03 59 832 072

11th March 2016

Infrastructure Victoria

Victorian State Government

Westernport and Peninsula Protection Council’s

Submission to Infrastructure Victoria 2016.

Westernport and Peninsula Protection Council (WPPC) has been working to protect and preserve Westernport and its hinterland since 1971. We are a membership-based not-for-profit environmental group. We are concerned with protecting Westernport Bay, but this does not mean we are not concerned with impacts of developing ports in other areas of environmental value. We work in co-operation with scientists and other environmental groups and have shared ideas from a variety of documents. We have commissioned our own documents which are summarised below.

Expansion of the Port of Hastings would cause significant environmental damage and economic loss in valuable marine and coastal environments.

It is not clear from the available information that a new port is required.

Infrastructure Victoria should consider a broader sweep of options for future ports and shipping operations in Victoria to fit into a National Transport Plan.

Any plans for changes to infrastructure and operations of Victoria’s commercial ports should be consistent with the Port Phillip Bay environmental management plan (in prep), the future Marine and Coastal Act and The State Of The Bays reports (in prep.).

The projected impacts of climate, as outlined in the Victorian coastal strategy 2014, should be factored into any planning for the use of the state’s marine and coastal environments, including ports and shipping.

Port Of Hastings

The environmental risks of port operation and port development in Westernport are unacceptable and remain as potential showstoppers.

Expensive and time consuming studies have now been carried out several times over a number of years, and they all continue to ignore the warnings of the science ‘on the table’. The science is well known and the dangers it foretells well understood.

Westernport Bay
Why is the South-east Marine Region Important? 85% of the known fish and 62% of the seafloor flora are considered endemic.The cool and warm currents have for millennia prevented the migration of species. This has in turn created an environment where new species have evolved over time and are now found nowhere else on the planet.

Western Port, because of its geographical position, is a very valuable and diverse area. It encompasses several islands including two national park islands and contains three marine national parks. Much of Western Port comes under RAMSAR and UNESCO Biosphere conventions covered by international treaties and agreements.

The shore vegetation is varied according to the substrate, from seagrasses, mangroves, grasslands and forests. Water depths are subject to extensive tidal variation and conditions. Because of Western Port’s position close to Melbourne it comes under considerable pressure from population, commercial, tourist, recreational and port development activities.

The Western Port ecosystem has considerable value for its habitat and cultural amenity services. It supports a rich marine invertebrate fauna of at least 1,350 species (three or four times greater than Port Phillip).

Westernport is shallow, narrow and highly tidal, approximately 40% of its area being inter-tidal mudflats which form the basis of a highly productive and diverse ecosystem. Twice a day the bottom of 40% of the Bay is in contact with the surface making any pollutant on the surface, such as oil, coat the benthic organisms (the plants and animals on the bottom) directly.
As well as the well known colonies of penguins and Australian fur seals, the bay is host to thousands of marine species, a breeding ground for ocean fish, and the summer feeding ground for about 35 species of migrant wader birds from Siberia, China, Japan and Alaska.Almost the entire area of the bay is listed as a Ramsar wetland, and it is the largest Ramsar site in Victoria.Many of the bird species listed in the JAMBA and CAMBA agreements use the bay. The ecological significance and the sensitivity of Westernport were brought to public attention in the 1970's by a major environmental study[1], and an up to date summary of that study and of subsequent work is contained in the Westernport Bay Strategy 1992[2].

Determining the need for expanded port capacity in Victoria

One of the great difficulties in determining the need for an expanded port (container and bulk cargo) capacity in Victoria, and the need for a second container port, is that any investigation of the capacity needed, and the time frame in which it is needed, is largely influenced by industry trade projections, not an independent data source.

The maximum capacity of a port is also affected by factors such as channel depths, berth capacity, land availability and rail and road connections, and the efficiency of use of capital assets such as berths and cranes. According to the Victorian ports strategic plan12, Australia has a relatively low efficiency in the use of such assets.

'The issue is that the Hastings or an alternative port development is needed at some stage, but probably not as soon as the government would like us to believe,' Mr Van-Duyn Victoria University .

He used the example of the Port of Melbourne, which both the current Victorian government and the opposition are in favour of selling or leasing out long-term. Current volume at Melbourne is 2.5m TEU and the proposed capacity for the future (including the new 1m TEU container terminal at Webb Dock) is 5m TEU. At a growth rate of 3 to 4% full capacity could take 15 to 20 years to be achieved, but Melbourne had a decline in container volume of 2.5% in 2012/2013.

