Key points and useful information for your EES submission
Key Points to make in a response to the AGL APA CRIB POINT Gas Import Jetty and Pipeline EES
seventeen state significant species, seven species listed and one species nominated under the Flora and Fauna Guarantee Act 1988 as threatened. (A follow up study was conducted in 2018). “In addition, a further 36 species recorded are considered to be of regional significance and seven species recorded are considered to be of high local significance. Due to large population and habitat losses within the local area (Mornington Peninsula Shire) the remaining native fauna can be considered to be at local significance levels”.
marine information taken from VNPA's Website
Key points on Marine impacts taken from VNPA’s Victorian National Parks Association website
The EES discounts any impacts on wetland birds by saying that because they are not in the direct project vicinity, they will not be impacted. It is well known that wetland birds have sensitivities to disturbance i.e. visual light, noise and predators.
• Chlorine released from the discharge points on the FSRU ship (produced for cooling operations) at its peak will release up to 47 kg/day.
• The FSRU ship will be releasing more than the identified safe levels identified by CSIRO for marine waters. It will be releasing 100 micrograms per litre, when the safe levels to protect 99% of species is set at just 6 micrograms per litre. This is over 16 times higher than safe levels for marine waters.
• This pool of chlorine, identified as being over safe limits for marine waters, is modelled to extend over an area of 5 hectares around the FSRU ship.
• Assumptions are made that it will be dissolved in no time, but the EES does not take into account the other contaminants (secondary products from the chlorine) which can be produced, pending what other particles are in the water.
• These contaminants have the potential for irreversible damage to the ecosystem.
• Major oil spill – such as the Iron Barren spill in the Tamar Estuary in 1995. Although the FSRU and supply vessels may not carry large quantities of fuel, their operations interact with tankers that do, especially given tankers will pass the FSRU to get to Long Island Point.
• Gas release or gas explosion incident – such as the ethane pipeline rupture in Port Phillip Bay in 2008. Although the ethane rupture event did not lead to catastrophic outcomes, it proves that events such as this can occur are not necessarily rare or unlikely.
• Marine pest invasions with permanent alterations of ecosystems ¬– such as Japanese Kelp or Northern Pacific Sea Stars, which have devastated swathes of habitat types in Port Phillip Bay already.
[1] State of Victoria (Agriculture Victoria), sites of Geographical and Geomorphical Significance, Resources Online, http://vro.agriculture.vic.gov.au/dpi/vro/portregn.nsf/pages/port_lf_sig_sites_watson, accessed August 2020
[2] Legg, 2013, Flora and Fauna Assessment at Crib Point Stony Point Foreshore Reserve, Stony Point Foreshore Committee of management.
[3] APA Transmission Pty Limited, Flora and Fauna Assessment Crib Point Pakenham Pipeline Project, 2018, Monarc Environmental, http://epbcnotices.environment.gov.au/_entity/annotation/1829f132-4dcc-e811-a2e6-005056ba00a8/a71d58ad-4cba-48b6-8dab-f3091fc31cd5?t=1539386077609, accessed July2020
[4] Melbourne Water, 2017, Westernport Catchment Snapshot,
[5] Department of Environment, Land, Water & Planning, November 2019, Flora and Fauna Guarantee Act 1988 Threatened List
Summary of Chlorine issue
The proposed terminal will use chlorine to prevent fouling on the heat exchanger system. As no water quality guidelines exist for the marine environment, new guidelines have been developed for the proposed terminal. The proposed new guideline values have been made on the basis that the toxicity risk will manifest itself via an acute toxicity mechanism. It is my considered opinion that the exposure regime in the proposed project should be considered chronic (ie regular recurring exposure) to sedentary organisms within the vicinity of the discharge. The size of the impact zone is therefore highly dependent on the chronic toxicity of CPOs and is likely to be larger than that considered here. Furthermore, while the acute toxicity of the chlorine residuals is relatively low and some occur naturally (bromoform), there are a wide spectrum of halogenated organic compounds produced when chlorine reacts with organic matter in seawater and their occurrence in the marine environment impacted by chlorine discharge has been poorly studied. These compounds have unknown synergistic and chronic impacts for which the risk has not been ruled out with a high degree of confidence (95-99% species protection) as was done for acute toxicity
Expert Witness Statement on the Crib Point Gas Import Terminal and Pipeline Project This statement is provided in regards to the brief attached provided by submitter number 3088.
Perran Cook 44 Greenways Rd, Glen Waverley, 3150 Qualifications and Expertise Professor, School of Chemistry, Monash University Bachelor Applied Science (Hons), Environmental Science RMIT PhD, Chemistry, University of Tasmania
- In short, we consider the location of the project as too risky to the degradation and population of threatened rare and vulnerable flora and fauna species. Westernport is of such unique environmental significance and fragility, that this level of risk is unacceptable
- The importance of Warringine, Crib Pt, Watsons and Kings Creeks, to the preservation of aquatic and land-based flora and fauna is highly significant.
- The squid video below has some errors but it demonstrates how fantastic this area is for marine life
- https://www.youtube.com/watch?v=Y-WfUnqPCLc&t=1133s
- The total pipeline, according to APA descriptions will be approximately 56.2 km in length, with a corridor of up to 30 metres in width. Horizontal Direction Drilling is proposed for under some creeks and other areas designated as environmentally sensitive, but not through all waterways. The list of waterways to have a trench dug through them differs in various tables within the EES documents.
- The Victorian Government grades Watson’s Creek and surrounds as Class 1, indicating: High priority must be given to preserving the entire tidal drainage system of Watson Inlet including the salt marsh, mangrove, inter-tidal and sub-tidal areas. Further dredging and deepening of tidal creek systems should be prohibited and control must be exercised on extending land drainage and wastewater outlets into and across the mangrove and salt marsh zone. The development of any harbour or launching facilities inside the area of the site should be prohibited.
- A study by Legg[2] 2013, of Woolleys Reserve and Crib Point areas found:
seventeen state significant species, seven species listed and one species nominated under the Flora and Fauna Guarantee Act 1988 as threatened. (A follow up study was conducted in 2018). “In addition, a further 36 species recorded are considered to be of regional significance and seven species recorded are considered to be of high local significance. Due to large population and habitat losses within the local area (Mornington Peninsula Shire) the remaining native fauna can be considered to be at local significance levels”.
