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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 Bay that have membership
open to members of the general public. It was formed
as an unincorporated body in 1970 in response to a
commercially-based surprise thrust by a consortium
of oil companies to lay a 600 mm diameter crude oil
pipeline across Port Phillip, from Brighton to Williamstown, under
the main shipping channel. That thrust, not
initially opposed by the then Victorian Government,
was eventually rejected after the risks to the Bay
were well publicized by PPCC and others.
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.
Port Phillip Bay: Its
history, as the site of Australia’s largest 19th Century
metropolis, and what is still its second-largest,
has led to Port Phillip not being predominantly a
protected natural area, but it is, at 1900 km2,
one of the largest single parcels of cohesive Crown
territory in Victoria.
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 Marine National Parks and Sanctuaries, very
few other declarations of enduring protection.
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 Victoria in the 21st Century.
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. Melbourne now faces a proposal to
reverse that approach that relies purely on the
purported need for larger container vessels carrying
larger volumes of cargo to enter the Port of Melbourne. This inconsistency in
approach is made more anomalous by the great
expansion in world knowledge about future global
warming, sea level rise and coastal erosion since
then.
Imposition of
Man-made Higher Tide on Increasing Mean Sea Level: The Victorian Government
has just released its consultation paper “Adapting
to Climate Change – Enhancing Victoria’s Capacity”,
and related local area information booklets
including the booklet “Climate Change
in Port Phillip and Westernport”. That paper
outlines some of the challenges for our society,
such as the increasing pressure on coastal
infrastructure resulting from sea-level rise.
The booklet on Port Phillip states that:
- Winds are likely to intensify in
coastal regions of Victoria, particularly in
winter as a result of more intense low pressure
systems.
- Sea level rise of 70 to 550 mm by
2070 (8 to 80 mm per decade).
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,
Australia’s pre-eminent scientific
research organization, confirms that the Port
Phillip region will experience temperature increases
of 1-5 ºC by 2070, significant rise in mean sea
levels, more frequent storms and increased run off,
all of which will affect the way we live. Despite
that, we see a proposal that acknowledges, in
Chapter 28 of the EES,
an 8 mm, i.e.1.6%, increase in each spring high tide
peak. It will occur for only 0.3% of each month, but
that will cause permanent salinity of the land
affected. The increase will be additive to the
steadily increasing mean sea level in the Bay caused
by global warming.
Mr Brett Lane of Ecological Research
and Management, in his report in the current EES,
notes a number of specific and important changes to
Port Phillip including an increase in the tidal
upper water mark at each high spring tide of up to
10 mm. He also notes:
"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 Port of Melbourne Corporation has not
provided accurate information about the extent and
topography of other low-lying land around Port Phillip Bay, and offers
no predictions of how much coastal land, including
beaches, estuaries and saltmarshes, could be
impacted by the direct effects of increased tide
heights as outlined by Mr Lane.
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:
- rock material loosened by
channel deepening and made liable to roll about by
the strong tidal currents in The Rip, thus
damaging plant and animal communities there, and
- the risk of large
congregations of certain animals in one place,
e.g. spider crabs, representing a great majority
of their numbers, being eradicated by works in
one incident.
Rejection of ersatz islands,
and other such destinations for spoil, is
welcomed:
We note that the EES (Sections
A4.2, A4.3, Table 14.3) recommends against:
- a spoil ground 3 km from the
Ricketts Point Marine Sanctuary, and
- all the other alternatives to
using the proposed two spoil areas,
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 Port Phillip Bay to be drastically
modified by smothering it many metres deep in spoil.
Imagine the public disquiet created by a proposal to
cover any other part of the territory of Victoria as large as 10 square
kilometres with a minimum thickness of 4 metres of
sandy or muddy spoil. Imagine it being accepted in
Gippsland, or the Wimmera or the Western District.
Most people have seen and disliked the
wastelands created by the tailings dumps made by
mining. Yet the floor of Port Phillip Bay is a part of
the territory of Victoria, and is one of its major
remaining undisturbed natural areas. The fact that
the sea will hide the proposed artificial seamount
does not alter the fact that the productive infauna
over 10 square kilometres, and the habitat over that
area for that infauna and their natural predators,
would be obliterated.
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 Melbourne suburb, such as Brighton. Its perimeter would be
11 km of sloping wet spoil. The extension of the
existing “Port of Melbourne
Dredged Material Ground”, and the creation of
that huge new “South-east Dredged Material Ground”
represent huge assaults on the life, quality and
natural condition of the sea-bed of Port Phillip,
and PPCC Inc. strongly opposes that.
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 Western Port Bay and its environs when
2030 arrives. The Port of Melbourne Corporation makes no
mention of what might happen after 2030 - just 25
years hence, nor did it forecast its present claim
25 years ago, in 1979. As there is no upper limit on
the size of ships yet to be built, it is
self-evident that Port Phillip is likely to be
subjected to further deepening proposals in the
future.
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 Australia onwards, Victorian
governments have let rail languish as a Cinderella
alternative to shipping. A catching up with the
greater and more effective emphasis on rail in Europe and elsewhere is long
overdue. Recognition that Melbourne’s shallow Bay has
reached its reasonable limit for shipping depths
should open minds to questioning the wisdom of
expanding port facilities at the centre of a huge,
crowded, sprawling city on a largely empty continent
of 7.5 million square kilometres. Places like London have the sense to direct
new shipping facilities well away from the
metropolis.
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 Port of Melbourne, with rail transport as
a better way of handling extra future volume, and
with Government effort on limiting population, not
increasing it.
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 Victoria to unduly tying up much
valuable and very desirable land on the edge of Port
Phillip, and to risks to Melbourne’s major natural asset.
In contrast, more emphasis on transporting Victoria's imports and exports by
rail would give a much more adaptable, constructive
and decentralized ingredient to Victoria’s transport system.
Ships in and out of Melbourne go nowhere else in Victoria, but rail can go
wherever a railway line is built - where producers
and consumers can also be.
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.
Victoria is only 3% of Australia's area. The centre
of
gravity of Australia's
population is moving steadily away from Victoria northwards at a
kilometre per year. Victoria should concentrate more
on maintaining a balance between industry for Melbourne and the recreational and
natural values of our surroundings, such as Port
Phillip, and also industry and activity in the rest
of Victoria.
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