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Referral Business Entry Point Environment Assessment Branch Sustainability, Environment, Water, Population and Communities GPO Box 787 CANBERRA ACT 2601 [email protected] Tuesday, 14 July 2015 RE: EPBC reference number 2015/7510 Ezion Offshore Logistics Hub (Tiwi) Pty Ltd/Transport water/Port Melville Marine Supply Base, Melville Island/NT/Operation of a marine supply base Dear Minister Hunt, I write in regards to the the Port Melville marine supply base project, which has been referred to you to decide whether assessment under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) is required for its operation. The Environment Centre of the Northern Territory (NT) is the peak community sector environment organisation in the Northern Territory. The mission of the Environment Centre NT is to protect and restore biodiversity, ecosystems and ecological processes, foster sustainable living and development, and cut greenhouse gas emissions and build renewable energy capacity. The Environment Centre NT was very disappointed to discover through the media that the proponent, Ezion, failed to refer this development for consideration under the EPBC Act prior to construction proceeding, given the clear threat it poses to matters of national significance, including a number of threatened species found in the area. The operation of the Marine Supply Base poses a new set of different threats which place the area’s surrounding pristine marine and coastal environment further at risk. Allowing this major development to proceed without any form of environmental impact assessment would make a mockery of the EPBC Act. Such an assessment would allow for a comprehensive review of Matters of National Environmental Significance (MNES), and assess all the following important environmental issues that are currently triggered by the proposed project: This development could have a significant impact upon MNES, including Tel: (08) 8981 1984 | Fax: (08) 8941 0387 | [email protected] | http://www.ecnt.org/ Postal: GPO Box 2120, Darwin NT 0801 | Office: Unit 3/98 Woods Street, Darwin Northern Territory - Australia • • • Listed threatened species and communities, Listed migratory species; and The proximity of Garig Gunak Barlu National Park Some 38 threatened species are found in the area, including 19 fauna species and 19 flora species (NT Government, 2009). The NT Government (ND) notes: “The Tiwi Islands support about 20 endemic plant and vertebrate animal taxa, and about 44 taxa considered threatened at Territory or national level (including 14 taxa listed under the EPBCA). The bioregion contains important breeding sites for marine turtles and colonial seabirds. …..There is currently no conservation security for most of the region’s important colonial seabird rookeries and nesting sites for marine turtles. These should be better protected, at least through management agreements with their Aboriginal landowners.” The site is a critical breeding site for Olive Ridley and Flatback turtles, as well as a foraging site for dugong and several species of turtles, seabirds and dolphins. In Tiwi Islands Sites of Conservation Significance, the NT Government (2009) states: “Sandy beaches on the Tiwi Islands, particularly the west coast of Bathurst Island and the north coast of Melville Island, are highly important for marine turtle nesting. Nesting is dominated by Flatback and Olive Ridley Turtles, but Green Turtles and Hawksbill Turtles also nest on Tiwi beaches. Seagull Island and the north-west coast of Melville Island are notable for significant numbers of nesting Olive Ridley Turtles (Chatto and Baker 2008). ….Five seabird breeding colonies are reported on small off-shore islands within this site (Chatto 2001). Counts of about 60 000 Crested Terns (Chatto 2001; Dutson 2006) in one colony on Seagull Island (S009), off the north-west coast of Melville Island, are internationally significant (>1% global population; G. Dutson in prep.) and believed to be the world’s largest breeding colony of this species (G. Dutson in prep.). Three colonies (S018, S138, S146) are considered of National significance for breeding records of Little Tern (Chatto 2001).” The Tiwi Islands Council states in its Natural Resource Management Strategy that Woinarksi et al (2003) reported “the Tiwi Islands have outstanding values for fauna conservation”, including 542 native fauna species, with 18 considered endangered or vulnerable at either a Territory or national level. Tel: (08) 8981 1984 | Fax: (08) 8941 0387 | [email protected] | http://www.ecnt.org/ Postal: GPO Box 2120, Darwin NT 0801 | Office: Unit 3/98 Woods Street, Darwin Northern Territory - Australia The Strategy refers to five species of turtle listed as threatened under EPBC Act. The endangered Olive Ridley turtle and vulnerable Flatback Turtle are already under threat from boat strike, habitat loss, ghost nets and fishing activities. The Tiwi Islands are in close proximity to the Gurig Gunak Barlu National Park, a