- The Monarc flora and fauna environmental management report[3] contracted by APA indicates twelve threatened fauna species with “High” likelihood of occurrence within the construction footprint. Nine of these listed species were recorded during Monarch’s field surveys, including the Growling Grass Frog, Southern Toadlet, Australasian Shoveler, Cattle Egret, Eastern Great Egret, Hardhead, Lewin's Rail, Southern Brown Bandicoot and the Glossy Grass Skink. Monarc were not able to locate several other threatened species, including the swamp skink, the swamp antechinus and the New Holland mouse.[4]
- The Swamp Skink, Lissolepis coventryi, is listed as Vulnerable in Victoria[5] and is listed as threatened under the FFG Act. Although The Victorian Biodiversity Atlas has records of 69 sightings of the Swamp Skink in the project area in the last 20 years, the Monarc survey did not sight or record any swamp skinks. They used Elliot traps and Infra red cameras which have been found to be outdated methodology. (See WPPC’s submission)
- The proposed construction would increase light, and compact soil. The Pipeline easement if constructed, will have 4 metres wide clearance even in areas that require re-vegetation. These bare areas would act as corridors for foxes, cats and rats encouraging their easy movement between sites, all leading to a potentially critical reduction in species.
- It is common for weeds to be easily spread by machinery, footwear, and by creating more open spaces in which weed seeds lodge.
- In addition to these concerns, 78 of the 180 samples taken along the pipeline confirmed the presence of Acid Sulphate Soils. (EES technical report E). The management of this during construction must follow EPA guidelines which can include use of clay, black plastic and/or lime. The existing pipeline through the acid sulphate soils area of Warringine is protected from corrosion by an electrical current. A sacrificial Anode. H2SO4, H2S from the acid Suplhate soil and Clay, plastic, lime, and low-voltage electrical currents from their management, may disturb many species of flora and fauna.
- We are unconvinced about the capacity of many suggested mitigation measures to make difference to outcomes.
- Suggestions to mitigate risk include a range of protocols in line with various relevant Acts and management plans, including: Using expert advice at construction - to advise construction workers in best environmental methodology to protect flora and fauna. Also Including fauna management standards in the Environmental Management Plan (EMP). Standards are only as effective as the adherence to them. Will there be external /local expert monitoring of the implementation of these standards? What are the consequences for breach? Rectification works are often too late for threatened, rare and vulnerable species.
- Other concerns regarding construction and ongoing operation of the works include noise, (impact on flora and fauna assessed as low, with no mitigation offered (7-39); machinery fuel and oil leakages or spills (mitigation suggestion is to fill machinery 50 metres away from waterways – which does not take into consideration unique and varied wetland and other soils and their drainage).
- Without knowledge of affected locations and proper controls in place, construction of the Pipeline will exacerbate Phytophthora risks; not only by spreading it along the length of the pipeline but potentially off site as well. The proposed works will make perfect conditions for the spread of this pathogen.
- There is also no mention of a plan to identify the risk, stop or manage the spread of Amphibian Chytrid Fungus, despite the Pipeline crossing many drainage lines, waterways and wetlands and the fungus spreading in water.
marine information taken from VNPA's Website
Key points on Marine impacts taken from VNPA’s Victorian National Parks Association website
The EES discounts any impacts on wetland birds by saying that because they are not in the direct project vicinity, they will not be impacted. It is well known that wetland birds have sensitivities to disturbance i.e. visual light, noise and predators.
• Chlorine released from the discharge points on the FSRU ship (produced for cooling operations) at its peak will release up to 47 kg/day.
• The FSRU ship will be releasing more than the identified safe levels identified by CSIRO for marine waters. It will be releasing 100 micrograms per litre, when the safe levels to protect 99% of species is set at just 6 micrograms per litre. This is over 16 times higher than safe levels for marine waters.
• This pool of chlorine, identified as being over safe limits for marine waters, is modelled to extend over an area of 5 hectares around the FSRU ship.
• Assumptions are made that it will be dissolved in no time, but the EES does not take into account the other contaminants (secondary products from the chlorine) which can be produced, pending what other particles are in the water.
• These contaminants have the potential for irreversible damage to the ecosystem.
• Major oil spill – such as the Iron Barren spill in the Tamar Estuary in 1995. Although the FSRU and supply vessels may not carry large quantities of fuel, their operations interact with tankers that do, especially given tankers will pass the FSRU to get to Long Island Point.
• Gas release or gas explosion incident – such as the ethane pipeline rupture in Port Phillip Bay in 2008. Although the ethane rupture event did not lead to catastrophic outcomes, it proves that events such as this can occur are not necessarily rare or unlikely.
• Marine pest invasions with permanent alterations of ecosystems ¬– such as Japanese Kelp or Northern Pacific Sea Stars, which have devastated swathes of habitat types in Port Phillip Bay already.
[1] State of Victoria (Agriculture Victoria), sites of Geographical and Geomorphical Significance, Resources Online, http://vro.agriculture.vic.gov.au/dpi/vro/portregn.nsf/pages/port_lf_sig_sites_watson, accessed August 2020
[2] Legg, 2013, Flora and Fauna Assessment at Crib Point Stony Point Foreshore Reserve, Stony Point Foreshore Committee of management.
[3] APA Transmission Pty Limited, Flora and Fauna Assessment Crib Point Pakenham Pipeline Project, 2018, Monarc Environmental, http://epbcnotices.environment.gov.au/_entity/annotation/1829f132-4dcc-e811-a2e6-005056ba00a8/a71d58ad-4cba-48b6-8dab-f3091fc31cd5?t=1539386077609, accessed July2020
[4] Melbourne Water, 2017, Westernport Catchment Snapshot,
[5] Department of Environment, Land, Water & Planning, November 2019, Flora and Fauna Guarantee Act 1988 Threatened List
Summary of Chlorine issue
The proposed terminal will use chlorine to prevent fouling on the heat exchanger system. As no water quality guidelines exist for the marine environment, new guidelines have been developed for the proposed terminal. The proposed new guideline values have been made on the basis that the toxicity risk will manifest itself via an acute toxicity mechanism. It is my considered opinion that the exposure regime in the proposed project should be considered chronic (ie regular recurring exposure) to sedentary organisms within the vicinity of the discharge. The size of the impact zone is therefore highly dependent on the chronic toxicity of CPOs and is likely to be larger than that considered here. Furthermore, while the acute toxicity of the chlorine residuals is relatively low and some occur naturally (bromoform), there are a wide spectrum of halogenated organic compounds produced when chlorine reacts with organic matter in seawater and their occurrence in the marine environment impacted by chlorine discharge has been poorly studied. These compounds have unknown synergistic and chronic impacts for which the risk has not been ruled out with a high degree of confidence (95-99% species protection) as was done for acute toxicity
Expert Witness Statement on the Crib Point Gas Import Terminal and Pipeline Project This statement is provided in regards to the brief attached provided by submitter number 3088.
