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PORT PHILLIP CONSERVATION COUNCIL INC.
Tel 0395891802, Fax 0395891680 ggd@netspace.net.au A0020093K Victoria www.vicnet.net.au/~phillip
ABN
46 291 176
191
8th December 2004
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Oral
Presentation to the Independent
Panel on the July 2004 Port
Phillip Channel Deepening
Environment Effects Statement by the President of Port Phillip
Conservation Council Inc, Geoffrey Goode Port
Phillip Conservation Council Inc: Port
Phillip
Conservation Council Inc. is
a federation of 16 conservation organizations around Port
Phillip
Conservation Council Inc. was incorporated in 1990. Its present 16 Member
Organizations
are listed on the screen. Some are submitters, giving you local views
in detail,
so my remarks today will be directed mostly to matters that concern all
our
Member Organizations. PPCC
Inc. regards its ethos, as specified in its
constitution, and its
corporate memory, as being of great value to members of successive
Commonwealth and Victorian governments and bayside municipalities.
Those
members, given the short-term focus of their electoral cycles and the
vast
number of their competing responsibilities, tend to be relatively
unaware of
the sad lessons of the Bay’s history, and the need for important
natural assets
to be protected in perpetuity, not just when it is briefly fashionable
or electorally
rewarding. Over the years, many MPs, councillors, and their advisers
have
appreciated and thanked us for our efforts. PPCC
Inc. sees the lack of a strong, clear view or position by both of the
Bay’s governments
on what important natural and environmental values of the Bay must
never be
impaired in peacetime as being a critical weakness in the management of
the
fine asset held in trust that the Bay is. There
have been welcome improvements in State Government environmental
management,
and this Panel process is an example of it, but there has been, apart
from the State
Environment Protection Policy on the Waters of Port Phillip Bay,
and
recent declarations of some small areas as This
large, important natural territory is thus left vulnerable to ad hoc claims for modification or use.
Judgements on whether such uses are allowed are not made in the light
of a
pre-determined and well-settled highest and best long-term use for the
area,
but instead tend to be made very much on the grounds of expediency
within a
time-frame as short as one or two terms of a particular Government. PPCC
has witnessed many major and minor ad hoc
‘development’ proposals for the waterways, seabed and fast-dwindling
areas of
natural coastline of Port Phillip. These developments are usually
portrayed as
much needed stimuli for local businesses or wider economic growth,
however the
result has more often been incremental degradation of public assets,
unproven
economic or social benefits, and failed works often simply abandoned
with no
provision for restoration having been made, but most often a distinct
loss of
public amenity. There have been plenty of examples, such as derelict
piers,
rock walls, groynes, sea baths, causeways, concrete hovercraft pads,
land
filling, and once even, near Point Wilson, whole ships dragged, in
third-world
style, into the shallows for ship-breaking. Conjunction
of Deepening
Proposal and Global Warming Concerns:
The Port of
Melbourne,
with its long approach path to it across Port Phillip, is the
shallowest of
Australia's major ports, and it is also the furthest from the ocean, so
the
issue of successive operations to further deepen its shipping channels,
particularly its entrance, The Rip, has arisen earlier - in previous
decades -
and will arise again in 2030 if this current proposal proceeds. PPCC
Inc. sees
this proposal as shortsighted, and parochial, and believes that a
different and
a national solution is required for an environmental and social issue
confronting In
the 1980s government deliberately chose to limit further deepening of
The Rip,
and to restrict transits of it by deep draught vessels to the higher
part of
the tidal cycle. Imposition
of
Man-made Higher Tide on Increasing Mean Sea Level:
That
predicted minimum mean sea level
rise for one decade of 8 mm approximates the predicted increase in
spring tidal
peaks that the Victorian Government’s channel deepening proposal would
deliberately impose on the region during a 6-week program of rock
removal at
The Rip. How does this action fit with the Victorian Government’s
desire to “... fight global warming on the front foot
and proactively plan ...”? The Hon. John Thwaites, Minister for Sustainability and the Environment, recently confirmed the serious and pressing issue of global warming and sea level rise for the Port Phillip region, in a speech in Frankston in August. Mr Thwaites stated, "The science is absolutely clear, climate change is happening." He said that the CSIRO, "In
relation to saltmarsh communities the predicted tidal changes could
produce a
22 mm increase in tidal range during spring tides. In intertidal zones
with low
gradients, such small tidal range increases can change the frequency of
inundation
over significant areas ... this scale of change can lead to an
adjustment of
corresponding environmental conditions of salinity and waterlogging,
which
could drive a change in corresponding vegetation community zonation ...
