SMITH BAY WHARF DRAFT ENVIRONMENTAL …...expansion of its proposal that makes a mockery of the Major Development process. KIPT is a proponent with no track record and no capabilities

SMITH BAY WHARF DRAFT ENVIRONMENTAL IMPACT STATEMENT RESPONSE by Yumbah Aquaculture

MAY 2019

SMITH BAY WHARF DRAFT ENVIRONMENTAL IMPACT STATEMENT RESPONSE by Yumbah Aquaculture

3 Smith Bay Wharf Environmental Impact Statement Yumbah Response

DISCLAIMER

This report has been prepared by Yumbah Aquaculture Ltd and may only be used and relied on by the South Australian Department of Planning and Infrastructure for the sole purpose of providing a public comment on the Environmental Impact Statement prepared by Kangaroo Island Plantation Timbers Limited for a “Deep Water Port Facility at Smith Bay, Kangaroo Island”.

All intellectual property rights, including copyright, in documents and reports created by, or for, Yumbah Aquaculture Ltd remain the property of the company. Except for the use by the Department stated above, any use of such documents or reports without the prior written approval of Yumbah Aquaculture Ltd will constitute an infringement of the rights of the company which reserves all legal rights and remedies in respect of any such infringement. Whilst Yumbah has made reasonable efforts to ensure the accuracy of third party sources, to the extent permitted by law, it disclaims any liability associated with such sources. In certain cases, the opinions stated are the views of Yumbah (and not any individual employee or agent of Yumbah) and are not intended as a substitute for comprehensive professional advice.


CONTENTS

EXECUTIVE SUMMARY ........................................................................................................... 5

INTRODUCTION ....................................................................................................................... 10

EPBC ACT - MATTERS OF NATIONAL ENVIRONMENT SIGNIFICANCE (MNES) ........ 12

COAST AND MARINE .............................................................................................................. 21

BIOSECURITY .......................................................................................................................... 49

ECONOMY ................................................................................................................................ 61

AIR QUALITY ........................................................................................................................... 65

ALTERNATIVE LOCATION: ................................................................................................... 70

ALTERNATIVE STRUCTURES (IN WATER) ......................................................................... 76

COMMUNITY ........................................................................................................................... 83

NATIVE VEGETATION AND FAUNA ................................................................................... 89

TRAFFIC & TRANSPORT ....................................................................................................... 92

WATER ...................................................................................................................................... 96

NOISE & LIGHT ....................................................................................................................... 101

CLIMATE CHANGE & SUSTAINABILITY ........................................................................... 108

RISKS & HAZARDS ................................................................................................................. 111

INFRASTRUCTURE ................................................................................................................ 117

ABORIGINAL & OTHER HERITAGE .................................................................................... 121

GEOLOGY & SOILS ............................................................................................................... 125

BUILT FORM & DESIGN ....................................................................................................... 130

CONSTRUCTION & OPERATION ....................................................................................... 135


DISCLAIMER

This report has been prepared by Yumbah Aquaculture Ltd and may only be used and relied on by the South Australian Department of Planning and Infrastructure for the sole purpose of providing a public comment on the Environmental Impact Statement prepared by Kangaroo Island Plantation Timbers Limited for a “Deep Water Port Facility at Smith Bay, Kangaroo Island”.

All intellectual property rights, including copyright, in documents and reports created by, or for, Yumbah Aquaculture Ltd remain the property of the company. Except for the use by the Department stated above, any use of such documents or reports without the prior written approval of Yumbah Aquaculture Ltd will constitute an infringement of the rights of the company which reserves all legal rights and remedies in respect of any such infringement. Whilst Yumbah has made reasonable efforts to ensure the accuracy of third party sources, to the extent permitted by law, it disclaims any liability associated with such sources. In certain cases, the opinions stated are the views of Yumbah (and not any individual employee or agent of Yumbah) and are not intended as a substitute for comprehensive professional advice.


CONTENTS

EXECUTIVE SUMMARY ........................................................................................................... 5

INTRODUCTION ....................................................................................................................... 10

EPBC ACT - MATTERS OF NATIONAL ENVIRONMENT SIGNIFICANCE (MNES) ........ 12

COAST AND MARINE .............................................................................................................. 21

BIOSECURITY .......................................................................................................................... 49

ECONOMY ................................................................................................................................ 61

AIR QUALITY ........................................................................................................................... 65

ALTERNATIVE LOCATION: ................................................................................................... 70

ALTERNATIVE STRUCTURES (IN WATER) ......................................................................... 76

COMMUNITY ........................................................................................................................... 83

NATIVE VEGETATION AND FAUNA ................................................................................... 89

TRAFFIC & TRANSPORT ....................................................................................................... 92

WATER ...................................................................................................................................... 96

NOISE & LIGHT ....................................................................................................................... 101

CLIMATE CHANGE & SUSTAINABILITY ........................................................................... 108

RISKS & HAZARDS ................................................................................................................. 111

INFRASTRUCTURE ................................................................................................................ 117

ABORIGINAL & OTHER HERITAGE .................................................................................... 121

GEOLOGY & SOILS ............................................................................................................... 125

BUILT FORM & DESIGN ....................................................................................................... 130

CONSTRUCTION & OPERATION ....................................................................................... 135

Smith Bay Wharf Environmental Impact Statement Yumbah Response 1


ABBREVIATIONS (continued)

KICRVMP

KIDP

KIFA

KIPT

MAZ

MNES

NAGD

NOEC

NTU

OEMP

OHS

OIE

PAR

PIRSA

POMS

PSD

PSP

TAPM

TDS

TOC

TSS

Yumbah KI

Kangaroo Island Council Roadside Vegetation Management Plan

Kangaroo Island Development Plan

Kangaroo Island Futures Authority

Kangaroo Island Plantation Timbers

Marine Activity Zone

Matters of National Environmental Significance

National Assessment Guideline for Dredging

No Observed Effect Concentration

Nephelometric Turbidity Unit

Operational Environmental Management Plan

Occupational Health and Safety

World Organisation for Animal Health

Photosynthetically Active Radiation

Primary Industries and Regions, South Australia

Pacific Oyster Mortality Syndrome

Particle Size Distribution

Paralytic Shellfish Poisoning

The Air Pollution Model

Total Dissolved Solid

Total Organic Carbon

Total Suspended Solids

Yumbah Kangaroo Island


ABBREVIATIONS

ANZECC

ARMCANZ

AVG

BGL

BIA

CCA

CEMP

COD

CSD

DAC

DAWR

DEW

DMP

DO

DPTI

EEZ

EIS

EMP

EPA

EPBC

FTE

GRP

(Australian and New Zealand Environment and Conservation Council)

Agriculture and Resource Management Council of Australia and New Zealand

Abalone Viral Ganglioneuritis

Below Ground Level

Biologically Important Area

Copper Chrome Arsenate

Construction Environmental Management Plan

Chemical Oxygen Demand

Cutter Suction Dredge

Development Assessment Commission

Department of Agriculture and Water Resources

Department for Environment and Water

Dredge Management Plan

Dissolved Oxygen

Department of Planning, Transport and Infrastructure

Exclusive Economic Zone

Environmental Impact Statement

Environment Management Plan

Environmental Protection Authority

Environment Protection and Biodiversity Conservation

Full Time Equivalent

Gross Regional Product

Smith Bay Wharf Environmental Impact Statement Yumbah Response2


ABBREVIATIONS (continued)

KICRVMP

KIDP

KIFA

KIPT

MAZ

MNES

NAGD

NOEC

NTU

OEMP

OHS

OIE

PAR

PIRSA

POMS

PSD

PSP

TAPM

TDS

TOC

TSS

Yumbah KI

Kangaroo Island Council Roadside Vegetation Management Plan

Kangaroo Island Development Plan

Kangaroo Island Futures Authority


Marine Activity Zone

Matters of National Environmental Significance

National Assessment Guideline for Dredging

No Observed Effect Concentration

Nephelometric Turbidity Unit

Operational Environmental Management Plan

Occupational Health and Safety

World Organisation for Animal Health

Photosynthetically Active Radiation

Primary Industries and Regions, South Australia

Pacific Oyster Mortality Syndrome

Particle Size Distribution

Paralytic Shellfish Poisoning

The Air Pollution Model

Total Dissolved Solid

Total Organic Carbon

Total Suspended Solids



ABBREVIATIONS

ANZECC

ARMCANZ

AVG

BGL

BIA

CCA

CEMP

COD

CSD

DAC

DAWR

DEW

DMP

DO

DPTI

EEZ

EIS

EMP

EPA

EPBC

FTE

GRP

(Australian and New Zealand Environment and Conservation Council)

Agriculture and Resource Management Council of Australia and New Zealand

Abalone Viral Ganglioneuritis

Below Ground Level

Biologically Important Area

Copper Chrome Arsenate

Construction Environmental Management Plan

Chemical Oxygen Demand

Cutter Suction Dredge

Development Assessment Commission

Department of Agriculture and Water Resources

Department for Environment and Water

Dredge Management Plan

Dissolved Oxygen

Department of Planning, Transport and Infrastructure

Exclusive Economic Zone

Environmental Impact Statement

Environment Management Plan

Environmental Protection Authority

Environment Protection and Biodiversity Conservation

Full Time Equivalent

Gross Regional Product



EXECUTIVE SUMMARY

THE SMITH BAY PROPOSAL

Kangaroo Island Plantation Timbers (KIPT) proposes a deep-water seaport at Smith Bay, in a remote corner of Kangaroo Island (KI), just over the fence from Yumbah Aquaculture’s onshore abalone farm.

This is a destructive proposal that fails the pub test, let alone the requisite scientific rigour required of the proponent.

It’s a proposal brought by a company that somehow convinced a previous South Australian Government that it should be accorded status as a Major Development.

Having achieved that, the proponent then set about persistent modification and expansion of its proposal that makes a mockery of the Major Development process.

KIPT is a proponent with no track record and no capabilities in building or managing infrastructure, conducting a profitable business, or operating sustainably in a highly sensitive natural environment.

It is an ASX-listed shell, propped up by sequential capital raisings, employing just four staff in 2018, and led by a Managing Director who proudly told eminent finance journalist, Alan Kohler, that “… nothing in life has equipped me to run a forestry company”.

KIPT chooses the expense of Supreme Court lawfare against its neighbours Yumbah over matters its draft Environmental Impact Statement (EIS) says don’t matter.

It is an entity managed from Sydney that has no social licence on Kangaroo Island, and an overly ambitious vision it expects KI ratepayers or South Australian taxpayers to underwrite.

A 12.5-KILOGRAM OPINION EDITORIAL

Independent experts of good academic and scientific standing consulted by Yumbah Aquaculture, whose work appears in this document, have assessed the draft EIS.

In polite terms, they have many questions to ask KIPT and the South Australian Government, questions that aren’t answered in the draft EIS, or have been raised in their thorough review.

In less polite terms, the expert consensus is that KIPT’s draft EIS is a 12.5-kilogram opinion editorial looking for a publisher.

It should be marked “fail” – but not sent back for a repeat.

Having failed to mount a case for Smith Bay, KIPT must be directed elsewhere – as Kangaroo Island Council has voted – to one of the many possible alternative Island sites its draft EIS dismisses out of hand.



EXECUTIVE SUMMARY

THE SMITH BAY PROPOSAL

Kangaroo Island Plantation Timbers (KIPT) proposes a deep-water seaport at Smith Bay, in a remote corner of Kangaroo Island (KI), just over the fence from Yumbah Aquaculture’s onshore abalone farm.

This is a destructive proposal that fails the pub test, let alone the requisite scientific rigour required of the proponent.

It’s a proposal brought by a company that somehow convinced a previous South Australian Government that it should be accorded status as a Major Development.

Having achieved that, the proponent then set about persistent modification and expansion of its proposal that makes a mockery of the Major Development process.

KIPT is a proponent with no track record and no capabilities in building or managing infrastructure, conducting a profitable business, or operating sustainably in a highly sensitive natural environment.

It is an ASX-listed shell, propped up by sequential capital raisings, employing just four staff in 2018, and led by a Managing Director who proudly told eminent finance journalist, Alan Kohler, that “… nothing in life has equipped me to run a forestry company”.

KIPT chooses the expense of Supreme Court lawfare against its neighbours Yumbah over matters its draft Environmental Impact Statement (EIS) says don’t matter.

It is an entity managed from Sydney that has no social licence on Kangaroo Island, and an overly ambitious vision it expects KI ratepayers or South Australian taxpayers to underwrite.

A 12.5-KILOGRAM OPINION EDITORIAL

Independent experts of good academic and scientific standing consulted by Yumbah Aquaculture, whose work appears in this document, have assessed the draft EIS.

In polite terms, they have many questions to ask KIPT and the South Australian Government, questions that aren’t answered in the draft EIS, or have been raised in their thorough review.

In less polite terms, the expert consensus is that KIPT’s draft EIS is a 12.5-kilogram opinion editorial looking for a publisher.

It should be marked “fail” – but not sent back for a repeat.

Having failed to mount a case for Smith Bay, KIPT must be directed elsewhere – as Kangaroo Island Council has voted – to one of the many possible alternative Island sites its draft EIS dismisses out of hand.



RESPONSE TO DRAFT EIS

In our response we present evidence to challenge KIPT’s claims against all 19 Guidelines, from our perspective as successful abalone farmers and aquaculture specialists, as well as on behalf of those who live and work on Kangaroo Island.

The most disturbing statement in the entire draft EIS is the cavalier expectation that a seaport can be built immediately adjacent, 400m from an on-shore aquaculture enterprise with no negative impact.

KIPT also purports its seaport will have no “significant” impact on Matters of National Environmental Significance.

Our response – and others submitting their informed and expert opinions – calls out a draft EIS that relies on flawed data and assumptions without the support of evidence-based science.

The real evidence demonstrates construction and operation of the proposed seaport will have a direct and immediate negative impact on Yumbah KI’s aquaculture activities located just metres away.

Particularly galling for Yumbah and its independent experts is KIPT’s reliance on inaccurate, inexpert characterisation of abalone behaviour and husbandry that is misguided, flawed and incapable of supporting the proponent’s claims.

UNAVOIDABLE RISKS AHEAD

The draft EIS offers silence, dismissal and ignorance on the risks and hazards of a seaport at Smith Bay.

The risk of introducing marine pests and diseases to Smith Bay could be reduced to what the draft EIS argues is an “acceptable” level by adopting “the most rigorous biosecurity standards prescribed by Biosecurity SA”.

What is an acceptable level of marine pests being introduced to Smith Bay?

For so many of its risk mitigation processes, KIPT simply asks to be “trusted” to do the right thing. This from a company that cannot manage a simple dredging test, let alone a major infrastructure project and attendant risks.

KIPT undertook unlicensed test drilling in Smith Bay, setting a precedent; the destruction of seagrass is yet another flag on inability or lack of appetite to build or operate complex infrastructure in a sensitive environment.

This “garbage in-garbage out” issue is obvious across the draft EIS, but most apparent in the sample dredging that went so wrong but was still relied upon as credible information upon which to model scenarios.

KIPT’s unlicensed dredging farce was followed by a combination of attempts to drill into a rock-hard seabed with survey coordinates that changed as the proposal grew, and finished with the use of scuba divers using pipes and mallets.

And from this garbage input, modellers were expected to offer substantive findings. Instead, garbage out.

Chemical and fuel spills are inevitable at a seaport; timber fumigation is required at


THE CASE FOR A FREIGHT PORT

There is no argument that improved freight options for Kangaroo Island are desirable.

Yumbah Aquaculture is an exporter and, with many other local KI businesses, sees benefit in improved infrastructure.

There is no argument that KI should be rid of the plantations. These failed Managed Investment Schemes left KI burdened with a low-value, low-yield monocultural land use that destroys community.

KIPT is a price-taker, with a small volume of cheap, no-value-add, base global commodity woodchips, and no consideration of alternative use or higher-value end use.

This proposal is bad economics.

TAKE THE TREES, BUT DON’T DESTROY AQUACULTURE

To take the trees off KI is a good thing.

To commit KI to a future of more plantations, more harvest rotations, fewer jobs in seasonal contract labour, low skills and reduced employment diversity is not what the Island needs.

Why would KIPT choose to deliberately drop a major port project on top of Yumbah Aquaculture, a world-class business that employs more than 25 highly skilled KI locals – and could employ many more?

A business that has grown sustainably for more than 24 years at Smith Bay? A business whose major growth and diversification plans have been shelved because of the risk KIPT’s Smith Bay proposal presents?

This proposal is unprecedented: massive infrastructure cannot co-exist with an aquaculture business less than 400m away.

AGAIN, WHY SMITH BAY?

Why the dogmatic pursuit of Smith Bay when a dozen or more alternative sites are closer to its plantations and KIPT already owns another former export wharf site?

This Smith Bay jetty-to-wharf-cum-seaport cannot be safely or cost-effectively serviced by a sub-standard road network.

KIPT plans A-double road trains 24 hours a day, seven days a week to and from its plantations to Smith Bay, but has no plan for who pays for the roads.

KIPT acknowledges its project will bring more road risk, more vehicle accidents and more dead wildlife.

It offers a biosecurity nightmare for a shallow, clean water bay that is currently pest-free, promising to introduce exotic marine pests and diseases, cause deafness in whales, dredge up to 200 000 cubic metres of seafloor to make a shallow bay “deep”.

It’s a proposal that touts economic benefit to the island but fails to account for the economic hit when a business like Yumbah KI is forced to relocate to another State where aquaculture is respected and supported.

In simple terms, supported by a suite of scientific responses, on the evidence of this draft EIS, this proposal cannot proceed at Smith Bay.



RESPONSE TO DRAFT EIS

In our response we present evidence to challenge KIPT’s claims against all 19 Guidelines, from our perspective as successful abalone farmers and aquaculture specialists, as well as on behalf of those who live and work on Kangaroo Island.

The most disturbing statement in the entire draft EIS is the cavalier expectation that a seaport can be built immediately adjacent, 400m from an on-shore aquaculture enterprise with no negative impact.

KIPT also purports its seaport will have no “significant” impact on Matters of National Environmental Significance.

Our response – and others submitting their informed and expert opinions – calls out a draft EIS that relies on flawed data and assumptions without the support of evidence-based science.

The real evidence demonstrates construction and operation of the proposed seaport will have a direct and immediate negative impact on Yumbah KI’s aquaculture activities located just metres away.

Particularly galling for Yumbah and its independent experts is KIPT’s reliance on inaccurate, inexpert characterisation of abalone behaviour and husbandry that is misguided, flawed and incapable of supporting the proponent’s claims.

UNAVOIDABLE RISKS AHEAD

The draft EIS offers silence, dismissal and ignorance on the risks and hazards of a seaport at Smith Bay.

The risk of introducing marine pests and diseases to Smith Bay could be reduced to what the draft EIS argues is an “acceptable” level by adopting “the most rigorous biosecurity standards prescribed by Biosecurity SA”.

What is an acceptable level of marine pests being introduced to Smith Bay?

For so many of its risk mitigation processes, KIPT simply asks to be “trusted” to do the right thing. This from a company that cannot manage a simple dredging test, let alone a major infrastructure project and attendant risks.

KIPT undertook unlicensed test drilling in Smith Bay, setting a precedent; the destruction of seagrass is yet another flag on inability or lack of appetite to build or operate complex infrastructure in a sensitive environment.

This “garbage in-garbage out” issue is obvious across the draft EIS, but most apparent in the sample dredging that went so wrong but was still relied upon as credible information upon which to model scenarios.

KIPT’s unlicensed dredging farce was followed by a combination of attempts to drill into a rock-hard seabed with survey coordinates that changed as the proposal grew, and finished with the use of scuba divers using pipes and mallets.

And from this garbage input, modellers were expected to offer substantive findings. Instead, garbage out.

Chemical and fuel spills are inevitable at a seaport; timber fumigation is required at


THE CASE FOR A FREIGHT PORT

There is no argument that improved freight options for Kangaroo Island are desirable.

Yumbah Aquaculture is an exporter and, with many other local KI businesses, sees benefit in improved infrastructure.

There is no argument that KI should be rid of the plantations. These failed Managed Investment Schemes left KI burdened with a low-value, low-yield monocultural land use that destroys community.

KIPT is a price-taker, with a small volume of cheap, no-value-add, base global commodity woodchips, and no consideration of alternative use or higher-value end use.

This proposal is bad economics.

TAKE THE TREES, BUT DON’T DESTROY AQUACULTURE

To take the trees off KI is a good thing.

To commit KI to a future of more plantations, more harvest rotations, fewer jobs in seasonal contract labour, low skills and reduced employment diversity is not what the Island needs.

Why would KIPT choose to deliberately drop a major port project on top of Yumbah Aquaculture, a world-class business that employs more than 25 highly skilled KI locals – and could employ many more?

A business that has grown sustainably for more than 24 years at Smith Bay? A business whose major growth and diversification plans have been shelved because of the risk KIPT’s Smith Bay proposal presents?

This proposal is unprecedented: massive infrastructure cannot co-exist with an aquaculture business less than 400m away.


Why the dogmatic pursuit of Smith Bay when a dozen or more alternative sites are closer to its plantations and KIPT already owns another former export wharf site?

This Smith Bay jetty-to-wharf-cum-seaport cannot be safely or cost-effectively serviced by a sub-standard road network.

KIPT plans A-double road trains 24 hours a day, seven days a week to and from its plantations to Smith Bay, but has no plan for who pays for the roads.

KIPT acknowledges its project will bring more road risk, more vehicle accidents and more dead wildlife.

It offers a biosecurity nightmare for a shallow, clean water bay that is currently pest-free, promising to introduce exotic marine pests and diseases, cause deafness in whales, dredge up to 200 000 cubic metres of seafloor to make a shallow bay “deep”.

It’s a proposal that touts economic benefit to the island but fails to account for the economic hit when a business like Yumbah KI is forced to relocate to another State where aquaculture is respected and supported.

In simple terms, supported by a suite of scientific responses, on the evidence of this draft EIS, this proposal cannot proceed at Smith Bay.



increasing water temperature not more than 300 metres from Yumbah’s intake pipes.

While the draft EIS says causeway gates or culverts will help alleviate issues for Yumbah, KIPT also argues such mitigation is “unnecessary”.

AN ECONOMIC FALLACY

KIPT and the draft EIS make great claims of economic benefit from this proposal.

No genuine cross-economy impact study is provided, job claims are fanciful for a facility operating at 20 per cent capacity, and no consideration has been given to non-port infrastructure costs, particularly roads.

There’s no accounting for tourism loss, road trauma cost, opportunity already lost through Yumbah’s shelving of investment plans – and perpetual loss from a shutdown of Yumbah.

“Monitoring” is proposed as the one-size-fits-all solution for everything from road safety and pest invasion to heritage management and air quality.

Monitoring is not a proxy for managing.

And notably, there is no exit strategy, no discussion of who will foot the clean-up bill when it all goes horribly wrong. This is of

particular concern given the proponent’s stated aim of selling the seaport to best serve its shareholders. Who will be responsible then?

CONCLUSION: THERE ARE BETTER PLACES

The Smith Bay EIS planning guidelines are well posed, with 19 clearly defined areas of concern.

A collective and individual review of the draft EIS says “fail”.

This proposal cannot stand on the sparse merits of a very poor draft EIS.

To date, we have 187 unanswered questions.

They appear in this document.

They should be of concern to those who decide if Smith Bay is to be squandered, if Yumbah and the promise of aquaculture are to be driven off the Island and out of South Australia, and if KIPT is cleared to establish a precedent that subordinates sustainable aquaculture and community benefit for needless environmental destruction.

If a seaport is to be built on Kangaroo Island, it must and can be built at a more suitable location.


ports handling logs; chemical leaching from timber used in construction or stored at the port is real.

The draft EIS suggests mitigation of some of these risks – and others – but acknowledges it can do nothing to eliminate them.

OTHER USERS: AN UNKNOWN UNKNOWN

The draft EIS forecasts timber will account for just 20 per cent of the seaport’s capacity.

For KIPT shareholders to earn a commercial return, KIPT must identify and cater for alternative uses.

Again, the draft EIS is silent. It fails to reveal, identify or consider risks and hazards of other uses for what it presents as a multi-use facility.

The proposed seaport will affect air quality.

Woodchipping and stockpiled timber will distribute airborne dust and particulate matter across Yumbah’s abalone farm, presenting substantial risks for the farm.

But the draft EIS data are unreliable and patchy, raising doubt about the validity of the air quality assessment.

It proposes its own “control measures” but gives no indication as to who will monitor these control measures and oversee compliance and enforcement; where the immense quantities of water required for air quality mitigation will come from; who will pay for the water; and how associated impacts of this water use will be managed.

THERE IS NO SHINING LIGHT

The draft EIS is particularly misleading on Smith Bay lighting.

KIPT claims the major source of artificial lighting at Smith Bay is Yumbah which is continuously lit at night. This “major source” consists of two single outdoor security lights. They are currently the only light source at Smith Bay.

These are minimal and shielded from the abalone for one simple reason – abalone feed predominantly at night, and onshore production mimics natural cycles by ensuring darkness at feeding times.

Anybody who has seen a working port at night will tell you it is brightly lit for operational and safety purposes. Will Smith Bay be the first 24-hour seaport to operate in the dark?

Escalated noise levels during construction and operations, on land and in water, will negatively affect amenity, native species – and the wellbeing of highly sensitive abalone.

A CAUSEWAY OF SPOIL

The seaport proposal includes a rock-armoured solid causeway extending 250 metres offshore, 25 per cent longer than the proposal originally submitted to the Development Assessment Commission.

The causeway will be built from dredge spoil. Or not. KIPT’s inadequate, outdated dredging tests leave another unknown: just what materials are in Smith Bay to actually dredge? And with what impact on the marine environment, and Yumbah’s water quality?

The causeway is an impermeable barrier that will block and modify oceanic currents, reducing tidal flow by 30-40 per cent and



increasing water temperature not more than 300 metres from Yumbah’s intake pipes.

While the draft EIS says causeway gates or culverts will help alleviate issues for Yumbah, KIPT also argues such mitigation is “unnecessary”.

AN ECONOMIC FALLACY

KIPT and the draft EIS make great claims of economic benefit from this proposal.

No genuine cross-economy impact study is provided, job claims are fanciful for a facility operating at 20 per cent capacity, and no consideration has been given to non-port infrastructure costs, particularly roads.

There’s no accounting for tourism loss, road trauma cost, opportunity already lost through Yumbah’s shelving of investment plans – and perpetual loss from a shutdown of Yumbah.

“Monitoring” is proposed as the one-size-fits-all solution for everything from road safety and pest invasion to heritage management and air quality.

Monitoring is not a proxy for managing.

And notably, there is no exit strategy, no discussion of who will foot the clean-up bill when it all goes horribly wrong. This is of

particular concern given the proponent’s stated aim of selling the seaport to best serve its shareholders. Who will be responsible then?

CONCLUSION: THERE ARE BETTER PLACES

The Smith Bay EIS planning guidelines are well posed, with 19 clearly defined areas of concern.

A collective and individual review of the draft EIS says “fail”.

This proposal cannot stand on the sparse merits of a very poor draft EIS.

To date, we have 187 unanswered questions.

They appear in this document.

They should be of concern to those who decide if Smith Bay is to be squandered, if Yumbah and the promise of aquaculture are to be driven off the Island and out of South Australia, and if KIPT is cleared to establish a precedent that subordinates sustainable aquaculture and community benefit for needless environmental destruction.

If a seaport is to be built on Kangaroo Island, it must and can be built at a more suitable location.


ports handling logs; chemical leaching from timber used in construction or stored at the port is real.

The draft EIS suggests mitigation of some of these risks – and others – but acknowledges it can do nothing to eliminate them.

OTHER USERS: AN UNKNOWN UNKNOWN

The draft EIS forecasts timber will account for just 20 per cent of the seaport’s capacity.

For KIPT shareholders to earn a commercial return, KIPT must identify and cater for alternative uses.

Again, the draft EIS is silent. It fails to reveal, identify or consider risks and hazards of other uses for what it presents as a multi-use facility.

The proposed seaport will affect air quality.

Woodchipping and stockpiled timber will distribute airborne dust and particulate matter across Yumbah’s abalone farm, presenting substantial risks for the farm.

But the draft EIS data are unreliable and patchy, raising doubt about the validity of the air quality assessment.

It proposes its own “control measures” but gives no indication as to who will monitor these control measures and oversee compliance and enforcement; where the immense quantities of water required for air quality mitigation will come from; who will pay for the water; and how associated impacts of this water use will be managed.

THERE IS NO SHINING LIGHT

The draft EIS is particularly misleading on Smith Bay lighting.

KIPT claims the major source of artificial lighting at Smith Bay is Yumbah which is continuously lit at night. This “major source” consists of two single outdoor security lights. They are currently the only light source at Smith Bay.

These are minimal and shielded from the abalone for one simple reason – abalone feed predominantly at night, and onshore production mimics natural cycles by ensuring darkness at feeding times.

Anybody who has seen a working port at night will tell you it is brightly lit for operational and safety purposes. Will Smith Bay be the first 24-hour seaport to operate in the dark?

Escalated noise levels during construction and operations, on land and in water, will negatively affect amenity, native species – and the wellbeing of highly sensitive abalone.

A CAUSEWAY OF SPOIL

The seaport proposal includes a rock-armoured solid causeway extending 250 metres offshore, 25 per cent longer than the proposal originally submitted to the Development Assessment Commission.

The causeway will be built from dredge spoil. Or not. KIPT’s inadequate, outdated dredging tests leave another unknown: just what materials are in Smith Bay to actually dredge? And with what impact on the marine environment, and Yumbah’s water quality?

The causeway is an impermeable barrier that will block and modify oceanic currents, reducing tidal flow by 30-40 per cent and



SUMMARY

The South Australian Government must decide.

Is it ongoing, year-round world-class aquaculture, economic diversification, and sustainable growth in skills and jobs for KI and South Australia?

Or is it a limited-purpose industrial wharf that will forever scar Smith Bay - and be used just 20 per cent of the time.

Plans for ongoing expansion at Yumbah KI, particularly a massive investment in increased production, have been shelved pending the decision of the South Australian Government over this detrimental use for Smith Bay.

Our other South Australian investments – and the jobs and skills that come with them – are likewise at risk if we are forced to close Yumbah KI and relocate to another

State more welcoming of aquaculture and cognisant of the benefits we bring to regional economies.

Yumbah KI and the proposed KI Seaport cannot co-exist in the proximity proposed by Kangaroo Island Plantation Timbers.

Its “seaport” is just 400m from Yumbah’s intake pipes. This is a proposal unlike any other. A port is incompatible stacked next-door to an aquaculture venture.

There are many alternative sites on KI for a port to remove the timber, but these have not been seriously contemplated. They should be.

This wharf will damage our KI business from the day the dredge starts turning.

And that explains why Yumbah presents this detailed rebuttal to the draft Environmental Impact Statement for a Smith Bay wharf presented by the proponent.


INTRODUCTION

YUMBAH’S SOUTH AUSTRALIAN STORY

Yumbah Aquaculture brings together respect for Indigenous Australians with the unique qualities of the Southern Ocean. With permission from the traditional custodians of the Yaygirr language we call ourselves Yumbah, meaning ‘larger shellfish’.

The Southern Ocean brings nutrient-rich currents from deep Antarctic canyons to the shores of southern Australia, in a phenomenon known as the Bonney Upwelling. Yumbah Aquaculture’s farms in South Australia, Victoria and Tasmania are placed to take advantage of these waters.

Yumbah has its most substantial infrastructure investments in South Australia, where a vertically-integrated model provides reliability with opportunity to scale and diversify. In 2017 these investments were rewarded with the company winning the National Agribusiness Exporter of the Year award.

YUMBAH KANGAROO ISLAND

We came to KI in 1995, and in 24 years of continuous operation have expanded to employ 25 FTE, with an onsite state-of-the-art processing facility, and a licence to breed 30 marine species at Smith Bay.

It was our intention to continue to grow our business and community benefit at a stretch of clean, unpolluted water at Smith Bay, producing world-class Yumbah greenlip abalone for export and domestic markets.

YUMBAH PORT LINCOLN

Our Port Lincoln farm employs 35 FTE, and has an oyster hatchery pioneering the rebuild of the State’s oyster industry following a 2016 outbreak of Pacific Oyster Mortality Syndrome (POMS), which decimated natural populations.

YUMBAH AQUAFEED

Consistent with our philosophy of sustainable and respectful production, Yumbah Aquaculture makes its own predominantly soy flour-based feed at its production facility in Lonsdale with a staff of five FTE.

YUMBAH PROCESSING

Yumbah’s Wingfield processing is the key to preserving the natural qualities of Yumbah Aquaculture’s farmed abalone. With a staff of 12 FTE, Yumbah Aquaculture uses natural brine or nitrogen freezing on-farm and ships to Wingfield where grading and packaging is centrally managed and Yumbah’s value-added product lines are developed and produced.



SUMMARY

The South Australian Government must decide.

Is it ongoing, year-round world-class aquaculture, economic diversification, and sustainable growth in skills and jobs for KI and South Australia?

Or is it a limited-purpose industrial wharf that will forever scar Smith Bay - and be used just 20 per cent of the time.