Perran Cook 44 Greenways Rd, Glen Waverley, 3150 Qualifications and Expertise Professor, School of Chemistry, Monash University Bachelor Applied Science (Hons), Environmental Science RMIT PhD, Chemistry, University of Tasmania
EES - Crib Point Gas Import Jetty & Pipeline (AGL)
WPPC has submitted to the EES for the Crib Point Gas Import Jetty and Pipeline inquirySee our response to the EES on page one.
We are going to speak to that submission at the Panel Hearing on November 19th 2020. You can watch by accessing the link on the Engage Victoria Website. Sandy Milne, Karri Giles are the team that are preparing our presentation for the Panel Hearing. This will be a summary of our submission, which seems to have unique information. We were part of a team of environmental groups and tasked with focussing on terrestrial biodiversity which is poorly represented in submissions.
We also have engaged Dr Mary Cole as an Expert Witness. She will give her presentation supported by Barrister James Kewley, in the same time slot: 10.15am until 1pm.
Dr Mary Cole ‘s Summary of Opinion
• a) There is a high risk of spread to the amphibian chytrid fungus, Batrachochytrium dendrobatidis. The infective propagules of the pathogen move freely in water and wet soil. No survey of infection appears to be available in the Report.
• b) Mitigation as outlined in the Technical report B is not sufficient to protect the amphibian population.
• c) Mitigation would need to be carried out at ‘research’ level of containment and would be improbable in a commercial enterprise.
• d) There is a high risk of spread of the pathogen, P. cinnamomi. This pathogen moves freely in water and wet soil.
• e) Many of the Australian native plant species are highly susceptible to infection by the pathogen so spread of the pathogen is likely in vegetation and farming areas.
REMINDER:
The Public Hearing for EES
Will commence on Monday 12 October and will run for 10 weeks.
To watch the Hearings live each day, go to https://engage.vic.gov.au/crib-point-IAC
At the top it says ‘How to access the Hearing’
Click on
‘Crib Point IAC - Hearing Link’
Type in your email address, and then click on the Zoom link to watch the Hearing from 10 am each day, (except Fridays)
See our website for our submission.
https://www.wppcinc.org/
The EES reports are now available online
This includes AGL’s Summary Report and a document called How to Navigate the EES
There’s an Executive Summary, three volumes of reports, and several attachments including Environmental Risk and Climate Change RiskAssessments and Maps.
The EES also contains the following technical reports:
Technical Report A: Marine Biodiversity
Technical Report B: Terrestrial and freshwater biodiversity
Technical Report C: Surface water
Technical Report D: Groundwater
Technical Report E: Contamination and acid sulfate soils
Technical Report F: Greenhouse gas
Technical Report G: Air quality
Technical Report H: Noise and vibration
Technical Report I: Landscape and visual
Technical Report J: Transport
Technical Report K: Safety, hazard and risk
Technical Report L: Land use
Technical Report M: Social
Technical Report N: Business
Technical Report O: Agriculture
Technical Report P: Aboriginal cultural heritage
Technical Report Q: Historic heritageYou can also make a submission about the AGL Crib Point proposal using the online form on the EngageVic website here:
https://engage.vic.gov.au/crib-point-IAC
While that’s a simple way to comment on the AGL proposal, it’s likely that an independent submission from you will probably ‘count’ for more.
Best to start reading the reports that interest you, taking notes on whatever concerns you, and watch this space for more information about how to write your own submission —and make sure your voice is heard.AGL Gas at Crib Point, Westernport and APA pipeline to Pakenham{From Save Westernport's WEBSITE}
AGL are proposing to install a Floating Storage and Regasification Unit (FSRU) at Crib Point, Westernport and have contracted APA to build a 60km pipeline from there to Pakenham.
The FSRU and pipeline proposals are being assessed independently. This in itself is a concern because the cumulative impact of the damage caused by this one project is being significantly lessened. See our section about the pipeline to understand why this is so bad for our landowners, agricultural land and businesses.
Our government will be allowing AGL to impose an enormous burden on the people and environment of Westernport. It’s a proposal that is totally out of the hands of the people who would be impacted the most – indeed could wear a catastrophic event while AGL gets all the benefit.
AGLHere are detials the Floating Storage and Regasification Unit and operation being proposed:
It is a unique, fragile and internationally recognised area; an intertidal Ramsar listed wetland that is vital for: birdlife (being a significant area for migratory birds); fish breeding; seagrasses; some of the most southerly mangroves; and many other highly sensitive ecological factors. It is also a designated UNESCO biosphere.
This critical habitat will be affected by the following:
This includes AGL’s Summary Report and a document called How to Navigate the EES
There’s an Executive Summary, three volumes of reports, and several attachments including Environmental Risk and Climate Change RiskAssessments and Maps.
The EES also contains the following technical reports:
Technical Report A: Marine Biodiversity
Technical Report B: Terrestrial and freshwater biodiversity
Technical Report C: Surface water
Technical Report D: Groundwater
Technical Report E: Contamination and acid sulfate soils
Technical Report F: Greenhouse gas
Technical Report G: Air quality
Technical Report H: Noise and vibration
Technical Report I: Landscape and visual
Technical Report J: Transport
Technical Report K: Safety, hazard and risk
Technical Report L: Land use
Technical Report M: Social
Technical Report N: Business
Technical Report O: Agriculture
Technical Report P: Aboriginal cultural heritage
Technical Report Q: Historic heritageYou can also make a submission about the AGL Crib Point proposal using the online form on the EngageVic website here:
https://engage.vic.gov.au/crib-point-IAC
While that’s a simple way to comment on the AGL proposal, it’s likely that an independent submission from you will probably ‘count’ for more.
Best to start reading the reports that interest you, taking notes on whatever concerns you, and watch this space for more information about how to write your own submission —and make sure your voice is heard.AGL Gas at Crib Point, Westernport and APA pipeline to Pakenham{From Save Westernport's WEBSITE}
AGL are proposing to install a Floating Storage and Regasification Unit (FSRU) at Crib Point, Westernport and have contracted APA to build a 60km pipeline from there to Pakenham.