Assuming
a gradient of 1% or less, an 8 mm increase in the height of the spring
tide
corresponds to a 0.8 m movement upslope of the high tide. Along 1 km of
shore,
this could amount to a shift in high spring tide level affecting up to
0.8
hectare of saltmarsh ... Unfortunately there is no information on the
topography of saltmarshes around Port Phillip Bay at the level of
accuracy
needed to determine the extent of the impact." The
PPCC
Inc. points out that until such information is examined publicly, and
unless it
can be shown that there will be no impacts on our natural resources,
this
project remains economically questionable and socially and
environmentally
unjustified. There
is much evidence that low-lying coastal areas, mudflats, estuaries etc.
are some
of our most economically productive natural environments. Deliberate
changes to
these ecosystems, even if dismissed in the EES as “small” or
“imperceptible”,
should be recognized for what they really are – deliberate damage to a
valuable
asset – often referred to as folly, or vandalism. Why
knowingly add, to any degree, to the adverse events and risks we will
encounter,
so convincingly outlined by the Government in its consultation paper
“Adapting
to Climate Change – Enhancing Victoria’s Capacity”, and in statements
by its
Minister, the Hon. John Thwaites? Special
case
of The Rip:
Port Phillip
Conservation Council Inc. supports the views put forward in the
submission by Dive Victoria
in which it detailed
the very great beauty and importance of the substantial plant and
animal
communities in The Rip. The EES admits that considerable parts of these
communities would be destroyed if the Channel Deepening proposal were
to
proceed. PPCC
Inc. also shares the concerns expressed in Chapter
5 of the EES about:
We
note that the EES (Sections
A4.2, A4.3, Table 14.3) recommends against:
for
what are very sound reasons. The
former Port Phillip Authority, of which I was a member in the early
1980s,
conducted a study, in response to a resurfacing then of a perennial
notion,
dear to the heart of many a real estate agent, of building islands in
Port
Phillip. The study easily convinced the then Victorian Liberal
government that the
notion was inappropriate, and government policy reflects that. It
should be mentioned in passing that the repeated use of the term, “environmental
island” in the EES, even as just a proposal, demeans the document.
Its use is
disturbingly revealing of a most regrettable attitude in public land
use debate
that one would have hoped would never have been raised in such a
document. Describing
a proposed artificial island – one that does not exist and that cannot
be
experienced until it does, by which time it is too costly to remove it
- as an
“environmental island” has an Orwellian ring to it. It is terminology
more appropriate
to propaganda than an EES. Objective terms such as a “rocky island”, or
even subjective
terms such as a “beautiful island” are credible, but “environmental
island” as
a euphemism for a visible spoil dump, deserves derision. The term is
about as
meaningful a term as a “political island” or a “philosophical island”.
Analyse
the logic of it. What is a non-environmental island? Massive
Smothering and
Shallowing of the Bay Floor by Spoil:
In Chapter
5 the EES has correctly recommended against all the options
entertained
earlier but, as Table 5.6 shows, it is still reduced to recommending
the
deposition, between 2005 and 2030, of the massive quantity of over 43
million
cubic metres of spoil (32 million cubic metres capital, and 11 million
cubic
metres maintenance) at two separate sites in the Bay. Chapter
5 states that the proposal entails a permanent 20% increase in
maintenance
dredging, which is a major disadvantage of the proposal. Table
5.6 in the EES shows that the northern spoil ground would receive
15 million
cubic metres of spoil and the southern ground, which is only 3.5 km
from the Mt
Martha coast, would receive 28 million cubic metres. Fig.
