[email protected]
www.wppcinc.org
16/07/2024
Westernport and Peninsula Protection Council (WPPC) is a volunteer, not-for –Profit environmental group, that was founded in 1971. We have participated in Port of Hastings community consultation for years.
We are submitting to the 2024 strategy by commenting on the 2018 strategy, rather than having being given a draft 2024 to comment on, which is unusual, and perhaps a great opportunity. We hope that the nadir of low-priority-environmental-stewardship-attitudes is behind us, as the understanding that the fact that The Westernport Bay is important ecologically, shallow and vulnerable has been so clearly spelt out by The Federal Government through Minister Plibersek’s Department this year. Before this the Infrastructure Victoria rejected building of a container port in Hastings, mainly because of the depth of Westernport would necessitate unthinkable amounts of dredging. The Port of Hastings needs to face reality that the potential of port expansion in Westernport Bay is limited by those three characteristics.
Your survey asks us to prioritise a range of Environment and Sustainability Topics.
We put Ensuring Environmental Protection and Management of Impacts first.
1.Large ships should not enter Upper North Arm without tidal assistance.
2.Alternatives to using large ships in Westernport Bay should be investigated. Tasmania has plans for its own wind farms, and some of their ports are naturally deep, and service Bass Strait. The Port of Hastings should encourage The Victorian State Government to thoroughly investigate using a Tasmanian port as a renewable energy terminal, as an alternative to shallow Westernport.
3.The Port of Hastings Development Authority should avoid plans that involve capital dredging.
Is Westernport Bay a Naturally deep-water port?
No, Western port has a partially deep shipping channel, but around 42% of WP is above water during low tide. 1.6 million m3 has been dredged as part of Port-related development and maintenance since 1964, with another 1.14 million m3 dredged for non-Port related purpose (jetties, boat ramp, marina).[1]
Dredging Infrastructure Victoria confirmed the amount of dredging needed for a container in Westernport Bay to be 23 million cubic metres and 24 million in Bass Strait, 47 million cubic metres all up. The former Port of Hastings Development Authority CEO Mike Lean, stated that the Port of Hastings is a “natural, deep-water port” even though his authority calculated, but did not release, estimates of the dredging needed to build a port. These word “natural deep-water port” appear to have been, generated by the spin doctors employed by the now disbanded Port of Hastings Development Authority and repeated by Liberal Party figures. It has confused the public, and people in positions of authority alike. The Port of Hastings Development Authority scandalously spent money on public relations companies in a failed attempt to manipulate Victoria into buying their flawed container Port Plan.
I, Tanya Plibersek Department of Climate Change, Energy, The Environment and Water provide the following Statement of Reasons for a decision that the action is clearly unacceptable under the EPBC Act 1999.
That the proposed action by PoH Corporation to develop and operate a port facility to serve as a base for the assembly of components for offshore wind farms would have clearly unacceptable impacts on a matter protected by part 3 of the EPBC Act. document as well.
From Within the development footprint the following activities are proposed:
Clearance of vegetation on the existing reclaimed land site 25 ha which is outside of, but adjacent to the Western port Ramsar Wetland (WPRW)
Reclamation of the seabed 29ha......
Development on the existing and newly reclaimed lands, with heavy duty pavements and approximately 2ha for warehousing etc.
Dredging up to 92 ha
I note and accept the advice..., that a key ecological characteristic of the WPRW is the extensive (approx. 270km2) intertidal mudflats ...These mudflats underpin the food webs that support migratory species and other marine fauna. I accept the department’s advice that these intertidal mudflats are a critical component of WPRW’s ecological character and contribute to and determine a number of other components, processes, benefits and services, such as food sources and nursery habitat for migratory birds, fish and marine species.
.......The department considers, and I agree, that the direct or indirect loss of any intertidal mudflats throughout WPRW caused by the proposed action will be an unacceptable impact.
Further, dredging directly contributes to increased sedimentation flow and turbidity, which would impact the intertidal mudflats of the WPRW...., directly decreasing the ability for flora species (namely saltmarsh, seagrass, and mangrove habitats...) to undertake critical ecological processes such as photosynthesis..........this impact ... is unacceptable as it will lead to a direct reduction in area of occupancy of these species.
I note and accept that the pattern of clockwise water circulation within the WPRW would amplify the impacts of toxicant suspension and poor water quality, and the flow of these contaminants throughout the WPRW system presents an unacceptable risk to seagrass, waterbirds and marine invertebrates.
The ECD states that “Pollution is a significant risk and could result from oil and chemical spills, discharge of ballast water, shipping accidents ... Bilge water, litter... oils spills.
pollution from increased shipping and wharf activities, combined with sedimentation from dredging will cause substantial and measurable change to the physio-chemical status of the WPRW.
8th March 2017
Dear Daniel Andrews, Infrastructure Victoria and the State Opposition,
The groups represented by their logos on this letter endorse the following:
Bass Coast Shire Council's Agreed Principles on the Impact of a Hastings Container Port:
--------------------------------------------------------------------------------------------------------------
1. We are opposed to any form of capital dredging, widening or deepening of channels in Westernport Bay.
2. Any change in, or continuation of, the Port of Hastings operations must result in no net loss for the economy, environment and amenity.
3. The Victorian Government and Infrastructure Victoria must demonstrate and justify the need and timing for a second major container port in Victoria through comprehensive, evidence-based assessment, including consideration of the current port capacity in Victoria, and via a national approach.
4. Independently verified, scientific research must form the basis of any recommendation for a second container port location in Victoria to ensure that the environmental impact is known, understood and shared with the community. Of equal importance are economic and social impacts. Specifically independent research must be undertaken on the impact on:
a) Coastline including increased erosion and inundation
b) Tourism and the impact on visitation
c)Fishing and the impact on the recreational fishing industry
d)Marine life impact including penguins and whales that enter Western Port
5. All previous research undertaken in relation to the expansion of the Port of Hastings, as well as to project and research scoping material and documents, must be made publically available with full access.
