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WESTERNPORT AND PENINSULA PROTECTION COUNCIL INC

Proposed Renewable Energy Port Hastings

 
​
Westernport and Peninsula Protection Council (WPPC) is a volunteer, not-for –Profit environmental group, that was founded in 1971.
[email protected]
 
Referrals Gateway 9 July 2025
Governance and Reform Branch
Department of Climate Change, Energy, the Environment and Water
GPO Box 858
Canberra ACT 2601
Proposed Action EPBC Number: 2025/10224 – 2025 Victorian Renewable Energy Terminal
Westernport and Peninsula Protection Council Inc (WPPC) is a 54-year-old community-based local environmental group. WPPC has contributed through educational activities, submissions, collaboration and research.
Given the clear, evidence-based findings of the Federal Environment Department’s Statement of Reasons Dec 2023, in regard to the wind farm port proposal, we were somewhat reluctant to participate in the current process. This process has been perceived by some as an attempt to undermine the Federal Environment Department’s decision.
Westernport remains a significant, valuable and fragile ecological biosphere, and its viability is put at risk by this proposed action.
Location
On more than one occasion, WPPC, as a participant in the Community Reference Group for the VRET EES, has unsuccessfully requested The Port of Hastings Corporation, and The Victorian Government through DEECA, to release their rationale for choosing the Port of Hastings against other ports as their “preferred location for the VRET”. A comparative assessment is needed of other sites and their environmental and economic values. (Westernport Bay is estimated to be worth 3 billion a year in its healthy state. see our website). The Victorian Government needs to assess if there are more suitable locations capable of minimising harm to our marine and coastal habitats. Tasmania has announced a “National” wind farm export port in Port Bell Bay to service Bass Strait’s wind farms. If Victoria’s aim is to lower emissions, energy and resource use, and money, avoiding duplication is the way forward.
It’s worth noting that the multi-port option is favoured in Europe and the UK, where offshore windfarm infrastructure has successfully been rolled out in the North Sea.
Geelong Port has experience with bringing in wind turbine components for land-based wind farms. Geelong Port is privatized, but we believe that is not sufficient reason to disregard it, particularly as they’ve advised their location requires no dredging or land reclamation, and could be ready sooner than the VRET proposal in the Port of Hastings. 
In 2023 the Victorian Government named the Port of Hastings as their preferred location for a port to bring in, assemble, store and take wind turbines to a new offshore windfarm, with maintenance of Victoria’s offshore windfarm infrastructure to continue indefinitely.
Offshore wind energy is predicted to replace fossil fuel electricity generation in Victoria in the coming decades and the Port of Hastings is located close to the Gippsland offshore wind zone (120 – 190 nautical miles).
The Port of Hastings Corporation (PoHC) is a government owned entity that manages maritime operations around Westernport, and would be responsible for the construction of the Victorian Renewable Energy Terminal (VRET) at the Old Tyabb Reclamation Area (OTRA) at Long Island Point in Hastings – subject to necessary approvals.
The construction of the VRET project would involve building a new wharf, quay wall and apron, onshore landside development, land reclamation and extensive dredging of the seabed.
The Department of Climate Change, Energy, The Environment and Water decided last time that the project did not warrant approval. WPPC welcomed the decision, agreeing that it was too drastic to consider.
If The Department of Climate Change, Energy, The Environment and Water decides this time, that the revised project still does not address the points made in the Minister’s 2024 Statements of Reasons, it must not progress to the next stage of environmental assessment. If they decide that the project does merit assessment, the proposed project should be assessed as a controlled action, subject to the approval process under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act).
Action:
EPBC Number: 2025/10224 – 2025 Victorian Renewable Energy Terminal requires assessment as a ‘controlled action’ due to potential direct or indirect impacts on wetlands of international importance, listed threatened species and ecological communities and listed migratory species.
The proposed offshore wind terminal project by the Port of Hastings will involve many processes considered ‘actions’ under the EPBC Act including construction, storage or transport of materials; waste disposal; earthworks as well as site preparation and construction, vegetation clearance, operation and maintenance of a project.
The Port of Hastings is proposing construction activities and dredging of the seabed within a Ramsar listed wetland.
An action is likely to have a significant impact on the ecological character of a declared Ramsar wetland if there is a real chance or possibility that it will result in:
• areas of the wetland being destroyed or substantially modified
• a substantial and measurable change in the hydrological regime of the wetland
• the habitat or lifecycle of native species, including invertebrate fauna and fish species, dependent upon the wetland being seriously affected
• a substantial and measurable change in the water quality of the wetland – for example, the level of salinity, pollutants or nutrients in the wetland which may adversely impact on biodiversity or ecological integrity
• an invasive species that is harmful to the ecological character of the wetland being established (or an existing invasive species being spread) in the wetland.
An action will require approval if the action has, will have, or is likely to have a significant impact on a species listed in any of the following categories:
• critically endangered
• endangered
• vulnerable.
An action will also require approval if the action has, will have, or is likely to have a significant impact on an ecological community listed in any of the following categories:
• critically endangered or
• endangered.
An action is likely to have a significant impact on a migratory species if there is a real chance or possibility that it will: • substantially modify (including by fragmenting, altering nutrient cycles or altering hydrological cycles), destroy or isolate an area of important habitat for a migratory species
• result in an invasive species that is harmful to the migratory species becoming established in an area of important habitat for the migratory species
• seriously disrupt the lifecycle (breeding, feeding, migration or resting behaviour) of an ecologically significant proportion of the population of a migratory species.
The precautionary principle requires decisions, action or conduct that may have adverse environmental consequences to be properly informed and subsequent responses to be properly calibrated to risk and what is and is not known.
It is our submission that EPBC Number: 2025/10224 for the VRET in the Port of Hastings triggers the following stipulations outlined above.
 