The FSRU and pipeline proposals are being assessed independently. This in itself is a concern because the cumulative impact of the damage caused by this one project is being significantly lessened. See our section about the pipeline to understand why this is so bad for our landowners, agricultural land and businesses.
Our government will be allowing AGL to impose an enormous burden on the people and environment of Westernport. It’s a proposal that is totally out of the hands of the people who would be impacted the most – indeed could wear a catastrophic event while AGL gets all the benefit.
AGLHere are detials the Floating Storage and Regasification Unit and operation being proposed:
- The FSRU is 300m long x 45m wide
- It will be permanently moored at Crib Point
- Foreign LNG ships of the same size deliver to the FSRU to transfer the liquid gas into FSRU
- The FSRU has an onboard regasification plant to return the LNG back into a gaseous state which will be transferred to a newly constructed pipeline to Pakenham.
It is a unique, fragile and internationally recognised area; an intertidal Ramsar listed wetland that is vital for: birdlife (being a significant area for migratory birds); fish breeding; seagrasses; some of the most southerly mangroves; and many other highly sensitive ecological factors. It is also a designated UNESCO biosphere.
This critical habitat will be affected by the following:
- The regasification process involves 450 million litres of organism rich seawater sucked in, chlorinated and spewed out dead and 7 degrees colder than the ambient seawater temperature per day
- Ship emissions including venting of gas build up
- Noise pollution
- Light pollution
- Greater numbers of ships increase the potential for collision
- Increase potential for marine strike by the foreign owned gas tankers (especially during whale season)
- Onshore 50m either side of the jetty will be cleared which will destroy some of Woolley’s reserve
- Government announced last year that they have “streamlined processes” in order for this disastrous proposal to be fast-tracked. That is the worst possible idea for such a complex proposal that affects land and water.
- Explosion – BLEVE (boiling liquid evaporative vapor explosion) impacting up to 3km. AGL says this can’t happen. Why then have other FSRUs included it in their assessments and subsequently place their floating regasification units offshore? The other FSRUs that are closer to shore are in very industrialised areas not like Westernport.
- Gas leaks
- Situated alongside bushfire prone area
- Close to township of Crib Point
- AGL will cite employing best practices as well as the good record of FSRU technology. This does not mean something could go wrong caused by and not limited to – human error, inexperienced staff, tired staff, technical issues, faulty part, poor or inadequate maintenance, living quarters on board.
- Even if the odds of catastrophe are only 1%, 0.5%, 5%. It’s irrelevant. You don’t put something that poses a threat so enormous near a community and world-renowned habitat.
- The FSRU will only provide 40 jobs. These positions require highly specialised skills. It is highly unlikely that locals will have this technical experience. There isn’t yet another FSRU in Australia so training will be overseas.
- The FSRU will be built overseas, the training is overseas, the ships bringing the LNG to the FSRU will be foreign owned and staffed, and under flags of convenience.
- The proposal will damage the local economy rather than enhance it. There are many businesses dependent on a healthy, attractive bay. Fishing, diving, kayaking, charter boats and sailing, wildlife watching and tourism.
- Real estate values and liveability will decline. This will result in less investment locally affecting tradespeople, shops, service industries, sporting events and so on.
- Reactive measures like AGL’s FSRU that are not developed in accordance with a long-term strategy for the region’s future are not beneficial for the region or the state.
| wppc_agl_epbc_submission_oct_2018.docx |
Crib Point AGL Gas Import Proposal
The No AGL Gas Terminus working Group has organised a public meeting
Public Meeting - Save Westernport NO AGL Gas Terminus for Crib Point - Tuesday 8th May 7.30pm Crib Point Community House. AGL are proposing a floating gas terminus at Crib Point jetty and approx. 60klm of pipeline from the jetty to Pakenham. AGL is importing gas (yes, our own gas coming back to us via a consortium!!) even though Australia is on the verge of being the biggest gas exporter in the world. Please attend to learn more. It's important we are informed. Thank you
They are working on our petition and first public meeting to be held: Tuesday 8th May 7:30pm Crib Point Community House, 7 Park Street Crib Point.
Please come and show your support, bring your questions and offer your suggestions.
Public Meeting - Save Westernport NO AGL Gas Terminus for Crib Point - Tuesday 8th May 7.30pm Crib Point Community House. AGL are proposing a floating gas terminus at Crib Point jetty and approx. 60klm of pipeline from the jetty to Pakenham. AGL is importing gas (yes, our own gas coming back to us via a consortium!!) even though Australia is on the verge of being the biggest gas exporter in the world. Please attend to learn more. It's important we are informed. Thank you
They are working on our petition and first public meeting to be held: Tuesday 8th May 7:30pm Crib Point Community House, 7 Park Street Crib Point.
Please come and show your support, bring your questions and offer your suggestions.
A new report has been tabled from AGL regarding the biocide process they intend to used at Crib Point to kill larvae etc that could grow on and block their pumps etc. It highlights the need to demand the use of multi-ports to help dilute cold, chlorinated water.
Chlorine in seawater heat exchange process at Crib Point DRAFT 27 February 2018
· The concentration of 0.5 mg/L of free chlorine generated at the entrance to the seawater heat exchange system will be toxic to a range of marine organisms passing through the heat exchange system. This is the desired outcome for the operation of the heat exchange system. · The concentration of 0.1 mg/L of free chlorine remaining in the seawater at it leaves the heat exchange system will be toxic to some marine organisms that are very close to the discharge point and that exposed for long enough for a toxic effect to occur. This is a generally accepted localised outcome for the operation of the heat exchange system provided that the effect is localised. · The toxicity test NOEC of 0.038 mg/L of free chlorine is higher than the USEPA and ANZECC safe concentrations (Table 1) for free chlorine.The evidence concludes that: · Discharge of the seawater modelled in the conservative one or two outlets case will require further dilution and time to react with seawater constituents in the marine environment to reach concentrations considered environmentally safe by USEPA and ANZECC. o This is likely to occur within the footprint described for the coldwater plume. o Further targeted nearfield modelling would be required to refine the extent of the chlorine and temperature gradients along the dispersion pathways from the coldwater discharge points. · Discharge of the seawater via multi-port discharge, in accordance with AGL’s preferred design, is likely to reach environmentally safe concentrations within the area that the discharge plume initially makes contact with the seabed.