Plans for ongoing expansion at Yumbah KI, particularly a massive investment in increased production, have been shelved pending the decision of the South Australian Government over this detrimental use for Smith Bay.

Our other South Australian investments – and the jobs and skills that come with them – are likewise at risk if we are forced to close Yumbah KI and relocate to another

State more welcoming of aquaculture and cognisant of the benefits we bring to regional economies.

Yumbah KI and the proposed KI Seaport cannot co-exist in the proximity proposed by Kangaroo Island Plantation Timbers.

Its “seaport” is just 400m from Yumbah’s intake pipes. This is a proposal unlike any other. A port is incompatible stacked next-door to an aquaculture venture.

There are many alternative sites on KI for a port to remove the timber, but these have not been seriously contemplated. They should be.

This wharf will damage our KI business from the day the dredge starts turning.

And that explains why Yumbah presents this detailed rebuttal to the draft Environmental Impact Statement for a Smith Bay wharf presented by the proponent.


INTRODUCTION

YUMBAH’S SOUTH AUSTRALIAN STORY

Yumbah Aquaculture brings together respect for Indigenous Australians with the unique qualities of the Southern Ocean. With permission from the traditional custodians of the Yaygirr language we call ourselves Yumbah, meaning ‘larger shellfish’.

The Southern Ocean brings nutrient-rich currents from deep Antarctic canyons to the shores of southern Australia, in a phenomenon known as the Bonney Upwelling. Yumbah Aquaculture’s farms in South Australia, Victoria and Tasmania are placed to take advantage of these waters.

Yumbah has its most substantial infrastructure investments in South Australia, where a vertically-integrated model provides reliability with opportunity to scale and diversify. In 2017 these investments were rewarded with the company winning the National Agribusiness Exporter of the Year award.


We came to KI in 1995, and in 24 years of continuous operation have expanded to employ 25 FTE, with an onsite state-of-the-art processing facility, and a licence to breed 30 marine species at Smith Bay.

It was our intention to continue to grow our business and community benefit at a stretch of clean, unpolluted water at Smith Bay, producing world-class Yumbah greenlip abalone for export and domestic markets.

YUMBAH PORT LINCOLN

Our Port Lincoln farm employs 35 FTE, and has an oyster hatchery pioneering the rebuild of the State’s oyster industry following a 2016 outbreak of Pacific Oyster Mortality Syndrome (POMS), which decimated natural populations.

YUMBAH AQUAFEED

Consistent with our philosophy of sustainable and respectful production, Yumbah Aquaculture makes its own predominantly soy flour-based feed at its production facility in Lonsdale with a staff of five FTE.

YUMBAH PROCESSING

Yumbah’s Wingfield processing is the key to preserving the natural qualities of Yumbah Aquaculture’s farmed abalone. With a staff of 12 FTE, Yumbah Aquaculture uses natural brine or nitrogen freezing on-farm and ships to Wingfield where grading and packaging is centrally managed and Yumbah’s value-added product lines are developed and produced.


Smith Bay Wharf Environmental Impact Statement Yumbah Response

13

• MNES not genuinely considered

o Dismissive response for an EPBC - controlled action

o False records on whales and other species

o Facile recommendations for mitigation of damage

EPBC STATEMENT HOLDS TRUE

On 24 November 2016, Yumbah submitted a formal response to the Department of Environment and Energy following the submission of KIPTs Smith Bay referral under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act).

At this time Yumbah expressed concerns about the practices employed by KIPT, and affirmed that the company:

“… demonstrably failed to consult, does not negotiate with concerned or even curious Kangaroo Island stakeholders, dismisses the likely impacts of its proposal on the natural fabric of Kangaroo Island, and cannot argue the relative merits of Smith Bay over other wharf sites on the Island.”

This Yumbah statement of nearly three years ago comprehensively describes the cultural mindset of this company. It doesn’t augur well for Smith Bay let alone Kangaroo Island, particularly when this draft EIS is addressing only part of the moving and expanding feast that is KIPT’s Smith Bay plan.

1 KIPT EIS Executive Summary, P44, 45

Following referral under the EPBC Act, the Department deemed the proposal to build and operate a deep-water port wharf facility a ‘controlled action’, likely to have a ‘significant impact’ on many matters of national environment significance.

The executive summary accompanying the draft EIS submitted by KIPT is 78 pages in length. Only two pages, less than 3 per cent of a document titled ‘Environmental Impact Statement’ deals with matters of national environmental significance. Those two scant pages summarise the impacts as negligible and agree to an offset to compensate for the ‘worst-case’ outcome of killing of the ‘relatively common’1 Kangaroo Island Echidna. This derisory and pitifully inadequate response is insulting to the gravity and seriousness of the requirement to respond to a ruling of a controlled action under the EPBC Act.

Yumbah has mounted a consistent case that this proposal presents a threat to Smith Bay, to Yumbah’s operations at Smith Bay, and to the wider interests of Kangaroo Island.


12

GUIDELINE 1:

EPBC ACT - MATTERS OF NATIONAL ENVIRONMENT SIGNIFICANCE (MNES)

DESCRIPTION:

The Commonwealth Minister for the Environment and Energy has determined (EPBC no.2016/7814) that the proposed action is likely to, or may have, a significant impact on the following controlling provisions (matters of national environmental significance (MNES)):

• Listed threatened species and communities (sections 18 & 18A) including but not limited to:

o the endangered and migratory southern right whale (Eubalaena australis)

o the endangered Kangaroo Island Echidna (Tachyglossus aculeatus multiaculeatus)

o the vulnerable Hooded Plover (eastern) (Thinornis rubricollis rubricollis)

o the Southern Brown Bandicoot (eastern) (Isoodon obesulus obesulus)

• Listed migratory species (sections 20 &20A) including but not limited to:

o the endangered and migratory southern right whale (Eubalaena australia)

o a number of species of pipefish will be lost with the removal of 10ha of seagrass (Syngnathid spp.)

• Commonwealth marine areas (sections 23 & 24A) – while it is understood the action is proposed to be taken outside a Commonwealth marine area, the assessment documentation must consider if there is a real chance or possibility that the action will impact a Commonwealth marine area, for example, because the action will have a substantial adverse effect on a population of a marine species such as a cetacean including its life cycle (e.g. breeding, feeding, migration behaviours, life expectancy) and spatial distribution.

RESPONSE SUMMARY

• What Yumbah said in 2016 holds true:

o KIPT fails the EPBC requirement on rigour

o Evidence is ignored and falsities offered

• Precedent on Smith Bay has wide ramifications

o Not just Smith Bay; sustainable aquaculture industry is threatened by KIPT



13

• MNES not genuinely considered

o Dismissive response for an EPBC - controlled action

o False records on whales and other species

o Facile recommendations for mitigation of damage

EPBC STATEMENT HOLDS TRUE

On 24 November 2016, Yumbah submitted a formal response to the Department of Environment and Energy following the submission of KIPTs Smith Bay referral under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act).

At this time Yumbah expressed concerns about the practices employed by KIPT, and affirmed that the company:

“… demonstrably failed to consult, does not negotiate with concerned or even curious Kangaroo Island stakeholders, dismisses the likely impacts of its proposal on the natural fabric of Kangaroo Island, and cannot argue the relative merits of Smith Bay over other wharf sites on the Island.”

This Yumbah statement of nearly three years ago comprehensively describes the cultural mindset of this company. It doesn’t augur well for Smith Bay let alone Kangaroo Island, particularly when this draft EIS is addressing only part of the moving and expanding feast that is KIPT’s Smith Bay plan.

1 KIPT EIS Executive Summary, P44, 45

Following referral under the EPBC Act, the Department deemed the proposal to build and operate a deep-water port wharf facility a ‘controlled action’, likely to have a ‘significant impact’ on many matters of national environment significance.

The executive summary accompanying the draft EIS submitted by KIPT is 78 pages in length. Only two pages, less than 3 per cent of a document titled ‘Environmental Impact Statement’ deals with matters of national environmental significance. Those two scant pages summarise the impacts as negligible and agree to an offset to compensate for the ‘worst-case’ outcome of killing of the ‘relatively common’1 Kangaroo Island Echidna. This derisory and pitifully inadequate response is insulting to the gravity and seriousness of the requirement to respond to a ruling of a controlled action under the EPBC Act.

Yumbah has mounted a consistent case that this proposal presents a threat to Smith Bay, to Yumbah’s operations at Smith Bay, and to the wider interests of Kangaroo Island.


12

GUIDELINE 1:

EPBC ACT - MATTERS OF NATIONAL ENVIRONMENT SIGNIFICANCE (MNES)

DESCRIPTION:

The Commonwealth Minister for the Environment and Energy has determined (EPBC no.2016/7814) that the proposed action is likely to, or may have, a significant impact on the following controlling provisions (matters of national environmental significance (MNES)):

• Listed threatened species and communities (sections 18 & 18A) including but not limited to:

o the endangered and migratory southern right whale (Eubalaena australis)

o the endangered Kangaroo Island Echidna (Tachyglossus aculeatus multiaculeatus)

o the vulnerable Hooded Plover (eastern) (Thinornis rubricollis rubricollis)

o the Southern Brown Bandicoot (eastern) (Isoodon obesulus obesulus)

• Listed migratory species (sections 20 &20A) including but not limited to:

o the endangered and migratory southern right whale (Eubalaena australia)

o a number of species of pipefish will be lost with the removal of 10ha of seagrass (Syngnathid spp.)

• Commonwealth marine areas (sections 23 & 24A) – while it is understood the action is proposed to be taken outside a Commonwealth marine area, the assessment documentation must consider if there is a real chance or possibility that the action will impact a Commonwealth marine area, for example, because the action will have a substantial adverse effect on a population of a marine species such as a cetacean including its life cycle (e.g. breeding, feeding, migration behaviours, life expectancy) and spatial distribution.

RESPONSE SUMMARY

• What Yumbah said in 2016 holds true:

o KIPT fails the EPBC requirement on rigour

o Evidence is ignored and falsities offered

• Precedent on Smith Bay has wide ramifications

o Not just Smith Bay; sustainable aquaculture industry is threatened by KIPT



15

The EPBC referral and draft EIS concentrates its attention on the following four species:

• Southern right whale

• Kangaroo Island echidna

• Hooded plover (eastern)

• Southern brown bandicoot (eastern)

Additional EPBC-listed species that are endemic to the region and have the potential to inhabit or forage the site include:

• bird species that fly over the site and along the coastline, including white bellied sea-eagles that nest within 3.5km of the site, sooty oystercatchers, ruddy turnstones, Australian fairy tern, Pacific gull and the endangered Glossy Back Cockatoo that inhabit two areas near the site

• The Australian Sea-Lion, subject to “unknown impact” from the proposal

• 20 Syngnathid species recorded in the area

• A single patch of the Kangaroo Island Narrow-leaved Mallee (Eucalyptus cneorifolia) Woodland Ecological Community on the adjacent southern property fence line that has potential to meet the size category for a threatened community.

The image below is of a white bellied sea-eagle flying past KIPT’s wave monitoring buoy at the proposed site for its Smith Bay seaport.

Figure 1 - A white bellied sea-eagle flying past a KIPT buoy at Smith Bay


14

PRECEDENT THREATENS SPECIES, SUSTAINABLE AQUACULTURE

Further, and with reference to the EPBC Act, any willingness to allow KIPT to proceed with this action creates a precedent that will set back the cause of sustainable aquaculture around Australia.

Smith Bay’s significance as a Coastal Conservation Zone, with species of State and Commonwealth significance is neither respected nor sufficiently recognised by KIPT.

Its draft EIS fails to appropriately value the ecology of the area and seeks to diminish the environmental values so widely recognised by others – and still being revealed by the actions of citizen scientists such as AusOcean.2

This proposal is incompatible with the natural landscape.

KIPT TOLL ON EPBC-LISTED SPECIES

The draft EIS records 46 EPBC-listed migratory species within 10km of Smith Bay, including:

• Eight threatened (endangered or vulnerable) marine species, which comprise mainly whales and turtles

• 32 nationally listed marine species, which include three seal species, three turtles and 26 syngnathid species (seahorses and pipefish)

• 12 species of whales or dolphins

• 12 migratory marine species

2 https://www.ausocean.org/s/doc/2019_AusOcean_Smith_Bay_Marine_Ecology_Report.pdf

Nationally threatened species include:

• southern right whale (Eubalaena australis)

• Humpback whale (Megaptera novaeangliae)

• Blue whale (Balaenoptera musculus)

• Australian sea-lion (Neophoca cinerea)

• Great white shark (Carcharodon carcharias)

• Loggerhead turtle (Caretta caretta)

• Leatherback turtle (Dermochelys coriacea); and

• Green turtle (Chelonia mydas)

In addition to nationally listed species, state-listed marine species potentially occurring in the area include:

• Pygmy right whale (Caperea marginate)

• Pygmy sperm whale (Kogia breviceps)

• Dusky dolphin (Lagenorhynchus obscurus); and

• Strap-toothed whale (Mesoplodon layardii)

Each of these is listed as rare.

The EPBC referral and draft EIS considers only five marine mammals, one shark and 15 species of pipefish are likely to occur, or may possibly occur at times, in Smith Bay.



15

The EPBC referral and draft EIS concentrates its attention on the following four species:

• Southern right whale

• Kangaroo Island echidna

• Hooded plover (eastern)

• Southern brown bandicoot (eastern)

Additional EPBC-listed species that are endemic to the region and have the potential to inhabit or forage the site include:

• bird species that fly over the site and along the coastline, including white bellied sea-eagles that nest within 3.5km of the site, sooty oystercatchers, ruddy turnstones, Australian fairy tern, Pacific gull and the endangered Glossy Back Cockatoo that inhabit two areas near the site

• The Australian Sea-Lion, subject to “unknown impact” from the proposal

• 20 Syngnathid species recorded in the area

• A single patch of the Kangaroo Island Narrow-leaved Mallee (Eucalyptus cneorifolia) Woodland Ecological Community on the adjacent southern property fence line that has potential to meet the size category for a threatened community.

The image below is of a white bellied sea-eagle flying past KIPT’s wave monitoring buoy at the proposed site for its Smith Bay seaport.

Figure 1 - A white bellied sea-eagle flying past a KIPT buoy at Smith Bay


14

PRECEDENT THREATENS SPECIES, SUSTAINABLE AQUACULTURE

Further, and with reference to the EPBC Act, any willingness to allow KIPT to proceed with this action creates a precedent that will set back the cause of sustainable aquaculture around Australia.

Smith Bay’s significance as a Coastal Conservation Zone, with species of State and Commonwealth significance is neither respected nor sufficiently recognised by KIPT.

Its draft EIS fails to appropriately value the ecology of the area and seeks to diminish the environmental values so widely recognised by others – and still being revealed by the actions of citizen scientists such as AusOcean.2

This proposal is incompatible with the natural landscape.

KIPT TOLL ON EPBC-LISTED SPECIES

The draft EIS records 46 EPBC-listed migratory species within 10km of Smith Bay, including:

• Eight threatened (endangered or vulnerable) marine species, which comprise mainly whales and turtles

• 32 nationally listed marine species, which include three seal species, three turtles and 26 syngnathid species (seahorses and pipefish)

• 12 species of whales or dolphins

• 12 migratory marine species

2 https://www.ausocean.org/s/doc/2019_AusOcean_Smith_Bay_Marine_Ecology_Report.pdf

Nationally threatened species include:

• southern right whale (Eubalaena australis)

• Humpback whale (Megaptera novaeangliae)

• Blue whale (Balaenoptera musculus)

• Australian sea-lion (Neophoca cinerea)

• Great white shark (Carcharodon carcharias)

• Loggerhead turtle (Caretta caretta)

• Leatherback turtle (Dermochelys coriacea); and

• Green turtle (Chelonia mydas)

In addition to nationally listed species, state-listed marine species potentially occurring in the area include:

• Pygmy right whale (Caperea marginate)

• Pygmy sperm whale (Kogia breviceps)

• Dusky dolphin (Lagenorhynchus obscurus); and

• Strap-toothed whale (Mesoplodon layardii)

Each of these is listed as rare.

The EPBC referral and draft EIS considers only five marine mammals, one shark and 15 species of pipefish are likely to occur, or may possibly occur at times, in Smith Bay.



17

SOUTHERN RIGHT WHALE

The Main report (page 223) recognises:

“Of particular conservation interest in the region are the southern right whales that migrate along the north coast of Kangaroo Island every winter.”

Risks to the south-east Australian subpopulation of southern right whales include acute industrial noise, infrastructure/coastal development (wharf construction, dredging and pile driving), vessel collisions and shipping noise. KPT largely ignores the impact of coastal development on cetaceans and has not adequately addressed the risk of injury or death of whales by vessel strikes because of the seaport traffic.

The Draft National Strategy for Mitigating Vessel Strike of Marine Mega-fauna states:

“The risk of vessel collision is a known threat for Australia’s marine mega-fauna”, including whales, dolphins and porpoises. Records show southern right whales are frequently struck by vessels in Australian waters, with 12 per cent of strikes from 1997 to 2015 affecting southern right whales.

KPT’s assertion that incidents of vessels “occasionally” striking whales are “extremely rare and would not be capable of affecting the population of southern right whales” is at odds with the Commonwealth which states:

“In the case of a species that is recovering, such as the east and west coast populations of humpback whales the loss of one individual would be unlikely to impact on either population. However, in the case of south-eastern Australian

3 Department of the Environment and Energy 2016, Draft National Strategy for Mitigating Vessel Strike of Marine Mega-fauna, p. 17 http://www.environment.gov.au/system/files/consultations/bd6174ee-1a4e-4b6d-b786-2d0675b3dbec/files/draft-national-vessel-strike-strategy.pdf 4 https://www.environment.gov.au/system/files/resources/4b8c7f35-e132-401c-85be-6a34c61471dc/files/e-australis-2011-2021.docx

population of the southern right whale which is showing little evidence of recovery, the loss of a female individual would be considered significant.”3

A ferry travelling between mainland South Australia and Kangaroo Island struck and killed an adult southern right whale in 2001, so the population has already been impacted by vessel strikes.

Data analysis for the period 2006 – 2018 confirms sightings of 69 large whales in Smith Bay: 57 southern right whales, nine humpback whales and three unconfirmed species. Of the southern right whales, 12 females and 17 calves/juveniles were confirmed, while the gender of 28 were unconfirmed (Tony Bartram, pers. Comm). Data regarding the dolphin populations also shows high levels of transience/migration through Smith Bay.

There is no question that Smith Bay is displaying the attributes of a Biologically Important Area (BIA) for southern right whales. BIAs are not defined under the EPBC Act, but they are areas that are particularly important for the conservation of protected species and where aggregations of individuals display biologically important behaviour such as calving, foraging, resting or migration.4


16

JUST ONE DAY IN THE FIELD

Despite the ecological riches stepped out above, and its responsibility to satisfy the needs of the EPBC referral, to fill out the pages in its draft EIS, KIPT completed just one terrestrial ecological survey over one day in 2016.

Its conclusion from this walk-past is an unequivocal confirmation (for the purpose of EPBC approval and EIS approval) that based on one single field survey for one day no individuals protected under Federal and State legislation are present on its site.

How can a proponent be granted Commonwealth and State approval for a major project requesting permission to destroy their preferred site and potentially affect matters of national environmental significance into perpetuity based on a single survey conducted for one day?

THEY’LL JUST GO SOMEWHERE ELSE

Table 5-4 of the draft EIS (Section 5) notes:

“Three of the species identified in the referral notice under the EPBC Act are also protected under the National Parks and Wildlife Act. They are the southern right whale, hooded plover (eastern) and southern brown bandicoot (eastern).”

KPT’s repeated defence is that affected species “…are likely to temporarily move…”; or “…being highly mobile, would relocate to alternative habitat that is abundant throughout the region”.

CHOOSE WHICH SPECIES TO RECOGNISE

The draft EIS recognises that the Kangaroo Island echidna is restricted to Kangaroo Island and its population is declining due to predation by cats, pigs and road mortality. Echidna scratchings were observed in 2016.

A community of southern brown bandicoots are known to reside at the rock reserve on the western side of KIPT’s site.

The potential impacts of construction and operations on MNES are ignored by KIPT’s draft EIS.

To reference Table 5-4 again:

“A recovery plan exists for the southern right whale. KIPT would manage the construction and operation of the KI Seaport so as to minimise the risk of any consequential harm to southern right whales.”

This statement appears to exclude and disregard other species this seaport will likely impact.

KIPT is brazen in assuming a seaport in Smith Bay will have negligible impact on MNES. Locating a seaport of the size and scale proposed in Smith Bay, within a widely recognised area renowned for sheltering populations of southern right whales fails on science - and fails on responsibility.



17

SOUTHERN RIGHT WHALE

The Main report (page 223) recognises:

“Of particular conservation interest in the region are the southern right whales that migrate along the north coast of Kangaroo Island every winter.”

Risks to the south-east Australian subpopulation of southern right whales include acute industrial noise, infrastructure/coastal development (wharf construction, dredging and pile driving), vessel collisions and shipping noise. KPT largely ignores the impact of coastal development on cetaceans and has not adequately addressed the risk of injury or death of whales by vessel strikes because of the seaport traffic.

The Draft National Strategy for Mitigating Vessel Strike of Marine Mega-fauna states:

“The risk of vessel collision is a known threat for Australia’s marine mega-fauna”, including whales, dolphins and porpoises. Records show southern right whales are frequently struck by vessels in Australian waters, with 12 per cent of strikes from 1997 to 2015 affecting southern right whales.

KPT’s assertion that incidents of vessels “occasionally” striking whales are “extremely rare and would not be capable of affecting the population of southern right whales” is at odds with the Commonwealth which states:

“In the case of a species that is recovering, such as the east and west coast populations of humpback whales the loss of one individual would be unlikely to impact on either population. However, in the case of south-eastern Australian

3 Department of the Environment and Energy 2016, Draft National Strategy for Mitigating Vessel Strike of Marine Mega-fauna, p. 17 http://www.environment.gov.au/system/files/consultations/bd6174ee-1a4e-4b6d-b786-2d0675b3dbec/files/draft-national-vessel-strike-strategy.pdf 4 https://www.environment.gov.au/system/files/resources/4b8c7f35-e132-401c-85be-6a34c61471dc/files/e-australis-2011-2021.docx

population of the southern right whale which is showing little evidence of recovery, the loss of a female individual would be considered significant.”3

A ferry travelling between mainland South Australia and Kangaroo Island struck and killed an adult southern right whale in 2001, so the population has already been impacted by vessel strikes.

Data analysis for the period 2006 – 2018 confirms sightings of 69 large whales in Smith Bay: 57 southern right whales, nine humpback whales and three unconfirmed species. Of the southern right whales, 12 females and 17 calves/juveniles were confirmed, while the gender of 28 were unconfirmed (Tony Bartram, pers. Comm). Data regarding the dolphin populations also shows high levels of transience/migration through Smith Bay.

There is no question that Smith Bay is displaying the attributes of a Biologically Important Area (BIA) for southern right whales. BIAs are not defined under the EPBC Act, but they are areas that are particularly important for the conservation of protected species and where aggregations of individuals display biologically important behaviour such as calving, foraging, resting or migration.4


16

JUST ONE DAY IN THE FIELD

Despite the ecological riches stepped out above, and its responsibility to satisfy the needs of the EPBC referral, to fill out the pages in its draft EIS, KIPT completed just one terrestrial ecological survey over one day in 2016.

Its conclusion from this walk-past is an unequivocal confirmation (for the purpose of EPBC approval and EIS approval) that based on one single field survey for one day no individuals protected under Federal and State legislation are present on its site.

How can a proponent be granted Commonwealth and State approval for a major project requesting permission to destroy their preferred site and potentially affect matters of national environmental significance into perpetuity based on a single survey conducted for one day?

THEY’LL JUST GO SOMEWHERE ELSE

Table 5-4 of the draft EIS (Section 5) notes:

“Three of the species identified in the referral notice under the EPBC Act are also protected under the National Parks and Wildlife Act. They are the southern right whale, hooded plover (eastern) and southern brown bandicoot (eastern).”

KPT’s repeated defence is that affected species “…are likely to temporarily move…”; or “…being highly mobile, would relocate to alternative habitat that is abundant throughout the region”.

CHOOSE WHICH SPECIES TO RECOGNISE

The draft EIS recognises that the Kangaroo Island echidna is restricted to Kangaroo Island and its population is declining due to predation by cats, pigs and road mortality. Echidna scratchings were observed in 2016.

A community of southern brown bandicoots are known to reside at the rock reserve on the western side of KIPT’s site.

The potential impacts of construction and operations on MNES are ignored by KIPT’s draft EIS.

To reference Table 5-4 again:

“A recovery plan exists for the southern right whale. KIPT would manage the construction and operation of the KI Seaport so as to minimise the risk of any consequential harm to southern right whales.”

This statement appears to exclude and disregard other species this seaport will likely impact.

KIPT is brazen in assuming a seaport in Smith Bay will have negligible impact on MNES. Locating a seaport of the size and scale proposed in Smith Bay, within a widely recognised area renowned for sheltering populations of southern right whales fails on science - and fails on responsibility.



19

THE WHALES OF SMITH BAY

Yumbah KI’s General Manager, David Connell, provides a personal communication about his observation of whales in Smith Bay, titled A memory never to be forgotten.

“Between 1999 and 2019 I have had the privilege of watching the southern right whales frolic, nurse and give birth in Smith Bay. As time has passed the visiting frequency and numbers has been on the increase.

“My initial encounter was a solitary mother sheltering in the bay with her calf and over the years the numbers grew as I became accustomed to when to expect them and where to keep a look out.

“At first it was birthing mothers and then the addition of mothers with juveniles.

“In 2018 a group of three played in the waters for several days as if it was their preferred place to be.

“Birthing mothers arrive and pace the bay just as any expecting mother paces her surroundings.

“Although I haven’t witnessed a birth, you can always tell it’s happened as by morning she will be very close to shore, so shallow her belly must be resting on the sea floor. It doesn’t take long before you spot a little head close by her side.

“Left alone without interruption, a mother will remain in the bay until their juvenile is strong enough to take on the open water. This time frame is usually around the 10-day mark, but it has taken as long as 14 days for one young one, that I did think wasn’t going to make it.

“Total time spent for a mother has been as long as four weeks from arrival until departure.

“I have noticed that once the juvenile begins to play openly, showing the strength to frolic around its mother and capable of making small lunges out of the water, it’s only a day or so and they will be gone.

“The most impressionable experience I have had was in the Spring of 2011 where a mother just following birth, lay so close to shore you could feel her breath passing through the rocks.

“On a dead calm evening, just sitting on the ironstone shoreline while her breath vibrated through my body, is a memory never to be forgotten.

“Smith Bay has an ironstone reef that runs parallel to its shores. I believe the mothers feel this is great protection for their young. The bay has minimal sand so even in onshore wind days water clarity is very good.

“It’s common to see the dolphins and whales interacting. It’s obvious they have respect for each other and do regularly co-exist.

“I have at times had multiple mothers in the bay at the same time, all with young.

“Interestingly they will be close from evening to morning but generally will spend the day alone with their young. Quite the sight to see three mothers all with their heads within 10 metres of each other, as if they are up for a chat and three young, dashing around them like kids in the playground.

“To date Smith Bay is a place of refuge for these whales and many other species.

“Let’s hope we can keep it this way.”


18

DRAFT EIS IS WRONG

The draft EIS Main report (page 247) is definitive:

“There is no evidence that Smith Bay is an important site for southern right whales. Although Smith Bay lies within an area described as the ‘current core coastal range’ for these animals (DSEWPaC 2012), it is not near a known aggregation area and is at the edge of a ‘historic high use’ area. Records of southern right whale sightings around Kangaroo Island provide evidence that they visit Smith Bay only infrequently.”

This is simply not true.

The draft EIS claims only ever one registered sighting of the southern right whale in Smith Bay.

KIPT must surely have known that their claim of one registered sighting was false from personal experience. In 2017 the vessel commissioned to perform investigative “drilling” of Smith Bay scared a mother and calf from the bay.

The truth as revealed by registered whale sightings in Smith Bay since 2006 include 57 confirmed southern right whales, nine humpback whales and three unconfirmed species (Tony Bartram, pers. comm. 22 May 2019).

Further, whales are regularly observed in Smith Bay at the front of Yumbah KI.

This is consistent with whale sightings in locations across the Southern Ocean where abalone farms are located, including Port Fairy and Narrawong (Victoria), Port Lincoln and Kangaroo Island (South Australia) and Bicheno (Tasmania).

Whales matter, and their increasing presence is affirmation that something is right with the world.

Figure 2 – A southern right whale mother and calf are scared away from Smith Bay during KIPT’s investigative drilling



19

THE WHALES OF SMITH BAY

Yumbah KI’s General Manager, David Connell, provides a personal communication about his observation of whales in Smith Bay, titled A memory never to be forgotten.

“Between 1999 and 2019 I have had the privilege of watching the southern right whales frolic, nurse and give birth in Smith Bay. As time has passed the visiting frequency and numbers has been on the increase.

“My initial encounter was a solitary mother sheltering in the bay with her calf and over the years the numbers grew as I became accustomed to when to expect them and where to keep a look out.

“At first it was birthing mothers and then the addition of mothers with juveniles.

“In 2018 a group of three played in the waters for several days as if it was their preferred place to be.

“Birthing mothers arrive and pace the bay just as any expecting mother paces her surroundings.

“Although I haven’t witnessed a birth, you can always tell it’s happened as by morning she will be very close to shore, so shallow her belly must be resting on the sea floor. It doesn’t take long before you spot a little head close by her side.

“Left alone without interruption, a mother will remain in the bay until their juvenile is strong enough to take on the open water. This time frame is usually around the 10-day mark, but it has taken as long as 14 days for one young one, that I did think wasn’t going to make it.

“Total time spent for a mother has been as long as four weeks from arrival until departure.

“I have noticed that once the juvenile begins to play openly, showing the strength to frolic around its mother and capable of making small lunges out of the water, it’s only a day or so and they will be gone.

“The most impressionable experience I have had was in the Spring of 2011 where a mother just following birth, lay so close to shore you could feel her breath passing through the rocks.

“On a dead calm evening, just sitting on the ironstone shoreline while her breath vibrated through my body, is a memory never to be forgotten.

“Smith Bay has an ironstone reef that runs parallel to its shores. I believe the mothers feel this is great protection for their young. The bay has minimal sand so even in onshore wind days water clarity is very good.

“It’s common to see the dolphins and whales interacting. It’s obvious they have respect for each other and do regularly co-exist.

“I have at times had multiple mothers in the bay at the same time, all with young.

“Interestingly they will be close from evening to morning but generally will spend the day alone with their young. Quite the sight to see three mothers all with their heads within 10 metres of each other, as if they are up for a chat and three young, dashing around them like kids in the playground.

“To date Smith Bay is a place of refuge for these whales and many other species.

“Let’s hope we can keep it this way.”


18

DRAFT EIS IS WRONG

The draft EIS Main report (page 247) is definitive:

“There is no evidence that Smith Bay is an important site for southern right whales. Although Smith Bay lies within an area described as the ‘current core coastal range’ for these animals (DSEWPaC 2012), it is not near a known aggregation area and is at the edge of a ‘historic high use’ area. Records of southern right whale sightings around Kangaroo Island provide evidence that they visit Smith Bay only infrequently.”

This is simply not true.

The draft EIS claims only ever one registered sighting of the southern right whale in Smith Bay.

KIPT must surely have known that their claim of one registered sighting was false from personal experience. In 2017 the vessel commissioned to perform investigative “drilling” of Smith Bay scared a mother and calf from the bay.

The truth as revealed by registered whale sightings in Smith Bay since 2006 include 57 confirmed southern right whales, nine humpback whales and three unconfirmed species (Tony Bartram, pers. comm. 22 May 2019).

Further, whales are regularly observed in Smith Bay at the front of Yumbah KI.

This is consistent with whale sightings in locations across the Southern Ocean where abalone farms are located, including Port Fairy and Narrawong (Victoria), Port Lincoln and Kangaroo Island (South Australia) and Bicheno (Tasmania).

Whales matter, and their increasing presence is affirmation that something is right with the world.

Figure 2 – A southern right whale mother and calf are scared away from Smith Bay during KIPT’s investigative drilling


Smith Bay Wharf Environmental Impact Statement Response

21

GUIDELINE 2:

COAST AND MARINE

DESCRIPTION:

As the proposed development is within, and directly adjacent to, the Coastal Conservation Zone of Smith Bay, there will be direct impacts to this sensitive environment. The environment and its ecological values of the area must be further understood to accurately identify the impacts from the construction and operation of the development, and to determine appropriate measures to manage, offset or mitigate these impacts. Although the area is not within a Marine Park (State), the construction and operation of the proposal, including the passageway of ships to and from the port and wharf may still have impacts on the neighbouring Marine Parks (i.e. Encounter and Southern Spencer Gulf Marine).

SUMMARY RESPONSE

Construction of this proposed seaport will dramatically modify the coastal habitat of Smith Bay. Impacts include alteration to sediment transport processes, both through hydrographical modifications caused by dredging and through reflection of waves from the seaport structures.

The draft EIS however attempts to persuade the reader through the conclusions of consultants reports that the seaport can be constructed with no negative impact on the immediately adjacent abalone farm. It further argues that no “significant” impact will occur to matters of national environmental significance.

