Download Abbot Point Port and Wetland Project

20 October 2014
Referrals Gateway
Environment Assessment Branch
Department of the Environment
GPO Box 787
Canberra ACT 2601
[email protected]
Dear Sir/Madam
EPBC referral 2014/7355: Abbot Point Port and Wetland Project (the
Project)
BirdLife Australia is a highly respected science-based conservation organisation with
more than 11,000 members and more than 65,000 supporters. We have an
extensive ongoing program of conservation research, including the ‘Australian
Painted Snipe Recovery Project’ developed to halt the rapid decline the species has
undergone over the last 50 years. Shorebird and wetland experts from across
Australia and internationally have contributed to the program and its database
includes all known records of the species dating back to 1836. The project aims to
improve our understanding of the population trends and ecology of the species to
provide best practice management advice to landholders in an attempt to reverse
the declines observed.
Thank you for the opportunity to comment on the Project. BirdLife Australia has
serious concerns about the potential for the Project to have a significant, negative
impact on the Caley Valley Wetlands and in particular, on the Endangered
Australian Painted Snipe Rostratula australis.
We have also provided a submission on the related Abbot Point Dredging and
onshore placement of dredged material project (2014/7356).
In reviewing the material in referrals 2014/7355 and 2014/7356, we believe there
are strong grounds for the Minister to exercise his power under s74A of the EPBC
Act to require that the two referrals are re-referred as a single project to ensure
that the cumulative impacts of the projects are properly assessed.
We recommend a comprehensive Environmental Impact Assessment that considers
the full cumulative effects of both the Abbot Point Port and Wetland Project, and the
Abbot Point Dredging and onshore placement of dredged material. In addition, we
emphasise the need for a management plan which is retained, implemented and
adjusted as circumstances require (as opposed to an EIA which is
produced/approved and usually discarded). The management plan should include
details such as: the construction design of tidal/freshwater barriers (under rail lines
and through existing grazing bunds), and grazing (i.e., whether to eliminate grazing
or allow controlled grazing to control ponded pasture species). Finally, we suggest a
surveyed and mapped tenure of the Caley Valley Wetland.
The Project
General Comment
We note that the referral documents are little more than ‘concept designs’ that do
not provide sufficient information or detail on the current Project for the Minister to
assess the likely environmental impacts of the Project. It is unacceptable that the
Proponent has attempted to take short cuts in the assessment process by referring
to previous environmental assessments (e.g. para 1, page 10) or public
consultations (para 5, page 10) for entirely different projects as sufficient evidence
of a rigorous assessment and consultation process for the current Project.
Caley Valley Wetland – value to bird life
Caley Valley Wetlands are recognized in the Directory of Important Wetlands in
Australia (Environment Australia 2001), meeting 5 of the 6 criteria for inclusion.
The wetlands support more than 20,000 waterbirds representing154 species and
provide breeding habitat for at least 24 bird species (BirdLife Australia’s Atlas of
Australian Birds).
In the spring and summer the area is regularly used by a suite of migratory
shorebirds (16 recorded) protected under international bilateral migratory bird
agreements (CAMBA, JAMBA and ROKAMBA) and under the EPBC Act.
Caley Valley Wetlands are known to provide very high quality habitat for the
Endangered Australian Painted Snipe and the Project is likely to have a significant
impact on the species.
The Australian Painted Snipe is a nomadic wader species endemic to Australia, with
very specific habitat requirements. The species is listed as Endangered under the
Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act). It is
currently estimated that there are between 1,000 and 1,500 mature individuals.
Research indicates that the species’ area of occupancy has decreased by over 50%
in three generations, with a clear continued reduction in numbers exceeding 20%
over 2 generations. Key threats include the loss and degradation of wetlands,
especially shallow ephemeral wetlands, through drainage and the diversion of
water.
Caley Valley Wetlands has been shown to provide habitat for more than 1% of the
species population and is considered by the Recovery Program to be of very high
international significance for the species.
The nomadic nature of the population and the species’ dependence on coastal
wetlands as drought refuges emphasises the importance of the Caley Valley
Wetland for the species throughout its life cycle.
Further concerns about this referral are outlined below:
1. Much of the discussion about impacts is based on a report by BAAM 2012,
and the number of Australian Painted Snipe individuals (10) identified near
the onshore disposal option. However it is important to note that the BAAM
study was limited, given some of the sites in the northern section near the
disposal site were inaccessible and it would therefore be easy to miss this
cryptic species.
2. Construction of the rail embankment and associated pipes is described as
being designed to protect and enhance the wetland. However we are not
confident that this has been adequately assessed and consider that the
works may in fact degrade the wetland and suitability of habitat for the
Australian Painted Snipe. While it is possible to manipulate a wetland for
better bird diversity or numbers, having one or more coal haul rail lines
around more than half of the perimeter is an impediment. Similarly,
removing two shallow arms of the wetland which are likely to be some of
the best ‘Suitable Habitat’ for Australian Painted Snipe also has the
potential to have significant negative impacts. We are very concerned that
the discharge may affect less disturbed freshwater/hypersaline wetlands
fringing Upstart Bay. The infrastructure is likely to increase sedimentation
and erosion and we would like to see robust modelling on potential impacts
to the ephemeral habitat.
