Part 2 of 2


The entrance to Port Phillip Bay is acknowledged as one of the most dangerous port entrances in the world. In ‘Guide dogs at Sea’ The Age, Saturday 30th August 2003, Sea Pilot Cpt. Richard Hart states:

“Bass Strait has a reputation worldwide and The Rip is regarded as the worst spot....The tides run very, very strongly through there...With an 8 knot ebb tide, it is impossible to slow a ship. It is particularly treacherous with a sou’westerly wind. The sea just stands up on its end.”

Given the present demands from ship builders/owners and some industry sectors, now is an opportune time to look at alternatives, rather than pursue further modifications to this very difficult port – otherwise we will be faced with similar demands in this and other ports indefinitely.

The observations of Mr. Keith Wilson, a person with many years experience in the shipping industry, and a submitter on Monday 29th November 2004 underlined the futility of our current reactionary response to the shipping industry, when he pointed out that at present thirty (30) ports around the world are facing demands for deepening of their harbours – and will again when the next round of deeper draft vessels are released into the trade.

There are a number of naturally deeper ports north of Victoria, such as Sydney, Brisbane and Darwin. We heard from shipping consultant and submitter Mr. Richard Clarke on Monday 29th November 2004, that the Port of Brisbane has a fifty (50) year planning process underway for the future of the port. Brisbane does not have the natural limitations of Melbourne. One can only wonder how Melbourne can continue to compete as a viable deep water port against these ports – all closer to our trading partners - even in the medium term, and even with (tide limited) access for 14 metre draft vessels. Mr. Clarke confirmed this.

It is of note that the VFLC relies upon the Australian Council for Infrastructure Development (AusCID) to support their position that Channel Deepening must proceed. It is of note however in their submission to the EES Panel Hearing, that AusCID put a concurrent firm view in relation to rail freight that:

“ It is well known that there have been decades of chronic under investment in Australia’s rail system, in particular the interstate rail network and the Sydney urban network.

In 2002 AusCID commissioned National Economics (2002) to undertake a study on the potential for transport infrastructure to contribute to economic growth. That study found that the following interstate rail projects could be readily justified given the returns to these projects were so high, one could conclude these projects should have already been undertaken and completed.
  • Melbourne to Brisbane inland rail link ($1.8 billion)
  • Melbourne to Sydney ($1.3 billion)
  • Sydney to Brisbane ($1.1 billion)....”
These figures contrast with the statement made by Mr. Ray Fehlberg VFLC to the Panel Hearing on Friday 26th November 2004 that the shipping industry receives government subsidies in order to operate.
Notably – the Brisbane Melbourne inland rail link is costed at a figure which approximates the probable FULL cost of the channel deepening project, once on-land infrastructure costs such as Footscray Market re-location, Footscray Road re-location, re-location of services under the Yarra, inevitable cost blow outs etc. are included The Brisbane Melbourne rail project could address the issues of handling the excess volumes of cargo expected in future – which is the only reason we have been offered for the channel deepening project.
The rail project and its ongoing operations would also provide significant employment numbers.
Although not included in the study, presumably because it would not have been completed at that time, the recently completed Alice Springs to Darwin rail link now also makes it an attractive option for the future, with its proximity to our major trading partners.

Other advantages include reduced time for cargo to be on the water by up to 7 days between Darwin and Melbourne, and perhaps 2-3 days Brisbane to Melbourne.  The EES estimates shipping costs per TEU per day – claiming this to be a major consideration for shippers. If rail was able to compete “on a level playing field” – that is, receive equivalent infrastructure funding to that provided to channel deepening, then transport costs could be significantly reduced by some goods being handled by rail from deep water ports such as Darwin or Brisbane, thus significantly reducing the total time and cost spent for goods in transit. 

The NT government website:
reports that Mitsubishi has indicated that a one day reduction in shipping times would save $A100,000 per day per shipment for every day that their cars were not in transit. In other words, if they were able to put a trainload of cars direct from Adelaide to Darwin, and save 6 days at sea, they would save $600,000 – less the cost of 2 days rail.

The reason rail projects such as those strongly recommended by AusCID have not proceeded to date is because of the power of the shipping, oil, steel, rubber and trucking industries – mainly foreign controlled. State based parochialism has also played its part, throwing up projects such as the one before us - Channel Deepening in Port Phillip Bay - which proposes only short term, environmentally destructive and costly responses to a long term National issue.