This response will demonstrate that flawed data and assumptions in the draft EIS have resulted in a “garbage in – garbage out” conclusion paraded as evidence-based science.

The real evidence will support common sense and demonstrate that the construction and operation of the proposed seaport involving dredging of potentially 200,000 m3 of environmentally valuable seabed will have a direct negative impact on Yumbah KI’s aquaculture activities located but metres away.

Furthermore, the reliance of the draft EIS on an inaccurate and inexpert characterisation of abalone behaviour and husbandry and the likely impact of the Seaport on the Yumbah KI farm is shown to be misguided, flawed and incapable of supporting its invalid claims.

Yumbah has therefore engaged marine specialists, scientists and industry experts to review the draft EIS and inform this section of our submission. GHD Pty Ltd (GHD) reviewed the predicted water quality impacts outlined in the draft EIS, with a primary focus on Appendix F (Marine Water Quality) of the draft EIS, which is presented in four sections:

• Assessment of Marine Sediments

• Hydrodynamic Modelling

• Marine Water Quality Baseline and Impact Assessment

• External Hydrodynamic Modelling Peer Review


20

KIPT DRAFT EIS FAILS EPBC TEST

Yumbah submits that KIPT fails to accurately represent the extant ecological values at its preferred seaport site.

The lack of consideration of the site and scant information in the draft EIS suggest to Yumbah that this proponent has no regard for Smith Bay as a Coastal Conservation Zone, and lacks concern for the ecological values across the development footprint that warrant protection.



21

GUIDELINE 2:

COAST AND MARINE

DESCRIPTION:

As the proposed development is within, and directly adjacent to, the Coastal Conservation Zone of Smith Bay, there will be direct impacts to this sensitive environment. The environment and its ecological values of the area must be further understood to accurately identify the impacts from the construction and operation of the development, and to determine appropriate measures to manage, offset or mitigate these impacts. Although the area is not within a Marine Park (State), the construction and operation of the proposal, including the passageway of ships to and from the port and wharf may still have impacts on the neighbouring Marine Parks (i.e. Encounter and Southern Spencer Gulf Marine).

SUMMARY RESPONSE

Construction of this proposed seaport will dramatically modify the coastal habitat of Smith Bay. Impacts include alteration to sediment transport processes, both through hydrographical modifications caused by dredging and through reflection of waves from the seaport structures.

The draft EIS however attempts to persuade the reader through the conclusions of consultants reports that the seaport can be constructed with no negative impact on the immediately adjacent abalone farm. It further argues that no “significant” impact will occur to matters of national environmental significance.

This response will demonstrate that flawed data and assumptions in the draft EIS have resulted in a “garbage in – garbage out” conclusion paraded as evidence-based science.

The real evidence will support common sense and demonstrate that the construction and operation of the proposed seaport involving dredging of potentially 200,000 m3 of environmentally valuable seabed will have a direct negative impact on Yumbah KI’s aquaculture activities located but metres away.

Furthermore, the reliance of the draft EIS on an inaccurate and inexpert characterisation of abalone behaviour and husbandry and the likely impact of the Seaport on the Yumbah KI farm is shown to be misguided, flawed and incapable of supporting its invalid claims.

Yumbah has therefore engaged marine specialists, scientists and industry experts to review the draft EIS and inform this section of our submission. GHD Pty Ltd (GHD) reviewed the predicted water quality impacts outlined in the draft EIS, with a primary focus on Appendix F (Marine Water Quality) of the draft EIS, which is presented in four sections:

• Assessment of Marine Sediments

• Hydrodynamic Modelling

• Marine Water Quality Baseline and Impact Assessment

• External Hydrodynamic Modelling Peer Review


Smith Bay Wharf Environmental Impact Statement Yumbah Aquaculture Response

23

by the proponent. Furthermore, the sand component of sediment estimated cannot be validated as sediment in the deeper profile has not been assessed; in essence, less than 30 per cent of the sediment has been profiled.

Therefore, the model does not consider the full extent of impact, distribution of sediment, plumes, settle ability, concentration, reduction in photosynthetically active radiation (PAR) or intake at pipes. In the light of this the Dredging program and proposed mitigation must be completely reassessed as what is proposed in the draft EIS is completely flawed.

In summary, due to the significant flaws and lack of adequate characterisation of sediment, Yumbah has no confidence in the outcomes of the models and the suggested impacts associated with dredging.

• Reduced circulation as a consequence of the causeway

A 250m solid impermeable causeway is proposed to be constructed, extending perpendicular to the coast. As a consequence, oceanic currents have been estimated to reduce by at least 30 per cent, changing the hydrodynamic conditions of Smith Bay forever.

• Drift algae, wrack accumulation

Increased mortality, reduced PAR from sediment plume and increased turbidity will further compromise survival of seagrass and macroalgae. This has not been modelled nor simulated however the destruction of 10ha of seagrass and the impact of the

loss of habitat is covered elsewhere in this report. Smothered intake pipes, increased pumping costs, increased detritus and lower oxygen concentration are among the impacts.

• Noise and vibration

Noise and vibration during construction and operation will impact marine mammals, potentially causing temporary or permanent hearing loss. Amenity of Smith Bay will be forever changed with the 24-hour continuous operation of an active seaport in an otherwise uninterrupted Coastal Conservation Zone.

• Mobilisation of fine sediments

The construction of a 250m causeway in this location, a capital dredging program of an unconfirmed volume of spoil, tailwater discharges from dewatering of sediments on land, maintenance dredging and shipping operations will create turbid plumes that will extend for kilometres.

• Ecotoxicology

One assay performed on abalone for 24 hours is in no way an ecotoxicology assessment to invent guideline trigger values for total suspended solids well in excess of well-established and recognised national water quality guidelines.

• Algal blooms

Changes to the light environment, reduced circulation of nearshore waters and elevated water temperatures increase the risk of harmful algal blooms at Smith Bay with potential catastrophic impacts on Yumbah’s farmed abalone.


22

A review of Appendix G (Coastal Processes) and Appendix T (Risk Assessment) has also been completed. The findings are titled KIPT Smith Bay Wharf Draft EIS Review of Predicted Water Quality Impacts (Romero, 2019) presented in Appendix 1 of this submission.

Professor Paul McShane undertook a thorough technical review of Appendix H. Professor McShane is highly regarded and internationally recognised for his expertise on fisheries biology and the early life history of abalone. His review is presented in Appendix 2, titled Smith Bay Wharf Response to Draft Environmental Impact Statement Kangaroo Island Plantation Timbers (McShane, 2019).

Issues identified from the draft EIS as having a significant impact on the coastal and marine environments of Smith Bay include:

• Inadequate sediment characterisation

In summary KIPT have failed to determine exactly the composition of the seabed that they plan to excavate. Because of this every conclusion that the draft EIS makes relating to dredging is suspect and invalid.

Sampling results are presented where the majority of samples are outside of the dredge area and therefore cannot be claimed to be representative.

Sediment sampling depths are not adequate as they do not extend to the depth of dredging. This is contrary to the National Assessment Guidelines for Dredging (NAGD) (2009) which require that the full depth be characterised.

Locals know that the seabed is hard and composed of what is referred to as “ironstone”. The unsurprising failure to drill into this hard floor is described in the proponents reports as “core

refusal” which indicates unconsolidated material, possibly rock that may need to be ground to achieve the desired approach and berth depth.

The claim of equivalence of core samples made with a drilling rig and those obtained by a solitary Scuba diver with a hammer and tube are farcical. This is further borne out by their own evidence that the seabed is not homogenous – for example total organic carbon (TOC) was reported at significantly higher concentrations in the one deeper sample.

Yumbah does not have issue with the methodology of the modelling performed rather we question each and every piece of input to the models. Widely attributed to an IBM programmer, George Fuechsel, “Garbage in – Garbage out” is an apt metaphor for what happens when flawed data is fed into a system producing, unsurprisingly, nonsense output or garbage.

Even the data revealed by the incomplete sampling is flawed. The discovery of the hard substrate of Smith Bay as evidenced by core refusal suggests that Cutter Suction Dredge (CSD) grinding may have to be used to excavate the seabed. The fine material (Class 3) produced by the grinding is not even contemplated or modelled by the proponent. Its volume is unknown and particle size distribution (PSD) is unknown. Likewise, the propensity of this class 3 material to remain suspended in the water column for a longer duration than the settling velocities measured for the shallower, unconsolidated sediment has been completely ignored



23

by the proponent. Furthermore, the sand component of sediment estimated cannot be validated as sediment in the deeper profile has not been assessed; in essence, less than 30 per cent of the sediment has been profiled.

Therefore, the model does not consider the full extent of impact, distribution of sediment, plumes, settle ability, concentration, reduction in photosynthetically active radiation (PAR) or intake at pipes. In the light of this the Dredging program and proposed mitigation must be completely reassessed as what is proposed in the draft EIS is completely flawed.

In summary, due to the significant flaws and lack of adequate characterisation of sediment, Yumbah has no confidence in the outcomes of the models and the suggested impacts associated with dredging.

• Reduced circulation as a consequence of the causeway

A 250m solid impermeable causeway is proposed to be constructed, extending perpendicular to the coast. As a consequence, oceanic currents have been estimated to reduce by at least 30 per cent, changing the hydrodynamic conditions of Smith Bay forever.

• Drift algae, wrack accumulation

Increased mortality, reduced PAR from sediment plume and increased turbidity will further compromise survival of seagrass and macroalgae. This has not been modelled nor simulated however the destruction of 10ha of seagrass and the impact of the

loss of habitat is covered elsewhere in this report. Smothered intake pipes, increased pumping costs, increased detritus and lower oxygen concentration are among the impacts.

• Noise and vibration

Noise and vibration during construction and operation will impact marine mammals, potentially causing temporary or permanent hearing loss. Amenity of Smith Bay will be forever changed with the 24-hour continuous operation of an active seaport in an otherwise uninterrupted Coastal Conservation Zone.

• Mobilisation of fine sediments

The construction of a 250m causeway in this location, a capital dredging program of an unconfirmed volume of spoil, tailwater discharges from dewatering of sediments on land, maintenance dredging and shipping operations will create turbid plumes that will extend for kilometres.

• Ecotoxicology

One assay performed on abalone for 24 hours is in no way an ecotoxicology assessment to invent guideline trigger values for total suspended solids well in excess of well-established and recognised national water quality guidelines.

• Algal blooms

Changes to the light environment, reduced circulation of nearshore waters and elevated water temperatures increase the risk of harmful algal blooms at Smith Bay with potential catastrophic impacts on Yumbah’s farmed abalone.


22

A review of Appendix G (Coastal Processes) and Appendix T (Risk Assessment) has also been completed. The findings are titled KIPT Smith Bay Wharf Draft EIS Review of Predicted Water Quality Impacts (Romero, 2019) presented in Appendix 1 of this submission.

Professor Paul McShane undertook a thorough technical review of Appendix H. Professor McShane is highly regarded and internationally recognised for his expertise on fisheries biology and the early life history of abalone. His review is presented in Appendix 2, titled Smith Bay Wharf Response to Draft Environmental Impact Statement Kangaroo Island Plantation Timbers (McShane, 2019).

Issues identified from the draft EIS as having a significant impact on the coastal and marine environments of Smith Bay include:

• Inadequate sediment characterisation

In summary KIPT have failed to determine exactly the composition of the seabed that they plan to excavate. Because of this every conclusion that the draft EIS makes relating to dredging is suspect and invalid.

Sampling results are presented where the majority of samples are outside of the dredge area and therefore cannot be claimed to be representative.

Sediment sampling depths are not adequate as they do not extend to the depth of dredging. This is contrary to the National Assessment Guidelines for Dredging (NAGD) (2009) which require that the full depth be characterised.

Locals know that the seabed is hard and composed of what is referred to as “ironstone”. The unsurprising failure to drill into this hard floor is described in the proponents reports as “core

refusal” which indicates unconsolidated material, possibly rock that may need to be ground to achieve the desired approach and berth depth.

The claim of equivalence of core samples made with a drilling rig and those obtained by a solitary Scuba diver with a hammer and tube are farcical. This is further borne out by their own evidence that the seabed is not homogenous – for example total organic carbon (TOC) was reported at significantly higher concentrations in the one deeper sample.

Yumbah does not have issue with the methodology of the modelling performed rather we question each and every piece of input to the models. Widely attributed to an IBM programmer, George Fuechsel, “Garbage in – Garbage out” is an apt metaphor for what happens when flawed data is fed into a system producing, unsurprisingly, nonsense output or garbage.

Even the data revealed by the incomplete sampling is flawed. The discovery of the hard substrate of Smith Bay as evidenced by core refusal suggests that Cutter Suction Dredge (CSD) grinding may have to be used to excavate the seabed. The fine material (Class 3) produced by the grinding is not even contemplated or modelled by the proponent. Its volume is unknown and particle size distribution (PSD) is unknown. Likewise, the propensity of this class 3 material to remain suspended in the water column for a longer duration than the settling velocities measured for the shallower, unconsolidated sediment has been completely ignored



25

SAMPLING AND ANALYSIS

The sediment sampling is flawed and, as a consequence, the results and outputs of the various models completed to inform the draft EIS cannot be relied upon.

Appendix 1 confirms the sampling and analysis of the seabed is deficient and does not provide an adequate description of the sediments to allow an assessment of the potential impacts of its disturbance (Romero, 2019).

The sampling location presented in the draft EIS appears to have been completed across a grid that is located both within and external to the proposed dredge area. It is presumed the sampling, conducted over two distinct events in 2017 and 2018 using different methods (drilling and SCUBA) was largely based on a previous dredge footprint.

Analysis of sediment has been conducted on 17 samples, 11 of which are actually located with the dredge pocket. Thus 35 per cent of all information presented in the EIS is derived from samples outside the dredge area. No reason has been given for the logic in sampling outside the dredge area – in fact there can be no valid reason. The inclusion of this data by KIPT casts doubt on their ability to mitigate other risks through management intervention.

Samples have been collected generally from a maximum depth of 80cm below the surface with one sample extracted from 1.4m below the seabed. As the proposed dredge depth is a maximum three metres, sediment sampling and ultimate characterisation of the physicochemical properties including Particle Size Distribution (PSD) is fundamentally flawed.


24

• Light-spill onto the abalone farm

The seaport will create continuous night light, emanating from the proposed infrastructure in the hard-standing area and along the wharf/causeway as well as from transport vehicles. Light adversely affects feeding and growth of abalone.

• Changes in coastal processes

Primarily associated with the construction of the causeway, changes would affect nearshore circulation with potential to:

o Increase the temperature of Yumbah’s intake water due to reduced mixing in the vicinity of the causeway with potential lethal impact on farmed abalone; and

o Changed sedimentation and resuspension processes due to changes in benthic sheer stress in the vicinity of the causeway and in the dredged areas

• General impact to marine ecology

The Smith Bay environment is renowned for its extensive seagrass meadows and species listed under the Commonwealth EPBC Act.

INADEQUATE ASSESSMENT OF MARINE SEDIMENTS

The impact of suspended sediment from dredging has potential catastrophic implications for Yumbah KI. The assessment of sediments proposed for dredging is of critical importance. Sampling and analysis of dredge spoil provides an understanding of the environmental acceptability of dredged material, management alternatives and means to minimise and manage potential impacts. The draft EIS provides detail of the results of the sediment sampling for the purpose of characterising the geotechnical properties for potential reuse and also understanding the physicochemical parameters of the material that will be disturbed for the purpose of understanding potential environmental impacts and fate of sediment.



25

SAMPLING AND ANALYSIS

The sediment sampling is flawed and, as a consequence, the results and outputs of the various models completed to inform the draft EIS cannot be relied upon.

Appendix 1 confirms the sampling and analysis of the seabed is deficient and does not provide an adequate description of the sediments to allow an assessment of the potential impacts of its disturbance (Romero, 2019).

The sampling location presented in the draft EIS appears to have been completed across a grid that is located both within and external to the proposed dredge area. It is presumed the sampling, conducted over two distinct events in 2017 and 2018 using different methods (drilling and SCUBA) was largely based on a previous dredge footprint.

Analysis of sediment has been conducted on 17 samples, 11 of which are actually located with the dredge pocket. Thus 35 per cent of all information presented in the EIS is derived from samples outside the dredge area. No reason has been given for the logic in sampling outside the dredge area – in fact there can be no valid reason. The inclusion of this data by KIPT casts doubt on their ability to mitigate other risks through management intervention.

Samples have been collected generally from a maximum depth of 80cm below the surface with one sample extracted from 1.4m below the seabed. As the proposed dredge depth is a maximum three metres, sediment sampling and ultimate characterisation of the physicochemical properties including Particle Size Distribution (PSD) is fundamentally flawed.


24

• Light-spill onto the abalone farm

The seaport will create continuous night light, emanating from the proposed infrastructure in the hard-standing area and along the wharf/causeway as well as from transport vehicles. Light adversely affects feeding and growth of abalone.

• Changes in coastal processes

Primarily associated with the construction of the causeway, changes would affect nearshore circulation with potential to:

o Increase the temperature of Yumbah’s intake water due to reduced mixing in the vicinity of the causeway with potential lethal impact on farmed abalone; and

o Changed sedimentation and resuspension processes due to changes in benthic sheer stress in the vicinity of the causeway and in the dredged areas

• General impact to marine ecology

The Smith Bay environment is renowned for its extensive seagrass meadows and species listed under the Commonwealth EPBC Act.

INADEQUATE ASSESSMENT OF MARINE SEDIMENTS

The impact of suspended sediment from dredging has potential catastrophic implications for Yumbah KI. The assessment of sediments proposed for dredging is of critical importance. Sampling and analysis of dredge spoil provides an understanding of the environmental acceptability of dredged material, management alternatives and means to minimise and manage potential impacts. The draft EIS provides detail of the results of the sediment sampling for the purpose of characterising the geotechnical properties for potential reuse and also understanding the physicochemical parameters of the material that will be disturbed for the purpose of understanding potential environmental impacts and fate of sediment.



27

POOR SEDIMENT CHARACTERISATION

Target core/sediment acquisition depths are inadequate to describe the sediment quality and PSD of the proposed material to be dredged. The sediment has been poorly characterised, particularly the hard substrate (consolidated) beneath the well-characterised veneer of unconsolidated-weakly shallower consolidated sediments. Due to the poor characterisation of sediment to be dredged, the worst case for PSD and settling velocity cannot be relied on. Estimates should be further explored with additional sediment sampling and modelling.

While the proposed maximum dredge depth is about three metres, sediment was only sampled in depths ranging from 25cm to 80cm, with only one sample extracted from 140cm. Analysis of this deeper core presents a much smaller PSD for the deeper sample subset. Information is lacking on the depth intervals analysed in this core. This deeper sample is outside the dredge footprint and hence cannot be relied on to characterise particle size in the deeper sections of the dredge footprint.

Appendix 1 provides further context for the significant gaps in the sediment sampling and analysis plan and interpretation based on shallow characterisation of the dredge material. Core penetration depths ranged from:

• ~60cm at sites ZZ3-ZZ8 (presumably via diver during second survey)

• 8 of 12 sites during the first survey were ≤25cm

• 3 of 12 sites during the first survey were 50-80cm

• 1 of 12 sites (site SB7) during the first survey had a penetration depth >1m (140cm)

The first survey with core acquisition (via 10 tonnes of drilling hydraulic pressure) yielded low penetrations prior to core refusal consistently below one metre for all samples except for site SB7.2, the one location where sediment was extracted at 140cm.

The interpretation of the geotechnical / borehole data in Section 5.2 cannot be confirmed for >1-3 metres of marine sediments because the core refusal depths were at one metre (except for SB7.2 outside of the dredge pocket) during the drilling rig sediment sampling survey.

This indicates the presence of a very hard substrate (possibly consolidated material) underlying a veneer of unconsolidated sediments that may require Cutter Suction Dredge (CSD) grinding, and subsequently a third class (Class 3) of dredge material. The CSD has the potential to generate very fine particles from the dredge-header grinding the hard substrate into material and small particle diameters not commonly distributed in the marine environment.

This material will ultimately have the propensity to remain suspended in the water column for a longer duration and distance than the settling velocities measured for the shallower, unconsolidated sediment.

The draft EIS Appendix F reports that sediment in Smith Bay consisted mainly of sand and gravel with between 10 and 25 per cent of fine particulates (clay and silt), apart from the deeper sediment at Site SB7 (SB7.2), with SB7.2 having the finest particles. The evaluation of sediment as 75 per cent coarse sands is incorrect. This conclusion cannot be validated as sediment in the deeper profile has not been assessed; in essence, less than 30 per cent of the sediment has been profiled.


26

Assumptions about the behaviour and ultimate fate of dredged sediment in the water column cannot be drawn from an incomplete sampling program. The NAGD (2009) is the primary framework and default guidance to ensure the impacts of dredged material loading and disposal are adequately assessed and that impacts are managed responsibly and effectively5.

The NAGD (2009) requires that the full depth of dredging is to be characterised in order to inform the dredge methodology and predict the potential environmental impact.

5 http://www.environment.gov.au/marine/publications/national-assessment-guidelines-dredging-2009

Figure 3 – Locations of sediment samples



27

POOR SEDIMENT CHARACTERISATION

Target core/sediment acquisition depths are inadequate to describe the sediment quality and PSD of the proposed material to be dredged. The sediment has been poorly characterised, particularly the hard substrate (consolidated) beneath the well-characterised veneer of unconsolidated-weakly shallower consolidated sediments. Due to the poor characterisation of sediment to be dredged, the worst case for PSD and settling velocity cannot be relied on. Estimates should be further explored with additional sediment sampling and modelling.

While the proposed maximum dredge depth is about three metres, sediment was only sampled in depths ranging from 25cm to 80cm, with only one sample extracted from 140cm. Analysis of this deeper core presents a much smaller PSD for the deeper sample subset. Information is lacking on the depth intervals analysed in this core. This deeper sample is outside the dredge footprint and hence cannot be relied on to characterise particle size in the deeper sections of the dredge footprint.

Appendix 1 provides further context for the significant gaps in the sediment sampling and analysis plan and interpretation based on shallow characterisation of the dredge material. Core penetration depths ranged from:

• ~60cm at sites ZZ3-ZZ8 (presumably via diver during second survey)

• 8 of 12 sites during the first survey were ≤25cm

• 3 of 12 sites during the first survey were 50-80cm

• 1 of 12 sites (site SB7) during the first survey had a penetration depth >1m (140cm)

The first survey with core acquisition (via 10 tonnes of drilling hydraulic pressure) yielded low penetrations prior to core refusal consistently below one metre for all samples except for site SB7.2, the one location where sediment was extracted at 140cm.

The interpretation of the geotechnical / borehole data in Section 5.2 cannot be confirmed for >1-3 metres of marine sediments because the core refusal depths were at one metre (except for SB7.2 outside of the dredge pocket) during the drilling rig sediment sampling survey.

This indicates the presence of a very hard substrate (possibly consolidated material) underlying a veneer of unconsolidated sediments that may require Cutter Suction Dredge (CSD) grinding, and subsequently a third class (Class 3) of dredge material. The CSD has the potential to generate very fine particles from the dredge-header grinding the hard substrate into material and small particle diameters not commonly distributed in the marine environment.

This material will ultimately have the propensity to remain suspended in the water column for a longer duration and distance than the settling velocities measured for the shallower, unconsolidated sediment.

The draft EIS Appendix F reports that sediment in Smith Bay consisted mainly of sand and gravel with between 10 and 25 per cent of fine particulates (clay and silt), apart from the deeper sediment at Site SB7 (SB7.2), with SB7.2 having the finest particles. The evaluation of sediment as 75 per cent coarse sands is incorrect. This conclusion cannot be validated as sediment in the deeper profile has not been assessed; in essence, less than 30 per cent of the sediment has been profiled.


26

Assumptions about the behaviour and ultimate fate of dredged sediment in the water column cannot be drawn from an incomplete sampling program. The NAGD (2009) is the primary framework and default guidance to ensure the impacts of dredged material loading and disposal are adequately assessed and that impacts are managed responsibly and effectively5.

The NAGD (2009) requires that the full depth of dredging is to be characterised in order to inform the dredge methodology and predict the potential environmental impact.

5 http://www.environment.gov.au/marine/publications/national-assessment-guidelines-dredging-2009

Figure 3 – Locations of sediment samples



29

SETTLEABILITY CONCERNS

An understanding of the settleability of the dredge material is of paramount importance to understand the fate of disturbed sediment.

The characterisation of sediment in the draft EIS is further discounted as the settleability reported in the draft EIS is on the basis of four shallow sediment samples with penetration depths of 20-25cm (SB3 and SB11) via the drill rig, to ~60cm (ZZ4 and ZZ9) via SCUBA.

The settleability of the sediment cannot be confirmed based on limited shallow samples collected from both within and outside of the dredge footprint.

Settleability needs to consider the deeper unconsolidated and consolidated (noting that small particle sizes are likely to be generated during CSD grinding) sediment horizons. The draft EIS cannot rely on settleability based on a small subset of samples that comprise only 25 per cent of the proposed maximum dredge depth.

Due to the significant flaws and lack of adequate characterisation of sediment, Yumbah has no confidence in the outcomes of the models and the suggested impacts associated with dredging.

IMPACTS OF THE CAUSEWAY

An important feature of the seaport is the construction of a 250m solid causeway extending perpendicular to the coastline. The causeway is the most concerning physical feature of the seaport for Yumbah.

The causeway will significantly reduce ocean currents by up to an estimated 40 per cent, which in turn will result in elevated water temperatures, reduced mixing and supply of fresh water, accumulation of seagrass wrack and overall compromise the oceanic conditions abalone are so reliant on.

Oceanic currents are vital to abalone farming. Circulation and mixing of marine waters guarantee the high-quality seawater that sustains the abalone. Reduced seawater quality will significantly impact Yumbah’s ability to continue its business.


28

To further raise doubt in the results in Appendix F, total organic carbon (TOC) was reported at significantly higher concentrations in the one deeper sample of SB7.2.

Two dredge material sediment classes were configured as dredging simulation inputs.

Class 1, comprising 75 per cent of the total simulation dredge volume, was representative PSD of all sediment samples reported in Sub-Appendix F1 except for sample SB7.2.

Class 2, comprising the other 25 per cent of the total simulation dredge volume, was based on one deep sample of SB7.2 (maximum 1.4m).

Uncertainties highlighted in Romero’s review with regard to the sediment sampling core depths and extrapolation to the dredge depth (core refusal generally <60cm) and the inclusion of sediment characteristics outside the dredge area, the assigned volumes of 75 per cent for Class 1 (primarily sand) and 25 per cent Class 2 (greater proportion of clay and silt) cannot be relied upon.

A worst-case Class 3 of dredge material for a reasonable worst-case estimate is valid given the information available and potential interactions between the CSD and the harder (consolidated) sediments of the deeper strata of the dredge area. This demands additional modelling for a worst-case dredge material characterisation that includes worst-case estimates from dredging of the third class and worst-case dredge volume allocations to the three classes.

The issues in interpretation of the sediment sampling and analysis are significant.

On the basis of the core refusal depth, the evidence alludes to a relatively thin veneer of marine sediments (primarily sand) with perhaps some scattered relatively deeper pockets of finer material (e.g. site SB7.2), and underlying sediments comprised of a harder substrate (consolidated material).

If so, then this would support a third class (Class 3) of dredge material. As a consequence of sampling not conducted for the full dredge depth, there is also considerable uncertainty regarding the Particle Size Distribution (PSD) and settling velocities of the material generated by the CSD. The PSD of the sediments released into the marine waters will potentially pose a much greater impact/risk in terms of a worst-case scenario than the duration and amount of dredging.

A potential CSD grinding of consolidated sediments (Class 3) scenario may lead to greater dredging related turbidity than predicted in the draft EIS and will potentially have greater impacts on primary producer benthic habitat (e.g. light reduction to proximal seagrass) and Yumbah KI’s inlet water.

Further, removal of Class 3 sediment will result in dredging far exceeding the estimated worst case of 75 days.



29

SETTLEABILITY CONCERNS

An understanding of the settleability of the dredge material is of paramount importance to understand the fate of disturbed sediment.

The characterisation of sediment in the draft EIS is further discounted as the settleability reported in the draft EIS is on the basis of four shallow sediment samples with penetration depths of 20-25cm (SB3 and SB11) via the drill rig, to ~60cm (ZZ4 and ZZ9) via SCUBA.

The settleability of the sediment cannot be confirmed based on limited shallow samples collected from both within and outside of the dredge footprint.

Settleability needs to consider the deeper unconsolidated and consolidated (noting that small particle sizes are likely to be generated during CSD grinding) sediment horizons. The draft EIS cannot rely on settleability based on a small subset of samples that comprise only 25 per cent of the proposed maximum dredge depth.

Due to the significant flaws and lack of adequate characterisation of sediment, Yumbah has no confidence in the outcomes of the models and the suggested impacts associated with dredging.

IMPACTS OF THE CAUSEWAY

An important feature of the seaport is the construction of a 250m solid causeway extending perpendicular to the coastline. The causeway is the most concerning physical feature of the seaport for Yumbah.

The causeway will significantly reduce ocean currents by up to an estimated 40 per cent, which in turn will result in elevated water temperatures, reduced mixing and supply of fresh water, accumulation of seagrass wrack and overall compromise the oceanic conditions abalone are so reliant on.

Oceanic currents are vital to abalone farming. Circulation and mixing of marine waters guarantee the high-quality seawater that sustains the abalone. Reduced seawater quality will significantly impact Yumbah’s ability to continue its business.


28

To further raise doubt in the results in Appendix F, total organic carbon (TOC) was reported at significantly higher concentrations in the one deeper sample of SB7.2.

Two dredge material sediment classes were configured as dredging simulation inputs.

Class 1, comprising 75 per cent of the total simulation dredge volume, was representative PSD of all sediment samples reported in Sub-Appendix F1 except for sample SB7.2.

Class 2, comprising the other 25 per cent of the total simulation dredge volume, was based on one deep sample of SB7.2 (maximum 1.4m).

Uncertainties highlighted in Romero’s review with regard to the sediment sampling core depths and extrapolation to the dredge depth (core refusal generally <60cm) and the inclusion of sediment characteristics outside the dredge area, the assigned volumes of 75 per cent for Class 1 (primarily sand) and 25 per cent Class 2 (greater proportion of clay and silt) cannot be relied upon.

A worst-case Class 3 of dredge material for a reasonable worst-case estimate is valid given the information available and potential interactions between the CSD and the harder (consolidated) sediments of the deeper strata of the dredge area. This demands additional modelling for a worst-case dredge material characterisation that includes worst-case estimates from dredging of the third class and worst-case dredge volume allocations to the three classes.

The issues in interpretation of the sediment sampling and analysis are significant.

On the basis of the core refusal depth, the evidence alludes to a relatively thin veneer of marine sediments (primarily sand) with perhaps some scattered relatively deeper pockets of finer material (e.g. site SB7.2), and underlying sediments comprised of a harder substrate (consolidated material).

If so, then this would support a third class (Class 3) of dredge material. As a consequence of sampling not conducted for the full dredge depth, there is also considerable uncertainty regarding the Particle Size Distribution (PSD) and settling velocities of the material generated by the CSD. The PSD of the sediments released into the marine waters will potentially pose a much greater impact/risk in terms of a worst-case scenario than the duration and amount of dredging.

A potential CSD grinding of consolidated sediments (Class 3) scenario may lead to greater dredging related turbidity than predicted in the draft EIS and will potentially have greater impacts on primary producer benthic habitat (e.g. light reduction to proximal seagrass) and Yumbah KI’s inlet water.

Further, removal of Class 3 sediment will result in dredging far exceeding the estimated worst case of 75 days.



31

the proposed causeway and any impacts/risks in terms of recirculation of the outlet waters into the Yumbah KI facility’s intakes has not been addressed.

• A number of figures present the modelled impacts and impact zones but are missing the seaport footprint and dredge area. This creates confusion interpreting the many figures and claims in the draft EIS.

IMPACT TO COASTAL PROCESSES

The modelling completed by BMT and presented in the draft EIS Appendix G indicates construction and operation of the seaport will alter the coastal processes in Smith Bay.

Appendix G states:

“The current circulation impacts show a slight reduction in current speeds flowing through Smith Bay nearshore waters as a result of the proposed development.”

This alteration is unacceptable to Yumbah and has the potential to deliver catastrophic impacts to its operations. Changes to coastal processes are likely to reduce circulation in the nearshore environment and compromise the health of the water which Yumbah KI is completely reliant upon. As highlighted previously, there is a lack of information in the draft EIS regarding impacts of nearshore flushing and potential for recirculation of Yumbah’s outlet waters through the intake.

This is a significant gap in the draft EIS. The statement ‘Coastal circulation impacts are not expected to result in reduced flushing of Smith Bay waters’ in Appendix G is not – and must be - demonstrated.

Similarly, the draft EIS Appendix G reports:

“Generally, impacts on coastal circulation are highly localised and in the immediate vicinity of the Project infrastructure where some local realignment and modification of current speeds will occur.”

It fails to mention that Yumbah KI is in the immediate vicinity of the “Project infrastructure” and will be significantly impacted by the realignment and modification of current speeds.