Our view
Every ship has the capacity to cause an oil spill, even just from engine oil. AGL ships are run from cooled liquid gas so the threat of oil spills is only from engine oil. The waters of Westernport are very shallow and some areas like Mchaffies Reef are rocky. The channel is very narrow. The tides are very strong. AGL ships are 260m long making running aground a real possibility. Most sailors of small boats in our yacht clubs around Westernport Bay have run aground because the Bay is so shallow.
Every ship has the capacity to bring in marine pests. AGL gas ship will be coming from ports that are infested with marine pests. Westernport Bay does not have the two common worst ones: Northern Pacific Sea star, that has contributed to a massive drop in fish stocks in Port Phillip Bay. It also does not have Spartina. Will AGL ships sterilize their ballast water with excess engine heat and exchange ballast water out to sea? AGL promised to staff their ships with Australian crews. Will they keep to that? International shipping companies are notoriously dodgy. We want Australian jobs.
Gas spills are rare but if ther is one the gas is so cold no human could be near a spill until all the liquid gas has spilt and warmed up. A vapour cloud then could end up in The Bay if it is raining or fuel a bush fire.
Stop Press Boral have until 28th of August to accept the conditions of the planning permit granted to them or it runs out.
Crib Point Bitumen Plant -WPPC's submission to the VCAT Panel
Crib Point Bitumen Hearing 14th August 2008
VCAT Reference No P2758/2007
Westernport Peninsula Protection Council Inc
Westernport and Peninsula Protection Council Inc. Believe the location of the proposed Bitumen Storage and Batching Facility is inappropriate, and offer the following grounds for objection for your consideration.
WPPC Inc.
• In Dec 30th 1970 there was a protest rally against the Ampol-Sleigh proposed refinery at Bittern, 600 people attended a meeting on Balnarring Race Track.
• The First formal meeting of the WPPC Jan 4th 1971. Our group is 37 years old
• We have approximately 300 members
Our Principle Objectives are
To engage in, support and promote:
• regional and local planning
• conservation of natural resources, including fauna and flora
• studies of the effects of pollution of all kinds
• the protection of the environment.
…of Westernport, the Mornington Peninsula and elsewhere.
In 1987 WPPC Inc. were the leading group in the successful campaign against The Western Mining Corporation Ammonia–Urea plant proposal on the BP site using the Crib Point Jetty. Later a key campaigner in that campaign, Rosy Buchanan became president of our group.
1992 Super tanker proposal for same BP site. Shell-Mobil bought it for a major oil import facility. Again an angry public put evidence on the table including the Shapiro report. We were key campaigners again in this campaign and in due course the Shell company advised our President Dr Brian Cuming, in a personal call from the Head Quarters in Holland that the plan was to be shelved indefinitely.
From there there was bipartisan support for a statement from the minister for planning Tom Roper that it was inappropriate for such an industry to develop there, and secoundly that a policy should be adopted which later became enshrined below….
We participated in government planning via The Westernport Regional Planning and Co-ordination Committee. The main planning change as a result of that same campaign was Document 1 below. Which we saw as a victory and we have never forgotten, and we will never forget, because there is so much sense to it
Another effort which WPPC initiated and were deeply involved in the three years 1988, 1989 and 1990 were the three Seagrass festivals which involved large puppets, hundreds of school children and massive community participation to celebrate the environmental values of Westernport Bay 1990.
Dr Brian Cuming Past President and research fellow of WPPC Inc,40 years resident of Bittern “I have always had great faith that the Hastings, Crib Point, Stony Point area would become a thriving residential area with great lifestyle facilities. Providing recreation for the region.
In the last ten years this has really happened. Pelican Park/ pantry symbolizes modern Hastings/Crib point,
Let us not spoil it with corruptions”
Document 1: Hastings Port Industrial Area Land use Structure Plan (1996), which in turn forms part of the State Planning Policy Framework.
This Plan states that
Planning for the area south of Hastings township should balance the importance of the area for industrial development and concern of residents to protect the amenity of the area. Consistent with this approach, industries which rely on fixed rail transport and pipelines should be encouraged…. Industries which generate high volumes of road transport to carry goods, in particular road transport of hazardous goods, should be directed to locate north of the Hastings Township.
Document 1: Hastings Port Industrial Area Land use Structure Plan (1996), which in turn forms part of the State Planning Policy Framework.
Planning Controls 5.2 Page 14
Zoning PUZ7- the proposed site is PUBLIC LAND with a zoning that has the object of recognizing public land for public utility and community services and providing associated uses that are consistent.
The granting of a relatively long term use of this public site to a private company that is not providing an essential service, such as liquid fuel is, we believe, not consistent with the zoning.
PUZ7- Other Public Use.
The use must be carried out by or on behalf of the public land manager. ( In this case it is The Port of Melbourne Authority)
Document 2:- Victoria Planning Provisions Feb 1999:
A public land manager should be able to use and develop public land for any purpose under its relevant land management legislation without the need of a permit. This is achieved by allowing many uses to be section 1 within a public land zone, subject to the use being conducted by or on behalf of the public land manager or a specified public authority these words should not be interpreted in a way that would allow a public land manager to have a blanket exemption within the zone to the extent that it could consent to any use or development by another party and have that use or development also automatically exempt from planning control.
The words by or on behalf of should be interpreted with regard to the particular statutory charter of the public land manger under its governing legislation and indicate that the use or development must be undertaken by the public land manger itself or by some other person or entity having a direct representative interest or relationship with the public land manager.
Document 3: Planning Permit Report Volume 1
Local Planning Policy Framework
Municipal strategic statement Clause 21.03.1
Port and industrial development should be physically separated from sensitive
urban development by the establishment of appropriate buffers which reduce
the impact from vibration, intrusive lighting noise and air emissions from port
activities
the objectives of this clause are not met by the development.
Particular Provisions Clause 52.10
Uses with adverse amenity potential – This clause provides a table
that sets out the threshold distances, the minimum distance from any
part of the site and adjacent residential zones.
The nearest resident is just less than 500 metres from the site.
Document 4 National Estate Register
WESTERNPORT
LIST: Register on the National Estate
CLASS: Natural
Legal Status (27/03/2001)
Place ID: 17846
Place File no.: 2/18/299/0007
Westernport is a large, diverse marine and coastal ecosystem with no equal in south –eastern Australia…… The Bay maintains one of the major mangrove and saltmarsh communities in Victoria. Parts of these stands are unique in exhibiting natural coastal processes that are largely free of industrial, recreational, and urban influences.