If the (estimated) billion dollars presently proposed to be spent on channel deepening and associated infrastructure was instead allocated to duplication and upgrading of rail track and provision of “inland terminal ports” for stevedoring purposes, we would have an enduring Nation building solution, rather than a “Patch Up” job until 2030 – as has been tacitly admitted by Minister Batchelor in his recent launch of the Victorian Port Strategic Framework on Friday November 12, 2004 and has recently been confirmed by Deputy Prime Minister Mark Vaile (Mr Vaile is quoted in The Age of May 1, 2007, page 5),  He said freight access into the port was outdated.  A new track will be built to increase traffic and double capacity.  Mr Vaile said 45 trains used the line every day but they could only operate one at a time while other trains needed to stand by waiting for the line to be cleared.  “It is incredibly inefficient, it is Third world infrastructure and not satisfactory in Australia today’”Mr Vaile said.  The new line would allow trains to run in both directions, he said.

What Mr Vaile appears to be unaware of, or not revealing, is that these trains will never be able to be double-stacked with containers because of the restriction at the Bunbury Street Overpass in Footscray.  The Victorian Government has already determined that the lowering of the rail track at that point has been rejected because the cost and inconvenience in the construction phase to the residents would be so horrendous.  This then negates any benefit from re-introducing rail into the Port of Melbourne.

That document and the comments of Mr Vaile acknowledge the limitations of Melbourne as a port and promotes the future development (or destruction) of Westernport.

The Melbourne Port Corporation’s Media Release dated 7th October 2002 ‘Business Development Manager appointed for regional New South Wales’ provides a further note of contradiction and futility.
(Copy available) 

We learn that the PoMC has appointed a Business Development Manager for NSW, based in Wagga Wagga. New appointee Mr. Horwell will be responsible for attracting largely road transport business from regional NSW and Sth. Queensland – thus bypassing rail and the closer, deeper and possibly more efficient ports at Brisbane and Sydney, all in the name of irrational competition.  

When the full environmental costs of shipping are considered - all emission issues, portside land acquisition issues, ocean and water pollution generated by shipping, marine pest invasions etc.  - Rail is the most environmentally friendly transport system, generally facilitating de-centralisation and making use of less environmentally sensitive parcels of land than that required by increasing port developments. (Remember the research of Costanza et al presented by the Blue Wedges Coalition – which estimates the cost of low lying coastal land – which is generally targeted for port development - as THE most valuable on the planet).


The Port of Melbourne provides an interesting case study on which to apply the research of Costanza and others – the PoM cannot expand without further filling in of Hobson’s Bay, ongoing development of coastal land, altering existing infrastructure, removing the fruit and vegetable market, shifting Footscray Rd. further north, lowering services under the Yarra River at massive cost to the taxpayer and the environment – all happening on our Yarra estuary, and all facilitating further congestion and destruction of that important estuarine environment.

My reading of the S-EES has revealed that there is further reduction of the cover over existing services under the Yarra bed and particularly the main trunk sewer, servicing nearly half of Melbourne’s properties.  The actual technical drawing that will reveal the amount of real cover over the sewer pipe is not included in the S-EES and once again the PoMC has procrastinated in producing the technical drawing that consent was based on by Melbourne Water.  This drawing has not been made available to the general public prior to the closing of submissions despite repeated requests.  This is a completely unacceptable behaviour by the PoMC and indicates that they are again wanting to withhold information on this vital issue to the health and welfare of the people of Melbourne and Port Phillip Bay.

The visit to the EES Panel by Phil McAdam and George Beazley, fishermen from the North of the Bay emphasised the importance of that environment – the Yarra estuary and Hobson’s Bay - for much more than its port activities – and for much longer than the 20 or so years that the government is now willing to admit is the capacity of the port and the life of the project.

We have also heard about the unacceptable levels of congestion and pollution in portside suburbs created by present activity levels at the port.  Even if rail is re-introduced into the port, government has only set a target of 30% of port container traffic moved by rail by 2010 – up from the present 10%.  This will have no positive effect when it is acknowledged that container traffic will have doubled by then.  Portside residents will not have gained anything.

The recent VCAT decision in relation to the Hazelwood Power station is notable.  Justice Stuart Morris found that the Terms of Reference set by the Minister were too restrictive and should have included consideration of indirect (Greenhouse) impacts.  I suggest that the same logic applies to this project.  The Terms of Reference have been set inappropriately and should be expanded to include alternatives; financing and land based impacts.


A flow on benefit from port rationalisation in Australia would be the opportunity to make a start on addressing the, to date, intractable problem of introduced marine pests.

In the marine environment, any mechanism that can rapidly transport organisms from shallow coastal waters across natural barriers in the ocean provides a vector for exotic marine organisms to invade new environments.  International shipping provides the most effective vector for marine pest transportation, either via ballast water, on ships hulls or for land based exotic pests, in the cargo or on deck. 

IMO figures estimate between 9,000 to 11,000 organisms are in or attached to every ship.  From on deck, we may be delivered such problem invaders as the Argentine Fire Ant.  The Fire Ant escaped into Brisbane via the port. It has cost up until 2003, $130 million to eradicate without success.  The Australian Government has now estimated the Fire Ant may cost the economy $8 billion over the years1.