30

MISCONSTRUED BENEFITS OF CAUSEWAY

Smith Creek is a freshwater catchment west of Yumbah KI that has been influenced by historic land clearance and agricultural activities. The draft EIS makes multiple unsubstantiated references to the causeway providing a benefit to Yumbah KI as a consequence of physically blocking Smith Creek’s flows and isolating potential flows from the farms intake pipes. In reality the causeway presents one of the greatest risks to Yumbah KI’s operations.

Its presence will alter coastal processes and longshore currents with currents estimated to reduce by up to 40 per cent, creating a permanent barrier to currents and thereby reducing mixing in the receiving environment and subsequent elevation of temperatures and reduced water quality.

It must be explicitly stated that Yumbah KI has been successfully operating at this site since 1995 with negligible impact from Smith Creek aside from a limited number of storm events in 2016. Romero (2019) outlines the conclusions of the review on the suggested benefits of the causeway, confirming that the catchment model used in the draft EIS to predict the impacts of flood plumes from Smith Creek into the proximal marine waters - with an emphasis on the effect to Yumbah KI seawater intakes - is flawed.

The suggested benefit to Yumbah KI’s inlet turbidity reduction from such very infrequent 1:10 AEP Smith Creek storm events does not justify the causeway’s construction.

According to Romero (2019), the objective of the draft EIS catchment modelling is seemingly to demonstrate the reduction in Smith Creek flood-derived suspended sediments into Yumbah KI’s intakes from the proposed causeway. The simulated

large discharge and sediment loads are not verifiable. The modelling of smaller storm events is required to demonstrate the frequency, magnitude and duration of any suggested benefit.

VAGARIES IN MARINE WATER QUALITY BASELINE AND IMPACT ASSESSMENT

The draft EIS sub-appendix F3 discusses baseline marine water quality and impacts from the seaport.

Issues with this report include:

• Ecological impact thresholds are predicted for a number of water quality parameters. Romero (2019) states the use of 10´ (Zone of High Impact) and 5´ (Zone of Low to Moderate Impact) standard deviations above the 50th and 80th percentile means to define ecological impact thresholds from turbidity are unjustified. Romero deems there to be no ecological basis for these criteria. The suggested thresholds do not address seasonality in biotic receptors. It has been demonstrated that ambient turbidity is highly correlated to wave climate in Smith Bay (Figure 2-10 in Sub-Appendix F2). The approach to define the impact thresholds does not seem to account for this sensitive period (mid-spring to mid-autumn), which from a benthic primary producer perspective is the worst-case timing to carry out the dredge program.

• The placement of a solid causeway to the east has the potential to alter the typical flushing patterns with a potential to increase the recirculation of the facility’s outlet waters to the inlets. The potential for changes to the very nearshore flushing of Yumbah KI’s outlet waters due to the presence of



31

the proposed causeway and any impacts/risks in terms of recirculation of the outlet waters into the Yumbah KI facility’s intakes has not been addressed.

• A number of figures present the modelled impacts and impact zones but are missing the seaport footprint and dredge area. This creates confusion interpreting the many figures and claims in the draft EIS.

IMPACT TO COASTAL PROCESSES

The modelling completed by BMT and presented in the draft EIS Appendix G indicates construction and operation of the seaport will alter the coastal processes in Smith Bay.

Appendix G states:

“The current circulation impacts show a slight reduction in current speeds flowing through Smith Bay nearshore waters as a result of the proposed development.”

This alteration is unacceptable to Yumbah and has the potential to deliver catastrophic impacts to its operations. Changes to coastal processes are likely to reduce circulation in the nearshore environment and compromise the health of the water which Yumbah KI is completely reliant upon. As highlighted previously, there is a lack of information in the draft EIS regarding impacts of nearshore flushing and potential for recirculation of Yumbah’s outlet waters through the intake.

This is a significant gap in the draft EIS. The statement ‘Coastal circulation impacts are not expected to result in reduced flushing of Smith Bay waters’ in Appendix G is not – and must be - demonstrated.

Similarly, the draft EIS Appendix G reports:

“Generally, impacts on coastal circulation are highly localised and in the immediate vicinity of the Project infrastructure where some local realignment and modification of current speeds will occur.”

It fails to mention that Yumbah KI is in the immediate vicinity of the “Project infrastructure” and will be significantly impacted by the realignment and modification of current speeds.


30

MISCONSTRUED BENEFITS OF CAUSEWAY

Smith Creek is a freshwater catchment west of Yumbah KI that has been influenced by historic land clearance and agricultural activities. The draft EIS makes multiple unsubstantiated references to the causeway providing a benefit to Yumbah KI as a consequence of physically blocking Smith Creek’s flows and isolating potential flows from the farms intake pipes. In reality the causeway presents one of the greatest risks to Yumbah KI’s operations.

Its presence will alter coastal processes and longshore currents with currents estimated to reduce by up to 40 per cent, creating a permanent barrier to currents and thereby reducing mixing in the receiving environment and subsequent elevation of temperatures and reduced water quality.

It must be explicitly stated that Yumbah KI has been successfully operating at this site since 1995 with negligible impact from Smith Creek aside from a limited number of storm events in 2016. Romero (2019) outlines the conclusions of the review on the suggested benefits of the causeway, confirming that the catchment model used in the draft EIS to predict the impacts of flood plumes from Smith Creek into the proximal marine waters - with an emphasis on the effect to Yumbah KI seawater intakes - is flawed.

The suggested benefit to Yumbah KI’s inlet turbidity reduction from such very infrequent 1:10 AEP Smith Creek storm events does not justify the causeway’s construction.

According to Romero (2019), the objective of the draft EIS catchment modelling is seemingly to demonstrate the reduction in Smith Creek flood-derived suspended sediments into Yumbah KI’s intakes from the proposed causeway. The simulated

large discharge and sediment loads are not verifiable. The modelling of smaller storm events is required to demonstrate the frequency, magnitude and duration of any suggested benefit.

VAGARIES IN MARINE WATER QUALITY BASELINE AND IMPACT ASSESSMENT

The draft EIS sub-appendix F3 discusses baseline marine water quality and impacts from the seaport.

Issues with this report include:

• Ecological impact thresholds are predicted for a number of water quality parameters. Romero (2019) states the use of 10´ (Zone of High Impact) and 5´ (Zone of Low to Moderate Impact) standard deviations above the 50th and 80th percentile means to define ecological impact thresholds from turbidity are unjustified. Romero deems there to be no ecological basis for these criteria. The suggested thresholds do not address seasonality in biotic receptors. It has been demonstrated that ambient turbidity is highly correlated to wave climate in Smith Bay (Figure 2-10 in Sub-Appendix F2). The approach to define the impact thresholds does not seem to account for this sensitive period (mid-spring to mid-autumn), which from a benthic primary producer perspective is the worst-case timing to carry out the dredge program.

• The placement of a solid causeway to the east has the potential to alter the typical flushing patterns with a potential to increase the recirculation of the facility’s outlet waters to the inlets. The potential for changes to the very nearshore flushing of Yumbah KI’s outlet waters due to the presence of



33

INACCURACIES WITH CURRENT FIELD IMPACTS

Yumbah KI deployed a tilt meter in the nearshore waters of its Smith Bay farm in order to characterise the current regime just offshore from its western seawater intakes in about eight metres of water over the six months from 24 August 2018 to 25 February 2019.

Measured current speeds are presented in Figure 1 of Romero (2019). Current speeds typically ranged between 2cm/s and 15 cm/s during neap tides and 2cm/s to 20cm/s during spring tides. Current directions at the site periodically alternate between the dominant directions of easterly during flood tides and westerly during ebb tides. The minimum current speed of ~2cm/s is sufficient to transport a turbid plume from the proposed port to the western intake of Yumbah KI’s facility, a distance of about just 300 metres.

Current speed in shallow waters in front of the abalone farm range across the 10th to 90th percentile of 4cm/s to 13cm/s measured over the six-month period.

Current field impacts are addressed in section 4.3 the draft of EIS sub appendix F2 to assess predicted changes in the proximal location to Yumbah KI inlets and outlets. The close-up figures of the differences in current velocities in the region of the aquaculture facility are not adequate. Finer current velocity intervals of 1-2cm/s rather than 10cm/s intervals (bottom panels of Appendix G Figures 6-8 and 6-9) are more representative and so should be applied.

The below diagram shows the probability distribution of the inshore currents over the six-month deployment. The 10th, 20th, 50th, 80th and 90th current speed percentiles are approximately 4, 6, 8, 12 and 13cm/s.

Modelling and impact assessment results and interpretations should be reassessed using these more representative measured range of current speeds.

Figure 5 – Probability distribution of current vector magnitudes


32

ACCUMULATION OF SEAWEED (WRACK)

The draft EIS reports that accumulation drift seagrass and macroalgae (wrack) will occur as a consequence of the construction of the causeway. This accumulation is unacceptable for the impact it will have on Yumbah KI’s seawater intakes.

Accumulation of drift seagrass and other macroalgae will clog intake pipes and degrade water quality.

The extent of degradation and potential impacts on Yumbah KI and Smith Bay more broadly are lacking in the EIS, and Romero (2019) has highlighted the need for additional information, including:

• A description of the seagrass wrack dynamics of Smith Bay

• Predictions of the effect of the proposed development on the seagrass wrack dynamics of Smith Bay

• Impacts of the predicted changes of seagrass wrack dynamics on the source waters to Yumbah KI’s abalone farm

•

Amendments to the risk assessment

o Though risk reference Item 8 in Table 4-1 of EIS Appendix G identifies the hazard, modification to seagrass wrack accumulation, the basis for a consequence of “minor” and likelihood of “possible” is not supported

o Further, mitigation measures only change the residual likelihood and not the residual consequence (note this comment also applies to reference Item 6 in Table 4-1, and it is uncertain why changes in residual likelihoods to references 2 and 3 are included with no [nil] mitigation measures noted)

o The inherent and residual risk for seagrass wrack accumulation is not supported

The risk of wrack accumulation on the quality of the source waters to Yumbah KI’s abalone farm is lacking and must be addressed, particularly given the close proximity of the proposed development to the inlet pipes.

Figure 4 - Seagrass Rack accumulated at nearby Emu Bay



33

INACCURACIES WITH CURRENT FIELD IMPACTS

Yumbah KI deployed a tilt meter in the nearshore waters of its Smith Bay farm in order to characterise the current regime just offshore from its western seawater intakes in about eight metres of water over the six months from 24 August 2018 to 25 February 2019.

Measured current speeds are presented in Figure 1 of Romero (2019). Current speeds typically ranged between 2cm/s and 15 cm/s during neap tides and 2cm/s to 20cm/s during spring tides. Current directions at the site periodically alternate between the dominant directions of easterly during flood tides and westerly during ebb tides. The minimum current speed of ~2cm/s is sufficient to transport a turbid plume from the proposed port to the western intake of Yumbah KI’s facility, a distance of about just 300 metres.

Current speed in shallow waters in front of the abalone farm range across the 10th to 90th percentile of 4cm/s to 13cm/s measured over the six-month period.

Current field impacts are addressed in section 4.3 the draft of EIS sub appendix F2 to assess predicted changes in the proximal location to Yumbah KI inlets and outlets. The close-up figures of the differences in current velocities in the region of the aquaculture facility are not adequate. Finer current velocity intervals of 1-2cm/s rather than 10cm/s intervals (bottom panels of Appendix G Figures 6-8 and 6-9) are more representative and so should be applied.

The below diagram shows the probability distribution of the inshore currents over the six-month deployment. The 10th, 20th, 50th, 80th and 90th current speed percentiles are approximately 4, 6, 8, 12 and 13cm/s.

Modelling and impact assessment results and interpretations should be reassessed using these more representative measured range of current speeds.

Figure 5 – Probability distribution of current vector magnitudes


32

ACCUMULATION OF SEAWEED (WRACK)

The draft EIS reports that accumulation drift seagrass and macroalgae (wrack) will occur as a consequence of the construction of the causeway. This accumulation is unacceptable for the impact it will have on Yumbah KI’s seawater intakes.

Accumulation of drift seagrass and other macroalgae will clog intake pipes and degrade water quality.

The extent of degradation and potential impacts on Yumbah KI and Smith Bay more broadly are lacking in the EIS, and Romero (2019) has highlighted the need for additional information, including:




•

Amendments to the risk assessment

o Though risk reference Item 8 in Table 4-1 of EIS Appendix G identifies the hazard, modification to seagrass wrack accumulation, the basis for a consequence of “minor” and likelihood of “possible” is not supported

o Further, mitigation measures only change the residual likelihood and not the residual consequence (note this comment also applies to reference Item 6 in Table 4-1, and it is uncertain why changes in residual likelihoods to references 2 and 3 are included with no [nil] mitigation measures noted)

o The inherent and residual risk for seagrass wrack accumulation is not supported

The risk of wrack accumulation on the quality of the source waters to Yumbah KI’s abalone farm is lacking and must be addressed, particularly given the close proximity of the proposed development to the inlet pipes.

Figure 4 - Seagrass Rack accumulated at nearby Emu Bay



35

FUNDAMENTAL FLAWS IN ABALONE ASSESSMENT

Appendix H declares the importance of good water quality to the success and viability of Yumbah KI with the statement: “In summary, the importance of good water quality to the health of the abalone aquaculture sector cannot be understated”.

This technical report is apparently relied upon as the scientific backbone of the draft EIS, but actually works only to attempt to negate the significance of adverse impacts the seaport will create for Yumbah KI.

The EIS guidelines (DAC 2017) requested the following information be reported in the draft EIS, but this is absent. The draft EIS cannot be considered a compliant document without required information that includes:

• Impacts that dredging may have on sediment loads and the neighbouring commercial land-based aquaculture operation. Detail measures for managing these impacts, including management of dredge spoil

• Description of the contaminants and toxicants that may accumulate on the property and the risks during stormwater events (where not managed) to the adjacent aquatic environments and commercial industries (e.g. fisheries and aquaculture) that rely on those environments.

MISGUIDED AND INCORRECT ASSUMPTIONS ABOUT YUMBAH KI

Statements regarding abalone husbandry in Appendix H of the draft EIS reflect a lack of expertise in the field. This concern is supported by Appendix 3 – a review of Appendix H by the peak body representing the abalone farm industry in Australia (AAGA submission, 2019).

Incorrect, inaccurate or false inclusions in Appendix H that relate to abalone aquaculture include:

• Feed moisture content is incorrect

• Abalone growth increases with temperature

• Abalone broodstock are not isolated

• Oxygen is not an issue that even requires monitoring for health

• Hatchery timeframes and mortality rates are incorrect; note, Yumbah produce what is needed for the coming season, not excess

• Estimates that Yumbah’s two South Australian abalone farms produce 337 tonnes of abalone fall well short of the actual 402-tonne production

• Nursery timeframes and filtration rates are wrong

• The hatchery operates by water flowthrough not recirculation, and water is filtered to 1µm

• Nursery water is filtered to 50µm to allow natural diatoms to pass

• Stocking levels for production are wrong

• Reported growth rates are wrong, and much slower than actual


34

FURTHER DRAFT EIS SHORTCOMINGS

Beyond the many concerns outlined above regarding water quality, Yumbah further concerns about conclusions drawn from the assessment that formed the draft EIS Appendix L Geology, Soils and Water.

These include the following unacceptable risks that, if realised, will significantly impact Yumbah KI:

• The sediment load in the dewatering discharge from the dredge slurry potentially could be high if not managed effectively

• Stormwater runoff could cause surface and beach wall erosion and could transport sediment to surface water if not appropriately managed

• Site activities during operations could result in the release and accumulation of chemicals which could result in site contamination (soil and groundwater) and the contamination of stormwater runoff if not appropriately managed

• Leachate from the woodchip stockpile and log storage could harm surface water via direct runoff or through stormwater transport, and groundwater via infiltration through a permeable base

KIPT’s reputation and performance to date with respect to its intentions at Smith Bay and across Kangaroo Island are questionable.

While this draft EIS presents a case for permitting construction in an earlier iteration of its seaport proposal, its terms of reference do not in any way seek protections for the natural environment, during operation of its seaport.

CONCLUSION OF WATER QUALITY

The details in the draft EIS on water quality, coastal processes and suspended solids is fundamentally flawed and the information it contains cannot be relied upon.

The draft EIS Main Report indicates the assessment of the impact of dredging on water quality relies heavily on dredge plume modelling results that consist of time series results and percentile contour plots of turbidity. These plots indicate the areas where turbidity was elevated at some point during the dredge campaign, rather than being snapshots of the dredge plume at any particular time.

The total suspended solids (TSS) impact assessment is questionable as there is considerable uncertainty in the PSD of the dredge material, and the need for deeper sediment understanding, particularly to confirm the presence of a Class 3 sediment of consolidated material.

The use of incorrect current field data further discounts any of the conclusions outlined in the draft EIS on water quality impacts and effects on Yumbah KI.

The behaviour of sediment dredged and potential zones of impact modelled are incorrect as the data generated to support the assumptions is wrong, and the actual impacts from both construction and operation of the seaport to Yumbah KI remain unknown.



35

FUNDAMENTAL FLAWS IN ABALONE ASSESSMENT

Appendix H declares the importance of good water quality to the success and viability of Yumbah KI with the statement: “In summary, the importance of good water quality to the health of the abalone aquaculture sector cannot be understated”.

This technical report is apparently relied upon as the scientific backbone of the draft EIS, but actually works only to attempt to negate the significance of adverse impacts the seaport will create for Yumbah KI.

The EIS guidelines (DAC 2017) requested the following information be reported in the draft EIS, but this is absent. The draft EIS cannot be considered a compliant document without required information that includes:

• Impacts that dredging may have on sediment loads and the neighbouring commercial land-based aquaculture operation. Detail measures for managing these impacts, including management of dredge spoil

• Description of the contaminants and toxicants that may accumulate on the property and the risks during stormwater events (where not managed) to the adjacent aquatic environments and commercial industries (e.g. fisheries and aquaculture) that rely on those environments.

MISGUIDED AND INCORRECT ASSUMPTIONS ABOUT YUMBAH KI

Statements regarding abalone husbandry in Appendix H of the draft EIS reflect a lack of expertise in the field. This concern is supported by Appendix 3 – a review of Appendix H by the peak body representing the abalone farm industry in Australia (AAGA submission, 2019).

Incorrect, inaccurate or false inclusions in Appendix H that relate to abalone aquaculture include:

• Feed moisture content is incorrect

• Abalone growth increases with temperature

• Abalone broodstock are not isolated

• Oxygen is not an issue that even requires monitoring for health

• Hatchery timeframes and mortality rates are incorrect; note, Yumbah produce what is needed for the coming season, not excess

• Estimates that Yumbah’s two South Australian abalone farms produce 337 tonnes of abalone fall well short of the actual 402-tonne production

• Nursery timeframes and filtration rates are wrong

• The hatchery operates by water flowthrough not recirculation, and water is filtered to 1µm

• Nursery water is filtered to 50µm to allow natural diatoms to pass

• Stocking levels for production are wrong

• Reported growth rates are wrong, and much slower than actual


34

FURTHER DRAFT EIS SHORTCOMINGS

Beyond the many concerns outlined above regarding water quality, Yumbah further concerns about conclusions drawn from the assessment that formed the draft EIS Appendix L Geology, Soils and Water.

These include the following unacceptable risks that, if realised, will significantly impact Yumbah KI:

• The sediment load in the dewatering discharge from the dredge slurry potentially could be high if not managed effectively

• Stormwater runoff could cause surface and beach wall erosion and could transport sediment to surface water if not appropriately managed

• Site activities during operations could result in the release and accumulation of chemicals which could result in site contamination (soil and groundwater) and the contamination of stormwater runoff if not appropriately managed

• Leachate from the woodchip stockpile and log storage could harm surface water via direct runoff or through stormwater transport, and groundwater via infiltration through a permeable base

KIPT’s reputation and performance to date with respect to its intentions at Smith Bay and across Kangaroo Island are questionable.

While this draft EIS presents a case for permitting construction in an earlier iteration of its seaport proposal, its terms of reference do not in any way seek protections for the natural environment, during operation of its seaport.

CONCLUSION OF WATER QUALITY

The details in the draft EIS on water quality, coastal processes and suspended solids is fundamentally flawed and the information it contains cannot be relied upon.

The draft EIS Main Report indicates the assessment of the impact of dredging on water quality relies heavily on dredge plume modelling results that consist of time series results and percentile contour plots of turbidity. These plots indicate the areas where turbidity was elevated at some point during the dredge campaign, rather than being snapshots of the dredge plume at any particular time.

The total suspended solids (TSS) impact assessment is questionable as there is considerable uncertainty in the PSD of the dredge material, and the need for deeper sediment understanding, particularly to confirm the presence of a Class 3 sediment of consolidated material.

The use of incorrect current field data further discounts any of the conclusions outlined in the draft EIS on water quality impacts and effects on Yumbah KI.

The behaviour of sediment dredged and potential zones of impact modelled are incorrect as the data generated to support the assumptions is wrong, and the actual impacts from both construction and operation of the seaport to Yumbah KI remain unknown.



37

Appendix H refers to:

“Sainsbury (1982) investigated the effects of sediments on an unfished (wild) population of Haliotis iris in Peraki Bay (New Zealand), in terms of population size and structure, growth, recruitment, mortality and reproduction. He concluded that a "major cause [of mortality]" was burial due to the movement of large volumes of benthic sediments that resulted in changes in sediment depths by up to 1m.”

This substantively supports Yumbah’s claims that sediment which enters the tank, falls out and accumulates, will eventually smother and kill the abalone. If TSS was at 10mg/l for 24 hours, each tank has the potential to accumulate about 2.6kg of sediment.

The draft EIS Main Report also concludes that TSS levels are predicted to increase at the Yumbah seawater intakes by approximately 4mg/L for the expected case, and up to 7mg/L under worst-case conditions.

A concerning factor with this conclusion is the PSD and the concentration of fine sediment likely to be dispersed during dredging is unknown, given sediment sampling and analysis has not been conducted to the complete dredge depth of three metres. Any resulting plume modelling is unreliable.

The draft EIS also reports suspended sediment particles sizes in water samples ranged from 0.2μm up to 3,000μm, with most particle sizes around 100-200μm. There was a higher proportion of inorganic sediment particles (53-65 per cent) compared to organic sediment particles (34-46 per cent) analysed in samples.

Dredging will result in disturbance of a higher concentration of fine sediment, and potentially Class 3 sediment. The usual coarse sediment in Smith Bay of around 100-200μm reported in the draft EIS Appendix F will be exacerbated with fine silt during dredging, potentially remaining in suspension for a significantly longer period than the worst case of 75 days dredging if Class 3 sediment requires dredging.


36

• Mortality statements are incorrect

• Meat yields are incorrect; they are historically about 40 per cent

• Grade size yields are incorrect

THE REAL STORY ABOUT SUSPENDED SOLIDS

The draft EIS Main report alleges extensive cropping and grazing industries

“… are likely to have had adverse effects on marine water quality along the north coast of Kangaroo Island through erosion processes within cleared catchments and along degraded creeks during rain events, resulting in the transport of silt into the marine environment via creeks, thereby increasing the turbidity of coastal waters.”

This statement by the proponent is both misleading and incorrect.

Baseline water quality of Smith Bay measured for the purpose of the draft EIS (presented in Appendix F) indicates the opposite is true.

Water quality in Smith Bay is indeed very healthy and lacks impact from anthropogenic influences, which explains why Smith Bay is an appropriate environment for long-term and continuing aquaculture at Yumbah KI – but not with a destructive seaport on its boundary.

The draft EIS Appendix F (Section 2.9) reports that background concentrations of TSS and turbidity are exceedingly low, with turbidity in Smith Bay mostly below 1 NTU for the 12-month monitoring period. There were frequent elevated turbidity periods coincident with weather patterns, but turbidity did not exceed 10 NTU at any time during 12 months of in situ monitoring.

Compared with the ANZECC/ARMCANZ (2000) guideline value for turbidity, the median turbidity from the monitoring buoy

data for the full year, along with the summer and spring months were below the ANZECC/ARMCANZ (2000) guideline value (0.5 NTU). During autumn and winter, median turbidity (0.7 NTU) slightly exceeded the guideline value. In contrast, the near-bed median turbidity measured during the summer months exceeded the ANZECC/ARMCANZ (2000) guideline value at both the 5m depth contour (1.7 NTU) and 10 m depth contour (1 NTU).

Most TSS values measured during grab samples between September 2017 and February 2018 (Table 2-7) are below the guideline value of 10 mg/L, with over 50% of values being <1 mg/L. The exception was the water sample collected on 22/2/18, which had a TSS value of 41 mg/L. However, this sample was collected at the shoreline following a period of strong northerly winds which resulted in visibly turbid conditions in Smith Bay.

As stated in the draft EIS, ultimately the turbidity plumes from construction and operation must be considered within the context of natural variability in turbidity in Smith Bay. TSS in Smith Bay is significantly low and generally does not exceed 10 mg/L.

It is not possible that the draft EIS purports the acceptability that acute TSS levels exceeding 10 mg/L above ambient will be restricted to within a few hundred metres of the dredging footprint for the expected case. TSS levels exceeding 10 mg/L above ambient have been predicted to extend up to two kilometres east of the dredging footprint under worst-case conditions.

Yumbah KI is less than 400m from the dredging activity area and will be directly impacted by elevated TSS.

This has been reported in the draft EIS as acceptable for the proponent, but it is far from the case.



37

Appendix H refers to:

“Sainsbury (1982) investigated the effects of sediments on an unfished (wild) population of Haliotis iris in Peraki Bay (New Zealand), in terms of population size and structure, growth, recruitment, mortality and reproduction. He concluded that a "major cause [of mortality]" was burial due to the movement of large volumes of benthic sediments that resulted in changes in sediment depths by up to 1m.”

This substantively supports Yumbah’s claims that sediment which enters the tank, falls out and accumulates, will eventually smother and kill the abalone. If TSS was at 10mg/l for 24 hours, each tank has the potential to accumulate about 2.6kg of sediment.

The draft EIS Main Report also concludes that TSS levels are predicted to increase at the Yumbah seawater intakes by approximately 4mg/L for the expected case, and up to 7mg/L under worst-case conditions.

A concerning factor with this conclusion is the PSD and the concentration of fine sediment likely to be dispersed during dredging is unknown, given sediment sampling and analysis has not been conducted to the complete dredge depth of three metres. Any resulting plume modelling is unreliable.

The draft EIS also reports suspended sediment particles sizes in water samples ranged from 0.2μm up to 3,000μm, with most particle sizes around 100-200μm. There was a higher proportion of inorganic sediment particles (53-65 per cent) compared to organic sediment particles (34-46 per cent) analysed in samples.

Dredging will result in disturbance of a higher concentration of fine sediment, and potentially Class 3 sediment. The usual coarse sediment in Smith Bay of around 100-200μm reported in the draft EIS Appendix F will be exacerbated with fine silt during dredging, potentially remaining in suspension for a significantly longer period than the worst case of 75 days dredging if Class 3 sediment requires dredging.


36

• Mortality statements are incorrect

• Meat yields are incorrect; they are historically about 40 per cent

• Grade size yields are incorrect

THE REAL STORY ABOUT SUSPENDED SOLIDS

The draft EIS Main report alleges extensive cropping and grazing industries

“… are likely to have had adverse effects on marine water quality along the north coast of Kangaroo Island through erosion processes within cleared catchments and along degraded creeks during rain events, resulting in the transport of silt into the marine environment via creeks, thereby increasing the turbidity of coastal waters.”

This statement by the proponent is both misleading and incorrect.

Baseline water quality of Smith Bay measured for the purpose of the draft EIS (presented in Appendix F) indicates the opposite is true.

Water quality in Smith Bay is indeed very healthy and lacks impact from anthropogenic influences, which explains why Smith Bay is an appropriate environment for long-term and continuing aquaculture at Yumbah KI – but not with a destructive seaport on its boundary.

The draft EIS Appendix F (Section 2.9) reports that background concentrations of TSS and turbidity are exceedingly low, with turbidity in Smith Bay mostly below 1 NTU for the 12-month monitoring period. There were frequent elevated turbidity periods coincident with weather patterns, but turbidity did not exceed 10 NTU at any time during 12 months of in situ monitoring.

Compared with the ANZECC/ARMCANZ (2000) guideline value for turbidity, the median turbidity from the monitoring buoy

data for the full year, along with the summer and spring months were below the ANZECC/ARMCANZ (2000) guideline value (0.5 NTU). During autumn and winter, median turbidity (0.7 NTU) slightly exceeded the guideline value. In contrast, the near-bed median turbidity measured during the summer months exceeded the ANZECC/ARMCANZ (2000) guideline value at both the 5m depth contour (1.7 NTU) and 10 m depth contour (1 NTU).

Most TSS values measured during grab samples between September 2017 and February 2018 (Table 2-7) are below the guideline value of 10 mg/L, with over 50% of values being <1 mg/L. The exception was the water sample collected on 22/2/18, which had a TSS value of 41 mg/L. However, this sample was collected at the shoreline following a period of strong northerly winds which resulted in visibly turbid conditions in Smith Bay.

As stated in the draft EIS, ultimately the turbidity plumes from construction and operation must be considered within the context of natural variability in turbidity in Smith Bay. TSS in Smith Bay is significantly low and generally does not exceed 10 mg/L.

It is not possible that the draft EIS purports the acceptability that acute TSS levels exceeding 10 mg/L above ambient will be restricted to within a few hundred metres of the dredging footprint for the expected case. TSS levels exceeding 10 mg/L above ambient have been predicted to extend up to two kilometres east of the dredging footprint under worst-case conditions.

Yumbah KI is less than 400m from the dredging activity area and will be directly impacted by elevated TSS.

This has been reported in the draft EIS as acceptable for the proponent, but it is far from the case.



39

There is confusion and direct separation between content in Appendix H and other technical reports presented in the draft EIS.

While Appendix H states that:

“… turbidity levels in Smith Bay routinely reach 5–6 NTU, which would likely correspond to suspended sediment loads in the range 10–20mg/L depending on when and where the measurements are made.”

This is in direct opposition to Appendix F which reports a linear correlation of 0.92mg/L of TSS per 1 NTU of turbidity. The Water Quality baseline reports background TSS as generally <5mg/L, with >50 per cent of grab sample measurements <1mg/L in Smith Bay.

The comparison with a background range of 10-20mg/L in Appendix H is incorrect.

The following claim in Appendix H is both far-fetched and incorrect:

“Assuming the implementation of an appropriate dredge management program, there is no potential for smothering of abalone within the abalone farm due to the proposed dredging.”

This submission already notes the draft EIS modelling of sediment transport is incorrect due to a lack of actual PSD data for the full dredge depth.

Further claims from Appendix H:

“… the BMT (2018a) study has synthesised data from COOE (2017) which provides a detailed analysis of sediment types and particularly the particle size distribution of sediments as a basis for determining the likely transport pathways and volumes for different types of sediments (Class 1 and Class 2 sediments as defined in BMT 2018a). This work has indicated that dredging operation is likely to encounter sediments comprising a mixture of 75% Silty-Sand and 25% Sandy-Silt.”

Only 25 per cent is forecast to be sandy-silt. As highlighted earlier, it would be a stretch to state that 30% of total dredge volume has been accurately characterised for PSD.

As already noted in this submission, the modelling is flawed and cannot be relied on to adequately predict sediment fate and behaviour.

Appendix H recognises that while summer mortality is not fully understood there are likely to be many other factors that contribute to mortality, including temperature spikes, reductions in the oxygen holding capacity of water, and increased disease susceptibility.

Appendix H lacks consideration of cumulative impacts to reduced water quality, and subsequent impacts to abalone particularly during the summer months when dredging is proposed. Changes to water quality during summer, particularly temperature elevations and degraded water quality, will be exacerbated by dredging in summer, with elevated TSS further stressing abalone. The potential risks to Yumbah KI during the summer months when dredging is proposed could be extreme - and even catastrophic - for abalone.

Yumbah Kangaroo Island Pty Ltd have recently acquired another licence (Active as of 1 July, 2018) which is immediately adjacent to the Kl Seaport land holding on Kangaroo Island. This licence is not currently producing any product. Yumbah’s intention with this licence was to expand production of abalone and investigate aquaculture of the other permitted species, but this has been placed on hold as a consequence of this destructive seaport and the legal litigation ensuing between KIPT and Yumbah.

The author of Appendix H purports that abalone are well adapted to high suspended sediment loads, and are more


38

INTOLERANCE TO FINE SEDIMENT

The concern with TSS and potential for fines to be disturbed is of greatest significance when highlighting what is incorrect in Appendix H. The author of Appendix H presents false and misleading information relating to abalone’s tolerances to TSS.

Construction of the causeway and the dredging of the berthing basin will collectively entail more than six months of exposure to fine sediment loads in Smith Bay. Fine sediment emanating from dredge spoil and construction debris will enter Yumbah’s seawater intakes. This presents an unacceptable risk and will significantly compromise the continuing viability of abalone farming at Yumbah KI.

Thus, the risks of the seaport on abalone should be further evaluated in terms of concentration (likely fine sediment loads) and exposure to the hazard (duration). This has not been applied to inform the draft EIS. Modelling and suggested zones of impact are inaccurate and based on incorrect PSD data.