6. The recommendation of Infrastructure Victoria to the Victorian Government on the timing and location of a second container port requires a strategic government approach to fully consider the implications on:
a) Tourism impact on domestic and international visitations
b) Environment
c)Economic development including impact on aquifers that service food production areas
d)Fisheries including recreational fishing and the industry it supports
e) Recreation
yours faithfully,
Karri Giles
Secretary
Westernport and Peninsula Protection Council
On behalf of Westernport and Peninsula Protection Council, Southern Peninsula Indigenous Flora and Fauna Association, Friends of The Earth, Blue Wedges, Environment Victoria, Surfriders Foundation, Victorian National Parks Association, Preserve Westernport and French Island Port Stoppers.
Footprint of the Port.
Hydrodynamic studies, known since the seventies have shown us that water spreads quickly because of the fast tides in Westernport and no area is isolated.
Tidal movements mean oil spills, marine pest larvae, and dredge spoil would not stay confined to the proposed port area. Western Port is a massive tidal wetland. Through the middle of the seagrass-covered mudflats runs the shipping channel, which surges with the tidal flows bringing the waters of the port into contact with the sensitive ecosystem. The water moves on each tide a distance of 10 to 20 kilometres and, over weeks, circulates around French Island - a giant washing machine. Based on observations of water movements, in The Shapiro Study, Professor Jon Hinwood and his colleagues designed a model that predicted how a polluting material. For example, the cloud of fine particles of silt produced by dredging - would spread around the whole bay within a few weeks. The inevitable polluting effects of port development and port operation - anywhere in the bay would in a short time affect the whole bay.
You can see on our website wppcinc.org that we and VNPA have commissioned consultants: Asia-Pacific Applied Science Associates (APASA), the leading oil spill modelling consultants in Australia for industry, government and Marine Safety Victoria. They modelled the effects of a relatively small oil spill from a ship in Western Port. The modelling did not study a major accident involving a spill from an oil tanker, but rather focused on the effects of a smaller spill of transport fuels (there have been 27 similar spills in 43 years in Australia).
The work, which was backed up by truthing out on The Bay, found oil would spread widely and quickly and in some conditions reach protected areas within hours.
Oil Spill Scenarios can be seen by pressing the relevant button on our website on our oil and Westernport Page. www.wppcinc.org They represent the hydrodynamic movement of water and can equally applied to the movement of marine pest larvae or a turbidity plume.
This is echoed By Tanya Plibersek Minister for The Department of Climate Change, Energy, The Environment and Water
Statement of Reasons for a decision that the action is clearly unacceptable. 18 December 2023.
Birds
Impact of proposed Port of Hastings expansion on the birdlife of Westernport.
http://vnpa.org.au/admin/library/attachments/PDFs/media%20backgrounders/bgr-oilspill-wport-birdspecies.pdf
• The potential for a single oil spill to have serious short and long-term impacts on migratory shorebird populations in Westernport is of great concern. The bay is one of the most important shorebird sites in Victoria, shorebirds are under considerable existing pressure throughout their range and their populations are known to be declining.
• Typically penguins are the birds most affected by oil spills. Little Penguins are at high risk of oiling and subsequent death from oil spills at McHaffies Reef. Phillip Island Penguins are worth approx $30,000 each.
• Seabirds foraging in the waters of Lower North Arm would be at high risk of oiling from spills at either Long Island Point jetty or McHaffies Reef. It is likely that large numbers of these birds would die. Large numbers of swans and ducks would also be at high risk of partial oiling. Hooded Plover on the northern beaches of Phillip Island are also susceptible to oil spills, particularly from spills at McHaffies Reef.
• Vessel-generated waves can impact on the productivity of seagrass beds and erode shorelines, impacting on foraging resources for birds such as swans, ducks and shorebirds.
• Land reclamation, dredging and the disposal of dredge spoil are likely to impact on the productivity of seagrass beds and benthic fauna, which would then impact on foraging resources for aquatic birds, such as waterfowl and fishers. The current risk of oil spill impacts was identified as a major threat at sites along the western coastline of French Island, at Hastings and Long Reef in 2011. The 270km2 of intertidal mudflats of Westernport Bay that provide foraging resources for thousands of shorebirds and waterbirds are at high risk of extensive, long-term contamination from any oil spill. Westernport is a site of international significance for aquatic birds and listed under the Ramsar Convention and other international bird treaties. Its extensive intertidal mudflats and wetlands regularly support more than 10,000 migratory shorebirds and 10,000 waterfowl, including 32 bird species listed under the Environment.
The report also finds waves generated by ships can have an impact on the productivity of seagrass beds and erode shorelines, which are again crucial for swans, ducks and shorebirds to forage. Also, reclaiming land and dredging is likely to affect seagrass beds.
Seagrass
The second report, by marine ecologist Dr Hugh Kirkman, studied the potential risks to the bay's seagrass, mangroves and saltmarsh communities. If a minor oil spill occurred all three could be damaged, depending on weather and tidal conditions. Mangroves are highly susceptible, and could be killed by spilt oil within weeks
Impact of proposed Hastings port expansion on seagrass Mangroves and saltmarsh. Kirkman 2014
Summarized: http://vnpa.org.au/admin/library/attachments/PDFs/media%20backgrounders/bgr-wport-seagrass-mangrove-saltmarsh.pdf
Westernport seagrass beds suffered die-off of up to two-thirds of the entire area in 1981-90. The main reason for this die-off was turbidity caused by suspended sediments. The recovery from catastrophe is progressing, but has taken decades.
The mangroves and seagrass beds are excellent absorbers of CO2. They are threatened by pollution from agricultural chemicals (pesticides and nutrients) and sediments causing epiphyte growth that smothers the seagrass. Microalgal growth blocks out light, preventing photosynthesis which eventually produces hydrogen sulphide and further prevents vegetation growth.
Suspended sediments threaten seagrass and other life forms by seriously reducing sunlight, adding nutrients that stimulate algae growth, and reduce oxygen levels threatening eutrophication. [3]
Seagrass habitat is crucial in driving fisheries production, contributing to %90 of the total nutrition of key fisheries target species.[4]
The roots of Seagrass and mangroves stabilise the sediments and provide oxygen, and where they have died back at the north of The Bay crabs and shell-fish dig air holes- providing oxygen to the muddy bottom of Westernport Bay. These crabs and shell-fish live off plant matter brought to them on the tides.