3. In particular, the report addresses the construction phase in relation to the
rail embankment and regulation of water flows, identifying the planned
development of a stormwater management plan and sequencing of
construction activities to limit impacts on the existing hydrological regime to
the ‘extent possible’ (p.39). However we would like to see further detail
about this, including investigation on the potential impacts of this
construction, the close proximity of the rail line to significant habitat, as
well as the regulation of flows through the pipes. The proposal for pipes
with flow valves could significantly affect hydrological conditions to the
detriment of the habitat.
4. The report states (p.20) that an area of 71.8 hectares for the Australian
Painted Snipe will be affected by this project out of a total of 5,150
hectares, implying that most of the wetland provides suitable habitat for
Australian Painted Snipe. This is extremely misleading as very little of the
wetland (<10%) provides the very shallow (< 5cm) freshwater habitat
required by the species. Suitable habitat is typically found along the
margins of the wetland. By their very nature, the two shallow arms of the
wetlands to be destroyed by the Project have a very large ratio of shoreline
to embayment and a significant amount of high quality habitat will be lost.
5. The report also states (p.38) that noise disturbance from the T1 Project has
not been an issue to date for wildlife, and therefore disturbance is unlikely
to be an issue during the construction phase of the current proposal. Again,
this assessment is based on the BAAM 2012 report, and refers to the area
adjacent to T1 which was more difficult to survey for Australian Painted
Snipe. More detail on how the proponents can be sure that construction
noise will not impact on this species in particular would be welcomed.
6. In relation to the enhanced wetland area, firstly it is difficult to remediate
such a pristine wetland to the quality of its natural state, and secondly, to
ensure that an enhanced wetland is kept in good condition would require
plans for significant and ongoing management. For example, the report
refers to ‘degraded, hypersaline land’ several times. It is highly likely that
the ‘degraded, hypersaline’ condition is the natural state in the dry season
and dryer cycles. Marine plain wetlands depend on the drying of algal mats
and ‘resting’ to fuel their huge productivity.
7. The phrase ‘enhanced wetlands’ can suggest deepened waterbody which is
likely to result in a lower diversity of bird species in the Caley Valley
Wetland. The ecosystem may become more suited to species such as Black
Swan Cygnus atratus and some ducks, but will lose value for many of the
numerous species of shallow water using migratory shorebirds which are
subject to State, Federal and International protective agreements. The
report hints at allowing for differing water levels, but needs a more
strategic plan. For example, the available wetland resources for migrant
waders on the Autumn Northward journey are extensive, but in dry spring
seasons, the suitable wetlands in the tropics can be very limited.
Management could aim to retain extensive shallow muddy areas at this
time, then drying into the summer in all but the wettest years. In regards
to Australian Painted Snipe, the report surveys show Australian Painted
Snipe recorded in the summer season; this is probably a result of very wet
years allowing wetlands to persist beyond spring. Managers could use this
as a tool in some years, but wetlands only support Australian Painted Snipe
for long periods if there is a continuum of drying muddy edges. As Caley
Valley Wetland has a small local catchment, careful attention should be paid
to retaining local rainfall inflows to support the marginal Australian Painted
Snipe habitat, and also sustaining the freshwater, tidal (High Water Spring
Tides) connection. The fresh/saltwater interface, correctly managed, will
also assist lifecycle maintenance of other catadromous species such as
barramundi and estuarine crustaceae.
8. Land-based dredge spoil ponds at harbours and other sites often create
optimal shorebird roosts, when partly filled basins have islands of spoil
surrounded by water. In other instances, conflict has arisen between
developers wishing to continue the infill process, and wader groups who
recognise an important roost. Planning for the permanent retention of
dredge spoil roosts would avoid this conflict.
9.
The report notes (p.12) that “further studies are underway to inform
specific aspects of the proposed action. The results from these studies will
feed into detailed project design and further impact assessment along with
post approval management.” On page 43 the report states that studies
specifically related to the proposed action, including: Hydrological processes
and surface water; Groundwater; Terrestrial ecology; Aquatic (wetland)
ecology; Noise; and Dust are currently underway and that an assessment
using preliminary information would appear appropriate. BirdLife Australia
considers that such a comprehensive list of studies are important to finalise
and assess properly in order to make an informed decision on this proposal.
Please do not hesitate to contact this office on (03) 9347 0757 should you require
any further information, or clarification of the information presented in this letter.
Sincerely,
Samantha Vine
Head of Conservation
Reference
Garnett, S.T., Szabo, J.K. and Dutson, G. The action plan for Australian Birds 2010.
CSIRO Melbourne (2011)