Examining the potential implications of disturbing Class 3 is the only way to correctly anticipate the potential extent of sediment plumes in dredging Smith Bay.

The following statement in the EIS does not constitute mitigation and management of dredge impacts:

“It is considered that it would be possible to mitigate unacceptable effects on water quality at Yumbah’s seawater intakes during capital dredging through the adoption of appropriate management measures with the implementation of the dredging management and monitoring plan, which is a normal industry practice adopted during dredging activities. The risk of exceeding TSS thresholds at the Yumbah intakes would be managed (and reduced) by installing alarms and live

monitoring of water quality at a point between the dredging footprint and the intakes. Dredging would cease if the alarms were triggered.”

And this statement from the draft EIS is incorrect:

“It is highly improbable that the dredging program would have adverse effects on water quality that would affect the aquaculture production of abalone.”

The draft EIS recognises impact is likely. It states:

“There are no clear environmental windows that offer the opportunity to significantly reduce impacts associated with dredging. Although dredging during winter rather than summer would avoid sensitive periods for the reproduction of seagrasses and invertebrates, it would not benefit macroalgae, which reproduces in winter, and southern right whales, which may visit the area during winter. Consequently, there are no persuasive ecological arguments for dredging during a particular season.”

Not surprisingly, there are relatively few studies which explore impacts of fine sediments on abalone as these are rarely, if ever, encountered in the natural habitat of abalone and have not, until now, been considered as an imminent risk to abalone.

This is also acknowledged in the draft EIS (Appendix H, page 33):

“The paucity of papers detailing negative effects of suspended sediments on sub-adult through to adult animals is likely because such impacts rarely occur in the natural environment.”



39

There is confusion and direct separation between content in Appendix H and other technical reports presented in the draft EIS.

While Appendix H states that:

“… turbidity levels in Smith Bay routinely reach 5–6 NTU, which would likely correspond to suspended sediment loads in the range 10–20mg/L depending on when and where the measurements are made.”

This is in direct opposition to Appendix F which reports a linear correlation of 0.92mg/L of TSS per 1 NTU of turbidity. The Water Quality baseline reports background TSS as generally <5mg/L, with >50 per cent of grab sample measurements <1mg/L in Smith Bay.

The comparison with a background range of 10-20mg/L in Appendix H is incorrect.

The following claim in Appendix H is both far-fetched and incorrect:

“Assuming the implementation of an appropriate dredge management program, there is no potential for smothering of abalone within the abalone farm due to the proposed dredging.”

This submission already notes the draft EIS modelling of sediment transport is incorrect due to a lack of actual PSD data for the full dredge depth.

Further claims from Appendix H:

“… the BMT (2018a) study has synthesised data from COOE (2017) which provides a detailed analysis of sediment types and particularly the particle size distribution of sediments as a basis for determining the likely transport pathways and volumes for different types of sediments (Class 1 and Class 2 sediments as defined in BMT 2018a). This work has indicated that dredging operation is likely to encounter sediments comprising a mixture of 75% Silty-Sand and 25% Sandy-Silt.”

Only 25 per cent is forecast to be sandy-silt. As highlighted earlier, it would be a stretch to state that 30% of total dredge volume has been accurately characterised for PSD.

As already noted in this submission, the modelling is flawed and cannot be relied on to adequately predict sediment fate and behaviour.

Appendix H recognises that while summer mortality is not fully understood there are likely to be many other factors that contribute to mortality, including temperature spikes, reductions in the oxygen holding capacity of water, and increased disease susceptibility.

Appendix H lacks consideration of cumulative impacts to reduced water quality, and subsequent impacts to abalone particularly during the summer months when dredging is proposed. Changes to water quality during summer, particularly temperature elevations and degraded water quality, will be exacerbated by dredging in summer, with elevated TSS further stressing abalone. The potential risks to Yumbah KI during the summer months when dredging is proposed could be extreme - and even catastrophic - for abalone.

Yumbah Kangaroo Island Pty Ltd have recently acquired another licence (Active as of 1 July, 2018) which is immediately adjacent to the Kl Seaport land holding on Kangaroo Island. This licence is not currently producing any product. Yumbah’s intention with this licence was to expand production of abalone and investigate aquaculture of the other permitted species, but this has been placed on hold as a consequence of this destructive seaport and the legal litigation ensuing between KIPT and Yumbah.

The author of Appendix H purports that abalone are well adapted to high suspended sediment loads, and are more


38

INTOLERANCE TO FINE SEDIMENT

The concern with TSS and potential for fines to be disturbed is of greatest significance when highlighting what is incorrect in Appendix H. The author of Appendix H presents false and misleading information relating to abalone’s tolerances to TSS.

Construction of the causeway and the dredging of the berthing basin will collectively entail more than six months of exposure to fine sediment loads in Smith Bay. Fine sediment emanating from dredge spoil and construction debris will enter Yumbah’s seawater intakes. This presents an unacceptable risk and will significantly compromise the continuing viability of abalone farming at Yumbah KI.

Thus, the risks of the seaport on abalone should be further evaluated in terms of concentration (likely fine sediment loads) and exposure to the hazard (duration). This has not been applied to inform the draft EIS. Modelling and suggested zones of impact are inaccurate and based on incorrect PSD data.

Examining the potential implications of disturbing Class 3 is the only way to correctly anticipate the potential extent of sediment plumes in dredging Smith Bay.

The following statement in the EIS does not constitute mitigation and management of dredge impacts:

“It is considered that it would be possible to mitigate unacceptable effects on water quality at Yumbah’s seawater intakes during capital dredging through the adoption of appropriate management measures with the implementation of the dredging management and monitoring plan, which is a normal industry practice adopted during dredging activities. The risk of exceeding TSS thresholds at the Yumbah intakes would be managed (and reduced) by installing alarms and live

monitoring of water quality at a point between the dredging footprint and the intakes. Dredging would cease if the alarms were triggered.”

And this statement from the draft EIS is incorrect:

“It is highly improbable that the dredging program would have adverse effects on water quality that would affect the aquaculture production of abalone.”

The draft EIS recognises impact is likely. It states:

“There are no clear environmental windows that offer the opportunity to significantly reduce impacts associated with dredging. Although dredging during winter rather than summer would avoid sensitive periods for the reproduction of seagrasses and invertebrates, it would not benefit macroalgae, which reproduces in winter, and southern right whales, which may visit the area during winter. Consequently, there are no persuasive ecological arguments for dredging during a particular season.”

Not surprisingly, there are relatively few studies which explore impacts of fine sediments on abalone as these are rarely, if ever, encountered in the natural habitat of abalone and have not, until now, been considered as an imminent risk to abalone.

This is also acknowledged in the draft EIS (Appendix H, page 33):

“The paucity of papers detailing negative effects of suspended sediments on sub-adult through to adult animals is likely because such impacts rarely occur in the natural environment.”



41

fine sediment that will be created during a dredge plume.

To challenge the statement:

“It is evident from the very nature of their environment that abalone must be adapted to suspended sediments simply because they rely upon drift algae, suspended in the water column, as their principal source of food.”

This statement is incorrect and misleading.

Fine clays can be 1000 times smaller than drift weed.

Abalone can tolerate course suspended sediment in moderation, but health is compromised when exposed to fine silt.

As highlighted in McShane (2019), a number of studies are referenced in Appendix F that purport to show a relatively benign effect of suspended solids on abalone. Most studies cited expose abalone to high total suspended solid concentrations, but few studies examine the specific impact of fine sediments.

Studies cited that examine fine sediments (e.g. Chung et al. 19936) clearly demonstrate that silt and clay can have a significant and negative impact on abalone survival, with mortality increasing with exposure time and concentration. Many experimental studies of sediment impacts examine concentration (of sediment) alone and duration of exposure is not considered.

The impact of extended exposure to concentrations of fine sediment likely to be disturbed during dredging is predicted to result in additional mortality as

6 Chung, E-Y., Shin, Y-K; and Lee, J-H. (1993) Effects of Silt and Clay on Respiration and Mortality of the Abalone, Nordotis discus. Korean Journal of Malacology. 9(2): 23-29

physiological impacts become exacerbated in abalone.

This detail on the relationship of exposure time and duration is a significant gap in the draft EIS and demands further investigation.

The author of Appendix H says temperature-dependent mortality reported by Chung et al. (1993), 5 to 7.5 per cent over four days to sediment is low. In the context of an abalone farming operation, mortalities of this rate would not be viable.

It must be noted that mortality was observed by Chung et al. (1993) following three days exposure. Trending data would indicate that continued exposure would result in exacerbating physiological impacts to abalone that would result in exponential abalone mortalities as the duration of exposure continued.

McShane (2019) refers to the Tissot (1992) study quoted extensively in Appendix H, presenting some adaptive strategies of various abalone species to tolerate high water movement – that is, to mitigate shear stress in adhering to reef surfaces.

This is not evidence of tolerance to high suspended sediment loads as claimed in Appendix H. Rather, such adaptations relate to withstanding the shear stress created by wave-induced turbulence in typical coastal subtidal habitat.


40

resilient than other aquaculture species that have been investigated. A further claim is that abalone are routinely subjected to high levels of suspended sediments in their natural habitat when material is entrained into the water column of high energy subtidal coastal environments.

This is misleading.

In their natural habitat, abalone are exposed to course sand, particularly in highly active coastal zones. The behaviour and impact of larger suspended matter to abalone is unrepresentative of fine sediments, characteristic of dredge spoil. Abalone can tolerate coarser sediment but are demonstrably not well adapted to fine sediments (silt and clay particles).

The information presented in Appendix H blatantly misconceives that data from Yumbah Narrawong (88 data sampling events since 2001) “provide additional evidence that elevated levels of suspended sediments during storm events are not likely to be the cause of elevated mortalities, at least at the levels experienced at Yumbah’s Narrawong (Victoria) farm which would otherwise experience much more frequent and presumably more debilitating mortality events.”

Surface water in Smith Bay has been reported in the draft EIS to range from 30μm to 300micron (with some larger particles around 1,000-3,000 micron), with a median sediment particle size (D50) of 89 microns (Appendix F3 p27).

The reported ambient grain size in Smith Bay is generally equivalent to sediment at Yumbah’s existing and future abalone farms in Portland Bay. Fifty per cent of sediment entering Yumbah Narrawong is 100 to 200 microns in size.

A review of TSS measured since 2001 in Yumbah Narrawong’s intake waters

irrevocably confirms that TSS concentrations are <10mg/L 91 percent of the time. Ninety four percent of water coming into Yumbah Narrawong contains no more 15mg/L of suspended solid.

Interpretation of Yumbah Narrawong’s data collected concludes that 5 per cent of the time, TSS results could be anywhere between 15 and 30mg/L, that’s 1.4 days a month.

This elevation is experienced with inclement weather patterns that are particularly common along the exposed and rugged coastline where Yumbah’s Narrawong farm is located.

The one measurement of 37mg/L was measured when wind gusts were exceedingly strong reaching 81km on the day of sampling.

This is hardly a scenario that can be used in the attempt to convince readers that abalone can tolerate high concentrations of fine dredge spoil as the inexperienced author of Appendix H attempts to purport. Dredging will create a highly turbid plume of fine sediment that will stretch for hundreds of metres, if not kilometres for more than seventy-five consecutive days.

Inclement coastal weather result in coarse sand entering grow out tanks through inlet water, and sand build up in the farming system is obvious. These events are given high priority in any abalone farm and intensified cleaning and husbandry is required to ensure tanks are adequately void of sediment in a timely manner. This increases labour costs and consumption of resources such as water and electricity.

The generalisations and ambiguous references in Appendix H to sediment in abalone habitat are flawed and do not reflect the reality that abalone are invariably exposed to coarser grain sizes which behave distinctly differently to the



41

fine sediment that will be created during a dredge plume.

To challenge the statement:

“It is evident from the very nature of their environment that abalone must be adapted to suspended sediments simply because they rely upon drift algae, suspended in the water column, as their principal source of food.”

This statement is incorrect and misleading.

Fine clays can be 1000 times smaller than drift weed.

Abalone can tolerate course suspended sediment in moderation, but health is compromised when exposed to fine silt.

As highlighted in McShane (2019), a number of studies are referenced in Appendix F that purport to show a relatively benign effect of suspended solids on abalone. Most studies cited expose abalone to high total suspended solid concentrations, but few studies examine the specific impact of fine sediments.

Studies cited that examine fine sediments (e.g. Chung et al. 19936) clearly demonstrate that silt and clay can have a significant and negative impact on abalone survival, with mortality increasing with exposure time and concentration. Many experimental studies of sediment impacts examine concentration (of sediment) alone and duration of exposure is not considered.

The impact of extended exposure to concentrations of fine sediment likely to be disturbed during dredging is predicted to result in additional mortality as

6 Chung, E-Y., Shin, Y-K; and Lee, J-H. (1993) Effects of Silt and Clay on Respiration and Mortality of the Abalone, Nordotis discus. Korean Journal of Malacology. 9(2): 23-29

physiological impacts become exacerbated in abalone.

This detail on the relationship of exposure time and duration is a significant gap in the draft EIS and demands further investigation.

The author of Appendix H says temperature-dependent mortality reported by Chung et al. (1993), 5 to 7.5 per cent over four days to sediment is low. In the context of an abalone farming operation, mortalities of this rate would not be viable.

It must be noted that mortality was observed by Chung et al. (1993) following three days exposure. Trending data would indicate that continued exposure would result in exacerbating physiological impacts to abalone that would result in exponential abalone mortalities as the duration of exposure continued.

McShane (2019) refers to the Tissot (1992) study quoted extensively in Appendix H, presenting some adaptive strategies of various abalone species to tolerate high water movement – that is, to mitigate shear stress in adhering to reef surfaces.

This is not evidence of tolerance to high suspended sediment loads as claimed in Appendix H. Rather, such adaptations relate to withstanding the shear stress created by wave-induced turbulence in typical coastal subtidal habitat.


40

resilient than other aquaculture species that have been investigated. A further claim is that abalone are routinely subjected to high levels of suspended sediments in their natural habitat when material is entrained into the water column of high energy subtidal coastal environments.

This is misleading.

In their natural habitat, abalone are exposed to course sand, particularly in highly active coastal zones. The behaviour and impact of larger suspended matter to abalone is unrepresentative of fine sediments, characteristic of dredge spoil. Abalone can tolerate coarser sediment but are demonstrably not well adapted to fine sediments (silt and clay particles).

The information presented in Appendix H blatantly misconceives that data from Yumbah Narrawong (88 data sampling events since 2001) “provide additional evidence that elevated levels of suspended sediments during storm events are not likely to be the cause of elevated mortalities, at least at the levels experienced at Yumbah’s Narrawong (Victoria) farm which would otherwise experience much more frequent and presumably more debilitating mortality events.”

Surface water in Smith Bay has been reported in the draft EIS to range from 30μm to 300micron (with some larger particles around 1,000-3,000 micron), with a median sediment particle size (D50) of 89 microns (Appendix F3 p27).

The reported ambient grain size in Smith Bay is generally equivalent to sediment at Yumbah’s existing and future abalone farms in Portland Bay. Fifty per cent of sediment entering Yumbah Narrawong is 100 to 200 microns in size.

A review of TSS measured since 2001 in Yumbah Narrawong’s intake waters

irrevocably confirms that TSS concentrations are <10mg/L 91 percent of the time. Ninety four percent of water coming into Yumbah Narrawong contains no more 15mg/L of suspended solid.

Interpretation of Yumbah Narrawong’s data collected concludes that 5 per cent of the time, TSS results could be anywhere between 15 and 30mg/L, that’s 1.4 days a month.

This elevation is experienced with inclement weather patterns that are particularly common along the exposed and rugged coastline where Yumbah’s Narrawong farm is located.

The one measurement of 37mg/L was measured when wind gusts were exceedingly strong reaching 81km on the day of sampling.

This is hardly a scenario that can be used in the attempt to convince readers that abalone can tolerate high concentrations of fine dredge spoil as the inexperienced author of Appendix H attempts to purport. Dredging will create a highly turbid plume of fine sediment that will stretch for hundreds of metres, if not kilometres for more than seventy-five consecutive days.

Inclement coastal weather result in coarse sand entering grow out tanks through inlet water, and sand build up in the farming system is obvious. These events are given high priority in any abalone farm and intensified cleaning and husbandry is required to ensure tanks are adequately void of sediment in a timely manner. This increases labour costs and consumption of resources such as water and electricity.

The generalisations and ambiguous references in Appendix H to sediment in abalone habitat are flawed and do not reflect the reality that abalone are invariably exposed to coarser grain sizes which behave distinctly differently to the



43

ERRORS IN ECOTOXICITY ASSUMPTIONS

The draft EIS claims the ANZECC (2000) TSS trigger value of 10 mg/L for aquaculture is overly conservative for abalone. The author attempts to justify a new guideline value of 25 mg/L: suspended sediment levels are not expected to exceed values of the defined threshold (25 mg/L) at which no chronic or acute effects are likely (Appendix H, Page 69).

National Water Quality Guidelines (ANZECC/ARMCANZ (2000)) state:

“Guideline trigger values are concentrations that, if exceeded, will indicate a potential environmental problem, and so ‘trigger’ further investigation. The investigation aims to both assess whether exceedance of a trigger value will result in environmental harm and refine a guideline value, by accounting for environmental factors that can modify the effect of the chemical. Although in some cases this will require more work, it will result in much more realistic goals for management and therefore has the potential to reduce both costs for industry and confrontation.”

The purported ecotoxicology results in the draft EIS are not generated from an ecotoxicology assay.

Results based on acute exposure to fine sediments over twenty-four hours are not representative of toxicity.

Abalone (even juveniles) can tolerate occasional elevated sediment loads. Short-term responses include increased mucous production (with subsequent energy demand). More importantly, exposure will create physiological impacts to feeding and respiration with the consequences of reduced growth rates and increased mortality.

Comments in Appendix H regarding sediment loads in the natural environment of abalone misses the point that it is the fine sediment (particularly clay) that does the damage to abalone. These fine sediments are rarely present in abalone natural habitat, as is stated in Appendix H.

The test conditions applied in the single, short-sighted bioassay are completely irrelevant to the practice of abalone farming. In a farming tank system, sediments concentrate in the shallow raceways and maze tanks and smother the abalone.

A claim in Appendix H that tippers will adequately deal with additional sediment loads from dredging with no adverse effects on farming operations is incorrect. Tippers are not used in a large proportion of grow out tanks at Yumbah KI. The testing environment is further flawed as test abalone were fed natural feed and tests were conducted at the optimal temperature of 18°C which is not representative of the likely water temperatures in Smith Bay during the proposed dredging period of warmer summer months.

Furthermore, McShane (2019) rightfully highlights that abalone cultivated at Yumbah KI have been selectively bred for Yumbah’s farming conditions from brood stock that have been genetically selected for optimal farming conditions. Juvenile abalone exposed to sediment in the laboratory test described by Springer (2018b) were sourced from wild populations and their behaviour cannot be directly compared to farmed abalone due to the genetic optimisation of Yumbah’s farmed stock.


42

SEDIMENT IMPACTS TO ABALONE

In the review of the draft EIS, McShane (2019) explores the impacts of sediment to abalone. The review confirms exposure to fine sediment can have an adverse impact on abalone anatomy and physiology in a number of ways. Abalone are primitive gastropods having a weak capacity to actively extract oxygen from the water column and ventilate their gills and, instead, rely on passive water movement in their natural habitat to drive water into the brachial chambers and to the mantle cavity (Ragg and Taylor 2006, Morash and Alter 2016).

Thus, abalone typically inhabit high energy sublittoral environments where water movement generated by waves and tide provide for the necessary gill ventilation.

Associated with the gills of abalone is a hypobranchial gland which functions to produce mucus to keep the gills and the mantle cavity clean (Wanichanon et al. 2004). When foreign particles from turbid water enter the mantle cavity, the mucus cells bind particles that can be expelled through the ciliary action of the epithelial cells. Abalone have limited capacity to clear fine sediment and associated mucus.

The author of Appendix H raises questions about “mass mortality” events at Yumbah KI associated with resuspension of sediments within Smith Bay during storm events. The extent of mortality during the storm events in 2016 did not trigger the notifiable level for compulsory reporting to PIRSA.

McShane (2019) presents results from qualified histopathologists following two distinct storm events which resulted in elevated suspended solids from Smith Creek entering Yumbah KI’s intake water.

In summary, following both storms, abalone appeared moribund two days after the storm and mortality occurred over six weeks following initial impact from storm suspension of fine sediment.

Histopathological analysis by Dr Richmond Loh, an aquatic animal health specialist, concluded:

“Mortalities were worst in 3 to 4-year old group (harvest class), though 1-year olds were also affected. Clinical signs reported in abalone include swollen head, swollen foot, and difficulty holding onto substrate, and death within 2 days of showing clinical signs. Storms and abalone deaths coincided with higher frequency of clogging of their 1µm water filters (in their hatchery).“

Further detail is presented in McShane (2019), yet a conclusion was:

“Upon examination, these affected abalone had inflammation throughout, but more severe in the muscle of the foot and head regions. The inflammation in the head probably reflects increased silt in the environment of these animals, including increased silt in the mouth.”



43

ERRORS IN ECOTOXICITY ASSUMPTIONS

The draft EIS claims the ANZECC (2000) TSS trigger value of 10 mg/L for aquaculture is overly conservative for abalone. The author attempts to justify a new guideline value of 25 mg/L: suspended sediment levels are not expected to exceed values of the defined threshold (25 mg/L) at which no chronic or acute effects are likely (Appendix H, Page 69).

National Water Quality Guidelines (ANZECC/ARMCANZ (2000)) state:

“Guideline trigger values are concentrations that, if exceeded, will indicate a potential environmental problem, and so ‘trigger’ further investigation. The investigation aims to both assess whether exceedance of a trigger value will result in environmental harm and refine a guideline value, by accounting for environmental factors that can modify the effect of the chemical. Although in some cases this will require more work, it will result in much more realistic goals for management and therefore has the potential to reduce both costs for industry and confrontation.”

The purported ecotoxicology results in the draft EIS are not generated from an ecotoxicology assay.

Results based on acute exposure to fine sediments over twenty-four hours are not representative of toxicity.

Abalone (even juveniles) can tolerate occasional elevated sediment loads. Short-term responses include increased mucous production (with subsequent energy demand). More importantly, exposure will create physiological impacts to feeding and respiration with the consequences of reduced growth rates and increased mortality.

Comments in Appendix H regarding sediment loads in the natural environment of abalone misses the point that it is the fine sediment (particularly clay) that does the damage to abalone. These fine sediments are rarely present in abalone natural habitat, as is stated in Appendix H.

The test conditions applied in the single, short-sighted bioassay are completely irrelevant to the practice of abalone farming. In a farming tank system, sediments concentrate in the shallow raceways and maze tanks and smother the abalone.

A claim in Appendix H that tippers will adequately deal with additional sediment loads from dredging with no adverse effects on farming operations is incorrect. Tippers are not used in a large proportion of grow out tanks at Yumbah KI. The testing environment is further flawed as test abalone were fed natural feed and tests were conducted at the optimal temperature of 18°C which is not representative of the likely water temperatures in Smith Bay during the proposed dredging period of warmer summer months.

Furthermore, McShane (2019) rightfully highlights that abalone cultivated at Yumbah KI have been selectively bred for Yumbah’s farming conditions from brood stock that have been genetically selected for optimal farming conditions. Juvenile abalone exposed to sediment in the laboratory test described by Springer (2018b) were sourced from wild populations and their behaviour cannot be directly compared to farmed abalone due to the genetic optimisation of Yumbah’s farmed stock.


42

SEDIMENT IMPACTS TO ABALONE

In the review of the draft EIS, McShane (2019) explores the impacts of sediment to abalone. The review confirms exposure to fine sediment can have an adverse impact on abalone anatomy and physiology in a number of ways. Abalone are primitive gastropods having a weak capacity to actively extract oxygen from the water column and ventilate their gills and, instead, rely on passive water movement in their natural habitat to drive water into the brachial chambers and to the mantle cavity (Ragg and Taylor 2006, Morash and Alter 2016).

Thus, abalone typically inhabit high energy sublittoral environments where water movement generated by waves and tide provide for the necessary gill ventilation.

Associated with the gills of abalone is a hypobranchial gland which functions to produce mucus to keep the gills and the mantle cavity clean (Wanichanon et al. 2004). When foreign particles from turbid water enter the mantle cavity, the mucus cells bind particles that can be expelled through the ciliary action of the epithelial cells. Abalone have limited capacity to clear fine sediment and associated mucus.

The author of Appendix H raises questions about “mass mortality” events at Yumbah KI associated with resuspension of sediments within Smith Bay during storm events. The extent of mortality during the storm events in 2016 did not trigger the notifiable level for compulsory reporting to PIRSA.

McShane (2019) presents results from qualified histopathologists following two distinct storm events which resulted in elevated suspended solids from Smith Creek entering Yumbah KI’s intake water.

In summary, following both storms, abalone appeared moribund two days after the storm and mortality occurred over six weeks following initial impact from storm suspension of fine sediment.

Histopathological analysis by Dr Richmond Loh, an aquatic animal health specialist, concluded:

“Mortalities were worst in 3 to 4-year old group (harvest class), though 1-year olds were also affected. Clinical signs reported in abalone include swollen head, swollen foot, and difficulty holding onto substrate, and death within 2 days of showing clinical signs. Storms and abalone deaths coincided with higher frequency of clogging of their 1µm water filters (in their hatchery).“

Further detail is presented in McShane (2019), yet a conclusion was:

“Upon examination, these affected abalone had inflammation throughout, but more severe in the muscle of the foot and head regions. The inflammation in the head probably reflects increased silt in the environment of these animals, including increased silt in the mouth.”



45

Further considerations are required in the draft EIS to reflect additional sources of contamination and ecotoxicity impacts to abalone. Leachate entering stormwater and then the marine environment presents a significant risk to Yumbah KI that should be reflected in the draft EIS Risk Assessment.

IMPACTS TO DIATOMS

McShane (2019) highlights dredge spoil as a risk to the viability of diatoms in the subtidal environment of Smith Bay by decreasing available light and affecting light quality.

Appendix H of the draft EIS makes unsubstantiated claims in relation to diatoms and dredge effects, including:

• Diatoms are only important in diet of early stages of abalone

• Algae exhibit a high level of plasticity in their adaptation to ambient light environments allowing adjustments to adverse light climate

• Changes in turbidity at shallow depths are small and will not have an adverse effect on diatom production

• Conditions that would promote harmful algal blooms (red tides) are not likely to occur in Smith Bay

The benthic diatoms preferred as food for farmed abalone lack the motility to migrate to surface waters where the full spectrum of photosynthetically active radiation (PAR) is available (Ault 2000).

Attenuation of light through suspension of fine sediments during construction of the proposed seaport and during maintenance dredging activities will have a deleterious effect on those benthic diatoms favoured in the diet of abalone farmed at Yumbah.

Changes to light climate in Smith Bay, coupled with the potential introduction of exotic dinoflagellates via ballast water, increases the risk of harmful algal blooms.

Yumbah KI relies on a mix of natural diatoms and tank algal growth.

Appendix H attempts to negate the importance of diatoms in abalone farming.

This is incorrect.

The risk of harmful algal blooms will be enhanced by reduction of nearshore currents following construction of a 250m solid causeway in Smith Bay. The draft EIS indicates that reduction in current speed at Yumbah’s westerly seawater intake will be about 30-40 per cent. This will lead to potential recirculation of Yumbah effluent and an increase in ambient water temperature: conditions favourable for dinoflagellate blooms.

The risk of recirculation and elevated temperature have not been adequately addressed in the draft EIS using coastal data representative of existing and ‘changed’ conditions at Yumbah KI.


44

ANZECC/ARMCANZ (2000) explicitly states that thorough assessments are required that are site specific and that consider all environmental factors. At a minimum, the establishment of adequate, more appropriate bioassays are required to quantify the true impact on abalone of sediment to be dredged. Exposure and duration within any bioassay must reflect the potential dredging activity.

Additional assessment to correctly quantify acute and chronic impacts of dredge sediment will inform the risk assessment relating to potential dredge impacts on abalone (Appendix H, Table H-12, Page 71) to justify any deviation from the ANZECC/ARMCANZ (2000) guideline value for suspended solids concentration.

Consensus among technical specialists engaged by Yumbah to review the draft EIS confirm that the crude conclusion of a water quality guidelines of 25mg/L for suspended sediment in Smith Bay is indeed significantly flawed.

This value has been derived from one bioassay that exposes abalone to a given concentration of 250 mg/L (reported as the NOEC) for one day, which is unrelated to the actual exposure resulting from dredging.

The findings presented in the draft EIS do not constitute an ecotoxicological evaluation of fine sediments on abalone. As the short-term tests revealed no mortalities (after 24 hours exposure and 48 hours recovery) these results do not constitute an ecotoxicological assessment. Acute and chronic impacts were not observed (e.g. feeding rates, respiration). As highlighted previously, results of Chung et al. (1993) indicate continued exposure will likely result in exponential mortality.

Given that there is no evidence in the draft EIS regarding acute or chronic effects of fine sediment on abalone, and the absolute necessity for further investigation, there is no justified basis for setting trigger values higher than the ANZECC/ARMCANZ aquaculture guideline of <10m/L.

TIMBER TOXINS NOT CONSIDERED

The draft EIS fails to address potential toxicity to the marine environment from timber chemicals. Likely chemicals that may be used or introduced to the Smith Bay seaport from KIPT timber operations include - but are not limited to - herbicides, fumigants and preservatives. The draft EIS appears to indicate that at this point in the regulatory approvals process, timber-associated chemicals are unlikely to be used on site.

An operations base (to be known as the Heartland Hub) is located at the site of the former sawmill (owned by KIPT) on KI’s Timber Creek Road and, if required, would be subject to separate planning approvals outside the scope of the EIS.

The existing site consists of timber products treatment works and a number of larger machinery sheds, currently containing disused sawmilling equipment. The timber treatment works may be retained but the sawmilling equipment would be disposed of.

The KIPT Timber Creek Road facility has an EPA SA licence from 2016 to enable use Copper Chrome Arsenate (CCA). The KIPT Main Report and Appendix C do not mention if timber and woodchips will be treated with CCA or other chemical agents at Smith Bay. Its possible timber will be treated at Timber Creek Road and transported to Smith Bay, creating implications for contamination of stormwater in KIPT’s land-based storage area.



45

Further considerations are required in the draft EIS to reflect additional sources of contamination and ecotoxicity impacts to abalone. Leachate entering stormwater and then the marine environment presents a significant risk to Yumbah KI that should be reflected in the draft EIS Risk Assessment.

IMPACTS TO DIATOMS

McShane (2019) highlights dredge spoil as a risk to the viability of diatoms in the subtidal environment of Smith Bay by decreasing available light and affecting light quality.

Appendix H of the draft EIS makes unsubstantiated claims in relation to diatoms and dredge effects, including:

• Diatoms are only important in diet of early stages of abalone

• Algae exhibit a high level of plasticity in their adaptation to ambient light environments allowing adjustments to adverse light climate

• Changes in turbidity at shallow depths are small and will not have an adverse effect on diatom production

• Conditions that would promote harmful algal blooms (red tides) are not likely to occur in Smith Bay

The benthic diatoms preferred as food for farmed abalone lack the motility to migrate to surface waters where the full spectrum of photosynthetically active radiation (PAR) is available (Ault 2000).

Attenuation of light through suspension of fine sediments during construction of the proposed seaport and during maintenance dredging activities will have a deleterious effect on those benthic diatoms favoured in the diet of abalone farmed at Yumbah.

Changes to light climate in Smith Bay, coupled with the potential introduction of exotic dinoflagellates via ballast water, increases the risk of harmful algal blooms.

Yumbah KI relies on a mix of natural diatoms and tank algal growth.

Appendix H attempts to negate the importance of diatoms in abalone farming.

This is incorrect.

The risk of harmful algal blooms will be enhanced by reduction of nearshore currents following construction of a 250m solid causeway in Smith Bay. The draft EIS indicates that reduction in current speed at Yumbah’s westerly seawater intake will be about 30-40 per cent. This will lead to potential recirculation of Yumbah effluent and an increase in ambient water temperature: conditions favourable for dinoflagellate blooms.

The risk of recirculation and elevated temperature have not been adequately addressed in the draft EIS using coastal data representative of existing and ‘changed’ conditions at Yumbah KI.


44

ANZECC/ARMCANZ (2000) explicitly states that thorough assessments are required that are site specific and that consider all environmental factors. At a minimum, the establishment of adequate, more appropriate bioassays are required to quantify the true impact on abalone of sediment to be dredged. Exposure and duration within any bioassay must reflect the potential dredging activity.

Additional assessment to correctly quantify acute and chronic impacts of dredge sediment will inform the risk assessment relating to potential dredge impacts on abalone (Appendix H, Table H-12, Page 71) to justify any deviation from the ANZECC/ARMCANZ (2000) guideline value for suspended solids concentration.

Consensus among technical specialists engaged by Yumbah to review the draft EIS confirm that the crude conclusion of a water quality guidelines of 25mg/L for suspended sediment in Smith Bay is indeed significantly flawed.