Turbidity
Many of the reports published in the collection of environmental and social reports referenced by Infrastructure Victoria mention turbidity as a threat. We agree with this assessment. The basic reality is that turbidity kills seagrass and once dead, seagrass cannot hold down sediment so the re-suspension of sediment increases, killing more seagrass, thus a vicious cycle is created. Seagrass must be kept alive for Westernport Bay to function properly.
The health of the benthos (bottom of The Bay) is crucial for absorbing the nutrients entering the water column from Shipping, stormwater or suspended sediments. Nutrients that are in excess create potentially toxic algae blooms and lower oxygen levels threatening eutrophication. 3
Recent Melbourne Water Westernport Seminars also highlighted the importance of seagrass and the benthic organisms that they support in Westernport Bay.
Perran Cook and Jeff Ross Presented Nutrient transformations on intertidal flats of Western Port Bay for the Monash University Water Studies Centre for Melbourne Water. They explained that the benthic organisms in the mud flats provide the oxygenated sites where nutrient transformation occurs: specifically nitrogen, is converted from nitrogen in the water to harmless nitrogen gas. It pointed out that Westernport Bay has a nitrogen balance at present.
How does de-nitrification and nitrogen fixation compare to N loads for the whole Bay?
Assuming the area of Northern Western Port is 70 km2 and scaling up the rates measured in this study (~10 g N m-2 y-1), then the annual rate of denitrification is ~700 tonnes N per year
This compares to an estimated annual average load of 600 tonnes per year to Western Port
Using literature measurements of N2 fixation rates, the whole bay fixes ~200 tonnes of N per year. Bay is roughly in balance!
The key finding of another report done by Melbourne Water and Monash Uni. Preliminary assessment of water quality requirements of seagrasses in Western Port was the importance of Total Suspended Solids (TSS) and/or light availability for seagrass distribution with the higher the TSS value, the sparser the seagrass.
Following the Inquiry one of Australia’s leading geomorphologists Associate Professor David Kennedy of the University of Melbourne considered the Victoria University findings and the Western Port Local Coastal Hazard Assessment in response to the Container Port Proposal reports. This is certainly relevant to the Renewable Energy Hub proposal.
Professor Kennedy has since stated: “I can conclude that the proposed development is almost certain to have major environmental impacts on the marine and coastal environment of Western Port Bay
“There would be immediate effects from dredging particularly associated with suspended sediment and its impact on the benthic intertidal and sub-tidal communities. A larger concern is the changes in hydrodynamics and associated sediment movement that will be associated with the development.”
“There is a very high risk of greatly increased erosion throughout the northern, western and southern shores of Western Port including the eastern shoreline of Bass Coast around Coronet Bay and the Phillip Island north shore. A general lack of knowledge of sediment transport pathways within the Bay means the potential impacts could be more widespread than inferred here as there is likely be strong connectively between sedimentary systems around the entire bay.”
Still from Yaringa Marine Pest Survey for WPPC by Fathom Pacific
Still from Stony Point Marine Pest Survey for WPPC conducted by Fathom Pacific
In 2019 WPPC and Save Westernport successfully applied through the Commonwealth Stronger Communities Environmental Grant program, and the local Member for Flinders, Mr Greg Hunt MP, for funding to allow underwater surveys for invasive Marine pest species to be carried out under BlueScope pier because we were concerned that Kawasaki was due to begin its pilot exporting hydrogen in Westernport Bay, without addressing the risk of introducing invasive marine pests.
WPPC initiated a letter to Kawasaki Heavy Industries, endorsed by eight local environmental groups, requesting the urgent monitoring for marine pests at the project site at BlueScope Hastings pier. https://drive.google.com/file/d/12knec8EN4-v8xrMycrgrUU7m1TIsZ0cM/view?usp=drivesdk
Because early detection and removal are the only effective means of preventing infestations, when Kawasaki declined our request, we decided to develop our own project.
Several years ago, BlueScope stopped sending Marine scientist Jan Watson under their pier to monitor for toxicity, she kept a look out for other species. The Port of Hastings Development Authority did not require or carry out its own regular assessment of marine pests from commercial shipping.
When BlueScope refused access to our professional divers from Fathom Pacific, we had to change our project location.
Westernport’s Stony Point jetty and Yaringa Harbour were assessed for invasive species Northern Pacific Seastar (Asterias amurensis) and Japanese Kelp (Undaria pinnatifida) by our professional divers and remote cameras. Professor Adrian Flynn from Fathom Pacific produced a report of their findings.
https://drive.google.com/file/d/1qqbdp9DHQadZK5h90gX1lM2c-kdmXkYQ/view?usp=drivesdk
Recent government surveys found no signs of the species at San Remo and Hastings Marina, and during their EES surveys, AGL recorded neither species at Crib Point jetty, nor a large area in lower North Arm. Parks Vic have worked on both The Cowes Jetty and Flinders Jetty recently with neither of these species found.
This suggests that Westernport’s marine environment remains free from the two most damaging invasive pest species.
After writing to Kawasaki and meeting with them, and answering questions about our project, in 2021 we welcomed news from Kawasaki confirming their decision to assess the BlueScope jetty for signs of marine species before, during and after the Hydrogen Energy Supply Chain pilot, or shipping trial.
Letter from Kawasaki
https://drive.google.com/file/d/1fSnLi0cV1zbFyAhsaVX0aINfIuPhEEFz/view?usp=drivesdk
This was carried out in 2022. ‘The marine-pest survey The Hydrogen Energy Supply Chain conducted under BlueScope pier was next to useless because it omitted one of the two key species: northern pacific seastar.’ Karri said. ‘We want to know if marine pests came in with the Hydrogen Energy Supply Chain Pilot Vessel Suiso Frontier, so they can be cleaned up. San Remo, Cowes, Yaringa, Hastings, Crib Pt, Stony Pt and some of Flinders’s pier have been surveyed lately and these two key species were not present. Are they under BlueScope? Why did their survey and leave out Northern Pacific Seastar? If these species are not present, we demand an environmental bond be paid by Japan before this project proceeds. The cost of monitoring and cleaning-up inevitable infestations should not be met by the Australian public. Better yet scrap this project.’