The marine and intertidal waters of the bay support a rich marine invertebrate fauna. At least 1,350 species have been recoreded which is approximately three to four times greater than the number recorded in nearby Port Phillip Bay………………Westernport sustains important remnants of vegetation communities that have been extensively cleared on the Mornington Peninsula and within the Westernport Catchment.
In addition to the Whole of Westernport Bay being listed on the National Estate Register Specifically the area next to the proposed development has its own additional lising:
Jacks Beach and Sandstone Island Enlarged Area, Woolleys Rd, Bittern,
VIC, Australia (see attachment 3)
Photographs: None
List: Register of the National Estate
Class: Natural
Legal Status: Registered (27/03/2001)
Place ID: 18743
Place File No: 2/18/024/0002
The area consists of a narrow coastal strip of Crown Land and Sandstone Island. It is an area of local significance and great general interest. Golden Point at the Southern end is of particular interest to geologists. The area is rich in wildflowers. It is a favourite spot for local people and a reef makes a natural boat ramp. Towards the north is swamp and salt marsh which is rich in bird life. The area is still natural and the shoreline includes mangroves fringes rocky outcrops and sandy patches.
Document 5: Flora and Fauna Survey of Crib Point and Stony pt Foreshore, October 2005 to October 2006- Malcolm Legg, Brent Hall and Paul Bertuch
31 species of regional significance
13 species of National significance and all these the indigenous species are locally significant.
Biosis- Boral’s contractors call the site Very High Conservation Significance.
Document 6:
Native Vegetation Framework Document Table 6
Very High conservation significance vegetation can only be cleared for projects of state significance if “exceptional circumstances apply” with the approval of the Minister for Conservation separate from the process under the Planning and Environmental Act.
The Hon Mr. Jennings has not approved
The offset for a Very High Conservation site could easily be very difficult to obtain. Substantial net gain has to be at least 2 times the loss. Finding an appropriate site to do the offsets of the same vegetation communities to rehabilitate would be difficult. They have not given a number to the number of hectares of vegetation that is to be lost.
.Document 7 Port of Hastings Land Use Study
Port of Hastings Strategic Land Use and Transport Access Corridor Planning
Study January 2006 is the reference for strategic planning considerations.
in the documentation.
In September 2006 Final Draft was released and the recommendations
for use of Crib Point indicate that heavy vehicle use as outlined in the
application is an activity that appears to be fundamentally inconsistent with
position outlined in the Port of Hastings Land Use and Transport Strategic Study
– Final Report (September 2006), which states that
“the key outcomes of the stage 1 evaluation are that the Crib Point precinct
performs unsatisfactorily in relation to transport access to and from the site and
potential amenity impacts on surrounding land use (page 61) ... and that …
“the Crib Point Options have a number of constraints as follows:
There is an insufficient buffer between Crib Point and the
surrounding residential and community areas, meaning that intensive
development could not occur without significant social impacts
The main transport routes to Crib Point (both road and rail) pass
through residential areas. Any significant increase in heavy vehicle
volumes would have high social impact.
For these reasons, it was determined that, while the option to develop
Crib Point further in the long terms needed to be retained, port layout
options would not be carried forward for further investigation in this
strategy.” (p85)
In addition, the Study comments:
“The Crib Point area is a low density residential area that has developed a
rural village atmosphere….
3
Significant amenity impacts to the broader Crib Point and Hastings
community are envisaged from the transportation of freight to and from the
precinct. Movement of freight by truck to gain access to the broader
transport corridors would need to be undertaken along the local roadways
of Woolleys Road and Stony Point Road and through the Hastings
Township, which would significantly increase heavy vehicle movements on
those roads.
The amenity impacts to the Hastings community associated with this
increased truck traffic through the township is envisaged to be not
sustainable in the short, medium or long term (page 239).
DOCUMENT 7 Outer Suburban Interface Services Development Committee Port Of Hastings Corporation Mr Ralph Kenyan Chief Executive Officer.
Crib Point- We see that as being retained as a liquid berthing facility. Crib Point was the home of BP back in the 60’s and 70’s. It was closed down in the early 1980’s, but the liquid berthing facility there is connected by pipeline from Crib Point up to Esso at Long Island and also to Altona and Geelong. In terms of its strategic importance to the state, Crib Point liquid berth is critical. It is essential that that facility is maintained and available for future access.
Traffic Access
Assessment is based on a proposal to operate 20-24 B Double truck
movements per day on the route to service the proposed facility. And the movement of an additional 20-24 B Double trucks a day would have negligible impact according to the application. Page 21 of the aplication states that there will usually be less than 1 loaded truck movement per hour This would indicate there could be more than 24 movements per day.
as the application states that 3 trucks can be loaded in an hour.
Climate Change.
Impacts of Climate Change on Human Settlements In The Westernport Region.
The report commissioned by Westernport Greenhouse Alliance and its member councils which include the Mornington Peninsula Shire. CSIRO 2008
Extreme Rainfall
Maximum flood heights to increase and flooding frequency to increase.
Extreme rainfall resulting in increased flood damage to public and private infrastructure.
Cost of insurance.
Emergency response and recovery
Disruption to transport 128km roads plus eight bridges.
Estimated 204 residential properties and 50 commercial properties.
MOST SENSITIVE LOCATIONS ARE CRIB POINT AND HASTINGS.
Sea level rise 2030 17cm 2070 49cm.
1 in 100 year storm tide event currently 2.10 m Cowes
2.29m 2030 2.74 metre 2070
Inundation area Westernport Area 1 in 100 year storm surge 12.6 sq km
2070 17.7 sq km
Estimated 14000 people
30 commercial properties
Increased maintenance
Cost of insurance
Loss of land values
631 residential properties
MOST SENSITIVE AREA CRIB PT AND HASTINGS.
If the tanks are dug in will they be flooded? If there is bunding will it affect the hydrology of the area? The width of the wildlife corridor. If there is digging is the area prone to acid sulphate soil?
Any digging in of
The application states
The development will stimulate the economy and generate employment
and will facilitate the construction of major road infrastructure
We understand that it is likely that only 2 jobs will be created, and
probably not for locals.
There is no guarantee that locals would be used in the construction process
We are of the opinion that this project does not hold benefits for the local
community.
Conclusion
The proponent refers to previous industrial activity in Crib Point. In 1963 the
then government passed legislation to enable the construction of the BP Refinery site at Crib Point which opened in 1966. The site closed in 1985 as is was no long viable. There has not been any industrial development south of Hastings in 41 years. With the exception of the BP site, all industrial development has occurred on Long Island and to the north of Hastings. Climte change is due to affect Hastings and Crib Point especially and any digging or bunding at the site will affect the hydrology and wildlife corridor width.
