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| Mr Geoff Ralphs
Environment Assessment Officer Planning Heritage and Building Division Department of Infrastructure Dear Mr Ralphs, Comments On Draft Assessment Guidelines: EES for VCA’s Port Phillip Channel Deepening Proposal Port Phillip Conservation Council Inc., which is a federation of 15 conservation organizations around Port Phillip, makes the following comments on the above draft guidelines, which also appear on our Web site above. Information on changed boundaries of Port Phillip’s seawater: The heading under Section 4.6, "Hydrodynamics and Coastal Processes" is followed by text that mentions "levels". However that text does not refer to the other most important consequence of the expected increase in maximum volume of seawater in Port Phillip, which is the expected new extent of hitherto unwetted areas of shoreline that would be regularly wetted by sea water if there were an increase in the maximum tide level. The Channels Authority has already provided an estimate for the simple increase of peak tide level (quoted as 10 mm, after an earlier claim of 20 mm). EES guidelines should ensure that an estimate is also explicitly stated for the increase in wetted area, expressed both in absolute units (square metres) and as a percentage intrusion into the existing total area of public foreshore reserves. It is important that the increase in area is also described in relation to where it will be distributed along the coast, as it is surely not expected to be distributed uniformly. The EES guidelines should require that a suitable scale of map should show the increased boundaries of land that will be inundated with sea water, and that should be marked with the actual distance of further penetration inland at its maximum points. The above figures and map depictions could most helpfully relate to a given high percentile value, such as 90% of higher high spring tide occurences. A median, or 50% percentile value, which is all that has been revealed so far, is not sufficiently indicative of the worst that can be expected, which should be revealed. The above figures and map depictions should appear as estimates assuming no erosion of the newly exposed surfaces, and also as estimates of the situation allowing for the likely erosion after one decade, and then after a further, second decade. The land surfaces newly exposed to marine erosion have not had the opportunity to reach the same relatively stable state that the existing exposed surfaces have had, and could well erode quite quickly. The EES should require that an estimate be provided for how long extra wetting by sea water from what we have now will occur each month. As well as the summary data above for Port Phillip as a whole, people in particular areas right around Port Phillip should be provided, as part of the EES data forthcoming, with estimates for each of the various sections of the coast as follows. These should include estimates, based on the shoreline grandients right around the long and valuable Port Phillip coastline, all of which would be subject to change, of
would penetrate and what length of the coastline would be penetrated further inland by more than one metre, and where that coastline affected would be. Water Quality, including Turbidity: A key point the EES must be required to deal with is the projected deterioration in water quality associated with this project. The project involves making channels deeper and then keeping them deeper, as well as increasing spoil area, volume and presumably height. Extra water turbidity can be expected by the deepening operations, the extra spoil left underwater in the Bay at the new or extended spoil ground, as well as the extra annual average spoil removal needed to maintain the extra depth. All of those changes could be expected to produce further deterioration in general sea water quality, and not just increases in turbidity. Turbidity expectations should be described also in terms of reduced light intensities, and spectral redistributions of that light, at all depths. The effect of changes in the nature of the spoil on water quality should be assessed. Increase in Area of Spoil Zones and Shallowing of Port Phillip: Full details should be required of any increases of area and height of accumulation of spoil zones needed. The EES should also reveal any changes in depth above those areas, and the extent to which the nature of the spoil might change from what has occurred to date. Critical Defect in Framing of Entire Proposal: PPCC Inc. believes that there is a critical defect with the whole channel deepening project and the way it is being evaluated. PPCC Inc. considers that the prime question should be one of how the thoughput of goods, freight and containers to and from Victoria and the rest of Australia and the world is to be facilitated further, as that is the policy of the Government. The question should not be directed automatically, and without published examination and public report, to shipping as the predominant means of that facilitation. Historically, shipping well preceded railway movement of goods. The newer railway option, although it quickly extinguished the hitherto dominant riverboat freight system, was set back greatly by monumental government ineptitude in creating different railway gauges between the mainland colonies. Nevertheless, recent expensive national public investment should give Australia a revitalized national standard gauge rail system, which should offer benefits in security, speed of travel, and decentralization. Ports inevitably tie up and degrade a highly limited selection of sites that would otherwise be choice coveted water front land, whereas railyards can be placed on any nondescript uncoveted land. Expanding ports entrench over-centralization and clog up capital cities with dirty, ugly installations that can be better placed, and would often be actually welcome, in more obscure sites. Rail facilities are infinitely better at containing contaminating leaks and spills of liquids than are ports, where the seawater we all use bears the continual brunt of many small and large discharges. PPCC Inc. wants the EES to include reference to studies of the working of a three deep ports option for Australia - Sydney, Fremantle and Darwin. These would be linked by the rapidly evolving national standard gauge rail system not just to capital cities as rigid port systems do, but to present and future inland sites, in a far more responsive way than ports can offer. Shallow-water ports like Melbourne, well away from the ocean, will suffer from a succession of ultimately futile deepening projects as the inexorable economies of ever-deepening-draught container ships take effect. PPCC Inc. notes that the federal environmental authorities invoked their Environment Protection and Biodiversity Conservation Act 1999 in requiring joint Commonwealth-Victorian studies into the deepening proposal. We consider that the heavy involvement in this decision of Victorian MPs and Victorian public servants, and a single-purpose Victorian Government body whose sole raison d'être is the management of shipping channels, should not be allowed to swamp what should be the predominance of a national long-term interest in this decision, but it is unclear how the present process will avoid that happening. Yours sincerely,
Geoffrey Goode, President, Port Phillip Conservation Council
Inc.
cc. Victorian Senators, MHRs, MLCs, MLAs and Municipal Councillors adjoining Port Phillip |