Matter of National Environmental Significance 1 – Ramsar Wetlands:
The proposed action if it goes ahead would have significant direct or indirect impacts on the Ramsar wetlands of Western Port.
The VRET project would result in areas of the Westernport Ramsar wetland being destroyed or permanently modified.
Approximately 9.38 hectares of intertidal and subtidal seagrass is anticipated to be removed during construction. Larger areas would be likely to die due to light loss from water turbidity and smothering by sediments. Surviving sea grasses may not be able to sustain the density required to form meadows that are known to provide the habitat for juvenile fish, and feeding opportunities for shorebirds.
Flood and ebb tidal currents in Western Port are strong, particularly in the channels with strong currents of up to 1 metre per second occurring in the Lower and Upper North Arm. If the project is allowed to proceed, the waters of North Arm travel 6km north and 6 kms south with every tide, (travelling gradually clockwise around French Island) according to Peter Crockett RPS consultants for PoH Principal marine scientist. Turbidity plumes would travel with the tide.
 
Historic Seagrass mapping shows two sites closest to historic dredging[1]:
 1956 Corinella had dense seagrass cover before:
1968-1969 Long Island phase one: dredging of 153,000 cubic metres
1970 Dense Cover at Stony Point
1969 -1970 Long Island phase two 294,000 cubic metres
1971-1972 John Lysaght 676,000 cubic metres
In the 1974 photos both Corinella and Stony Point sites had dropped to medium cover
1988 Main Shipping channel  dredge spoil dropped at Tankerton 24,000 cubic metres
1989 both Corinella and Stony Point had dropped to sparse cover.[2]
 
Heterozostera nigricaulis the sub-tidal species of seagrass, with stiffer, upright stems, found in the proposed project area is found in meadows at 0-8m depth[3] and has a 50% mortality rate at 4cm to 8cm burial. [4]
Zostera muelleri the intertidal species is not going to re-establish in deepened areas. This is likely to be more sensitive to burial than Heterozostera nigricaulis, due to its floppy structure.
4 to 8 months of dredging induced sediment. Sedimentation levels are projected to be 2-4mm which is within existing background level. VRET
Sampling and digging for cores have been continuing in the background. The eroding cliffs at Lang Lang Bay and irrigation drains from the Koo Wee Rup have been shown to provide an unnatural amount of sediment. The amount of sediment moving around in 8 months of dredging, and storm water run off from the spoil site, in an area influenced by a strong tide, is likely to be greater than these high background amounts.
Turbidity levels may not return to background levels without seagrass roots holding down the muddy benthos. Seagrass, a sentinel species, may not re-establish given the depth the proponents say will be required by vessels of 11 metres. The seagrass species Heterozostera nigricaulis grows into meadows up to 8m depth.
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 an increased risk to marine habitat in the event of 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 predicting how a polluting material would impact the bay. 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.


Please see on our website https://www.wppcinc.org/  to view our commissioned report with VNPA, by 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.
https://epbcpublicportal.environment.gov.au/_entity/sharepointdocumentlocation/b5d2985b-bfad-ee11-a569-002248933951/2ab10dab-d681-4911-b881-cc99413f07b6?file=2023-09609-Statement-of-Reasons.pdf
 
 
 
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.An old estimation of Phillip Island Penguins is approximately $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.
   
    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.
 
Nutrients
 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, or events such as the disater in South Australia at present. 
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?
 

1                     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
2                     This compares to an estimated annual average load of 600 tonnes per year to Western Port
3                     Using literature measurements of N2 fixation rates, the whole bay fixes ~200 tonnes of N per year. Westernport Bay is roughly in nitrogen balance!
4                      
5                      Our Interpretation: This means as mud, and nutrients with it, are dredged up into the water column, nitrogen will become out of balance. Epiphytal algae, and potentially toxic blooms could be a serious threat to Westernport Bay. We only need to see the toxic algae bloom in South Australia to become very worried.