Ships coming in from the Temperate waters of the Japanese area hold a special risk because the larvae and spores finds themselves in water of a suitable temperature and can take hold. The infestations in Tasmania and Port Phillip Bay have shocked marine users and scientists with the speed of their spread and the disappearance of native flora and fauna, including fish.
WPPC suspect some of the 80 million dollars given to the Port of Hastings Development Authority during the Baillieu/ Napthine Governments was spent on public relations firms to aid in the suppression of studies, such as the link between fish stocks and northern Pacific seastar.
The next priorities from your 2024 hard copy survey we put:
6. Design and develop port infrastructure using sustainable building practices,
7. and Ensuring compliance with environmental regulations and industry best practice governing port operations
8. and Preserve Cultural Heritage.
Does that mean you build any future expansion out of recycled glass instead of sand? Digging sand up for concrete isn’t sustainable.
It would be great to hear of where The POH is at with aboriginal cultural heritage.
Social Topics
2024 hard copy survey includes social topics to prioritize. The most important are information flow and safety. Esso’s operations are potentially dangerous and Long Island has a limit to the number of people allowed in case it blows. WPPC were told about seven years ago by a contractor that Esso have not been maintaining their pipes and it makes it more likely an explosion will take place.
9. Port of Hastings to require Esso to prove safety and maintenance compliance.
Population
10.Port of Hastings Corporation should oppose current population growth rates. A key driver of environmental decline is rapid population growth. Victoria's population growth rate of 1.9 per cent last year. The Queensland academic Jane O'Sullivan points out that maintaining infrastructure in a population growing at 2 per cent doubles the infrastructure cost for governments, who have only 2 per cent extra taxpayers to pay for it. The task of keeping up with the infrastructure requirements of a rapidly growing population is impossible.
11.We have an obligation under Rio to foster intergenerational equity. The Port of Hastings should adopt the United Nations sustainable development goals.
Economic Priorities
From your 2024 hard copy survey we prioritise –
Government subsidies are ridiculously high, and scandalous for the fossil fuel industry. [2] The failure of most of the development proposals in Westernport have been because the business cases were weak, not through community opposition. Though the community do expect value for money. The CSIRO 1996 Port Phillip Bay Study found that if Port Phillip Bay went anoxic it would be economically disastrous and the government would fall. Westernport Bay is too precious to lose too, in its current state because it is so economically valuable to have a diverse abundant, sheltered bay right next to a big city. It is economically valuable to have healthy saltmarsh, seagrass and mangroves.
The cost–benefit analysis of the expansion of the Port of Hastings must include the extent to which the value of the ecosystem is likely to be compromised – in other words, the cost penalty of the expansion paid in the diminishing of this value needs to be worked out.
14.A proper 21st Century economic study including the value of ecosystem services needs to be used by leading organisations, and The Victoria Government to determine the best infrastructure solutions.
The commissioner of Environmental sustainability is doing some economic valuation of Westernport Bay currently.
The Westernport and Peninsula Protection Council (WPPC) commissioned a study by New Economics Advisory Service of the Australian Conservation Foundation (ACF). It is on our website Estimating the value of ecosystem services of Westernport Bay ACF 2014.
http://vnpa.org.au/admin/library/attachments/PDFs/Reports/rpt-ecosystem_service_value_westernportBay.pdf
The ACF based its study on a study conducted in 2006 by Costanza et al., which calculated estimates for ecosystem service benefits using annual values per acre per ecosystem type.
The ACF study estimated that Westernport Bay generates ecosystem services valued at between $205 million and $2.6 billion per year. The specific values include commercial fishing ($50 thousand per year) recreational fishing ($46 million per year). Ten years ago, tourism from Philip Island alone added approximately $393 million per year to the study. Since this report was published Tourism Victoria release estimate of Phillip Island and Bass Coast Tourism in 2022 is worth up to $753 million to the economy per year. Kilcunda to Inverloch is roughly comparable to Lang Lang to Flinders- the rest of Westernport Tourism, so already we need to take away $393 million and add $753 million.
Since this report the value of carbon sequestration that seagrass and mangroves provide is proven to be much greater than previously thought.
The Victorian government is considering collecting Blue Carbon Credits to fund the management of Westernport Bay.
The Distribution and Abundance of ‘Blue Carbon’ within Port Phillip and Westernport A report for the Port Phillip & Westernport Catchment Management Authority Commissioned by Emmaline Froggatt February 2015 Authors: Paul Carnell, Carolyn Ewers, Ellen Rochelmeyer, Richard Zavalas, Bruce Hawke. The above report states that:
The Port Phillip and Westernport catchment contains a significant portion of the blue carbon ecosystems present across Victoria. And many other vegetated coastal habitat locations are under threat from anthropogenic influences. The saltmarsh and mangroves at Hastings were among the highest sediment carbon stocks within the catchment. Yet, saltmarsh, mangroves, and seagrass at Hastings are potentially under threat from the planned Port of Hastings development. While the project is in the planning and approval phase, any proposal to remove or negatively impact these vegetated coastal habitats (and thus their carbon stocks) should be taken into account before proceeding.
Therefore, our estimation of the value of Westernport Bay is worth at least $3 billion per year, in its healthy state.
Many expensive and time-consuming studies have now been carried out several times over a number of years. It is good that Tanya Plibersek’s Department has uncovered some of the science “on the table”. The science is well-known and the dangers it foretells well understood. It is important that The Port of Hastings is no longer out-of-step with reality. The 2024 Port of Hastings Development Strategy should be completely different to the 2018 one.
Karri Giles
Secretary
Westernport and Peninsula Protection Council Inc
[1] [1] Infrastructure Victoria: Port of Hastings Development Project, Dredging History in Western Port, March 2015, p. iii.
[2] Gergis Joelle 2024 Highway to Hell Quarterly Essay
[email protected]
www.wppcinc.org
16/07/2024
Westernport and Peninsula Protection Council (WPPC) is a volunteer, not-for –Profit environmental group, that was founded in 1971. We have participated in Port of Hastings community consultation for years.
