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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)