'Growth rates for container volumes in Australia (and across the world) have slowed down significantly and in my view and other experts, are not likely to vary that much in the near future.'" (see

They warn of the danger of building a failed port.

Ralph Kenyan, Mike Lean’s predecessor stated that the business case for The Port of Hastings was weak.

We don’t believe the consultants when they say we need the same amount of containers as England per year- 9 million containers. England has 60million people.Why would we ever need 9 million when less than 2million containers are processed here per year at present? Port of Melbourne will have double that capacity and should be sufficient. Even with predicted population growth they say our personal consumption will increase four times. This is incredible.

As the perceived need for capacity increases are largely for importing consumer retail goods, we can be assured that Victoria will not become a backwater if we don’t retain premier port status. If the perceived increased need for port capacity was for exports, if we were limited in some way with exports, this would have a negative effect on Victoria’s economy; whereas farmers are rightly worried that they will have to pay more for using a more expensive port.

Many of the containers brought into Melbourne are destined for interstate cities. Instead of listening to consultants that say 12 billion dollars is worth spending to retain Victoria’s Premier Port status we say we do not need more ports; we need a visionary national trade and transport strategy making use of existing deep water ports (Darwin, Brisbane) closer to our trading partners and a reinvigorated national rail and coastal shipping network. It is time to prepare for a very different future.

The Age Editorial 10th April 2014

“Rather than ploughing headlong into such a major infrastructure development, and doing so on the basis of ideology or a race to be the biggest, we urge the leaders to pause and consider the impact of all this on the amenity of people who live, work and travel through these areas every day: the people of Melbourne. Put thousands more freight trucks on inner city roads and you risk destroying the amenity of this city. Similarly, is it really the best plan to have freight trains thundering through Melbourne's suburbs, 24 hours a day, so that shipping containers can get to the other side of the city?
Both the Coalition and Labour have a more important responsibility than simply touting their preferred option at this November's state election. They must articulate how the development of a major port will be for the benefit of all Victorians. Not just for the shipping companies. Not just for political point-scorers; for everyone.
The various port plans may create, or simply retain jobs, but at what cost to the people who live here? Will these benefits outweigh the huge cost in financial, environmental and social terms? Perhaps we have to concede we do not have the right natural advantages to be a major international port. It is time for the debate to focus on the broader issues, and not just Bay West versus Hastings.”

Estimates the value of ecosystem services of Westernport Bay

The cost–benefit analysis of the proposed 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.A proper 21st Centaury economic study including the value of ecosystem services needs to be used by Infrastructure Victoria to determine the best infrastructure solutions.

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.

We asked them to establish an annual value of the ecosystem services provided by Westernport Bay. There has been a considerable body of rigorous, international, academic research work undertaken to place a value on ‘ecosystem services’ provided by marine and coastal environments.

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). 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 Tourism is worth up to 1.9 billion to the economy per year.

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 EmmalineFroggatt 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.

WPPC held an evening with ProfessorRobert Costanza at Somers Yacht Club

This was followed up with a 5 day workshop at Newhaven hosted by Preserve Westernport for stakeholders to give their input.

The scenario planning workshop was followed by a survey:

The three scenarios that had various elements of ecologically sustainable development were most favoured by survey respondents, along with the principles of environmental health and an equal society. This was also the case with the options for environmental, economic, community and built infrastructure, and the comments made in the survey’s two open ended questions.

Climate change mitigation and adaptation initiatives, the establishment of a renewable energy sector, diversified growth in ecotourism, agriculture, education and manufacturing, environmental restoration and protection projects and the linking of population to the region’s carrying capacity all received strong support.

For most respondents, protecting and conserving the environmental values of the Westernport Bay Region was central to its future.

Robert Costanza commented that this is what people all over the world want. Infrastructure Victoria should aim to develop these things.

Oil Spills

You can see on our website wppcinc.org that we and VNPA have commissioned consultants to model 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 bytruthing out on The Bay, found oil would spread widely and quickly and in some conditions reach protected areas within hours.

The report called: Quantative assessment of exposure risks due to oil spills from shipping in Westernport Bay:

pages long

See the media backgrounder summary, 4 pages.