We are submitting to the 2024 strategy by commenting on the 2018 strategy, rather than having being given a draft 2024 to comment on, which is unusual, and perhaps a great opportunity. We hope that the nadir of low-priority-environmental-stewardship-attitudes is behind us, as the understanding that the fact that The Westernport Bay is important ecologically, shallow and vulnerable has been so clearly spelt out by The Federal Government through Minister Plibersek’s Department this year. Before this the Infrastructure Victoria rejected building of a container port in Hastings, mainly because of the depth of Westernport would necessitate unthinkable amounts of dredging. The Port of Hastings needs to face reality that the potential of port expansion in Westernport Bay is limited by those three characteristics.
Your survey asks us to prioritise a range of Environment and Sustainability Topics.
We put Ensuring Environmental Protection and Management of Impacts first.
1.Large ships should not enter Upper North Arm without tidal assistance.
2.Alternatives to using large ships in Westernport Bay should be investigated. Tasmania has plans for its own wind farms, and some of their ports are naturally deep, and service Bass Strait. The Port of Hastings should encourage The Victorian State Government to thoroughly investigate using a Tasmanian port as a renewable energy terminal, as an alternative to shallow Westernport.
3.The Port of Hastings Development Authority should avoid plans that involve capital dredging.
Is Westernport Bay a Naturally deep-water port?
No, Western port has a partially deep shipping channel, but around 42% of WP is above water during low tide. 1.6 million m3 has been dredged as part of Port-related development and maintenance since 1964, with another 1.14 million m3 dredged for non-Port related purpose (jetties, boat ramp, marina).[1]
Dredging Infrastructure Victoria confirmed the amount of dredging needed for a container in Westernport Bay to be 23 million cubic metres and 24 million in Bass Strait, 47 million cubic metres all up. The former Port of Hastings Development Authority CEO Mike Lean, stated that the Port of Hastings is a “natural, deep-water port” even though his authority calculated, but did not release, estimates of the dredging needed to build a port. These word “natural deep-water port” appear to have been, generated by the spin doctors employed by the now disbanded Port of Hastings Development Authority and repeated by Liberal Party figures. It has confused the public, and people in positions of authority alike. The Port of Hastings Development Authority scandalously spent money on public relations companies in a failed attempt to manipulate Victoria into buying their flawed container Port Plan.
I, Tanya Plibersek Department of Climate Change, Energy, The Environment and Water provide the following Statement of Reasons for a decision that the action is clearly unacceptable under the EPBC Act 1999.
That the proposed action by PoH Corporation to develop and operate a port facility to serve as a base for the assembly of components for offshore wind farms would have clearly unacceptable impacts on a matter protected by part 3 of the EPBC Act. document as well.
From Within the development footprint the following activities are proposed:
Clearance of vegetation on the existing reclaimed land site 25 ha which is outside of, but adjacent to the Western port Ramsar Wetland (WPRW)
Reclamation of the seabed 29ha......
Development on the existing and newly reclaimed lands, with heavy duty pavements and approximately 2ha for warehousing etc.
Dredging up to 92 ha
I note and accept the advice..., that a key ecological characteristic of the WPRW is the extensive (approx. 270km2) intertidal mudflats ...These mudflats underpin the food webs that support migratory species and other marine fauna. I accept the department’s advice that these intertidal mudflats are a critical component of WPRW’s ecological character and contribute to and determine a number of other components, processes, benefits and services, such as food sources and nursery habitat for migratory birds, fish and marine species.
.......The department considers, and I agree, that the direct or indirect loss of any intertidal mudflats throughout WPRW caused by the proposed action will be an unacceptable impact.
Further, dredging directly contributes to increased sedimentation flow and turbidity, which would impact the intertidal mudflats of the WPRW...., directly decreasing the ability for flora species (namely saltmarsh, seagrass, and mangrove habitats...) to undertake critical ecological processes such as photosynthesis..........this impact ... is unacceptable as it will lead to a direct reduction in area of occupancy of these species.
I note and accept that the pattern of clockwise water circulation within the WPRW would amplify the impacts of toxicant suspension and poor water quality, and the flow of these contaminants throughout the WPRW system presents an unacceptable risk to seagrass, waterbirds and marine invertebrates.
The ECD states that “Pollution is a significant risk and could result from oil and chemical spills, discharge of ballast water, shipping accidents ... Bilge water, litter... oils spills.
pollution from increased shipping and wharf activities, combined with sedimentation from dredging will cause substantial and measurable change to the physio-chemical status of the WPRW.
8th March 2017
Dear Daniel Andrews, Infrastructure Victoria and the State Opposition,
The groups represented by their logos on this letter endorse the following:
Bass Coast Shire Council's Agreed Principles on the Impact of a Hastings Container Port:
--------------------------------------------------------------------------------------------------------------
1. We are opposed to any form of capital dredging, widening or deepening of channels in Westernport Bay.
2. Any change in, or continuation of, the Port of Hastings operations must result in no net loss for the economy, environment and amenity.
3. The Victorian Government and Infrastructure Victoria must demonstrate and justify the need and timing for a second major container port in Victoria through comprehensive, evidence-based assessment, including consideration of the current port capacity in Victoria, and via a national approach.
4. Independently verified, scientific research must form the basis of any recommendation for a second container port location in Victoria to ensure that the environmental impact is known, understood and shared with the community. Of equal importance are economic and social impacts. Specifically independent research must be undertaken on the impact on:
a) Coastline including increased erosion and inundation
b) Tourism and the impact on visitation
c)Fishing and the impact on the recreational fishing industry
d)Marine life impact including penguins and whales that enter Western Port
5. All previous research undertaken in relation to the expansion of the Port of Hastings, as well as to project and research scoping material and documents, must be made publically available with full access.
6. The recommendation of Infrastructure Victoria to the Victorian Government on the timing and location of a second container port requires a strategic government approach to fully consider the implications on:
a) Tourism impact on domestic and international visitations
b) Environment
c)Economic development including impact on aquifers that service food production areas
d)Fisheries including recreational fishing and the industry it supports
e) Recreation
yours faithfully,
Karri Giles
Secretary
Westernport and Peninsula Protection Council
On behalf of Westernport and Peninsula Protection Council, Southern Peninsula Indigenous Flora and Fauna Association, Friends of The Earth, Blue Wedges, Environment Victoria, Surfriders Foundation, Victorian National Parks Association, Preserve Westernport and French Island Port Stoppers.
Footprint of the Port.
Hydrodynamic studies, known since the seventies have shown us that water spreads quickly because of the fast tides in Westernport and no area is isolated.