This value has been derived from one bioassay that exposes abalone to a given concentration of 250 mg/L (reported as the NOEC) for one day, which is unrelated to the actual exposure resulting from dredging.

The findings presented in the draft EIS do not constitute an ecotoxicological evaluation of fine sediments on abalone. As the short-term tests revealed no mortalities (after 24 hours exposure and 48 hours recovery) these results do not constitute an ecotoxicological assessment. Acute and chronic impacts were not observed (e.g. feeding rates, respiration). As highlighted previously, results of Chung et al. (1993) indicate continued exposure will likely result in exponential mortality.

Given that there is no evidence in the draft EIS regarding acute or chronic effects of fine sediment on abalone, and the absolute necessity for further investigation, there is no justified basis for setting trigger values higher than the ANZECC/ARMCANZ aquaculture guideline of <10m/L.

TIMBER TOXINS NOT CONSIDERED

The draft EIS fails to address potential toxicity to the marine environment from timber chemicals. Likely chemicals that may be used or introduced to the Smith Bay seaport from KIPT timber operations include - but are not limited to - herbicides, fumigants and preservatives. The draft EIS appears to indicate that at this point in the regulatory approvals process, timber-associated chemicals are unlikely to be used on site.

An operations base (to be known as the Heartland Hub) is located at the site of the former sawmill (owned by KIPT) on KI’s Timber Creek Road and, if required, would be subject to separate planning approvals outside the scope of the EIS.

The existing site consists of timber products treatment works and a number of larger machinery sheds, currently containing disused sawmilling equipment. The timber treatment works may be retained but the sawmilling equipment would be disposed of.

The KIPT Timber Creek Road facility has an EPA SA licence from 2016 to enable use Copper Chrome Arsenate (CCA). The KIPT Main Report and Appendix C do not mention if timber and woodchips will be treated with CCA or other chemical agents at Smith Bay. Its possible timber will be treated at Timber Creek Road and transported to Smith Bay, creating implications for contamination of stormwater in KIPT’s land-based storage area.



47

ADDITIONAL ERRORS AND OMISSIONS

• Information in the EIS has been largely based on the original seaport plan. The wharf and its associated footprint have since been extended from the original design and now sits 420m out to sea

• Sediment to be dredged has not been fully characterised by KPT

• “Fuel/oil spills will be minimised through mandated compliance with established storage and handling standards/protocols.”7

No clarification of who monitors/enforces/assumes risk. Who sets standards and protocols?

• “The risk of exceeding TSS thresholds at the Yumbah intakes would be managed (and reduced) by installing alarms and live monitoring of water quality at a point between the dredging footprint and the intakes. Dredging would cease if the alarms were triggered.”8

The plan is to stop dredging when an alarm rings. Does this assume somehow the abalone will know to stop eating at the same time? There will be unacceptable effects on water quality at Yumbah’s seawater intakes. This will happen. The risks may be reduced but not eliminated. Alarms may sound when TSS thresholds are reached, but containing unacceptable dredge plumes will be difficult

7 EIS Executive Summary p32 8 EIS Executive Summary p32 9 EIS Executive Summary p53 10 EIS Main Report p74

• “The hydrodynamic modelling outcomes suggest that the worst case increases in suspended sediments at Yumbah’s seawater intakes are unlikely to have any adverse effects on the health of abalone within the farm.”9

The drill core sample is not reflective of what 100 000 tonnes (or 200 000 tonnes – to be confirmed to some point in the future) will release and bring up from the seafloor

• “If local areas of hard substrate not indicated in the geophysical or geotechnical assessment was found to be too strong for cutter suction dredging methods, a long-arm excavator mounted on a jack-up barge may be employed.”10

Have excavator impacts on sediment plume been modelled?


46

TEMPERATURE INTOLERANCES

Appendix H further claims:

“The study also concluded that land-based abalone farms in South Australia are particularly vulnerable to climate change impacts that have resulted in increased sea water temperatures. It should be noted that the predicted changes in coastal processes associated with the causeway may result in a very slight increase in water temperature at the Yumbah seawater intakes (maximum effect less than 0.1 °C). Such an increase may provide benefits during winter but may increase the risk of summer mortality events.”

Additional modelling of this expected temperature increase is required to determine the pattern and frequency to understand if there is reduction in mixing in the immediate shallow inshore environment that will result in greater atmospheric influence on diurnal temperature variation of water; that is, the variation between a high temperature and a low temperature that occurs during the same day.

In winter the cold spikes may get colder and in summer the warm spikes might get hotter.

And again from Appendix H:

“Notably, in 2012/2013, the Kangaroo Island farm experienced losses of 50% of all animals in a growth trial under conditions of elevated temperatures (Stone et al. 2014).”

Truth is, this mortality was under controlled conditions solely for the purpose of understanding feed rates during various temperature regimes.

Appendix H reports a maximum temperature increase of 0.1°C when it is stated that a maximum increase could actually be 0.2°C. Further inaccuracies suggest abalone at Yumbah KI are increasingly at risk of elevated temperatures because of climate change impacts. Smith Bay has experienced minimal change in the rate of temperature charge over the last 14 years. Similarly, summer dissolved oxygen (DO) do not pose a problem to Yumbah Ki as DO is on average higher in summer compared with winter concentrations.

Appendix H:

“… the future viability of the industry is clearly threatened by rises in summer water temperature and ocean acidification (Doubleday et al. 2013) and unless a substantial improvement in temperature tolerance of cultivated abalone can be achieved the viability of the South Australian industry will be at risk over coming years.”

The increase in temperature as a consequence of the causeway has been widely reported in the draft EIS. The above statement, though inflated and distorting, confirms KIPT is aware of the potential implications of the seaport affecting Yumbah KI.

Abalone are extremely sensitive to temperature differentials. It is not known if the reported changes in temperature are cumulative, which could have a deleterious impact to farmed abalone. Alterations and increases in temperature due to reduced mixing have not been sufficiently modelled to incorporate the farm’s exit water temperature.



47

ADDITIONAL ERRORS AND OMISSIONS

• Information in the EIS has been largely based on the original seaport plan. The wharf and its associated footprint have since been extended from the original design and now sits 420m out to sea

• Sediment to be dredged has not been fully characterised by KPT

• “Fuel/oil spills will be minimised through mandated compliance with established storage and handling standards/protocols.”7

No clarification of who monitors/enforces/assumes risk. Who sets standards and protocols?

• “The risk of exceeding TSS thresholds at the Yumbah intakes would be managed (and reduced) by installing alarms and live monitoring of water quality at a point between the dredging footprint and the intakes. Dredging would cease if the alarms were triggered.”8

The plan is to stop dredging when an alarm rings. Does this assume somehow the abalone will know to stop eating at the same time? There will be unacceptable effects on water quality at Yumbah’s seawater intakes. This will happen. The risks may be reduced but not eliminated. Alarms may sound when TSS thresholds are reached, but containing unacceptable dredge plumes will be difficult

7 EIS Executive Summary p32 8 EIS Executive Summary p32 9 EIS Executive Summary p53 10 EIS Main Report p74

• “The hydrodynamic modelling outcomes suggest that the worst case increases in suspended sediments at Yumbah’s seawater intakes are unlikely to have any adverse effects on the health of abalone within the farm.”9

The drill core sample is not reflective of what 100 000 tonnes (or 200 000 tonnes – to be confirmed to some point in the future) will release and bring up from the seafloor

• “If local areas of hard substrate not indicated in the geophysical or geotechnical assessment was found to be too strong for cutter suction dredging methods, a long-arm excavator mounted on a jack-up barge may be employed.”10

Have excavator impacts on sediment plume been modelled?


46

TEMPERATURE INTOLERANCES

Appendix H further claims:

“The study also concluded that land-based abalone farms in South Australia are particularly vulnerable to climate change impacts that have resulted in increased sea water temperatures. It should be noted that the predicted changes in coastal processes associated with the causeway may result in a very slight increase in water temperature at the Yumbah seawater intakes (maximum effect less than 0.1 °C). Such an increase may provide benefits during winter but may increase the risk of summer mortality events.”

Additional modelling of this expected temperature increase is required to determine the pattern and frequency to understand if there is reduction in mixing in the immediate shallow inshore environment that will result in greater atmospheric influence on diurnal temperature variation of water; that is, the variation between a high temperature and a low temperature that occurs during the same day.

In winter the cold spikes may get colder and in summer the warm spikes might get hotter.

And again from Appendix H:

“Notably, in 2012/2013, the Kangaroo Island farm experienced losses of 50% of all animals in a growth trial under conditions of elevated temperatures (Stone et al. 2014).”

Truth is, this mortality was under controlled conditions solely for the purpose of understanding feed rates during various temperature regimes.

Appendix H reports a maximum temperature increase of 0.1°C when it is stated that a maximum increase could actually be 0.2°C. Further inaccuracies suggest abalone at Yumbah KI are increasingly at risk of elevated temperatures because of climate change impacts. Smith Bay has experienced minimal change in the rate of temperature charge over the last 14 years. Similarly, summer dissolved oxygen (DO) do not pose a problem to Yumbah Ki as DO is on average higher in summer compared with winter concentrations.

Appendix H:

“… the future viability of the industry is clearly threatened by rises in summer water temperature and ocean acidification (Doubleday et al. 2013) and unless a substantial improvement in temperature tolerance of cultivated abalone can be achieved the viability of the South Australian industry will be at risk over coming years.”

The increase in temperature as a consequence of the causeway has been widely reported in the draft EIS. The above statement, though inflated and distorting, confirms KIPT is aware of the potential implications of the seaport affecting Yumbah KI.

Abalone are extremely sensitive to temperature differentials. It is not known if the reported changes in temperature are cumulative, which could have a deleterious impact to farmed abalone. Alterations and increases in temperature due to reduced mixing have not been sufficiently modelled to incorporate the farm’s exit water temperature.



49

GUIDELINE 3:

BIOSECURITY

DESCRIPTION:

Kangaroo Island’s remoteness and isolation has created a unique environment, free from many of the pests and diseases found on mainland Australia. The development of a port will inevitably introduce pest and nuisance species (both terrestrial and marine) to Smith Bay which will be a major threat to Yumbah KI and can have devastating impacts on the Island’s environment and agricultural industries. Smith Bay is a Coastal Conservation Zone without threat from exotic pests and diseases and its existing state of health is vital to Yumbah’s livelihood.

SUMMARY RESPONSE

Marine pests are coming and KIPT appears to suggest there’s nothing they can do about it. The risk of introducing exotic invasive pest species and diseases to Smith Bay is the single biggest hazard for Yumbah KI, and its livelihood.

KIPT recognises construction and operation of its port is highly likely to introduce marine pests and aquatic diseases to Smith Bay which is, through careful stewardship and relative isolation, currently free of exotic marine pests.

KIPT further indicate the risk of introducing marine pests and diseases to Smith Bay could be reduced to what the draft EIS describes as an “acceptable” level by adopting “the most rigorous biosecurity standards prescribed by Biosecurity SA”.

Yumbah simply makes the point there is no acceptable level that can be demonstrated as having “no negative impact” on the abalone farm.

• Smith Bay is currently free of exotic marine pests. KIPT admits construction and operational activities, which include dredging and the movement of domestic shipping vessels into Smith Bay, have the potential to introduce marine pests and/or aquatic diseases

• Biosecurity is a major risk with ballast water exchange and ship fouling, introducing exotic species and disease agents to the pristine environment of Smith Bay

• Complying with national ballast water exchange and the legally sanctioned mechanisms does little to mitigate risk to the environment. There is not a seaport in the world that is void of significant issues associated with introduced marine pests. There are whimsical suggestions in the draft EIS about how to “minimise” the spread of exotic marine pests, but no discussion of eliminating the possibility of them arriving at Smith Bay. KIPT admits its activities will introduce problems to Smith Bay


48

• ”The north coast is a relatively moderate to low energy environment as it is largely sheltered from the prevailing south westerly swells in the Southern Ocean (Edyvane 1999). Nevertheless, it does at times receive relatively small westerly swells that refract around the island and decline in size and energy as they travel east. The north coast is also sheltered from waves generated by strong south-westerly winds in winter, and the prevailing south-easterly winds and sea breezes in summer. It is, however, exposed to waves generated by occasional strong northerly winds.”11

11 EIS Appendix I p3 12 EIS Appendix G p12

Statement of sheltered calm location is false. North-west and westerly winds are the strongest winds Kangaroo Island experiences. Westerly swells regularly reach a height of five metres

• “Winter minimum temperatures were

around 14°c.”12

Smith Bay water temperature gets colder than 14°C



49

GUIDELINE 3:

BIOSECURITY

DESCRIPTION:

Kangaroo Island’s remoteness and isolation has created a unique environment, free from many of the pests and diseases found on mainland Australia. The development of a port will inevitably introduce pest and nuisance species (both terrestrial and marine) to Smith Bay which will be a major threat to Yumbah KI and can have devastating impacts on the Island’s environment and agricultural industries. Smith Bay is a Coastal Conservation Zone without threat from exotic pests and diseases and its existing state of health is vital to Yumbah’s livelihood.

SUMMARY RESPONSE

Marine pests are coming and KIPT appears to suggest there’s nothing they can do about it. The risk of introducing exotic invasive pest species and diseases to Smith Bay is the single biggest hazard for Yumbah KI, and its livelihood.

KIPT recognises construction and operation of its port is highly likely to introduce marine pests and aquatic diseases to Smith Bay which is, through careful stewardship and relative isolation, currently free of exotic marine pests.

KIPT further indicate the risk of introducing marine pests and diseases to Smith Bay could be reduced to what the draft EIS describes as an “acceptable” level by adopting “the most rigorous biosecurity standards prescribed by Biosecurity SA”.

Yumbah simply makes the point there is no acceptable level that can be demonstrated as having “no negative impact” on the abalone farm.

• Smith Bay is currently free of exotic marine pests. KIPT admits construction and operational activities, which include dredging and the movement of domestic shipping vessels into Smith Bay, have the potential to introduce marine pests and/or aquatic diseases

• Biosecurity is a major risk with ballast water exchange and ship fouling, introducing exotic species and disease agents to the pristine environment of Smith Bay

• Complying with national ballast water exchange and the legally sanctioned mechanisms does little to mitigate risk to the environment. There is not a seaport in the world that is void of significant issues associated with introduced marine pests. There are whimsical suggestions in the draft EIS about how to “minimise” the spread of exotic marine pests, but no discussion of eliminating the possibility of them arriving at Smith Bay. KIPT admits its activities will introduce problems to Smith Bay


48

• ”The north coast is a relatively moderate to low energy environment as it is largely sheltered from the prevailing south westerly swells in the Southern Ocean (Edyvane 1999). Nevertheless, it does at times receive relatively small westerly swells that refract around the island and decline in size and energy as they travel east. The north coast is also sheltered from waves generated by strong south-westerly winds in winter, and the prevailing south-easterly winds and sea breezes in summer. It is, however, exposed to waves generated by occasional strong northerly winds.”11

11 EIS Appendix I p3 12 EIS Appendix G p12

Statement of sheltered calm location is false. North-west and westerly winds are the strongest winds Kangaroo Island experiences. Westerly swells regularly reach a height of five metres

• “Winter minimum temperatures were

around 14°c.”12

Smith Bay water temperature gets colder than 14°C



51

tourism. The application revealed there would be an expected 13 truck movements per hour both ways between Strathblane and Judbury if the operation ran 10 hours a day, six days a week. There would also be 800 additional truck movements per week delivering wood to Southwood for chipping.

Community opposed the proposed port due to threat to the area’s “clean green” tourism credentials, and environmental impacts on native flora and fauna, including protected species, both marine and terrestrial.

The state’s biggest salmon producer Tassal opposed the proposed plant due to the close proximity to its fish farms. Tassal expressly opposed the location and close proximity of the woodchip facility as the two operations could "simply not co-exist" as immediate neighbours.

Tassal’s concerns were explicitly related to fish health and biosecurity issues. Bio-security risks, including contaminated bilge release and introduction of pests and diseases were regarded as unacceptable.

Tassal refused to accept the impending risk to its aquaculture operations. As a consequence of the impasse between Tassal and Southwood Fibre, the Tasmania government committed to assist Southwood Fibre with finding a new site for the woodchip export facility recognising the proximity of the salmon lease right out the front of the proposed woodchip location.

This case provides a firm example that Yumbah’s concerns as an aquaculture facility are not unfounded and biosecurity is a universally recognised risk.

13 http://www.fish.wa.gov.au/Documents/occasional_publications/fop132.pdf

SEPARATION DISTANCES

Buffer zones or separation distances between sensitive uses are commonly applied across Australia. As an example, the government of Western Australia has adopted a framework for effective management of risks, contemporary biosecurity management practices and practical measures to improve abalone health management based on sound epidemiological principles for disease prevention and control13.

The key principles considered in this guideline when assessing applications for abalone aquaculture are a risk based approach and the precautionary principle.

The precautionary principle defined is a legal and policy principle addressing the problem of scientific uncertainty in environmental decision-making. It is of great concern that the draft EIS does not contemplate any possibility of scientific uncertainty clouding its findings and proceeds to recommend an outcome free of precaution.

This WA guideline recognises that spatial separation is of significance in abalone biosecurity management and is an important biosecurity tool. It focuses on proximity to alternative aquaculture farms to productive reefs, and the principles can be applied to other commercial land uses such as ports.

As stated in the WA guideline “The risk of disease agents being transported along various distances can be described as a continuum, in which the number of infectious particles drops steeply with distance from the source, with only a few infectious particles travelling relatively long distances. Although the likelihood of disease spread is reduced almost


50

• KIPT consider that the risk of introducing marine pests and/or diseases to Smith Bay could “be reduced to an acceptable level by adopting the most rigorous biosecurity standards prescribed by Biosecurity SA”. Yumbah disagrees and references the report by Industry specialists Professor Chad Hewitt and Professor Marnie Campbell (see below).

• The unanswered questions include:

o What’s an acceptable level of marine pests arriving in Smith Bay?

o What happens when “the most rigorous standards prescribed by Biosecurity SA” aren’t met?

o Who will implement a marine pest management program? Introduced marine pests are impossible to eradicate

o Which cop on the beat will be resourced and located to oversee this and drive compliance by this company, which has a poor track record of regulatory compliance.

WITHOUT BIOSECURITY, AQUACULTURE FAILS

Biosecurity of aquaculture is one of the most significant factors affecting the success of an aquaculture facility.

The biosecurity risks to South Australia posed by animal and plant pests and diseases, food-borne illnesses and misuse of rural chemicals is managed by Primary Industries and Regions SA (PIRSA). PIRSA has developed the Biosecurity Standards (abalone aquaculture) which outline biosecurity standards for abalone aquaculture with the objective to minimise the risk of outbreaks and spread of disease.

The Federal Government’s Department of Agriculture and Water Resources (DAWR) has published the National Guidelines - Biosecurity Plan Guidelines for land based abalone farms (the Guideline). An objective of this is to strengthen existing biosecurity within abalone farms and implement preventative biosecurity measures, rather than reacting to a disease outbreak.

The DAWR Guideline recognises ports as high-risk sites with the potential to compromise biosecurity3 of aquaculture.

Eliminating biosecurity risks associated with ballast water, biofouling and imported seafood products, maintaining water quality and disease-free status are essential to the success of aquaculture industries, including Yumbah KI.

The proximity of the proposed KIPT seaport at Smith Bay to Yumbah KI constitutes a significant risk to the existing and ongoing operation of the abalone farm. The impending seaport fraught with all its issues hanging in the shadows curtails any possibility of Yumbah’s ongoing investment in KI.

EXAMPLE CASE

In 2017, Southwood Fibre lodged a development plan to establish a $42 million export facility for woodchips at Dover, in the Huon Valley of southern Tasmania.

Similar to KIPT seaport, the Dover proposal included an onshore loading facility and amenities, woodchip pile site, access roads and a ship loading conveyor belt to transport the woodchips to waiting bulk carrier ships, which was set to dock between the shore and Tassal's salmon farm lease areas.

The proposal raised a number of concerns from the community, particularly relating to truck movements, safety and local



51

tourism. The application revealed there would be an expected 13 truck movements per hour both ways between Strathblane and Judbury if the operation ran 10 hours a day, six days a week. There would also be 800 additional truck movements per week delivering wood to Southwood for chipping.

Community opposed the proposed port due to threat to the area’s “clean green” tourism credentials, and environmental impacts on native flora and fauna, including protected species, both marine and terrestrial.

The state’s biggest salmon producer Tassal opposed the proposed plant due to the close proximity to its fish farms. Tassal expressly opposed the location and close proximity of the woodchip facility as the two operations could "simply not co-exist" as immediate neighbours.

Tassal’s concerns were explicitly related to fish health and biosecurity issues. Bio-security risks, including contaminated bilge release and introduction of pests and diseases were regarded as unacceptable.

Tassal refused to accept the impending risk to its aquaculture operations. As a consequence of the impasse between Tassal and Southwood Fibre, the Tasmania government committed to assist Southwood Fibre with finding a new site for the woodchip export facility recognising the proximity of the salmon lease right out the front of the proposed woodchip location.

This case provides a firm example that Yumbah’s concerns as an aquaculture facility are not unfounded and biosecurity is a universally recognised risk.

13 http://www.fish.wa.gov.au/Documents/occasional_publications/fop132.pdf

SEPARATION DISTANCES

Buffer zones or separation distances between sensitive uses are commonly applied across Australia. As an example, the government of Western Australia has adopted a framework for effective management of risks, contemporary biosecurity management practices and practical measures to improve abalone health management based on sound epidemiological principles for disease prevention and control13.

The key principles considered in this guideline when assessing applications for abalone aquaculture are a risk based approach and the precautionary principle.

The precautionary principle defined is a legal and policy principle addressing the problem of scientific uncertainty in environmental decision-making. It is of great concern that the draft EIS does not contemplate any possibility of scientific uncertainty clouding its findings and proceeds to recommend an outcome free of precaution.

This WA guideline recognises that spatial separation is of significance in abalone biosecurity management and is an important biosecurity tool. It focuses on proximity to alternative aquaculture farms to productive reefs, and the principles can be applied to other commercial land uses such as ports.

As stated in the WA guideline “The risk of disease agents being transported along various distances can be described as a continuum, in which the number of infectious particles drops steeply with distance from the source, with only a few infectious particles travelling relatively long distances. Although the likelihood of disease spread is reduced almost


50

• KIPT consider that the risk of introducing marine pests and/or diseases to Smith Bay could “be reduced to an acceptable level by adopting the most rigorous biosecurity standards prescribed by Biosecurity SA”. Yumbah disagrees and references the report by Industry specialists Professor Chad Hewitt and Professor Marnie Campbell (see below).

• The unanswered questions include:

o What’s an acceptable level of marine pests arriving in Smith Bay?

o What happens when “the most rigorous standards prescribed by Biosecurity SA” aren’t met?

o Who will implement a marine pest management program? Introduced marine pests are impossible to eradicate

o Which cop on the beat will be resourced and located to oversee this and drive compliance by this company, which has a poor track record of regulatory compliance.

WITHOUT BIOSECURITY, AQUACULTURE FAILS

Biosecurity of aquaculture is one of the most significant factors affecting the success of an aquaculture facility.

The biosecurity risks to South Australia posed by animal and plant pests and diseases, food-borne illnesses and misuse of rural chemicals is managed by Primary Industries and Regions SA (PIRSA). PIRSA has developed the Biosecurity Standards (abalone aquaculture) which outline biosecurity standards for abalone aquaculture with the objective to minimise the risk of outbreaks and spread of disease.

The Federal Government’s Department of Agriculture and Water Resources (DAWR) has published the National Guidelines - Biosecurity Plan Guidelines for land based abalone farms (the Guideline). An objective of this is to strengthen existing biosecurity within abalone farms and implement preventative biosecurity measures, rather than reacting to a disease outbreak.

The DAWR Guideline recognises ports as high-risk sites with the potential to compromise biosecurity3 of aquaculture.

Eliminating biosecurity risks associated with ballast water, biofouling and imported seafood products, maintaining water quality and disease-free status are essential to the success of aquaculture industries, including Yumbah KI.

The proximity of the proposed KIPT seaport at Smith Bay to Yumbah KI constitutes a significant risk to the existing and ongoing operation of the abalone farm. The impending seaport fraught with all its issues hanging in the shadows curtails any possibility of Yumbah’s ongoing investment in KI.

EXAMPLE CASE

In 2017, Southwood Fibre lodged a development plan to establish a $42 million export facility for woodchips at Dover, in the Huon Valley of southern Tasmania.

Similar to KIPT seaport, the Dover proposal included an onshore loading facility and amenities, woodchip pile site, access roads and a ship loading conveyor belt to transport the woodchips to waiting bulk carrier ships, which was set to dock between the shore and Tassal's salmon farm lease areas.

The proposal raised a number of concerns from the community, particularly relating to truck movements, safety and local



53

AN EXPERT REVIEW

An independent expert assessment of the potential biosecurity risks to Yumbah KI if the KIPT seaport is established directly adjacent the farm in Smith Bay was completed by industry specialists Professor Chad Hewitt and Professor Marnie Campbell, titled Review of Marine Biosecurity Aspects of Smith Bay Wharf, Draft Environmental Impact Statement (May 2019) (Hewitt and Campbell, 2019).

This report is presented as Appendix 4 of this document. The report outlines the biosecurity risks to Yumbah and critiques the content of the EIS Marine Biosecurity section and Appendix I. Many issues and concerns with the content of the EIS were highlighted in Hewitt and Campbell (2019) and are discussed further, below.

Notably, the author/s of the biosecurity report presented by KIPT, primarily Appendix I5 that the draft EIS has heavily relied on, have not been identified. The experience or qualifications to undertake such an important assessment of potential risks to Smith Bay cannot be verified. The assessment of biosecurity risks in the draft EIS is further questionable as disease risks are further discussed in Appendix H by an author that is not an expert in contemporary onshore abalone aquaculture. Further he has previously advised and been involved in high-profile failed offshore abalone investment schemes.

Smith Bay is a pristine environment and is free from invasive marine species and exotic diseases. It needs to be maintained in this state to protect its environmental values that are so heavily relied on by all its users.

Realistically Smith Bay should be awarded the highest level of conservation status on Kangaroo Island due to its relatively untainted environment. In essence, its status as a Coastal Conservation Zone is in place to do just this.

This environment will significantly change if the seaport is established.

The Victorian Government has recognised the need to protect aquaculture zones by restricting non-aquaculture activities within designated reserves.

The same approach should be applied to protect existing aquaculture and encourage such sustainable investment in South Australia.


52

exponentially with distance from the source, extensive distances are required before the likelihood of infection approaches zero. Other factors that influence the level of risk are the number of infectious particles, host density and the strength and direction of water currents.”

Of importance is the comment “the likelihood of disease spread is reduced almost exponentially with distance from the source, extensive distances are required before the likelihood of infection approaches zero”.

The WA guideline then recommends:

“As a guide to reduce the likelihood of disease spread, the distance between abalone farms, and between abalone farms and productive reef areas, five nautical miles (measured over water) is considered a suitably precautionary distance. However, based on risk assessments, a distance greater than or less than five nautical miles may be required or acceptable, as the case may be.”

The distance of five nautical miles is arbitrarily picked – put simply further away is better and closer is worse but presumably has been chosen such that at this distance the “likelihood of infection approaches zero”. Likewise, at 0km the maths tells us the likelihood of infection approaches 100%.

Yumbah Aquaculture operates a farm in Allestree, Victoria which is known as Yumbah Narrawong. It operates in the Portland Bay and is located five nautical miles from the Port of Portland. A frequent ill-informed argument made to denigrate our biosecurity concerns is that “you operate next to a port in Victoria and don’t have a problem”. Clearly at five nautical miles the principle of separation is respected by the Narrawong farm and clearly violated by the KI Seaport planned just a few hundred metres from Yumbah KI. At this proximity the biosecurity risk becomes a certainty.

The proximity of the KIPT seaport therefore provides an unprecedented extreme risk to an abalone farm that should be afforded a significantly greater separation distance from this incompatible use.

Based on precautional principles a risk based approach should be applied to define an adequate separation distance between the KIPT seaport and Yumbah KI. The location of the seaport does not provide an effective buffer between port operations and the sensitive use of aquaculture and as such, impact to amenity on land adjacent to the proposed port is unacceptable.

Traditionally, Australian state governments have provided an effective buffer between port operations and sensitive uses.

Maintaining appropriate threshold distances and preventing encroachment of sensitive use and development is important to the long-term sustainability of Yumbah.



53

AN EXPERT REVIEW

An independent expert assessment of the potential biosecurity risks to Yumbah KI if the KIPT seaport is established directly adjacent the farm in Smith Bay was completed by industry specialists Professor Chad Hewitt and Professor Marnie Campbell, titled Review of Marine Biosecurity Aspects of Smith Bay Wharf, Draft Environmental Impact Statement (May 2019) (Hewitt and Campbell, 2019).

This report is presented as Appendix 4 of this document. The report outlines the biosecurity risks to Yumbah and critiques the content of the EIS Marine Biosecurity section and Appendix I. Many issues and concerns with the content of the EIS were highlighted in Hewitt and Campbell (2019) and are discussed further, below.

Notably, the author/s of the biosecurity report presented by KIPT, primarily Appendix I5 that the draft EIS has heavily relied on, have not been identified. The experience or qualifications to undertake such an important assessment of potential risks to Smith Bay cannot be verified. The assessment of biosecurity risks in the draft EIS is further questionable as disease risks are further discussed in Appendix H by an author that is not an expert in contemporary onshore abalone aquaculture. Further he has previously advised and been involved in high-profile failed offshore abalone investment schemes.

Smith Bay is a pristine environment and is free from invasive marine species and exotic diseases. It needs to be maintained in this state to protect its environmental values that are so heavily relied on by all its users.

Realistically Smith Bay should be awarded the highest level of conservation status on Kangaroo Island due to its relatively untainted environment. In essence, its status as a Coastal Conservation Zone is in place to do just this.

This environment will significantly change if the seaport is established.

The Victorian Government has recognised the need to protect aquaculture zones by restricting non-aquaculture activities within designated reserves.

The same approach should be applied to protect existing aquaculture and encourage such sustainable investment in South Australia.


52

exponentially with distance from the source, extensive distances are required before the likelihood of infection approaches zero. Other factors that influence the level of risk are the number of infectious particles, host density and the strength and direction of water currents.”

Of importance is the comment “the likelihood of disease spread is reduced almost exponentially with distance from the source, extensive distances are required before the likelihood of infection approaches zero”.

The WA guideline then recommends:

“As a guide to reduce the likelihood of disease spread, the distance between abalone farms, and between abalone farms and productive reef areas, five nautical miles (measured over water) is considered a suitably precautionary distance. However, based on risk assessments, a distance greater than or less than five nautical miles may be required or acceptable, as the case may be.”

The distance of five nautical miles is arbitrarily picked – put simply further away is better and closer is worse but presumably has been chosen such that at this distance the “likelihood of infection approaches zero”. Likewise, at 0km the maths tells us the likelihood of infection approaches 100%.

Yumbah Aquaculture operates a farm in Allestree, Victoria which is known as Yumbah Narrawong. It operates in the Portland Bay and is located five nautical miles from the Port of Portland. A frequent ill-informed argument made to denigrate our biosecurity concerns is that “you operate next to a port in Victoria and don’t have a problem”. Clearly at five nautical miles the principle of separation is respected by the Narrawong farm and clearly violated by the KI Seaport planned just a few hundred metres from Yumbah KI. At this proximity the biosecurity risk becomes a certainty.

The proximity of the KIPT seaport therefore provides an unprecedented extreme risk to an abalone farm that should be afforded a significantly greater separation distance from this incompatible use.

Based on precautional principles a risk based approach should be applied to define an adequate separation distance between the KIPT seaport and Yumbah KI. The location of the seaport does not provide an effective buffer between port operations and the sensitive use of aquaculture and as such, impact to amenity on land adjacent to the proposed port is unacceptable.

Traditionally, Australian state governments have provided an effective buffer between port operations and sensitive uses.

Maintaining appropriate threshold distances and preventing encroachment of sensitive use and development is important to the long-term sustainability of Yumbah.



55

As the risk is considered high, Yumbah expected to see an identification of source ports for vessel transfer during the construction phase, and explicit statements surrounding species known from those ports/regions that might pose a risk of transfer.

Biosecurity risks during operation are far greater and assessment of biosecurity risks in the EIS is restricted to the operation phase with a primary focus on ballast water and biofouling.

There is no discussion of the risks from bilge water, which was a required inclusion of the EIS.

The draft EIS is further deficient as it has limited description of the methods used to identify risk species other than a reference to the previously developed generic Commonwealth and South Australian pest identification. The assessment of biosecurity risks used to inform the draft EIS is restricted to a standard list of species.

It should be noted that many of the species identified in Table 1 (draft EIS Appendix I5) are not native to, nor currently introduced to, the Northwest Pacific. As the Northwest Pacific is proposed as the main market for the timber exports, it is critical for Smith Bay that species from this geographic region should feature heavily in the biosecurity risk profile.

This may be an accidental oversight or an omission from the EIS, but it cannot be stressed strongly enough: as the main port traffic is proposed to originate from the Northwest Pacific the exclusion of invasive marine species native to the Northwest Pacific is of paramount concern.