The Age article at the time

The main point of this oil spill study is ...New research finds Hastings port expansion plan an oil spill disaster in the making.Massive development plans for Victoria’s Westernport Bay will expose the area’s globally significant marine and coastal wetlands to potentially huge damage from oil spills, new research shows.The findings have sparked calls for the Federal Government to launch an immediate environmental assessment of the Victorian Government’s port expansion plans under national conservation laws.The new research found that even relatively small amounts of oil spilled from shipping traffic in Westernport could reach local shorelines within minutes and high conservation areas within less than six hours.“We aren’t talking about oil tankers, but rather heavy fuel oil and diesel spills from container ships and port support vessels.” Simon Branigan VNPAThe research modelled six credible oil spill scenarios based on 27 previous oil spill accidents across Australia since 1970. Computer modelling tracked the spills over a two-week period from two locations within Westernport Bay.The modelling shows Phillip Island Nature Park is vulnerable to oil spill contamination, and French Island Marine National Park is also at high risk of exposure. It also highlighted the fact that once oil is in the water, it will be hard to stop.Both these parks and many other parts of the bay are home to key roosting, feeding and breeding habitats for waterbirds including annual migrants that breed in Russia, China, Japan and Alaska, spending the summer months feeding in the bay.The report was commissioned in response to the Victorian Government’s proposal to expand the Port of Hastings into an international container port, increasing shipping traffic from under 100 ships a year to more than 3000. Such an increase in shipping is likely to heighten the risk of oil spill.All of Westernport Bay is listed under the international Ramsar Convention. It is home to 32 species of migratory birds protected by international agreements, making its waters and shorelines subject to national environmental laws.“Westernport Bay is one of Victoria’s richest marine and coastal environments, and we call for the port expansion plans to have the highest level assessment available under national laws as a matter of urgency,” said Mr Branigan.The Victorian National Parks Association and the Westernport and Peninsula Protection Council are calling on federal Labor and the Coalition to commit to a comprehensive and independent assessment using the full force of national environmental laws before any further work or money is spent on expanding the port.“Westernport is Victoria’s marine playground, a unique tidal bay and wetland of international importance with remarkable environmental and recreational values right on the doorstep of Melbourne,” said Westernport and Peninsula Protection Council spokesperson Chris Chandler.“We are very concerned that the State Government’s plans to turn Westernport into an international container port will expose the bay to a spill disaster, threatening the area’s rich biodiversity including its beautiful beaches, seagrass meadows, native wildlife such as Little Penguins and Black Swan, as well as highly prized recreational fishing species King George Whiting and Snapper.”Both groups fear the port expansion will require major dredging, the clearing of mangroves to fill in parts of the bay, and road and rail transport corridors through Gippsland, the Mornington Peninsula and suburban Melbourne.Expanding the Port of Hastings poses unacceptable danger to Westernport’s unique environmental, social and recreational values. Any proper assessment must consider environmental impacts, all risks and alternative port locations with links to national transport planning.

Mr. P McGrath, Chief Executive of AMSA, stated at Spillcon 94:"other than in exceptional circumstances, current technology does not exist to prevent weather driven oil from an inshore incident coming ashore on the coastline."Westernport consists of narrow, tidal waterways around two islands, so that a ship must always be within 2 to 5 km of a coastline.Much of the time there is "weather", so current technology doesnot exist to save Westernport from a moderate or major spill. A moderate (say 550tonnes!)or major (10,000 tonnes) spill would be catastrophic, and once deposited more damage would be caused by attempted removal.
"What is the risk of a major oil spill?"[6]. To quote ANAO:"As AMSA says, 'It is only a matter of time'.The remarks made in the second and third paragraphs of this section are all especially relevant to Westernport: …."Oil may be ingested by marine and animal life and the toxic chemicals in oil, and dispersants used to treat the oil, can have a significant ecological impact.This is a particular problem in mangroves, seagrass, and reef areas where it is difficult to remove the oil."….."Spilled oil can have a serious economic impact on coastal activities such as tourism and the fishing industry."
Also relevant to Westernport Bay in the ANAO report is the observation[7]that:…."The National Plan Review identified that swift currents and high tidal velocities severely limit the opportunity for physical response (use of booms and skimmers) throughout Torres Strait and Northern Territory waters." These conditions also apply in Westernport, where tides run at up to 5 knots along the narrow arms of the bay. These conditions render the use of booms largely ineffective.The alternative response tool pointed to in the audit for Torres Strait and Northern Territory, namelydispersant,should also be regarded as generally unacceptable in Westernport, due to its toxicity. Thus the two principal oil-spill response tools will be generally unavailable in Westernport.