 
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.”


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). 
 
Westernport’s Stony Point jetty and Yaringa Harbour were assessed for invasive species Northern Pacific Seastar (Asterias amurensis) and Japanese Kelp (Undaria pinnatifida) by professional divers and remote cameras, for WPPC and Save Westernport. 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 was recently free from the two most damaging invasive pest species.
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. (Federal government 2023)
 
 The National Light Pollution Guidelines for Wildlife Including Marine Turtles, Seabirds and Migratory Shorebirds
(Light Pollution Guidelines) states that artificial light is known to adversely affect many species and ecological communities. Lights can disorient flying birds (and other fauna), particularly during migration and cause them to divert from efficient migratory routes or collide with infrastructure.
The Light Pollution Guidelines state that where there is important habitat for listed species that are known to be affected by artificial light within 20 km of a project, species specific impacts should be considered and the 20 km threshold provides a precautionary limit based on observed effects of sky glow on fledgling seabirds grounded in response to artificial light 15 km away.
While the area surrounding the proposed VRET site is already disturbed and has artificial lighting, the reclaimed land and new wharf will extend light impacts further into the Ramsar site suggesting that light pollution impacts are likely to occur which cannot be mitigated or offset.
Biofouling on the exterior of vessels visiting the VRET site would pose a risk for invasive species being introduced into Western Port. An increase in shipping would increase the risk of invasive species impacting the Ramsar wetlands.
Stormwater impacts on Western Port may result from direct coastal stormwater outlets discharging stormwater into the Ramsar wetlands due to all rainfall being captured at the OTRA site. The large volume of stormwater being discharged into a small offshore area may impact local marine species for the life   of the VRET terminal project. [5]
Matter of National Environmental Significance 2 – Listed Threatened Species and Ecological Communities:
The proposed action will have significant direct or indirect impacts on listed threatened species and ecological communities around Western Port.
Coastal Saltmarsh at the south of the Old Tyabb Reclamation Area (OTRA) site supports a substantial population of threatened Swamp Skink. Direct loss of saltmarsh on the OTRA as a result of this Project would significantly impact habitat for the Swamp Skink.
Approximately 1.341ha of the EPBC Act listed Threatened Ecological Community (TEC) Subtropical and Temperate Coastal Saltmarsh has been identified in the VRET project area as being at risk of direct loss and may result in the modification of adjacent areas of the community over time or due to indirect effects of sedimentation.
The removal of all terrestrial vegetation within the VRET project footprint will result in the loss of approximately
5 hectares of Swamp Skink habitat and potential habitat for another five EPBC listed species.
Swamp Skink are present within the Project Area on the OTRA site in the Coastal Saltmarsh vegetation.
Suitable habitat is also present in Coastal Saltmarsh immediately south of the OTRA site. This species will be directly impacted by the Project through habitat removal and potential mortality of individuals during vegetation clearing for construction. Swamp Skink are considered likely to be significantly impacted by the Project and it is likely that the species also occurs throughout the surrounding area around Long Island Point.
With the Port of Hastings operating for over 60 years, the disturbance of onshore contaminated soils within the VRET project area has the potential to release particulate and dissolved contaminants (e.g., heavy metals and organics) and nutrients into the Western Port Ramsar site and water column, with consequential toxicity effects on local marine fauna – e.g. as a result of a severe weather event during construction.
Preliminary modelling of underwater noise shows that sound pressure level exposures within 70m of piledriving and 24hr sound exposure levels over an area of 15ha around pile driving could reach levels that may cause mortal injury or mortality to fish larvae (such as Australian grayling).
Human-generated sounds from activities such as pile driving have the potential to interfere with the behaviour of terrestrial and marine fauna, particularly marine mammals that communicate and navigate using sound.
Other effects can include sensory damage to noise sensitive marine fauna and damage to swim bladders of some fish species.
Matter of National Environmental Significance 3 – Listed Migratory Species:
The proposed action will have significant direct or indirect impacts on listed migratory species around Western Port.
The construction of the Terminal will result in removal of defined important habitat for migratory shorebirds.
The function and biodiversity of mudflats and seagrass is expected to be impacted due to the VRET project such as intertidal and sub-tidal habitats for waterbirds.
The proposed action is therefore likely to result in a significant impact to migratory species by resulting in the removal or substantial modification of areas that meet the definition of important habitat.
A spill of hazardous materials into the Western Port Ramsar wetlands would have an impact on local and migratory bird populations.
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).[6]
 
 The area of the proposed action and the Disturbance Footprint
 
The Referral (POHC 2024: 3) refers to the "Project Area" of 148ha and "key onshore and marine components that would make up the project" (see POHC 2025b: Fig 2, p8), the area enclosed by blue border in Figure 2 reproduced above. The proponents state that 77% of the Project Area is located within the Western Port Ramsar Site (POHC 2024: 25). But the disturbance footprint – the area probably affected by the proposed action -Bay is not depicted on the proponent’s maps.
 