Hewitt and Campbell (2019) identify a significant number of invasive marine species native to the Northwest Pacific not considered further in the EIS. Hewitt et al (2009) identified 324 marine species

introduced to the Northwest Pacific bioregion (107 of which are not present in Australia) and 645 native species that have been introduced to other parts of the world (266 of which are not present in Australia).

The 373 species with an invasion history and known to be present in the Northwest Pacific but not present in Australasia represent a significant risk to Smith Bay that have not been considered in the EIS.

Concern is raised by Hewitt and Campbell (2019) that threat of toxic dinoflagellates in the genus Alexandrium and the Pacific oyster, Crassostrea gigas, establishing in Smith Bay is considered ‘unlikely’.

This is in direct contrast to Appendix H Aquaculture Studies (pg 67) that states:

“The risk of red-tide species being introduced via ballast water is real. Such species have been transported around the world in ballast water and most introductions have been to Ports and Harbors.”

Both agents represent significant threats to coastal waters and warrant consideration, particularly as Smith Bay will provide ideal conditions for both agents to proliferate. Appendix H (pg 67) further continues to state:

“While dinoflagellates are present in almost every marine system in the world, the presence of red-tide species is normally restricted to areas where dinoflagellate blooms can occur; this particularly includes protected/ sheltered embayments with high levels of nutrient pollution. Such conditions are not present in Smith Bay (BMT 2018b) where water quality is very good due to the normally low levels of nitrogen and phosphorus.”


54

REAL RISKS

Biosecurity risks to Yumbah are imminent during the seaport construction and operation. In a previous report, Hewitt and Campbell (2010) highlighted a large majority of recognised global marine invaders are capable of being transported by multiple vectors, with ballast water (of commercial vessels) and biofouling (of commercial and recreational vessels) presenting the greatest contribution. It must be highlighted that the risks of bilge water are not discussed in any detail in the EIS, which was required by DAC.

The biosecurity risks to Smith Bay and Yumbah KI are real. If realised, they will be catastrophic to the Yumbah KI business. The EIS has recognised that risk of introducing invasive pest species and disease-causing agents is highly likely in Smith Bay if the seaport is established. It will be inevitable.

The EIS highlights shipping vectors (ballast water and biofouling) and acknowledges other vectors are relevant during construction but provides no discussion of risks from sediment associated with dredge or hopper barges.

The most recent article published on biosecurity (Choi May 2019)14 recognises that with the imminent increase of maritime traffic by a staggering 240 to 1,209 percent by 2005, the risk of marine invasions is likely to risk 3 to 20-fold. This risk is of greatest importance to the large, fast-growing economies such as north-east Asia. KIPT is expecting the majority of its seaport traffic from this region.

14 https://www.hakaimagazine.com/news/as-global-shipping-grows-prepare-for-a-surge-of-invasive-species/ 15 http://www.agriculture.gov.au/pests-diseases-weeds/marine-pests

Lack of Priority Pest Species

Introduced marine pests are marine plants or animals that are not native to Australia but have been introduced by human activities such as shipping. They have the potential to significantly impact our natural environment and marine industries, particularly impacting the viability of aquaculture15

.

The EIS notes that “all exotic species are of concern to the South Australian Government”.

The EIS does not clearly articulate the extent of potential invasive species that may be introduced by ballast water and biofouling to Smith Bay during both construction and operation of the proposed seaport.

Hewitt and Campbell (2019) confirm the seaport construction creates a high potential for species transfer due to the movement and arrival of slow-moving vessels with long port residence times, including the potential for sediment transport (dredges and barges) which may lead to the transfer of invasive marine species and harmful algal blooms.

Dredges and supporting vessels are explicitly linked to the transfer and spread of non-native marine species, particularly biofouling species such as Sabella spallanzanii, and dinoflagellate cysts in retained sediments from the last port of operations.

There is no explicit assessment of species’ transfer risk associated with the construction phase, despite this representing a very high potential due to the movement and arrival of slow-moving vessels with long port residence times.



55

As the risk is considered high, Yumbah expected to see an identification of source ports for vessel transfer during the construction phase, and explicit statements surrounding species known from those ports/regions that might pose a risk of transfer.

Biosecurity risks during operation are far greater and assessment of biosecurity risks in the EIS is restricted to the operation phase with a primary focus on ballast water and biofouling.

There is no discussion of the risks from bilge water, which was a required inclusion of the EIS.

The draft EIS is further deficient as it has limited description of the methods used to identify risk species other than a reference to the previously developed generic Commonwealth and South Australian pest identification. The assessment of biosecurity risks used to inform the draft EIS is restricted to a standard list of species.

It should be noted that many of the species identified in Table 1 (draft EIS Appendix I5) are not native to, nor currently introduced to, the Northwest Pacific. As the Northwest Pacific is proposed as the main market for the timber exports, it is critical for Smith Bay that species from this geographic region should feature heavily in the biosecurity risk profile.

This may be an accidental oversight or an omission from the EIS, but it cannot be stressed strongly enough: as the main port traffic is proposed to originate from the Northwest Pacific the exclusion of invasive marine species native to the Northwest Pacific is of paramount concern.

Hewitt and Campbell (2019) identify a significant number of invasive marine species native to the Northwest Pacific not considered further in the EIS. Hewitt et al (2009) identified 324 marine species

introduced to the Northwest Pacific bioregion (107 of which are not present in Australia) and 645 native species that have been introduced to other parts of the world (266 of which are not present in Australia).

The 373 species with an invasion history and known to be present in the Northwest Pacific but not present in Australasia represent a significant risk to Smith Bay that have not been considered in the EIS.

Concern is raised by Hewitt and Campbell (2019) that threat of toxic dinoflagellates in the genus Alexandrium and the Pacific oyster, Crassostrea gigas, establishing in Smith Bay is considered ‘unlikely’.

This is in direct contrast to Appendix H Aquaculture Studies (pg 67) that states:

“The risk of red-tide species being introduced via ballast water is real. Such species have been transported around the world in ballast water and most introductions have been to Ports and Harbors.”

Both agents represent significant threats to coastal waters and warrant consideration, particularly as Smith Bay will provide ideal conditions for both agents to proliferate. Appendix H (pg 67) further continues to state:

“While dinoflagellates are present in almost every marine system in the world, the presence of red-tide species is normally restricted to areas where dinoflagellate blooms can occur; this particularly includes protected/ sheltered embayments with high levels of nutrient pollution. Such conditions are not present in Smith Bay (BMT 2018b) where water quality is very good due to the normally low levels of nitrogen and phosphorus.”


54

REAL RISKS

Biosecurity risks to Yumbah are imminent during the seaport construction and operation. In a previous report, Hewitt and Campbell (2010) highlighted a large majority of recognised global marine invaders are capable of being transported by multiple vectors, with ballast water (of commercial vessels) and biofouling (of commercial and recreational vessels) presenting the greatest contribution. It must be highlighted that the risks of bilge water are not discussed in any detail in the EIS, which was required by DAC.

The biosecurity risks to Smith Bay and Yumbah KI are real. If realised, they will be catastrophic to the Yumbah KI business. The EIS has recognised that risk of introducing invasive pest species and disease-causing agents is highly likely in Smith Bay if the seaport is established. It will be inevitable.

The EIS highlights shipping vectors (ballast water and biofouling) and acknowledges other vectors are relevant during construction but provides no discussion of risks from sediment associated with dredge or hopper barges.

The most recent article published on biosecurity (Choi May 2019)14 recognises that with the imminent increase of maritime traffic by a staggering 240 to 1,209 percent by 2005, the risk of marine invasions is likely to risk 3 to 20-fold. This risk is of greatest importance to the large, fast-growing economies such as north-east Asia. KIPT is expecting the majority of its seaport traffic from this region.

14 https://www.hakaimagazine.com/news/as-global-shipping-grows-prepare-for-a-surge-of-invasive-species/ 15 http://www.agriculture.gov.au/pests-diseases-weeds/marine-pests

Lack of Priority Pest Species

Introduced marine pests are marine plants or animals that are not native to Australia but have been introduced by human activities such as shipping. They have the potential to significantly impact our natural environment and marine industries, particularly impacting the viability of aquaculture15

.

The EIS notes that “all exotic species are of concern to the South Australian Government”.

The EIS does not clearly articulate the extent of potential invasive species that may be introduced by ballast water and biofouling to Smith Bay during both construction and operation of the proposed seaport.

Hewitt and Campbell (2019) confirm the seaport construction creates a high potential for species transfer due to the movement and arrival of slow-moving vessels with long port residence times, including the potential for sediment transport (dredges and barges) which may lead to the transfer of invasive marine species and harmful algal blooms.

Dredges and supporting vessels are explicitly linked to the transfer and spread of non-native marine species, particularly biofouling species such as Sabella spallanzanii, and dinoflagellate cysts in retained sediments from the last port of operations.

There is no explicit assessment of species’ transfer risk associated with the construction phase, despite this representing a very high potential due to the movement and arrival of slow-moving vessels with long port residence times.



57

INADEQUATE MANAGEMENT AND MITIGATION MEASURES

Hewitt and Campbell (2019) reviewed the management and mitigation measures outlined in the draft EIS and these are insufficiently defined to determine the level of biosecurity protection required.

Management and mitigation measures have been provided for two elements:

• Discharges and Ballast Water Management, and

• Biofouling

The draft EIS argues compliance with international and Commonwealth law as mitigation for discharges and ballast water management. As the stakeholder with the most at risk, Yumbah believes this is inadequate. It will result in failure to protect the marine ecology of Smith Bay and Yumbah KI. Additional risks with construction and operation of the seaport - not included in the draft EIS - are to be considered.

Standard ballast water management practices are insufficient for ballast water sediments, and do not provide protection from domestic ballast water.

Similarly, it remains unclear how vessels that do not complete ballast water exchange; undertake ballast water exchange in coastal waters; or do not undertake ballast water exchange due to safety of life at sea considerations, will be treated.

Yumbah would like to know if these vessels will be allowed entry to Smith Bay and therefore be able to release "untreated" water? Will domestic ballast water be allowed to be released in Smith Bay?

Given that domestic voyages are unlikely to have sufficient time, or attain "high seas" for exchange, they are unlikely to meet the "safe" standards.

Yumbah has grave concerns that the "Same area" concept used at Port Adelaide will be pursued at Smith Bay, despite sureties in the draft EIS that this will not be sought.

CONCLUSION

It is Yumbah’s submission that establishing a seaport in Smith Bay will result in significant biosecurity risks to the marine ecology of Smith Bay, and be catastrophic to the ongoing operations and any possible investment at Yumbah KI.

Hewitt and Campbell (2019) conclude:

• methodology for determining marine biosecurity risk activities, vectors and species is unclear and, based on the material presented in the draft EIS, inadequate

• species assessments do not appropriately consider either the domestic or international source locations to determine the species (and disease agents and parasites) likely to be transported into Smith Bay waters

• risk mitigation measures proposed are generic and meet the letter, rather than the intent, of international, Commonwealth and State requirements

• measures for discharges and ballast water management focus explicitly on the operational phase using commercial trading vessels and are insufficiently detailed to address the construction phase, particularly for the


56

It has been verified in the EIS that the construction of the causeway will alter circulation patterns, and reduce currents. These are the conditions that require further consideration to assess the likelihood of dinoflagellate bloom formation. Additionally, the introduction of toxic dinoflagellates leading to uptake within the Yumbah facility creates imminent internal biosecurity risks for Yumbah KI that do not currently exist.

Already established pests also lacking consideration in the EIS include toxic, bloom forming microalga, Gymnodinium catenatum; European fan worm, Sabella spallanzanii; Codium fragile ssp tomentosoides; the Northern Pacific Seastar, Asterias amurensis; and the Japanese kelp, Undaria pinnatifida.

POOR DISEASE ASSESSMENT

Australia has a relative advantage through its freedom from many aquatic animal diseases that occur in other countries. Maintaining this status is important for the aquaculture industry to ensure growth and profitability is not jeopardised by exotic pathogens or the emergence of endemic pathogens.16

The emergence and spread of significant known and unknown aquatic animal diseases has posed, and will continue to pose, an increasing threat to Australia’s relatively favourable aquatic animal health status. Inadvertent transfers via biofouling or water-borne mechanisms are recognised as significant risk pathways for the introduction of new diseases.

The abalone and oyster industries are two sectors with first-hand experience of the devastating impacts of infectious animal diseases.

16 agriculture.gov.au/fisheries/aquaculture/national-aquaculture-strategy 17 http://www.frdc.com.au/Archived-Reports/FRDC%20Projects/2016-245-DLD.pdf

In the last decade Abalone Viral Ganglioneuritis (AVG) and Pacific Oyster Mortality Syndrome (POMS) have caused substantial economic impacts in Australia and now present trade barriers for movement of livestock17.

AVG and POMS have been noted as significant diseases in the draft EIS, however no methodology is presented that suggests a rigorous process was employed to determine either the significance or likelihood of these two species being introduced to Smith Bay by KIPT. The imminent risk of paralytic shellfish poisoning (PSP) and its impact on Yumbah KI’s operations is also considered a significant threat that demands further and well-informed consideration.

The draft EIS selection of disease-causing agents appears to have ignored the likelihood of introduction from the prospective trading locations in the Northwest Pacific (China, Japan).

Several abalone diseases resulting in abalone mass mortalities and hatchery losses are known to originate from this region. These include a number of Vibrio-related outbreaks causing mass abalone mortalities. The extent to which these disease agents pose a risk to Australian native species has not been investigated or discussed in the draft EIS.

Vibrio is widely considered a significant and real threat to abalone. Consideration of transfer through ballast water (including retention after ballast water exchange), or via biofouling is lacking in this draft EIS.



57

INADEQUATE MANAGEMENT AND MITIGATION MEASURES

Hewitt and Campbell (2019) reviewed the management and mitigation measures outlined in the draft EIS and these are insufficiently defined to determine the level of biosecurity protection required.

Management and mitigation measures have been provided for two elements:

• Discharges and Ballast Water Management, and

• Biofouling

The draft EIS argues compliance with international and Commonwealth law as mitigation for discharges and ballast water management. As the stakeholder with the most at risk, Yumbah believes this is inadequate. It will result in failure to protect the marine ecology of Smith Bay and Yumbah KI. Additional risks with construction and operation of the seaport - not included in the draft EIS - are to be considered.

Standard ballast water management practices are insufficient for ballast water sediments, and do not provide protection from domestic ballast water.

Similarly, it remains unclear how vessels that do not complete ballast water exchange; undertake ballast water exchange in coastal waters; or do not undertake ballast water exchange due to safety of life at sea considerations, will be treated.

Yumbah would like to know if these vessels will be allowed entry to Smith Bay and therefore be able to release "untreated" water? Will domestic ballast water be allowed to be released in Smith Bay?

Given that domestic voyages are unlikely to have sufficient time, or attain "high seas" for exchange, they are unlikely to meet the "safe" standards.

Yumbah has grave concerns that the "Same area" concept used at Port Adelaide will be pursued at Smith Bay, despite sureties in the draft EIS that this will not be sought.

CONCLUSION

It is Yumbah’s submission that establishing a seaport in Smith Bay will result in significant biosecurity risks to the marine ecology of Smith Bay, and be catastrophic to the ongoing operations and any possible investment at Yumbah KI.

Hewitt and Campbell (2019) conclude:

• methodology for determining marine biosecurity risk activities, vectors and species is unclear and, based on the material presented in the draft EIS, inadequate

• species assessments do not appropriately consider either the domestic or international source locations to determine the species (and disease agents and parasites) likely to be transported into Smith Bay waters

• risk mitigation measures proposed are generic and meet the letter, rather than the intent, of international, Commonwealth and State requirements

• measures for discharges and ballast water management focus explicitly on the operational phase using commercial trading vessels and are insufficiently detailed to address the construction phase, particularly for the


56

It has been verified in the EIS that the construction of the causeway will alter circulation patterns, and reduce currents. These are the conditions that require further consideration to assess the likelihood of dinoflagellate bloom formation. Additionally, the introduction of toxic dinoflagellates leading to uptake within the Yumbah facility creates imminent internal biosecurity risks for Yumbah KI that do not currently exist.

Already established pests also lacking consideration in the EIS include toxic, bloom forming microalga, Gymnodinium catenatum; European fan worm, Sabella spallanzanii; Codium fragile ssp tomentosoides; the Northern Pacific Seastar, Asterias amurensis; and the Japanese kelp, Undaria pinnatifida.

POOR DISEASE ASSESSMENT

Australia has a relative advantage through its freedom from many aquatic animal diseases that occur in other countries. Maintaining this status is important for the aquaculture industry to ensure growth and profitability is not jeopardised by exotic pathogens or the emergence of endemic pathogens.16

The emergence and spread of significant known and unknown aquatic animal diseases has posed, and will continue to pose, an increasing threat to Australia’s relatively favourable aquatic animal health status. Inadvertent transfers via biofouling or water-borne mechanisms are recognised as significant risk pathways for the introduction of new diseases.

The abalone and oyster industries are two sectors with first-hand experience of the devastating impacts of infectious animal diseases.

16 agriculture.gov.au/fisheries/aquaculture/national-aquaculture-strategy 17 http://www.frdc.com.au/Archived-Reports/FRDC%20Projects/2016-245-DLD.pdf

In the last decade Abalone Viral Ganglioneuritis (AVG) and Pacific Oyster Mortality Syndrome (POMS) have caused substantial economic impacts in Australia and now present trade barriers for movement of livestock17.

AVG and POMS have been noted as significant diseases in the draft EIS, however no methodology is presented that suggests a rigorous process was employed to determine either the significance or likelihood of these two species being introduced to Smith Bay by KIPT. The imminent risk of paralytic shellfish poisoning (PSP) and its impact on Yumbah KI’s operations is also considered a significant threat that demands further and well-informed consideration.

The draft EIS selection of disease-causing agents appears to have ignored the likelihood of introduction from the prospective trading locations in the Northwest Pacific (China, Japan).

Several abalone diseases resulting in abalone mass mortalities and hatchery losses are known to originate from this region. These include a number of Vibrio-related outbreaks causing mass abalone mortalities. The extent to which these disease agents pose a risk to Australian native species has not been investigated or discussed in the draft EIS.

Vibrio is widely considered a significant and real threat to abalone. Consideration of transfer through ballast water (including retention after ballast water exchange), or via biofouling is lacking in this draft EIS.



59

ERRORS AND OMISSIONS

• Movement of domestic ships into Smith Bay from Port Adelaide is considered to pose a higher biosecurity risk than international shipping and would be managed accordingly.19

What does ‘managed accordingly’ mean? How will this be managed?

• It is considered that the risk of introducing marine pests and/or diseases to Smith Bay could be reduced to an acceptable level by adopting the most rigorous biosecurity standards prescribed by Biosecurity SA.20

Another hypothetical: “…could be reduced.” What is an acceptable number of marine pests arriving in Smith Bay? What happens when the most rigorous standards aren’t in place?

• More than 20 introduced marine species have been recorded around Kangaroo Island, but none at Smith Bay.21

It is necessary to list and detail exotic pests - and include paralytic shellfish poisoning.

19 EIS Executive Summary p46 20 EIS Executive Summary p50 21 EIS Executive Summary p46 22 EIS Main Report p80 23 EIS Appendix U p21 24 EIS Appendix U p19

• Tugs and/or bow and stern thrusters (if available) would bring the vessel into the wharf where it would be secured prior to ship loading activities.22

These tugs present a sizeable biosecurity threat, especially from Vic AVG.

• Other than in exceptional circumstances, vessels would discharge foreign-sourced ballast water on the high seas (that is, further than 200 nautical miles from the Australian shoreline) before entering the Australian EEZ, in conformance with the Biosecurity Act 2015.23

To propose such discharge is unacceptable in itself.

• The pontoon (purchased in Korea as a barge) has been sandblasted and repainted with anti-fouling paint and would be inspected by Australian engineers before arrival at Smith Bay.24

Pontoon is coated with anti-fouling paint. What chemicals are in the paint and what study has been done to prove no harm and that the pontoon will be incapable of becoming a massive host for marine pests.


58

risks associated with slow moving vessels including dredges and barges

• lack of mitigation measures that consider sediment transfer risk either in the dredges and barges, or in the commercial trading vessels, is insufficient to provide harmful algal bloom protections

• Domestic ballast water movement is unlikely to attain distances offshore to meet the definition of “high seas” and therefore will not be able to undertake adequate protections

• Biofouling species hazards associated with both construction and operational phases will continue to pose unmitigated risks. A restriction on in-water or dry dock cleaning at Smith Bay will not prevent mature species from spawning or being dislodged into Smith Bay

• Mature biofouling assemblages are likely to pose the additional risk of transferring disease agents and parasites into Smith Bay waters

The Kangaroo Island Biosecurity Strategy 2017-202718 is clear:

“…the financial impact on primary production and tourism could be significant if particular pests were to establish on Kangaroo Island, with the success of niche agricultural enterprises relying heavily on freedom from pests and disease. Kangaroo Island’s biosecurity system supports the export of higher quality primary products, which may

18 Triggs, AS. 2017. Biosecurity Strategy for Kangaroo Island 2017–2027. Department of Environment, Water and Natural Resources, South Australia

provide a competitive advantage in some markets and allow entry into others.”

The proximity of this proposed seaport to Yumbah KI provides a significant risk to the biosecurity of the farm and its subsequent accreditation with Abalone Health Accreditation Plan (AHAP). This formally recognised accreditation provides Australian land-based abalone farms with the tools and templates to create fully auditable biosecurity plans.

“The relationship between the natural environment and aquaculture is critical because aquaculture relies on a clean and healthy environment”.

It must be reinforced that mitigation of risks does not guarantee removal of the risk.

To protect Yumbah KI’s thriving business and its future growth, and the natural environment of Smith Bay, appropriate controls must be placed on the introduction and movement of aquatic organisms.

Controls help manage risks associated with emergence and invasion of exotic species, and disease incursions. Applying a robust risk-based approach to managing biosecurity for all industries is central to ensuring the biosecurity of Australia’s aquaculture industry.

In Yumbah’s view, the only control to eliminate the introduction and movement of aquatic organisms and ultimate impact on Yumbah KI is not to establish a seaport adjacent to the abalone farm at Smith Bay.



59


• Movement of domestic ships into Smith Bay from Port Adelaide is considered to pose a higher biosecurity risk than international shipping and would be managed accordingly.19

What does ‘managed accordingly’ mean? How will this be managed?

• It is considered that the risk of introducing marine pests and/or diseases to Smith Bay could be reduced to an acceptable level by adopting the most rigorous biosecurity standards prescribed by Biosecurity SA.20

Another hypothetical: “…could be reduced.” What is an acceptable number of marine pests arriving in Smith Bay? What happens when the most rigorous standards aren’t in place?

• More than 20 introduced marine species have been recorded around Kangaroo Island, but none at Smith Bay.21

It is necessary to list and detail exotic pests - and include paralytic shellfish poisoning.

19 EIS Executive Summary p46 20 EIS Executive Summary p50 21 EIS Executive Summary p46 22 EIS Main Report p80 23 EIS Appendix U p21 24 EIS Appendix U p19

• Tugs and/or bow and stern thrusters (if available) would bring the vessel into the wharf where it would be secured prior to ship loading activities.22

These tugs present a sizeable biosecurity threat, especially from Vic AVG.

• Other than in exceptional circumstances, vessels would discharge foreign-sourced ballast water on the high seas (that is, further than 200 nautical miles from the Australian shoreline) before entering the Australian EEZ, in conformance with the Biosecurity Act 2015.23

To propose such discharge is unacceptable in itself.

• The pontoon (purchased in Korea as a barge) has been sandblasted and repainted with anti-fouling paint and would be inspected by Australian engineers before arrival at Smith Bay.24

Pontoon is coated with anti-fouling paint. What chemicals are in the paint and what study has been done to prove no harm and that the pontoon will be incapable of becoming a massive host for marine pests.


58

risks associated with slow moving vessels including dredges and barges

• lack of mitigation measures that consider sediment transfer risk either in the dredges and barges, or in the commercial trading vessels, is insufficient to provide harmful algal bloom protections

• Domestic ballast water movement is unlikely to attain distances offshore to meet the definition of “high seas” and therefore will not be able to undertake adequate protections

• Biofouling species hazards associated with both construction and operational phases will continue to pose unmitigated risks. A restriction on in-water or dry dock cleaning at Smith Bay will not prevent mature species from spawning or being dislodged into Smith Bay

• Mature biofouling assemblages are likely to pose the additional risk of transferring disease agents and parasites into Smith Bay waters

The Kangaroo Island Biosecurity Strategy 2017-202718 is clear:

“…the financial impact on primary production and tourism could be significant if particular pests were to establish on Kangaroo Island, with the success of niche agricultural enterprises relying heavily on freedom from pests and disease. Kangaroo Island’s biosecurity system supports the export of higher quality primary products, which may

18 Triggs, AS. 2017. Biosecurity Strategy for Kangaroo Island 2017–2027. Department of Environment, Water and Natural Resources, South Australia

provide a competitive advantage in some markets and allow entry into others.”

The proximity of this proposed seaport to Yumbah KI provides a significant risk to the biosecurity of the farm and its subsequent accreditation with Abalone Health Accreditation Plan (AHAP). This formally recognised accreditation provides Australian land-based abalone farms with the tools and templates to create fully auditable biosecurity plans.

“The relationship between the natural environment and aquaculture is critical because aquaculture relies on a clean and healthy environment”.

It must be reinforced that mitigation of risks does not guarantee removal of the risk.

To protect Yumbah KI’s thriving business and its future growth, and the natural environment of Smith Bay, appropriate controls must be placed on the introduction and movement of aquatic organisms.

Controls help manage risks associated with emergence and invasion of exotic species, and disease incursions. Applying a robust risk-based approach to managing biosecurity for all industries is central to ensuring the biosecurity of Australia’s aquaculture industry.

In Yumbah’s view, the only control to eliminate the introduction and movement of aquatic organisms and ultimate impact on Yumbah KI is not to establish a seaport adjacent to the abalone farm at Smith Bay.



61

GUIDELINE 4:

ECONOMY

DESCRIPTION:

The proposal is likely to generate jobs on Kangaroo Island, directly and indirectly, during both the construction and operational phases of the proposed development. Given the proximity to the nearby existing aquaculture operation, consideration needs to be given to how the proposed development and use of the port and wharf may impact on the operation of this established business, and how any such impacts will be managed. As the facility is proposed to be a multi-user facility, this may have potential positive impacts on other components of the Kangaroo Island economy.

RESPONSE SUMMARY

• Proposal’s economic benefit over-stated

o No genuine cross-economy impact study completed

o Jobs claims fanciful for facility operating at 20 per cent capacity

o No consideration of non-port infrastructure costs, particularly roads

• Claimed economic contribution ignores

direct losses

o Project approval jeopardises Yumbah KI, endangers other small businesses

o Aquaculture investment at threat if KIPT creates planning precedent

o Only KIPT arguing aquaculture and a deep-water port can co-exist next door to each other

o Peak community representative body, KI Council, says no KIPT at Smith Bay

o Proponent encouraged to move proposal further west, closer to its trees

• Benefits to Kangaroo Island calculated

to show…benefit

o No assessment of dispersed losses, including social and economic amenity

o No socio-economic analysis of alternative sites, only site visits by Google Earth

o No accounting for tourism loss, road trauma cost

o No consultation with community to realise shared benefit

ECONOMIC CLAIMS DON’T STACK UP

The economic projections of Appendix O Economic Assessment of the draft EIS can only be accepted on face value. The discounting of KIPT’s estimation and calculation of negative effect can be left to others.

Yumbah has engaged expert analysis to assess the economic impact of its current activity at Smith Bay, and the future impact of its own – stalled, on account of KIPT – investment plans.


60

• Regarding the proposed KI Seaport and the existing adjacent abalone farm, it would be essential that measures were taken to ensure that no abalone-related diseases were introduced. The two most significant diseases are Abalone Viral Ganglioneuritis and the parasite Perkinsus.25

Nine OIE-listed reportable diseases or etiological agents are recognised from Japan or China that cause impacts to one or more of the approved aquaculture genera. These include two abalone diseases, one oyster disease and six fish diseases.

Eight are not considered in the EIS. Abalone Viral Ganglioneuritis is considered, but only as a domestic threat, not a threat from Japan where the etiological agent has been detected.

25 EIS Appendix I4 p7



61

GUIDELINE 4:

ECONOMY

DESCRIPTION:

The proposal is likely to generate jobs on Kangaroo Island, directly and indirectly, during both the construction and operational phases of the proposed development. Given the proximity to the nearby existing aquaculture operation, consideration needs to be given to how the proposed development and use of the port and wharf may impact on the operation of this established business, and how any such impacts will be managed. As the facility is proposed to be a multi-user facility, this may have potential positive impacts on other components of the Kangaroo Island economy.

RESPONSE SUMMARY

• Proposal’s economic benefit over-stated

o No genuine cross-economy impact study completed

o Jobs claims fanciful for facility operating at 20 per cent capacity

o No consideration of non-port infrastructure costs, particularly roads

• Claimed economic contribution ignores

direct losses

o Project approval jeopardises Yumbah KI, endangers other small businesses

o Aquaculture investment at threat if KIPT creates planning precedent

o Only KIPT arguing aquaculture and a deep-water port can co-exist next door to each other

o Peak community representative body, KI Council, says no KIPT at Smith Bay

o Proponent encouraged to move proposal further west, closer to its trees

• Benefits to Kangaroo Island calculated

to show…benefit

o No assessment of dispersed losses, including social and economic amenity

o No socio-economic analysis of alternative sites, only site visits by Google Earth

o No accounting for tourism loss, road trauma cost

o No consultation with community to realise shared benefit

ECONOMIC CLAIMS DON’T STACK UP

The economic projections of Appendix O Economic Assessment of the draft EIS can only be accepted on face value. The discounting of KIPT’s estimation and calculation of negative effect can be left to others.

Yumbah has engaged expert analysis to assess the economic impact of its current activity at Smith Bay, and the future impact of its own – stalled, on account of KIPT – investment plans.


60

• Regarding the proposed KI Seaport and the existing adjacent abalone farm, it would be essential that measures were taken to ensure that no abalone-related diseases were introduced. The two most significant diseases are Abalone Viral Ganglioneuritis and the parasite Perkinsus.25

Nine OIE-listed reportable diseases or etiological agents are recognised from Japan or China that cause impacts to one or more of the approved aquaculture genera. These include two abalone diseases, one oyster disease and six fish diseases.

Eight are not considered in the EIS. Abalone Viral Ganglioneuritis is considered, but only as a domestic threat, not a threat from Japan where the etiological agent has been detected.

25 EIS Appendix I4 p7



63

It is difficult to estimate the net negative effect on KI’s tourism industry of a woodchip mountain dominating the Smith Bay landscape and seascape.

It’s equally challenging to determine the cost of industrialising the North Coast marine tourist experience.

Or to assess the impact of perpetual heavy truck traffic on the tourist experience, the cost of roads KIPT assumes ratepayers or taxpayers will bear – or the tragic cost of inevitable road trauma.

What can be said is that the combined effects of KIPT’s Smith Bay proposal provide are a negative transformation for KI.

YUMBAH’S KI VISION

Dench McLean Carlson’s modelling assessed Yumbah’s contribution to the Kangaroo Island economy under three scenarios:

• Current operation – Yumbah KI’s contribution today

• Stage 1, Licenced state – a plan to expand the current Yumbah KI site to the maximum production permitted by current licences

• Stage 2, Desired state – an expansion to 1000 tonnes production, with accompanying public access, education and tourism infrastructure

Yumbah KI as it is today value adds to the KI economy some $ 4.11m annually.

Although the farm has grown over its 24 years of operation, simple mathematics shows an historic contribution to KI nearing $100m.

Add a tourism-education facility, and it adds an additional $1.15m annually.

Yumbah’s planned expansions are on hold because of the threat of KIPT’s seaport.

For the past four years, all KI-based investment proposals presented to the Yumbah Board have been dismissed because of the overwhelming risk posed by KIPT.

Because of this threat Yumbah Aquaculture had to look elsewhere for expansion opportunities, and has recently gained planning and EPA approval for a 1000-tonne farm and aligned production infrastructure near Portland in Victoria.

Yumbah Aquaculture actively practises risk mitigation through diversification of its farm assets across geographically distant areas.

Imminent construction of the Nyamat farm creates the need for 1000 tonnes of production elsewhere. This is the base for the stage 2 proposal to find appropriate land on Kangaroo Island to expand production.

The economic value added to the local economy in these scenarios are estimated as:

• Current – $4 .1m annually

• Stage 1 + tourism – $14.85m annually (includes current)

• Stage 2 – $35.4m annually (includes current, Stage 1 + tourism)

Any economic benefit projected by the proponent for the seaport in its draft EIS must be discounted by the unmeasured loss of tourist dollars and the projected loss of up to $ 35.4 million of potential input to the local economy, every year.


62

JOB CREATION CLAIMS DON’T STACK UP

The draft EIS estimates 45 construction jobs at the seaport, but apparently only 15 at a time. It suggests 160 jobs will be created for KI at the port and in forestry, but 140 of these will be filled by people from the mainland.

KIPT has explained in the past that KI residents don’t have the skills it needs and it will instead import these as it needs them as seasonal or project labour.