This Application for a Bitumen Storage and Transport Facility should not proceed because the associated long-term impacts on the environment and community. This is unquestionably a special area, recognized by its listing on National Estate Register, Ramsar Listing, It makes up a key part of the Westernport and Mornington Peninsula Bioregion and the area around the site itself has a Very High Significant status within the National Vegetation Framework. The application does not allow positive options for alternative development of Crib Point and surrounding areas. The application is in conflict with the planning for the area.aph.
VCAT Reference No P2758/2007
Westernport Peninsula Protection Council Inc
Westernport and Peninsula Protection Council Inc. Believe the location of the proposed Bitumen Storage and Batching Facility is inappropriate, and offer the following grounds for objection for your consideration.
WPPC Inc.
• In Dec 30th 1970 there was a protest rally against the Ampol-Sleigh proposed refinery at Bittern, 600 people attended a meeting on Balnarring Race Track.
• The First formal meeting of the WPPC Jan 4th 1971. Our group is 37 years old
• We have approximately 300 members
Our Principle Objectives are
To engage in, support and promote:
• regional and local planning
• conservation of natural resources, including fauna and flora
• studies of the effects of pollution of all kinds
• the protection of the environment.
…of Westernport, the Mornington Peninsula and elsewhere.
In 1987 WPPC Inc. were the leading group in the successful campaign against The Western Mining Corporation Ammonia–Urea plant proposal on the BP site using the Crib Point Jetty. Later a key campaigner in that campaign, Rosy Buchanan became president of our group.
1992 Super tanker proposal for same BP site. Shell-Mobil bought it for a major oil import facility. Again an angry public put evidence on the table including the Shapiro report. We were key campaigners again in this campaign and in due course the Shell company advised our President Dr Brian Cuming, in a personal call from the Head Quarters in Holland that the plan was to be shelved indefinitely.
From there there was bipartisan support for a statement from the minister for planning Tom Roper that it was inappropriate for such an industry to develop there, and secoundly that a policy should be adopted which later became enshrined below….
We participated in government planning via The Westernport Regional Planning and Co-ordination Committee. The main planning change as a result of that same campaign was Document 1 below. Which we saw as a victory and we have never forgotten, and we will never forget, because there is so much sense to it
Another effort which WPPC initiated and were deeply involved in the three years 1988, 1989 and 1990 were the three Seagrass festivals which involved large puppets, hundreds of school children and massive community participation to celebrate the environmental values of Westernport Bay 1990.
Dr Brian Cuming Past President and research fellow of WPPC Inc,40 years resident of Bittern “I have always had great faith that the Hastings, Crib Point, Stony Point area would become a thriving residential area with great lifestyle facilities. Providing recreation for the region.
In the last ten years this has really happened. Pelican Park/ pantry symbolizes modern Hastings/Crib point,
Let us not spoil it with corruptions”
Document 1: Hastings Port Industrial Area Land use Structure Plan (1996), which in turn forms part of the State Planning Policy Framework.
This Plan states that
Planning for the area south of Hastings township should balance the importance of the area for industrial development and concern of residents to protect the amenity of the area. Consistent with this approach, industries which rely on fixed rail transport and pipelines should be encouraged…. Industries which generate high volumes of road transport to carry goods, in particular road transport of hazardous goods, should be directed to locate north of the Hastings Township.
Document 1: Hastings Port Industrial Area Land use Structure Plan (1996), which in turn forms part of the State Planning Policy Framework.
Planning Controls 5.2 Page 14
Zoning PUZ7- the proposed site is PUBLIC LAND with a zoning that has the object of recognizing public land for public utility and community services and providing associated uses that are consistent.
The granting of a relatively long term use of this public site to a private company that is not providing an essential service, such as liquid fuel is, we believe, not consistent with the zoning.
PUZ7- Other Public Use.
The use must be carried out by or on behalf of the public land manager. ( In this case it is The Port of Melbourne Authority)
Document 2:- Victoria Planning Provisions Feb 1999:
A public land manager should be able to use and develop public land for any purpose under its relevant land management legislation without the need of a permit. This is achieved by allowing many uses to be section 1 within a public land zone, subject to the use being conducted by or on behalf of the public land manager or a specified public authority these words should not be interpreted in a way that would allow a public land manager to have a blanket exemption within the zone to the extent that it could consent to any use or development by another party and have that use or development also automatically exempt from planning control.
The words by or on behalf of should be interpreted with regard to the particular statutory charter of the public land manger under its governing legislation and indicate that the use or development must be undertaken by the public land manger itself or by some other person or entity having a direct representative interest or relationship with the public land manager.
Document 3: Planning Permit Report Volume 1
Local Planning Policy Framework
Municipal strategic statement Clause 21.03.1
Port and industrial development should be physically separated from sensitive
urban development by the establishment of appropriate buffers which reduce
the impact from vibration, intrusive lighting noise and air emissions from port
activities
the objectives of this clause are not met by the development.
Particular Provisions Clause 52.10
Uses with adverse amenity potential – This clause provides a table
that sets out the threshold distances, the minimum distance from any
part of the site and adjacent residential zones.
The nearest resident is just less than 500 metres from the site.
Document 4 National Estate Register
WESTERNPORT
LIST: Register on the National Estate
CLASS: Natural
Legal Status (27/03/2001)
Place ID: 17846
Place File no.: 2/18/299/0007
Westernport is a large, diverse marine and coastal ecosystem with no equal in south –eastern Australia…… The Bay maintains one of the major mangrove and saltmarsh communities in Victoria. Parts of these stands are unique in exhibiting natural coastal processes that are largely free of industrial, recreational, and urban influences.
The marine and intertidal waters of the bay support a rich marine invertebrate fauna. At least 1,350 species have been recoreded which is approximately three to four times greater than the number recorded in nearby Port Phillip Bay………………Westernport sustains important remnants of vegetation communities that have been extensively cleared on the Mornington Peninsula and within the Westernport Catchment.