Tidal movements mean oil spills, marine pest larvae, and dredge spoil would not stay confined to the proposed port area. Western Port is a massive tidal wetland. Through the middle of the seagrass-covered mudflats runs the shipping channel, which surges with the tidal flows bringing the waters of the port into contact with the sensitive ecosystem. The water moves on each tide a distance of 10 to 20 kilometres and, over weeks, circulates around French Island - a giant washing machine. Based on observations of water movements, in The Shapiro Study, Professor Jon Hinwood and his colleagues designed a model that predicted how a polluting material. For example, the cloud of fine particles of silt produced by dredging - would spread around the whole bay within a few weeks. The inevitable polluting effects of port development and port operation - anywhere in the bay would in a short time affect the whole bay.
You can see on our website wppcinc.org that we and VNPA have commissioned consultants: Asia-Pacific Applied Science Associates (APASA), the leading oil spill modelling consultants in Australia for industry, government and Marine Safety Victoria. They modelled the effects of a relatively small oil spill from a ship in Western Port. The modelling did not study a major accident involving a spill from an oil tanker, but rather focused on the effects of a smaller spill of transport fuels (there have been 27 similar spills in 43 years in Australia).
The work, which was backed up by truthing out on The Bay, found oil would spread widely and quickly and in some conditions reach protected areas within hours.
Oil Spill Scenarios can be seen by pressing the relevant button on our website on our oil and Westernport Page. www.wppcinc.org They represent the hydrodynamic movement of water and can equally applied to the movement of marine pest larvae or a turbidity plume.
This is echoed By Tanya Plibersek Minister for The Department of Climate Change, Energy, The Environment and Water
Statement of Reasons for a decision that the action is clearly unacceptable. 18 December 2023.
Birds
Impact of proposed Port of Hastings expansion on the birdlife of Westernport.
http://vnpa.org.au/admin/library/attachments/PDFs/media%20backgrounders/bgr-oilspill-wport-birdspecies.pdf
• The potential for a single oil spill to have serious short and long-term impacts on migratory shorebird populations in Westernport is of great concern. The bay is one of the most important shorebird sites in Victoria, shorebirds are under considerable existing pressure throughout their range and their populations are known to be declining.
• Typically penguins are the birds most affected by oil spills. Little Penguins are at high risk of oiling and subsequent death from oil spills at McHaffies Reef. Phillip Island Penguins are worth approx $30,000 each.
• Seabirds foraging in the waters of Lower North Arm would be at high risk of oiling from spills at either Long Island Point jetty or McHaffies Reef. It is likely that large numbers of these birds would die. Large numbers of swans and ducks would also be at high risk of partial oiling. Hooded Plover on the northern beaches of Phillip Island are also susceptible to oil spills, particularly from spills at McHaffies Reef.
• Vessel-generated waves can impact on the productivity of seagrass beds and erode shorelines, impacting on foraging resources for birds such as swans, ducks and shorebirds.
• Land reclamation, dredging and the disposal of dredge spoil are likely to impact on the productivity of seagrass beds and benthic fauna, which would then impact on foraging resources for aquatic birds, such as waterfowl and fishers. The current risk of oil spill impacts was identified as a major threat at sites along the western coastline of French Island, at Hastings and Long Reef in 2011. The 270km2 of intertidal mudflats of Westernport Bay that provide foraging resources for thousands of shorebirds and waterbirds are at high risk of extensive, long-term contamination from any oil spill. Westernport is a site of international significance for aquatic birds and listed under the Ramsar Convention and other international bird treaties. Its extensive intertidal mudflats and wetlands regularly support more than 10,000 migratory shorebirds and 10,000 waterfowl, including 32 bird species listed under the Environment.
The report also finds waves generated by ships can have an impact on the productivity of seagrass beds and erode shorelines, which are again crucial for swans, ducks and shorebirds to forage. Also, reclaiming land and dredging is likely to affect seagrass beds.
Seagrass
The second report, by marine ecologist Dr Hugh Kirkman, studied the potential risks to the bay's seagrass, mangroves and saltmarsh communities. If a minor oil spill occurred all three could be damaged, depending on weather and tidal conditions. Mangroves are highly susceptible, and could be killed by spilt oil within weeks
Impact of proposed Hastings port expansion on seagrass Mangroves and saltmarsh. Kirkman 2014
Summarized: http://vnpa.org.au/admin/library/attachments/PDFs/media%20backgrounders/bgr-wport-seagrass-mangrove-saltmarsh.pdf
Westernport seagrass beds suffered die-off of up to two-thirds of the entire area in 1981-90. The main reason for this die-off was turbidity caused by suspended sediments. The recovery from catastrophe is progressing, but has taken decades.
The mangroves and seagrass beds are excellent absorbers of CO2. They are threatened by pollution from agricultural chemicals (pesticides and nutrients) and sediments causing epiphyte growth that smothers the seagrass. Microalgal growth blocks out light, preventing photosynthesis which eventually produces hydrogen sulphide and further prevents vegetation growth.
Suspended sediments threaten seagrass and other life forms by seriously reducing sunlight, adding nutrients that stimulate algae growth, and reduce oxygen levels threatening eutrophication. [3]
Seagrass habitat is crucial in driving fisheries production, contributing to %90 of the total nutrition of key fisheries target species.[4]
The roots of Seagrass and mangroves stabilise the sediments and provide oxygen, and where they have died back at the north of The Bay crabs and shell-fish dig air holes- providing oxygen to the muddy bottom of Westernport Bay. These crabs and shell-fish live off plant matter brought to them on the tides.
Turbidity
Many of the reports published in the collection of environmental and social reports referenced by Infrastructure Victoria mention turbidity as a threat. We agree with this assessment. The basic reality is that turbidity kills seagrass and once dead, seagrass cannot hold down sediment so the re-suspension of sediment increases, killing more seagrass, thus a vicious cycle is created. Seagrass must be kept alive for Westernport Bay to function properly.
The health of the benthos (bottom of The Bay) is crucial for absorbing the nutrients entering the water column from Shipping, stormwater or suspended sediments. Nutrients that are in excess create potentially toxic algae blooms and lower oxygen levels threatening eutrophication. 3
Recent Melbourne Water Westernport Seminars also highlighted the importance of seagrass and the benthic organisms that they support in Westernport Bay.
