the Bay to its current terrific condition. This proposal will destroy all of that effort in a very short time frame.
I appeal to the human nature of the decision makers in this process.
LEAVE OUR BAY ALONE! SAY NO CHANNEL DEEPENING!