The proponents state "changes to hydrodynamics will be negligible beyond the immediate vicinity (approximately a 2 km radius around the Terminal Project Area)" (POHC 2025c: 4). This statement suggests that disturbance to hydrodynamics from the proposed action will be within a roughly semi-circular arc of 2km, from the immediate marine environment of the proposed Terminal, an area of approximately 628ha.
 
According to the DCCEEW Glossary of Definitions (2025), "Disturbance footprint" is the physical extent of a temporary change in environmental conditions that causes a pronounced change in the ecosystem. In the administration of the EPBC Act, this term is used to describe the physical extent of the impact of a proposed action on the natural environment of the site.
 
Despite the semi-circular area of changes to hydrodynamics described above and disturbance of approximately 628ha, the claimed "Disturbance Footprint" within the POHC Referral is only 76.3ha (POHC 2024: 3; see also Project Footprint, POHC 2024: 19).
 
The claim of only 76.3ha disturbance footprint is founded upon both a lack of rigour, in particular, regarding positing Limits of Acceptable Change "criteria" for the Project Area, and the false foundation assumption that the area of the proposed action is a discrete component of the Ramsar ecosystem that can be managed separately.
 
Dredging reduced 70% (Att18:5) from the original proposal. Dredge footprint 28ha ((Att18: 11) Dredging 25.5ha (Att7: 5)
 
Dredging Volume:       Option 9, 364,000(m3) (Att18: 11)
 
Depending on the outcome of further studies and refinement of the project design, there is a possibility that the berth pocket and quay wall will need to be deepened further to ensure that the seabed is stable enough to support the legs of jack up vessels. The amount of material required to be removed in this location will depend on the results of further geotechnical testing and impact assessment. (Referral: p5)
 
This statement above leaves an opening to ‘deepen the berth pocket and quay wall further’ so more than 364,000m3.
The Old Tyabb Reclamation site was where the 676,000cubic metres of dredge spoilt was dumped in 1971-1972. This material is not strong enough for a wharf so a noisy and expensive procedure for injecting concrete into the ground is proposed, after material is removed.
 
When the Victorian Government were considering building a container port in Westernport, the current material at the bottom of North Arm was not considered good enough to build a container port, so a dredger was to dump it in Bass Strait, then dredge the sand out of Bass Strait to make the container port wharf with.: (This means the total dredge volume for the Hastings concept is about 47 million cubic metres, made up of 24 million cubic metres for the channels and port area, 5 million cubic metres for the reclamation footprint and 18 million cubic metres for the sand dredged from Bass Strait to build the reclamation.[7] )
 
Westernport remains a significant, valuable and fragile ecological biosphere that benefits marine and birdlife, and the people of Melbourne.
Its future viability will be placed at significant, risk should this project be approved.
 
 References:
WPPC website
2025 Stohr Dale VRET submission
2025 Ganat Bill VRET submission
 2025 Dredging history VRET attachment 12
 2001, Ball, David, Blake, Sean,  Seagrass Mapping of Westernport MAFRI Vic and Aus Gov
 2015 Jenkins.GP, Keough.MJ, Ball.D, Cook.P. Seagrass Resilience in Port Phillip Bay Final Report
 2017 Hirst. A.J, Gain. S,  Jenkins.G.P, The Impact of burial on the survival and recovery of  Zostera nigricaulis. Aquatic Botany
2017 Securing Victoria’s Port Capacity by Infrastructure Victoria.[8]
 


[1]              2025 Dredging history VRET attachment 12

[2]              2001, Ball, David, Blake, Sean,  Seagrass Mapping of Westernport MAFRI Vic and Aus Gov

[3]              2015 Jenkins.GP, Keough.MJ, Ball.D, Cook.P. Seagrass Resilience in Port Phillip Bay Final Report

[4]              2017 Hirst. A.J, Gain. S,  Jenkins.G.P, The Impact of burial on the survival and recovery of  Zostera nigricaulis. Aquatic Botany

[5]             

[6]              [1] I
 

[7]               2017 Securing Victoria’s Port Capacity by Infrastructure Victoria.

[8]              
​
 
[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:
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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.”


  1. Port of Hastings Corporation should require regular assessments of marine pests and action to reduce or eliminate them.
  2. 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.
 
  1. 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 –
  1. 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