In addition to the Whole of Westernport Bay being listed on the National Estate Register Specifically the area next to the proposed development has its own additional lising:
Jacks Beach and Sandstone Island Enlarged Area, Woolleys Rd, Bittern,
VIC, Australia (see attachment 3)
Photographs: None
List: Register of the National Estate
Class: Natural
Legal Status: Registered (27/03/2001)
Place ID: 18743
Place File No: 2/18/024/0002
The area consists of a narrow coastal strip of Crown Land and Sandstone Island. It is an area of local significance and great general interest. Golden Point at the Southern end is of particular interest to geologists. The area is rich in wildflowers. It is a favourite spot for local people and a reef makes a natural boat ramp. Towards the north is swamp and salt marsh which is rich in bird life. The area is still natural and the shoreline includes mangroves fringes rocky outcrops and sandy patches.
Document 5: Flora and Fauna Survey of Crib Point and Stony pt Foreshore, October 2005 to October 2006- Malcolm Legg, Brent Hall and Paul Bertuch
31 species of regional significance
13 species of National significance and all these the indigenous species are locally significant.
Biosis- Boral’s contractors call the site Very High Conservation Significance.
Document 6:
Native Vegetation Framework Document Table 6
Very High conservation significance vegetation can only be cleared for projects of state significance if “exceptional circumstances apply” with the approval of the Minister for Conservation separate from the process under the Planning and Environmental Act.
The Hon Mr. Jennings has not approved
The offset for a Very High Conservation site could easily be very difficult to obtain. Substantial net gain has to be at least 2 times the loss. Finding an appropriate site to do the offsets of the same vegetation communities to rehabilitate would be difficult. They have not given a number to the number of hectares of vegetation that is to be lost.
.Document 7 Port of Hastings Land Use Study
Port of Hastings Strategic Land Use and Transport Access Corridor Planning
Study January 2006 is the reference for strategic planning considerations.
in the documentation.
In September 2006 Final Draft was released and the recommendations
for use of Crib Point indicate that heavy vehicle use as outlined in the
application is an activity that appears to be fundamentally inconsistent with
position outlined in the Port of Hastings Land Use and Transport Strategic Study
– Final Report (September 2006), which states that
“the key outcomes of the stage 1 evaluation are that the Crib Point precinct
performs unsatisfactorily in relation to transport access to and from the site and
potential amenity impacts on surrounding land use (page 61) ... and that …
“the Crib Point Options have a number of constraints as follows:
There is an insufficient buffer between Crib Point and the
surrounding residential and community areas, meaning that intensive
development could not occur without significant social impacts
The main transport routes to Crib Point (both road and rail) pass
through residential areas. Any significant increase in heavy vehicle
volumes would have high social impact.
For these reasons, it was determined that, while the option to develop
Crib Point further in the long terms needed to be retained, port layout
options would not be carried forward for further investigation in this
strategy.” (p85)
In addition, the Study comments:
“The Crib Point area is a low density residential area that has developed a
rural village atmosphere….
3
Significant amenity impacts to the broader Crib Point and Hastings
community are envisaged from the transportation of freight to and from the
precinct. Movement of freight by truck to gain access to the broader
transport corridors would need to be undertaken along the local roadways
of Woolleys Road and Stony Point Road and through the Hastings
Township, which would significantly increase heavy vehicle movements on
those roads.
The amenity impacts to the Hastings community associated with this
increased truck traffic through the township is envisaged to be not
sustainable in the short, medium or long term (page 239).
DOCUMENT 7 Outer Suburban Interface Services Development Committee Port Of Hastings Corporation Mr Ralph Kenyan Chief Executive Officer.
Crib Point- We see that as being retained as a liquid berthing facility. Crib Point was the home of BP back in the 60’s and 70’s. It was closed down in the early 1980’s, but the liquid berthing facility there is connected by pipeline from Crib Point up to Esso at Long Island and also to Altona and Geelong. In terms of its strategic importance to the state, Crib Point liquid berth is critical. It is essential that that facility is maintained and available for future access.
Traffic Access
Assessment is based on a proposal to operate 20-24 B Double truck
movements per day on the route to service the proposed facility. And the movement of an additional 20-24 B Double trucks a day would have negligible impact according to the application. Page 21 of the aplication states that there will usually be less than 1 loaded truck movement per hour This would indicate there could be more than 24 movements per day.
as the application states that 3 trucks can be loaded in an hour.
Climate Change.
Impacts of Climate Change on Human Settlements In The Westernport Region.
The report commissioned by Westernport Greenhouse Alliance and its member councils which include the Mornington Peninsula Shire. CSIRO 2008
Extreme Rainfall
Maximum flood heights to increase and flooding frequency to increase.
Extreme rainfall resulting in increased flood damage to public and private infrastructure.
Cost of insurance.
Emergency response and recovery
Disruption to transport 128km roads plus eight bridges.
Estimated 204 residential properties and 50 commercial properties.
MOST SENSITIVE LOCATIONS ARE CRIB POINT AND HASTINGS.
Sea level rise 2030 17cm 2070 49cm.
1 in 100 year storm tide event currently 2.10 m Cowes
2.29m 2030 2.74 metre 2070
Inundation area Westernport Area 1 in 100 year storm surge 12.6 sq km
2070 17.7 sq km
Estimated 14000 people
30 commercial properties
Increased maintenance
Cost of insurance
Loss of land values
631 residential properties
MOST SENSITIVE AREA CRIB PT AND HASTINGS.
If the tanks are dug in will they be flooded? If there is bunding will it affect the hydrology of the area? The width of the wildlife corridor. If there is digging is the area prone to acid sulphate soil?
Any digging in of
The application states
The development will stimulate the economy and generate employment
and will facilitate the construction of major road infrastructure
We understand that it is likely that only 2 jobs will be created, and
probably not for locals.
There is no guarantee that locals would be used in the construction process
We are of the opinion that this project does not hold benefits for the local
community.
Conclusion
The proponent refers to previous industrial activity in Crib Point. In 1963 the
then government passed legislation to enable the construction of the BP Refinery site at Crib Point which opened in 1966. The site closed in 1985 as is was no long viable. There has not been any industrial development south of Hastings in 41 years. With the exception of the BP site, all industrial development has occurred on Long Island and to the north of Hastings. Climte change is due to affect Hastings and Crib Point especially and any digging or bunding at the site will affect the hydrology and wildlife corridor width.
This Application for a Bitumen Storage and Transport Facility should not proceed because the associated long-term impacts on the environment and community. This is unquestionably a special area, recognized by its listing on National Estate Register, Ramsar Listing, It makes up a key part of the Westernport and Mornington Peninsula Bioregion and the area around the site itself has a Very High Significant status within the National Vegetation Framework. The application does not allow positive options for alternative development of Crib Point and surrounding areas. The application is in conflict with the planning for the area.aph.