5.8 shows the northern spoil ground extension as covering 3 square
kilometres of bay floor, which would necessitate a layer of added
material 5
metres deep, and it shows the southern spoil ground as covering 7
square
kilometres of bay floor, requiring the layer to be 4 metres deep. That
huge
volume of spoil would cover a total area of over 10 square kilometres
that is
presently part of the natural seabed of Port Phillip. It
might be argued by the proponent that 10 square kilometres is only 0.5%
of the
area of the whole Bay, but that does not undermine the case that 10
square
kilometres is, in absolute terms, a large area of natural environment,
close to
a very large area of already highly urbanized land, where remaining
untouched
natural environment is scarce, and therefore at a premium. It
is nevertheless proposed for 10 square kilometres of the seabed of Most
people have seen and disliked the wastelands created by the tailings
dumps made
by mining. Yet the floor of In
Section
A5.5, Conclusion, it states, “The
marine ecology specialist confirmed that by ensuring that the footprint
of the
south-east DMG was minimized, the initial high risk to local benthic
infauna
would become a moderate residual risk.” This confirms our
expectation that
a large area of spoil ground presents a high risk to benthic infauna,
but it is
hard to regard a spoil area of 7 square kilometres as being
“minimized”. We
note that Sections
A4.2 and A4.3 properly cite smothering of benthic habitat as
arguments
against building islands in the Bay, but they do not use that same
argument
against their less visible counterparts, the seamounts that the two
proposed
new vast spoil grounds represent. Section A.5.2.1 refers to the benefit
of the
land disposal possibility of a significant reduction in smothering, but
then
forcefully, and understandably, argues against the case for that. Many
people find visualizing square kilometres hard. The 7 square kilometres
of
seabed that would be smothered by the proposed new south-east spoil
ground
alone is similar in area to a whole Problem of
Contaminated
Spoil in Northern Areas: The
EES
recognizes that removing spoil from the Bay’s
contaminated northern areas poses risks, but appears rather sanguine
about the
effects in practice. PPCC Inc. notes the conclusion of the EES that
data on
winter effects on the Little Penguin population of the northern area of
the
Bay, and the health of the fish it lives on, has not yet been acquired,
and
that that is necessary before the birds can be considered safe. Seagrass
Communities:
The EES, and
at least one commentator, Dr Graham Harris, the Director of the CSIRO’s
1996
Port Phillip Bay Study, consider that seagrass communities will be
harmed by
the effects of dredging, and that recovery will be slow and not
necessarily
fully assured. Volume
3 Sub-volume 16 of the EES also stated that a doubling in noise
intensities
of the larger ships that the deepening will cater for will add extra
stresses
to fish and other higher organisms in seagrass communities. Time
to
Reconsider
Endless Expansion:
Are the
economics of shipping, which favour
ever-increasing volumes for individual container ships, expected to
lose their
appeal by 2030? Victorians can expect renewed demands for yet deeper
channels,
or a similar assault on Port
Phillip Conservation Council Inc. considers that the Bay is far better
protected by a definite decision to limit its channel depth to the
present
depth, as opposed to the substantial risks of further and
ever-increasing
deepening and greater maintenance dredging. The Bay has already been
altered
enough by the impact of large ships and the provisions made for them,
and the
industry should be content with the concessions that have been made for
it,
rather than provoking increasing opposition to its continual claims for
expansion. Table
5.2 states that, for the volume of cargo expected by 2030, the
number of
ships annually would be 1,814 if the channels were deepened, compared
to 2,210
if they were not. The estimate for the number of ships in 2030 given
deeper
channels would thus be only 18% lower than that given the present
depth, but it
would come at the cost of a permanent 20% increase in the volume
dredged
annually. Those figures are for the same annual volume of cargo for
each
option. From
the decision to build a non-standard rail gauge used nowhere else in As
the environmental effects of deeper channels are enduring, and
cumulative,
Victorians will need to end this practice of ever-increasing
modification of
Port Phillip, and ever-increasing population pressure around it, at
some time.
That time would be better early rather than late. We
propose no reduction in the existing port size, but rather a change of
focus
for the The
approach to transport biased so much more to ocean navigation than to
internal
carriage, to use the terminology of Section
92
of the Constitution, condemns The
present EES perfunctorily dismisses rail as an alternative. It does not
reveal
the comparative costs of moving a container by rail versus moving it by
ship if
the funds for channel deepening and extra maintenance were allocated to
further
improvement of the standard gauge rail system between existing natural
deep
water ports in Sydney, Brisbane, Fremantle and Darwin. *
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