Perran Cook and Jeff Ross Presented Nutrient transformations on intertidal flats of Western Port Bay for the Monash University Water Studies Centre for Melbourne Water. They explained that the benthic organisms in the mud flats provide the oxygenated sites where nutrient transformation occurs: specifically nitrogen, is converted from nitrogen in the water to harmless nitrogen gas. It pointed out that Westernport Bay has a nitrogen balance at present.
How does de-nitrification and nitrogen fixation compare to N loads for the whole Bay?
Assuming the area of Northern Western Port is 70 km2 and scaling up the rates measured in this study (~10 g N m-2 y-1), then the annual rate of denitrification is ~700 tonnes N per year
This compares to an estimated annual average load of 600 tonnes per year to Western Port
Using literature measurements of N2 fixation rates, the whole bay fixes ~200 tonnes of N per year. Bay is roughly in balance!
The key finding of another report done by Melbourne Water and Monash Uni. Preliminary assessment of water quality requirements of seagrasses in Western Port was the importance of Total Suspended Solids (TSS) and/or light availability for seagrass distribution with the higher the TSS value, the sparser the seagrass.
Following the Inquiry one of Australia’s leading geomorphologists Associate Professor David Kennedy of the University of Melbourne considered the Victoria University findings and the Western Port Local Coastal Hazard Assessment in response to the Container Port Proposal reports. This is certainly relevant to the Renewable Energy Hub proposal.
Professor Kennedy has since stated: “I can conclude that the proposed development is almost certain to have major environmental impacts on the marine and coastal environment of Western Port Bay
“There would be immediate effects from dredging particularly associated with suspended sediment and its impact on the benthic intertidal and sub-tidal communities. A larger concern is the changes in hydrodynamics and associated sediment movement that will be associated with the development.”
“There is a very high risk of greatly increased erosion throughout the northern, western and southern shores of Western Port including the eastern shoreline of Bass Coast around Coronet Bay and the Phillip Island north shore. A general lack of knowledge of sediment transport pathways within the Bay means the potential impacts could be more widespread than inferred here as there is likely be strong connectively between sedimentary systems around the entire bay.”
- Port of Hastings Corporation should require regular assessments of marine pests and action to reduce or eliminate them.
- Any new project that involves ship movements from known marine pest areas should include an environmental bond to help with the cost of a clean-up.
Marine Pests An increase in shipping means an increase in the threat of marine pests. Westernport Bay had 7 species of marine pest in 1997, none of them major marine pests. Corio Bay in Port Phillip and Derwent River Hobart are two bays that have Dry Bulk facilities used buy Woodchip Ships from Japan where the Northern Pacific Seastars originate. Northern Pacific Sea stars in Port Phillip Bay have been identified as a contributor to the dramatic loss of commercial fish stocks in Port Phillip Bay. In the last fifteen years or so fish stocks in the middle of the Bay, where these creatures dominate, have fallen by 20% (conservatively) [5] We are so lucky that Westernport Bay is not also swamped with these pests. No sane person would propose a dry bulk facility for Westernport Bay that instituted ships from the Japanese seas.
Still from Yaringa Marine Pest Survey for WPPC by Fathom Pacific
Still from Stony Point Marine Pest Survey for WPPC conducted by Fathom Pacific
In 2019 WPPC and Save Westernport successfully applied through the Commonwealth Stronger Communities Environmental Grant program, and the local Member for Flinders, Mr Greg Hunt MP, for funding to allow underwater surveys for invasive Marine pest species to be carried out under BlueScope pier because we were concerned that Kawasaki was due to begin its pilot exporting hydrogen in Westernport Bay, without addressing the risk of introducing invasive marine pests.
WPPC initiated a letter to Kawasaki Heavy Industries, endorsed by eight local environmental groups, requesting the urgent monitoring for marine pests at the project site at BlueScope Hastings pier. https://drive.google.com/file/d/12knec8EN4-v8xrMycrgrUU7m1TIsZ0cM/view?usp=drivesdk
Because early detection and removal are the only effective means of preventing infestations, when Kawasaki declined our request, we decided to develop our own project.
Several years ago, BlueScope stopped sending Marine scientist Jan Watson under their pier to monitor for toxicity, she kept a look out for other species. The Port of Hastings Development Authority did not require or carry out its own regular assessment of marine pests from commercial shipping.
When BlueScope refused access to our professional divers from Fathom Pacific, we had to change our project location.
Westernport’s Stony Point jetty and Yaringa Harbour were assessed for invasive species Northern Pacific Seastar (Asterias amurensis) and Japanese Kelp (Undaria pinnatifida) by our professional divers and remote cameras. Professor Adrian Flynn from Fathom Pacific produced a report of their findings.
https://drive.google.com/file/d/1qqbdp9DHQadZK5h90gX1lM2c-kdmXkYQ/view?usp=drivesdk
Recent government surveys found no signs of the species at San Remo and Hastings Marina, and during their EES surveys, AGL recorded neither species at Crib Point jetty, nor a large area in lower North Arm. Parks Vic have worked on both The Cowes Jetty and Flinders Jetty recently with neither of these species found.
This suggests that Westernport’s marine environment remains free from the two most damaging invasive pest species.
After writing to Kawasaki and meeting with them, and answering questions about our project, in 2021 we welcomed news from Kawasaki confirming their decision to assess the BlueScope jetty for signs of marine species before, during and after the Hydrogen Energy Supply Chain pilot, or shipping trial.
Letter from Kawasaki
https://drive.google.com/file/d/1fSnLi0cV1zbFyAhsaVX0aINfIuPhEEFz/view?usp=drivesdk
This was carried out in 2022. ‘The marine-pest survey The Hydrogen Energy Supply Chain conducted under BlueScope pier was next to useless because it omitted one of the two key species: northern pacific seastar.’ Karri said. ‘We want to know if marine pests came in with the Hydrogen Energy Supply Chain Pilot Vessel Suiso Frontier, so they can be cleaned up. San Remo, Cowes, Yaringa, Hastings, Crib Pt, Stony Pt and some of Flinders’s pier have been surveyed lately and these two key species were not present. Are they under BlueScope? Why did their survey and leave out Northern Pacific Seastar? If these species are not present, we demand an environmental bond be paid by Japan before this project proceeds. The cost of monitoring and cleaning-up inevitable infestations should not be met by the Australian public. Better yet scrap this project.’