There is ample evidence that exotic organisms are already wreaking havoc on the ecosystem of Port Phillip Bay.  The DPI unpublished report cited in The Age December 19-20th 2003 has found that fish stocks in the Bay have been reduced by 40% due to the Northern Pacific Seastar. 

According to the S-EES Port Phillip Bay is considered to be one of the most invaded marine ecosystems in the southern hemisphere (Hewitt et al. 2004).  Most of these introduced species (78 per cent) are thought to have been introduced via hull fouling, with ballast water and aquaculture being the other predominant vectors.  Further introductions are expected as the dominant vectors of introduction and the trading regions are shifting and the diversity of introduced species in Port Phillip Bay indicate that this ecosystem is highly susceptible to invasions (Technical Appendices, Vol. 6, Marine Ecology Existing Conditions – Key Features – 3.2.6 Page 32).

We really need to reduce the volume of shipping in Port Phillip Bay, not increase it, in order to protect the health and diversity of the natural species in the Bay, whereas channel deepening can only exacerbate the problem.

In response to a growing awareness that marine pests can be as environmentally devastating as oil spills, the Marine Environment Protection Committee of the United Nations IMO has introduced voluntary international guidelines to limit the movement of organisms in ballast water. No consideration is given however in the IMO guidelines to hull fouling as a possible import vector.

The increasing size and speed of bulk carriers on international shipping routes makes survivial of various organisms in ballast water even more likely. Transit times for example between Japanese ports and Australia is usually less than 20 days, shorter than the larval cycle for many fish and invertebrate species. A key factor in introduced species being able to establish themselves is likely to be the number of import opportunities (visits by international ships) rather than the volume of ballast discharged. More frequent visits increases the chances that the receiving port conditions will be suitable for the introduced species to survive and become established. Each year over 6,000 different ships visit Australian ports and discharge their ballast water (in a variety of self or non - regulated methods).

If the number of ports to which international ships made their calls was limited and strictly regulated, the costly treatment methods which WILL be required to manage exotic organism transfers from more ships from more ports could be better targeted. More strategic management of our International arrival ports could also better target our quarantine, immigration and national security spending.

Instead we are being told that not only will we have increased ship numbers in the PoM, within 20 years the threat of exotic organism transfers will be fully imposed onto Westernport as well – twice the problem for Victorian taxpayers to manage.


Unimpeded transport of organisms by international shipping has been likened to ecological roulette. Most impacts are slight, but every so often the losses will be devastating. The potential scale of major losses is well illustrated by the following examples:
  • In the USA and Canada, the European Zebra mussel (Dreissena Polymorpha) was accidentally introduced into the Great Lakes system before 1988. It has now spread through most of the waterways in eastern USA. The mussel out competes local species and blocks water intakes for vessels and power stations. Remedial engineering and anti-fouling alone are estimated to cost over $US 1 billion per year2.
  • Note: We had a similar outbreak of the black striped mussel in 3 Darwin harbours in 1999 which required the quarantining of all vessels and chlorinating of all the affected waters which in turn killed all the marine life in those harbours – and cost many millions of taxpayers dollars3.
  • The Comb Jelly (Mnemiopsis leidyi) was introduced into the Black Sea in ballast water before 1987 and now constitutes up to 95% of the biomass of the Black Sea. The collapse of the Black Sea fisheries, worth $250 million per year has been directly attributed to this species2.
  • The 1991 cholera outbreak in Peru. Several million people were infected, more than 10,000 people died. This strain of cholera was quite distinctive, and was traced back to Bangladesh, where sewers feed into harbours. A ship took on ballast in one of these harbours and then disgorged it in ports in Peru. The cholera organisms survived in the ballast water, found their way into shellfish beds, and people who ate the shellfish become infected1. The full environmental, human and economic cost of that appalling incident are unknown – in spite of the vastness of the incident, to my knowledge it attracted very little media attention.

These are issues which the shipping industry do not want to talk about and have no solution for.

(It is noteworthy that some of PP Bay’s aquaculture reserves are near the shipping channels or fairway, ie: Pinnace, Mt. Martha and Dromana.)

Preventing the entry of exotic species (barrier control) is the only effective long term way of eliminating or minimising the risks associated with introduced pest species. There are however no barrier control techniques available anywhere in the world which meet all the requirements set by the IMO of being cost effective, technically feasible, safe and environmentally sound. IMO estimate ballast water invaders alone (hull and cargo transported pests not included) are costing the world’s economies tens of billions of dollars per year.