Commonwealth area, and form part of the Tiwi Cobourg Bioregion. The islands are an important refuge for many species in critically low numbers on the mainland, including the Butler’s Dunnart, False Water Rat and Red Goshawk (NT Government, 2009). Greater research is required to ascertain the specific conservation values and species threatened by the operation of the Marine Supply Base. We are very concerned about the following impacts associated with operations of the Marine Supply Base which pose a significant threat to MNES: 1) The Aspley Strait, within which the Marine Supply Base is located is very narrow and rocky, which is likely to necessitate dredging and/or blasting of the surrounding marine environment to allow for shipping – this in turn would cause sedimentation, damage to reef and seismic impacts. 2) The site is subject to strong tidal currents and highly vulnerable to cyclones, meaning there is a high risk of shipping accidents and oil spills which in turn cause damage to surrounding reef and marine species, including threatened species (Olive Ridley Turtle, Flatback Turtle) and seabird rookeries, including an internationally listed seabird colony at the eastern entrance to the channel. 3) Increased potential for vessel strike on marine threatened and migratory species, due to a 20% increase in shipping during 2015 -2019 by vessels up to 200 m in length, poses a significant threat to turtles and cetaceans in particular. 4) The three large fuel tanks which have already been installed without any environmental impact assessment, pose a risk to the environment if severe weather or human error cause a rupture of these tanks. This may cause increased pollution and reduced water quality as a result of poorly managed runoff, spills associated with the inadequate bund walls and on site storage of 30.795 million litres of diesel, fracking chemicals, soil fumigants and pesticides (friction reducers, stabilizers, surfactants; corrosion inhibitors, and biocides such as glutaraldehyde, dibromo, and nitrilopropionamide). 5) Increased light, noise and vibration at the site, increased road traffic and spread of weeds could pose a threat to the Tiwi Masked Owl and Brush-Tailed Rabbit Rat, which are also recorded in the area. The spread of invasive exotic grasses may affect a number of ecosystems on the islands and will potentially change the fire regime. (NT Government, 2009). 6) High biosecurity risk of introduction of pests and diseases through increased boat and vehicle traffic. Remote Indigenous communities such as Pirlangimbi and Milikapiti are particularly vulnerable to diseases such as Dengue fever, Malaria, Japanese encephalitis and Ross River virus. Marine pests have the potential to cause damage to the relatively pristine Tel: (08) 8981 1984 | Fax: (08) 8941 0387 | [email protected] | http://www.ecnt.org/ Postal: GPO Box 2120, Darwin NT 0801 | Office: Unit 3/98 Woods Street, Darwin Northern Territory - Australia marine environment surrounding the site, as well as threaten aquaculture industries. Other invasive species such as the newly eradicated Tropical Red Ant, Yellow Crazy Ant and the Cane Toad also pose an increased threat through greater boat activity. There is a high risk of spread of the African Big-headed Ant to other areas of the island through increased traffic. (Tiwi Land Council, 2003) 7) Erosion and runoff caused by ongoing disturbance may impact upon surrounding vegetation communities and water quality at the port site. 8) The lack of detailed independent research to support the proponent’s claim that operation of the Marine Supply Base will not have a significant impact upon matters of national significance, including threatened species, migratory species and the Gurig Gunak Barlu National Park. Australia is a party to the UN Convention on Biological Diversity. Under the UNCBD the Precautionary Principle must be employed where there is insufficient scientific information available about a risk posed to the environment. The proponent, Ezion, has not acted in good faith by failing to refer this proposal prior to construction. For this reason the Environment Centre NT is not confident that Ezion is capable or willing to manage environmental impacts of this development if it does not undergo any formal environmental impact assessment. Operation of the Tiwi Islands Marine Supply Base poses a significant threat to MNES. The high conservation values of the area alone at the very least warrant an assessment. The Environment Centre NT calls on you to require Environmental Impact Assessment of Ezion Offshore Logistics Hub (Tiwi) Pty Ltd/Transport - water/Port Melville Marine Supply Base, Melville Island/NT/Operation of a marine supply base under the EPBC Act as a controlled action. Sincerely, Anna Boustead Acting Director e. [email protected] m. 0406 145 953 Tel: (08) 8981 1984 | Fax: (08) 8941 0387 | [email protected] | http://www.ecnt.org/ Postal: GPO Box 2120, Darwin NT 0801 | Office: Unit 3/98 Woods Street, Darwin Northern Territory - Australia