Ships coming in from the Temperate waters of the Japanese area hold a special risk because the larvae and spores finds themselves in water of a suitable temperature and can take hold. The infestations in Tasmania and Port Phillip Bay have shocked marine users and scientists with the speed of their spread and the disappearance of native flora and fauna, including fish.
WPPC suspect some of the 80 million dollars given to the Port of Hastings Development Authority during the Baillieu/ Napthine Governments was spent on public relations firms to aid in the suppression of studies, such as the link between fish stocks and northern Pacific seastar.
The next priorities from your 2024 hard copy survey we put:
6. Design and develop port infrastructure using sustainable building practices,
7. and Ensuring compliance with environmental regulations and industry best practice governing port operations
8. and Preserve Cultural Heritage.
Does that mean you build any future expansion out of recycled glass instead of sand? Digging sand up for concrete isn’t sustainable.
It would be great to hear of where The POH is at with aboriginal cultural heritage.
Social Topics
2024 hard copy survey includes social topics to prioritize. The most important are information flow and safety. Esso’s operations are potentially dangerous and Long Island has a limit to the number of people allowed in case it blows. WPPC were told about seven years ago by a contractor that Esso have not been maintaining their pipes and it makes it more likely an explosion will take place.
9. Port of Hastings to require Esso to prove safety and maintenance compliance.
Population
10.Port of Hastings Corporation should oppose current population growth rates. A key driver of environmental decline is rapid population growth. Victoria's population growth rate of 1.9 per cent last year. The Queensland academic Jane O'Sullivan points out that maintaining infrastructure in a population growing at 2 per cent doubles the infrastructure cost for governments, who have only 2 per cent extra taxpayers to pay for it. The task of keeping up with the infrastructure requirements of a rapidly growing population is impossible.
11.We have an obligation under Rio to foster intergenerational equity. The Port of Hastings should adopt the United Nations sustainable development goals.
- Port of Hastings should invest back into the engineering profession, for example through Cadetship graduate programs.
Economic Priorities
From your 2024 hard copy survey we prioritise –
- Ensuring that infrastructure development is economically viable.
Government subsidies are ridiculously high, and scandalous for the fossil fuel industry. [2] The failure of most of the development proposals in Westernport have been because the business cases were weak, not through community opposition. Though the community do expect value for money. The CSIRO 1996 Port Phillip Bay Study found that if Port Phillip Bay went anoxic it would be economically disastrous and the government would fall. Westernport Bay is too precious to lose too, in its current state because it is so economically valuable to have a diverse abundant, sheltered bay right next to a big city. It is economically valuable to have healthy saltmarsh, seagrass and mangroves.
The cost–benefit analysis of the expansion of the Port of Hastings must include the extent to which the value of the ecosystem is likely to be compromised – in other words, the cost penalty of the expansion paid in the diminishing of this value needs to be worked out.
14.A proper 21st Century economic study including the value of ecosystem services needs to be used by leading organisations, and The Victoria Government to determine the best infrastructure solutions.
The commissioner of Environmental sustainability is doing some economic valuation of Westernport Bay currently.
The Westernport and Peninsula Protection Council (WPPC) commissioned a study by New Economics Advisory Service of the Australian Conservation Foundation (ACF). It is on our website Estimating the value of ecosystem services of Westernport Bay ACF 2014.
http://vnpa.org.au/admin/library/attachments/PDFs/Reports/rpt-ecosystem_service_value_westernportBay.pdf
The ACF based its study on a study conducted in 2006 by Costanza et al., which calculated estimates for ecosystem service benefits using annual values per acre per ecosystem type.
The ACF study estimated that Westernport Bay generates ecosystem services valued at between $205 million and $2.6 billion per year. The specific values include commercial fishing ($50 thousand per year) recreational fishing ($46 million per year). Ten years ago, tourism from Philip Island alone added approximately $393 million per year to the study. Since this report was published Tourism Victoria release estimate of Phillip Island and Bass Coast Tourism in 2022 is worth up to $753 million to the economy per year. Kilcunda to Inverloch is roughly comparable to Lang Lang to Flinders- the rest of Westernport Tourism, so already we need to take away $393 million and add $753 million.
Since this report the value of carbon sequestration that seagrass and mangroves provide is proven to be much greater than previously thought.
The Victorian government is considering collecting Blue Carbon Credits to fund the management of Westernport Bay.
The Distribution and Abundance of ‘Blue Carbon’ within Port Phillip and Westernport A report for the Port Phillip & Westernport Catchment Management Authority Commissioned by Emmaline Froggatt February 2015 Authors: Paul Carnell, Carolyn Ewers, Ellen Rochelmeyer, Richard Zavalas, Bruce Hawke. The above report states that:
The Port Phillip and Westernport catchment contains a significant portion of the blue carbon ecosystems present across Victoria. And many other vegetated coastal habitat locations are under threat from anthropogenic influences. The saltmarsh and mangroves at Hastings were among the highest sediment carbon stocks within the catchment. Yet, saltmarsh, mangroves, and seagrass at Hastings are potentially under threat from the planned Port of Hastings development. While the project is in the planning and approval phase, any proposal to remove or negatively impact these vegetated coastal habitats (and thus their carbon stocks) should be taken into account before proceeding.
Therefore, our estimation of the value of Westernport Bay is worth at least $3 billion per year, in its healthy state.
Many expensive and time-consuming studies have now been carried out several times over a number of years. It is good that Tanya Plibersek’s Department has uncovered some of the science “on the table”. The science is well-known and the dangers it foretells well understood. It is important that The Port of Hastings is no longer out-of-step with reality. The 2024 Port of Hastings Development Strategy should be completely different to the 2018 one.
Karri Giles
Secretary
Westernport and Peninsula Protection Council Inc
[1] [1] Infrastructure Victoria: Port of Hastings Development Project, Dredging History in Western Port, March 2015, p. iii.
[2] Gergis Joelle 2024 Highway to Hell Quarterly Essay