I support the suggestion put by Dr. Tim Low that a levy should be paid on all global shipping trade to address the environmental and economic losses borne by the communities who receive the unwanted exotic organism cargo which the shipping industry are irresponsibly transferring around the world.

In my opinion, if the real costs of the shipping industry were included in the pricing of cargo carried, a rationalisation of port use would occur, with a corresponding rapid increase in land bridging at a national level. No longer would the champions of the shipping industry be able to claim that they offer the cheapest, ‘greenest’ and most reliable method of moving goods.


Throughout the EES Panel Hearing, we have heard from the PoMC who want to dig deep trenches in the Bay, remove much of the reef at the entrance to the Bay and remove a considerable amount of the Yarra Bed and dump it in the Bay. We have also heard from others, generally interested in smaller vessels, who think it would be a good idea to fill in the Bay, turning water into land – and then call it an “environmental” island.

In my home town of Dromana, one of the last remaining undeveloped creeks entering the Bay on the Southern Peninsula is currently being destroyed so that boats can be brought inland and parked outside somebody’s back door. 95 hectares of farmland is going to be flooded with salt water to create a Marina so that ocean going yachts can sail over land.  Millions of cubic metres of spoil excavated from that land is going to be relocated further upstream of the creek, and dumped on top of it – thereby destroying native fish habitat. The turbidity which has entered the Bay to date as a result of this project has been alarming and the subject of EPA pollution abatement notices, claims and counter claims.

We are seeing thousands of cubic metres of Dromana granite removed from Arthurs Seat and dumped in the Bay at Safety Beach to create the entrance to the “safe harbour” into this monstrosity.

Mornington beaches are now under threat with a Marina development demanded by the Mornington Yacht Club, and Frankston Council is keen to fill in acres of the Bay to create another Marina.  Beaumaris, Brighton, Blairgowrie and Sandringham Yacht Squadrons are all causing extensive and expensive damage to the coastline, and in doing so have severely reduced the public amenity of the areas which they occupy. Any endorsement of further damage to the Bay from these bodies is unwelcome.

On the west side of the Bay, we are currently confronted with Marina proposals at Werribee and Queenscliff.

What all of these examples have in common, including the PoMC’s proposal, is an insatiable appetite for scarce valuable coastal crown land and seabed, which is rightly the property of all of us.  There appears to be no end to this demand for exclusive use of our public space.

What is wrong with the current shape of Port Phillip Bay and its seabed that requires such extensive modification?

I put it to you that there is nothing wrong with the current shape of the coastline and the health of the Bay.  It is us, and these ridiculous proposals which are being thrown up at an unsustainable rate, which are wrong.

A classic example of unbridled coastal development, and exploitation of seabed, is that of San Fransisco Harbour – a once beautiful Bay. Much of the coastline of San Fransisco Bay is now 1.5 Km seaward of the natural coastline – because the citizens were not vigilant in opposing the incremental assault to their coastline.

In its 1995 ‘Living on the Coast’ report, the Commonwealth government identified two recurrent problems which contribute significantly to sustainable management of our coastal zone. These are:
  • Fragmented management arrangements based on issue or sectorial management
  • The ‘tyranny of small decisions’, whereby over time a number of decisions that in themselves are not significant accumulate and interact to result in a significant impact on the coastal zone.
The situation has not improved since 1995, and it must. This project is an outstanding example of a decision based on issue and sectorial interests, which will not benefit the Bay communities – humans and all other species.  There is no convincing evidence that any Australians will benefit at all.

The first day of public submissions heard Queenscliff resident Mr. David Kenwood tell the Panel in some detail how, as an employee of the then Ports and Harbours in the 1980s he assisted in the destruction in the Pinnacles at the entrance to Port Phillip Bay by the use of explosives.  Dead fish were everywhere for the first 5 days of blasting – after 5 days there were no more fish. 

Twenty years later Mr. Kenwood now very much regrets having been involved in that destruction, and now describes himself as a conservationist. He also told the Panel that he feels very protective of that part of the Bay. He walks along the beach nearby every day and enjoys its beauty.

You now have the choice to participate in destruction on a much grander scale - of a beautiful reef area – merely, as Mr. Kenwood did, to cater yet again for the latest design whim of the shipping industry.

If the Panel decides that a much larger attack on that same area can occur, you may in twenty years time, find yourselves in the same position as Mr. Kenwood - very much regretting a decision that could have prevented irreversible destruction to a beautiful area.

I formally advise that I wish to make an oral presentation at  the Enquiry Hearing.

Yours sincerely,
Len Warfe


  [1] Figures from Dr. Tim Low Director of the Invasive Species Council of Australia Radio National interview 6th September 2003 Transcript -Trade and the Environment


  [3] ‘Aquatic Pests: Treat ‘em mean – keep your boat clean’ pamphlet DSE 2004

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