It’s also unclear as to how many jobs are full time, given the draft EIS reports the possibility of as few as 10 or as many as 20 vessels using the port annually.

JOB LOSSES NOT FACTORED

The draft EIS builds an assumption that KIPT’s proposal will somehow benefit Yumbah. The reality is the opposite.

In simple terms, the first sediment plume generated by KIPT’s unmanaged dredging program – barely detailed in the draft EIS – that enters Yumbah’s intake pipes marks the end of Yumbah KI. With it go more than 25 direct and seven associated FTE jobs, and a local economic contribution of more than $4 million annually.

Gone also is a long-term growth plan (shelved by the appearance of KIPT’s Smith Bay proposal), that would see Yumbah driving an 8.9% increase on all current FTE jobs in the Kangaroo Island local economy. These FTEs are KI resident workers – on the Island, year-round.

SAY IT AGAIN: THERE ARE OTHER, BETTER SITES

The arguments have been presented elsewhere and by others, including Kangaroo Island Shire Council, for a more sensible relocation of this project to a more appropriate site.

There are many alternative sites, all dismissed summarily by the draft EIS.

To direct KIPT elsewhere on KI will allow the Island to benefit from the substantial growth trajectory of Yumbah and aquaculture generally. At the same time, it will facilitate the removal of plantations that have blighted Kangaroo Island and stalled its economic performance for more than 20 years.

ALTERNATIVE ASSESSMENT: NET ECONOMIC EFFECT

To contrast the economic claims of the draft EIS, Yumbah engaged Dench McLean Carlson to complete an econometric analysis of Yumbah’s current economic contribution to KI, and the greater contribution that would accompany Yumbah’s stalled investment program.

This analysis is presented as Appendix 5.

This investment program includes significantly expanded abalone production and a Discovery Centre at Smith Bay. The Discovery Centre concept has been discussed with Ministers of both the current State Government and their predecessors. In simple terms, the Discovery Centre combines an aquaculture education facility, a global research base, and a high-end “cellar door” tourism model showcasing Yumbah product and the best of KI’s gourmet food and high-end fibre producers.



63

It is difficult to estimate the net negative effect on KI’s tourism industry of a woodchip mountain dominating the Smith Bay landscape and seascape.

It’s equally challenging to determine the cost of industrialising the North Coast marine tourist experience.

Or to assess the impact of perpetual heavy truck traffic on the tourist experience, the cost of roads KIPT assumes ratepayers or taxpayers will bear – or the tragic cost of inevitable road trauma.

What can be said is that the combined effects of KIPT’s Smith Bay proposal provide are a negative transformation for KI.

YUMBAH’S KI VISION

Dench McLean Carlson’s modelling assessed Yumbah’s contribution to the Kangaroo Island economy under three scenarios:

• Current operation – Yumbah KI’s contribution today

• Stage 1, Licenced state – a plan to expand the current Yumbah KI site to the maximum production permitted by current licences

• Stage 2, Desired state – an expansion to 1000 tonnes production, with accompanying public access, education and tourism infrastructure

Yumbah KI as it is today value adds to the KI economy some $ 4.11m annually.

Although the farm has grown over its 24 years of operation, simple mathematics shows an historic contribution to KI nearing $100m.

Add a tourism-education facility, and it adds an additional $1.15m annually.

Yumbah’s planned expansions are on hold because of the threat of KIPT’s seaport.

For the past four years, all KI-based investment proposals presented to the Yumbah Board have been dismissed because of the overwhelming risk posed by KIPT.

Because of this threat Yumbah Aquaculture had to look elsewhere for expansion opportunities, and has recently gained planning and EPA approval for a 1000-tonne farm and aligned production infrastructure near Portland in Victoria.

Yumbah Aquaculture actively practises risk mitigation through diversification of its farm assets across geographically distant areas.

Imminent construction of the Nyamat farm creates the need for 1000 tonnes of production elsewhere. This is the base for the stage 2 proposal to find appropriate land on Kangaroo Island to expand production.

The economic value added to the local economy in these scenarios are estimated as:

• Current – $4 .1m annually

• Stage 1 + tourism – $14.85m annually (includes current)

• Stage 2 – $35.4m annually (includes current, Stage 1 + tourism)

Any economic benefit projected by the proponent for the seaport in its draft EIS must be discounted by the unmeasured loss of tourist dollars and the projected loss of up to $ 35.4 million of potential input to the local economy, every year.


62

JOB CREATION CLAIMS DON’T STACK UP

The draft EIS estimates 45 construction jobs at the seaport, but apparently only 15 at a time. It suggests 160 jobs will be created for KI at the port and in forestry, but 140 of these will be filled by people from the mainland.

KIPT has explained in the past that KI residents don’t have the skills it needs and it will instead import these as it needs them as seasonal or project labour.

It’s also unclear as to how many jobs are full time, given the draft EIS reports the possibility of as few as 10 or as many as 20 vessels using the port annually.

JOB LOSSES NOT FACTORED

The draft EIS builds an assumption that KIPT’s proposal will somehow benefit Yumbah. The reality is the opposite.

In simple terms, the first sediment plume generated by KIPT’s unmanaged dredging program – barely detailed in the draft EIS – that enters Yumbah’s intake pipes marks the end of Yumbah KI. With it go more than 25 direct and seven associated FTE jobs, and a local economic contribution of more than $4 million annually.

Gone also is a long-term growth plan (shelved by the appearance of KIPT’s Smith Bay proposal), that would see Yumbah driving an 8.9% increase on all current FTE jobs in the Kangaroo Island local economy. These FTEs are KI resident workers – on the Island, year-round.

SAY IT AGAIN: THERE ARE OTHER, BETTER SITES

The arguments have been presented elsewhere and by others, including Kangaroo Island Shire Council, for a more sensible relocation of this project to a more appropriate site.

There are many alternative sites, all dismissed summarily by the draft EIS.

To direct KIPT elsewhere on KI will allow the Island to benefit from the substantial growth trajectory of Yumbah and aquaculture generally. At the same time, it will facilitate the removal of plantations that have blighted Kangaroo Island and stalled its economic performance for more than 20 years.

ALTERNATIVE ASSESSMENT: NET ECONOMIC EFFECT

To contrast the economic claims of the draft EIS, Yumbah engaged Dench McLean Carlson to complete an econometric analysis of Yumbah’s current economic contribution to KI, and the greater contribution that would accompany Yumbah’s stalled investment program.

This analysis is presented as Appendix 5.

This investment program includes significantly expanded abalone production and a Discovery Centre at Smith Bay. The Discovery Centre concept has been discussed with Ministers of both the current State Government and their predecessors. In simple terms, the Discovery Centre combines an aquaculture education facility, a global research base, and a high-end “cellar door” tourism model showcasing Yumbah product and the best of KI’s gourmet food and high-end fibre producers.



65

GUIDELINE 5:

AIR QUALITY

DESCRIPTION:

It is expected that air pollution (in particular dust) will occur during the construction phase as a result of the use of earthmoving equipment and the physical construction of the port infrastructure. Post construction, the movement of vehicles to and from the proposed site, stockpiling and ship loading operations onsite at Smith Bay will generate air pollution (in particular dust). There exists a sensitive receptor (aquaculture/abalone farm) immediately adjacent to the site that is critically sensitive to dust.

RESPONSE SUMMARY

The activity of woodchipping and stockpiled timber will distribute airborne dust and particulate matter across Yumbah Aquaculture’s KI abalone farm, presenting substantial risks for the farm.

The draft EIS presentation and interpretation of available data is unreliable and patchy. The obvious omission of critical data and interpretation is of concern for Yumbah and raises doubt about the validity of the air quality assessment in the draft EIS.

• The opinion in the draft EIS is quite firm, that air quality will not be affected by the proposal, if the following control measures are in place:

o unpaved roads watered during construction and operation

o cleared areas watered during construction and land clearing activities

o woodchip ship loading conveyor covered

o vehicle speeds within the site limited to 15km/h

The draft EIS gives no indication as to who will monitor control measures and oversee compliance and enforcement; where the required immense quantities of water required for air quality mitigation will come from; who will pay for the water; and how associated impacts of this water use will be managed

• Abalone are extremely sensitive to environmental conditions and any change to the equilibrium established at Yumbah KI can be catastrophic for its operations and viability

• Dust from trucks, timber and woodchip storage, plus unpaved site pans will be a significant issue for the abalone farm. Dust will settle on the farm’s permeable shade cloth roofing changing carefully calibrated light filtration and during rain events will be washed directly into grow out tanks

• There is no discussion in the draft EIS about the particle size of dust or the chemical composition of the dust. Fine airborne dust will compromise health and productivity of abalone


64


• An expected annual average contribution to Kangaroo Island’s GRP over the first five years of $41.7 million each year, of which $34.9 million is direct investment and $6.8 million is from flow-on effects.26

These dollar figures don’t include the negative effect of losing Yumbah, one of KI’s largest employers

• A boost in Kangaroo Island’s GRP of around 16 per cent.27

Again, doesn’t include losses suffered from Yumbah’s demise or lost tourism revenue

• More than 230 new full-time jobs would be created on the Island; 160 at the port and in forest operations (e.g. harvesting, haulage, forest management etc.) and a further 70 jobs would be created from the flow-on benefits associated with this new activity.28

160 jobs ‘at the port and in forest operations’ to service 10 ships a year? Most of these jobs are relatively low-paid seasonal timber workers contracted through labour hire

26 EIS Executive Summary p60 27 EIS Executive Summary p60 28 EIS Executive Summary p i 29 EIS Executive Summary p66

• There are unlikely to be sufficient skilled workers on Kangaroo Island to fill the new positions. Consequently, at least 60 per cent of the workers (140 FTE jobs) would be recruited from the mainland, increasing the Island's population by an estimated 330.29

140 jobs to go to people not from or on KI. Not exactly a positive employment outcome for KI



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GUIDELINE 5:

AIR QUALITY

DESCRIPTION:

It is expected that air pollution (in particular dust) will occur during the construction phase as a result of the use of earthmoving equipment and the physical construction of the port infrastructure. Post construction, the movement of vehicles to and from the proposed site, stockpiling and ship loading operations onsite at Smith Bay will generate air pollution (in particular dust). There exists a sensitive receptor (aquaculture/abalone farm) immediately adjacent to the site that is critically sensitive to dust.

RESPONSE SUMMARY

The activity of woodchipping and stockpiled timber will distribute airborne dust and particulate matter across Yumbah Aquaculture’s KI abalone farm, presenting substantial risks for the farm.

The draft EIS presentation and interpretation of available data is unreliable and patchy. The obvious omission of critical data and interpretation is of concern for Yumbah and raises doubt about the validity of the air quality assessment in the draft EIS.

• The opinion in the draft EIS is quite firm, that air quality will not be affected by the proposal, if the following control measures are in place:

o unpaved roads watered during construction and operation

o cleared areas watered during construction and land clearing activities

o woodchip ship loading conveyor covered

o vehicle speeds within the site limited to 15km/h

The draft EIS gives no indication as to who will monitor control measures and oversee compliance and enforcement; where the required immense quantities of water required for air quality mitigation will come from; who will pay for the water; and how associated impacts of this water use will be managed

• Abalone are extremely sensitive to environmental conditions and any change to the equilibrium established at Yumbah KI can be catastrophic for its operations and viability

• Dust from trucks, timber and woodchip storage, plus unpaved site pans will be a significant issue for the abalone farm. Dust will settle on the farm’s permeable shade cloth roofing changing carefully calibrated light filtration and during rain events will be washed directly into grow out tanks

• There is no discussion in the draft EIS about the particle size of dust or the chemical composition of the dust. Fine airborne dust will compromise health and productivity of abalone


64


• An expected annual average contribution to Kangaroo Island’s GRP over the first five years of $41.7 million each year, of which $34.9 million is direct investment and $6.8 million is from flow-on effects.26

These dollar figures don’t include the negative effect of losing Yumbah, one of KI’s largest employers

• A boost in Kangaroo Island’s GRP of around 16 per cent.27

Again, doesn’t include losses suffered from Yumbah’s demise or lost tourism revenue

• More than 230 new full-time jobs would be created on the Island; 160 at the port and in forest operations (e.g. harvesting, haulage, forest management etc.) and a further 70 jobs would be created from the flow-on benefits associated with this new activity.28

160 jobs ‘at the port and in forest operations’ to service 10 ships a year? Most of these jobs are relatively low-paid seasonal timber workers contracted through labour hire

26 EIS Executive Summary p60 27 EIS Executive Summary p60 28 EIS Executive Summary p i 29 EIS Executive Summary p66


140 jobs to go to people not from or on KI. Not exactly a positive employment outcome for KI



67

the deposition modelling assumes a particle density that needs to be different from the other sources. This is not discussed and should be re-modelled correctly.

• Both assumptions have the potential to cause inaccurate predictions.

• There are differences in measurement method (wind) and exposure (temperature and rain) at the two sites used to model air quality, raising questions about the reliance on meteorological inland data as representative of the coastal location at Smith Bay.

The draft EIS refers to wind-blown dust currently being deposited “onto the shade cloth which covers the existing raceway and nursery tank systems” (Main report page 222). How this information is gained is not known; suffice to say it cannot be substantiated.

The draft EIS also recognises that dust may fall into raceways and mix with seawater to potentially contaminate water with already increased sediment loads.

Due to the paucity of substantive information proffered by KIPT to support its position in this draft EIS, the resulting air quality impact from the seaport to Yumbah KI cannot be substantiated. The data is poor, inconsistent and lacks accurate interpretation.

• There is no reference, discussion or consideration of prevailing winds at Kangaroo Island and Smith Bay.

• There is a discussion that afternoon winds are stronger than morning which might be considered a universal truth

• There is no description of the prevailing winds for direction or speed at all hours and all seasons

The closest analysis in the reporting is the contour plots for annual total dust deposition (figure 17-11d (EIS, p.395). This indicates the greatest proportion of wind going to the north-north-west (NNW) with a “secondary lobe” to the east-south-east (ESE), directly from KIPT’s proposed woodchip piles and log stacks across the abalone farm boundary.

The results of the TAPM modelling are not available to confirm the validity of the data.

Doubt is compounded as it appears the annualised analysis of woodchip dust has been modelled incorrectly as soil.

The lack of discussion and accurate consideration of prevailing winds, and the influences of climate and seasons has not been discussed in the draft EIS. The assumed predominant winds are the most problematic for Yumbah KI as the timber will be located directly upwind of prevailing winds.

WOODCHIP OMISSIONS

A range of assumptions around woodchip emission factors (including the – incorrect - particle size distribution being similar to crustal soil and fibrous material), an investigation of particulate matter fallout across port boundaries is considered more accurate than the modelling approach in the draft EIS.

The draft EIS indicate that changes to air quality because of the proposed seaport are likely to be limited to minor increases in ground-level concentrations of dust (modelled as soil, not woodchips) and are


66

• It is impossible to control meteorological conditions and resulting airborne dust. Cumulative dust gathering on shade cloth is the biggest issue. If concentrations of accumulated dust became high and heavy rains occurred, events such as the mass mortality that occurred during an intense sediment plume from Smith Creek are likely

• The absence from this draft EIS of discussion and accurate consideration of prevailing winds, and the influences of climate and seasons, is stark. The predominant winds are most problematic for Yumbah KI with the seaport, unloading and log and woodchip storage piles are directly upwind of Yumbah’s abalone tanks

AIR QUALITY

Abalone farming is highly biologically sensitive and environmental stabilisation is critical to success.

Air quality results are presented in Appendix M of the draft EIS and interpretation of air quality modelling is in Section 17 of the main report. The impacts of change in air quality on human health, amenity and ecology have reportedly been assessed. The not surprising assumption of the draft EIS is that there will be no likely significant nearby impacts from the construction or operation of this seaport.

Yumbah engaged GHD to review the Air Quality impacts, inclusive of dust, claimed in the draft EIS.

This review is presented as a letter titled Smith Bay Aquaculture Assessment Review of Air Quality Impacts (Cook, 2019) in Appendix 6.

The findings indicate concerns with the modelled inputs and outputs:

• Appendix M purely presents the output data from the air quality modelling. The input data used for modelling is a big unknown

• Assessment against compliance with air quality standards and guidelines with potential effects of dust emissions on neighbours is primarily focused on impacts to human health and amenity, with little relevance to Yumbah KI

• The Air Pollution Model under-predicts wind speed

• Wind erosion emissions are considered overly conservative and do not adequately predict impact

• Emission factors for dust-generating activities and assumptions for both construction and operations are based on conservative assumptions and again do not adequately predict impact

• Modelling assumes unsealed dirt roads will be constantly dampened, which is clearly impossible

• Broad assumptions have been made for the handling of woodchips, which invites errors in the accuracy of any draft EIS claims

• Rigor has been applied to partition the data into size fractions - but these assume soil characteristics and not fibrous/cellulous material relevant for timber products

• Wind erosion from the woodchip stockpile has assumed the same default NPI emission factor as that used for mine-site overburden. Further,



67

the deposition modelling assumes a particle density that needs to be different from the other sources. This is not discussed and should be re-modelled correctly.

• Both assumptions have the potential to cause inaccurate predictions.

• There are differences in measurement method (wind) and exposure (temperature and rain) at the two sites used to model air quality, raising questions about the reliance on meteorological inland data as representative of the coastal location at Smith Bay.

The draft EIS refers to wind-blown dust currently being deposited “onto the shade cloth which covers the existing raceway and nursery tank systems” (Main report page 222). How this information is gained is not known; suffice to say it cannot be substantiated.

The draft EIS also recognises that dust may fall into raceways and mix with seawater to potentially contaminate water with already increased sediment loads.

Due to the paucity of substantive information proffered by KIPT to support its position in this draft EIS, the resulting air quality impact from the seaport to Yumbah KI cannot be substantiated. The data is poor, inconsistent and lacks accurate interpretation.

• There is no reference, discussion or consideration of prevailing winds at Kangaroo Island and Smith Bay.

• There is a discussion that afternoon winds are stronger than morning which might be considered a universal truth

• There is no description of the prevailing winds for direction or speed at all hours and all seasons

The closest analysis in the reporting is the contour plots for annual total dust deposition (figure 17-11d (EIS, p.395). This indicates the greatest proportion of wind going to the north-north-west (NNW) with a “secondary lobe” to the east-south-east (ESE), directly from KIPT’s proposed woodchip piles and log stacks across the abalone farm boundary.

The results of the TAPM modelling are not available to confirm the validity of the data.

Doubt is compounded as it appears the annualised analysis of woodchip dust has been modelled incorrectly as soil.

The lack of discussion and accurate consideration of prevailing winds, and the influences of climate and seasons has not been discussed in the draft EIS. The assumed predominant winds are the most problematic for Yumbah KI as the timber will be located directly upwind of prevailing winds.

WOODCHIP OMISSIONS

A range of assumptions around woodchip emission factors (including the – incorrect - particle size distribution being similar to crustal soil and fibrous material), an investigation of particulate matter fallout across port boundaries is considered more accurate than the modelling approach in the draft EIS.

The draft EIS indicate that changes to air quality because of the proposed seaport are likely to be limited to minor increases in ground-level concentrations of dust (modelled as soil, not woodchips) and are


66

• It is impossible to control meteorological conditions and resulting airborne dust. Cumulative dust gathering on shade cloth is the biggest issue. If concentrations of accumulated dust became high and heavy rains occurred, events such as the mass mortality that occurred during an intense sediment plume from Smith Creek are likely

• The absence from this draft EIS of discussion and accurate consideration of prevailing winds, and the influences of climate and seasons, is stark. The predominant winds are most problematic for Yumbah KI with the seaport, unloading and log and woodchip storage piles are directly upwind of Yumbah’s abalone tanks

AIR QUALITY

Abalone farming is highly biologically sensitive and environmental stabilisation is critical to success.

Air quality results are presented in Appendix M of the draft EIS and interpretation of air quality modelling is in Section 17 of the main report. The impacts of change in air quality on human health, amenity and ecology have reportedly been assessed. The not surprising assumption of the draft EIS is that there will be no likely significant nearby impacts from the construction or operation of this seaport.

Yumbah engaged GHD to review the Air Quality impacts, inclusive of dust, claimed in the draft EIS.

This review is presented as a letter titled Smith Bay Aquaculture Assessment Review of Air Quality Impacts (Cook, 2019) in Appendix 6.

The findings indicate concerns with the modelled inputs and outputs:

• Appendix M purely presents the output data from the air quality modelling. The input data used for modelling is a big unknown

• Assessment against compliance with air quality standards and guidelines with potential effects of dust emissions on neighbours is primarily focused on impacts to human health and amenity, with little relevance to Yumbah KI

• The Air Pollution Model under-predicts wind speed

• Wind erosion emissions are considered overly conservative and do not adequately predict impact

• Emission factors for dust-generating activities and assumptions for both construction and operations are based on conservative assumptions and again do not adequately predict impact

• Modelling assumes unsealed dirt roads will be constantly dampened, which is clearly impossible

• Broad assumptions have been made for the handling of woodchips, which invites errors in the accuracy of any draft EIS claims

• Rigor has been applied to partition the data into size fractions - but these assume soil characteristics and not fibrous/cellulous material relevant for timber products

• Wind erosion from the woodchip stockpile has assumed the same default NPI emission factor as that used for mine-site overburden. Further,



69

THIS IS WRONG, AND MISLEADING.

Dust accumulating on the shade cloth and a worst-case scenario if this dust is then washed into the farm during rain was considered. It was noted longer gaps between rain would create more intense dust deposits.

As evidenced elsewhere in this Yumbah response document, the assumptions about abalone husbandry presented in the draft EIS are generally ill-informed and are not provided from either a position of well-informed knowledge or robust scientific analysis. They are, at best, opinion favourable to the proponent.

The physiology and behaviour of abalone are intimately known to Yumbah. Abalone remain in Yumbah’s farming system for three years and the cumulative impact of such dust accumulation to stock could be catastrophic.

As such, the conclusion in the draft EIS (Main Report, p223) that the “small increase” in the rate of dust deposition on the Yumbah facility because of the proposed development would have only a “very marginal effect” on the farm’s water quality, and would have no effect on the health of abalone, cannot meet the test required of a valid Environmental Impact Statement.

30 EIS Executive Summary p38 31 EIS Executive Summary p39


• Modelling assumed that the following control measures were in place30:

o Unpaved roads were watered during construction and operation

o Cleared areas were watered during construction/land clearing activities

o The woodchip ship loading conveyor was covered

o Vehicle speeds within the site were limited to 15km/h.

There is no place for assumption under the requirements the South Australian Government has placed on the proponent

• The following mitigation methods may be implemented.31

A draft EIS built on assumptions that strict control measures will be in place with no reference to who will implement them, who will pay for them and who will maintain them.


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confined to within one to two kilometres of the operations.

The nature of impact across one to two kilometres is not “confined”.

The draft EIS does not consider the sensitive receptors across this wide radius of impact.

The bioassays using woodchip dust performed by Stringer (2018c) do not provide any indication of ecotoxicity of woodchip dust and cannot be relied on to indicate acute or chronic impacts of airborne dust on abalone.

Further consideration of biological impacts from dust to farmed abalone is required.

DUST DURING CONSTRUCTION

The risk of airborne dust during construction and operation to air quality on human health and the sensitive biological system of farming abalone cannot be underestimated.

• The proximity of the abalone farm to the primary dust source places it at severe risk

• The risks to the farm will be exacerbated during summer when cumulative environmental impacts from the dredging and increased sediment loads are forecast, and following construction when wrack (seagrass and macroalgae) will accumulate, temperatures will be elevated and water will be poorly circulated

• These combined risks are unacceptable to Yumbah KI

The draft EIS says (Main report page 222) that the increase in airborne dust will be inconsequential in the abalone tanks when

compared to the reported tolerance of abalone species (25mg/L).

As discussed substantively in Yumbah’s response to Guideline 2 (Coast and Marine) the revised TSS figure of 25mg/L has been invented by the proponent and contrary to the National Water Quality Guidelines (ANZECC/ARMCANZ (2000)).



69

THIS IS WRONG, AND MISLEADING.

Dust accumulating on the shade cloth and a worst-case scenario if this dust is then washed into the farm during rain was considered. It was noted longer gaps between rain would create more intense dust deposits.

As evidenced elsewhere in this Yumbah response document, the assumptions about abalone husbandry presented in the draft EIS are generally ill-informed and are not provided from either a position of well-informed knowledge or robust scientific analysis. They are, at best, opinion favourable to the proponent.

The physiology and behaviour of abalone are intimately known to Yumbah. Abalone remain in Yumbah’s farming system for three years and the cumulative impact of such dust accumulation to stock could be catastrophic.

As such, the conclusion in the draft EIS (Main Report, p223) that the “small increase” in the rate of dust deposition on the Yumbah facility because of the proposed development would have only a “very marginal effect” on the farm’s water quality, and would have no effect on the health of abalone, cannot meet the test required of a valid Environmental Impact Statement.



• Modelling assumed that the following control measures were in place30:

o Unpaved roads were watered during construction and operation

o Cleared areas were watered during construction/land clearing activities

o The woodchip ship loading conveyor was covered

o Vehicle speeds within the site were limited to 15km/h.

There is no place for assumption under the requirements the South Australian Government has placed on the proponent

• The following mitigation methods may be implemented.31

A draft EIS built on assumptions that strict control measures will be in place with no reference to who will implement them, who will pay for them and who will maintain them.


68

confined to within one to two kilometres of the operations.

The nature of impact across one to two kilometres is not “confined”.

The draft EIS does not consider the sensitive receptors across this wide radius of impact.

The bioassays using woodchip dust performed by Stringer (2018c) do not provide any indication of ecotoxicity of woodchip dust and cannot be relied on to indicate acute or chronic impacts of airborne dust on abalone.

Further consideration of biological impacts from dust to farmed abalone is required.

DUST DURING CONSTRUCTION

The risk of airborne dust during construction and operation to air quality on human health and the sensitive biological system of farming abalone cannot be underestimated.

• The proximity of the abalone farm to the primary dust source places it at severe risk

• The risks to the farm will be exacerbated during summer when cumulative environmental impacts from the dredging and increased sediment loads are forecast, and following construction when wrack (seagrass and macroalgae) will accumulate, temperatures will be elevated and water will be poorly circulated

• These combined risks are unacceptable to Yumbah KI

The draft EIS says (Main report page 222) that the increase in airborne dust will be inconsequential in the abalone tanks when

compared to the reported tolerance of abalone species (25mg/L).

As discussed substantively in Yumbah’s response to Guideline 2 (Coast and Marine) the revised TSS figure of 25mg/L has been invented by the proponent and contrary to the National Water Quality Guidelines (ANZECC/ARMCANZ (2000)).



71

and community), and the estimated capital and operating costs (economic).”32

KIPT says it conducted desktop assessments using Google Earth Pro to arrive at these evaluations. Yumbah has significant concerns that none of the 12 sites was physically assessed with a studious review to verify the desktop findings.

The selection of Smith Bay appears to be based on KIPT’s economic factors and financial return, with the social and environmental impacts assessed with minimal weight.

In its draft EIS, KIPT states:

“Smith Bay was considered to have a number of advantages that make it the best site on Kangaroo Island for a deep-water port. It is the closest practicable sheltered north coast site to the timber resource that is suitable for deep-draft ocean-going vessels to transport timber products directly to Asian markets.”33

KIPT means Smith Bay is ‘the cheapest’ location rather than “the most appropriate”.

The draft EIS notes alternative sites were capable of exporting woodchips but not logs. It stated:

“… the inability to export logs would represent a material loss of value and income for KIPT and leave the independent growers w ho have 100 per cent pine facing financial hardship.”34

32 EIS Executive Summary p17 33 EIS Executive Summary p17 34 EIS Executive Summary p17

KIPT wouldn’t want to bestow financial hardship on the good people of KI, yet it doesn’t hesitate to dismiss a successful aquaculture business of long-standing corporate, social and sustainable credentials, which has stalled significant growth plans due to KIPT’s intent.

KIPT mapped the following locations:

• American River

• Ballast Head (owned by KIPT and established in the past as an export facility)

• Cape Dutton

• De Mole River

• Kangaroo Head

• Kingscote

• Penneshaw

• Point Morrison

• Smith Bay

• Snug Cove

• Vivonne Bay

• Western River Cove

It must be noted that two additional suitable locations were not assessed, Point Marsden and D’estrees Bay.

KIPT’s assessment was conducted using Google Earth Pro, no actual site inspection was performed. This has resulted in a failure to properly assess the most appropriate locations at each site (see further detail below about the alternative sites that question the validity and


70

GUIDELINE 6:

ALTERNATIVE LOCATION:

DESCRIPTION:

To enable a thorough assessment, and a comparative basis of the suitability of the location of the proposal, information should be included on alternative locations that have been considered for the development. This information should include investigations that have been undertaken and reasoning behind why the proponent has deemed them less suitable than the proposed location.

RESPONSE SUMMARY

KIPT is absolutely dogmatic about its choice of Smith Bay. It discounts at least four other locations that could be used to transport timber from Kangaroo Island by sea. It is only at Smith Bay that KIPT will undertake industrial-level environmental destruction, destroy adjacent businesses and create Island-wide environmental and safety threats. Why Smith Bay? Because KIPT says it is the “most practicable”, cheapest option – which comes at the highest cost for KI and its people.

• KIPT identified 12 sites, and shortlisted four sites with a desktop assessment. None of the 12 sites were physically assessed. Rather, the company used Google to discount every other option, including one existing export wharf site it already owns.

• In its draft EIS for a Smith Bay seaport, KIPT states:

“The construction and operation of the facility, with appropriate management measures, would have no negative effects on the land-based abalone farm …”

• The basis of KIPT’s absolute “no negative impact” claim is fundamentally flawed.

• There are at least three other sites on KI that would allow for the removal of timber from the island, and allow Yumbah to continue operating. These must be more comprehensively addressed.

ALTERNATIVE LOCATIONS

The draft EIS states:

“Initially, 16 different options at 12 potential locations and sites were evaluated to determine their suitability for use as a deep-water export facility. A shortlist of four options was chosen for more detailed evaluation … in terms of distance to deep water from shore, the topography of the coastal environment, the ability to establish a multi-user, multi-cargo operation (physical), the impact on sensitive receptors (environmental), potential impacts on neighbours (social



71

and community), and the estimated capital and operating costs (economic).”32

KIPT says it conducted desktop assessments using Google Earth Pro to arrive at these evaluations. Yumbah has significant concerns that none of the 12 sites was physically assessed with a studious review to verify the desktop findings.

The selection of Smith Bay appears to be based on KIPT’s economic factors and financial return, with the social and environmental impacts assessed with minimal weight.

In its draft EIS, KIPT states:

“Smith Bay was considered to have a number of advantages that make it the best site on Kangaroo Island for a deep-water port. It is the closest practicable sheltered north coast site to the timber resource that is suitable for deep-draft ocean-going vessels to transport timber products directly to Asian markets.”33

KIPT means Smith Bay is ‘the cheapest’ location rather than “the most appropriate”.

The draft EIS notes alternative sites were capable of exporting woodchips but not logs. It stated:

“… the inability to export logs would represent a material loss of value and income for KIPT and leave the independent growers w ho have 100 per cent pine facing financial hardship.”34


KIPT wouldn’t want to bestow financial hardship on the good people of KI, yet it doesn’t hesitate to dismiss a successful aquaculture business of long-standing corporate, social and sustainable credentials, which has stalled significant growth plans due to KIPT’s intent.

KIPT mapped the following locations:

• American River

• Ballast Head (owned by KIPT and established in the past as an export facility)

• Cape Dutton

• De Mole River

• Kangaroo Head

• Kingscote

• Penneshaw

• Point Morrison

• Smith Bay

• Snug Cove

• Vivonne Bay

• Western River Cove

It must be noted that two additional suitable locations were not assessed, Point Marsden and D’estrees Bay.

KIPT’s assessment was conducted using Google Earth Pro, no actual site inspection was performed. This has resulted in a failure to properly assess the most appropriate locations at each site (see further detail below about the alternative sites that question the validity and


70

GUIDELINE 6:

ALTERNATIVE LOCATION:

DESCRIPTION:

To enable a thorough assessment, and a comparative basis of the suitability of the location of the proposal, information should be included on alternative locations that have been considered for the development. This information should include investigations that have been undertaken and reasoning behind why the proponent has deemed them less suitable than the proposed location.

RESPONSE SUMMARY

KIPT is absolutely dogmatic about its choice of Smith Bay. It discounts at least four other locations that could be used to transport timber from Kangaroo Island by sea. It is only at Smith Bay that KIPT will undertake industrial-level environmental destruction, destroy adjacent businesses and create Island-wide environmental and safety threats. Why Smith Bay? Because KIPT says it is the “most practicable”, cheapest option – which comes at the highest cost for KI and its people.

• KIPT identified 12 sites, and shortlisted four sites with a desktop assessment. None of the 12 sites were physically assessed. Rather, the company used Google to discount every other option, including one existing export wharf site it already owns.

• In its draft EIS for a Smith Bay seaport, KIPT states:


• The basis of KIPT’s absolute “no negative impact” claim is fundamentally flawed.

• There are at least three other sites on KI that would allow for the removal of timber from the island, and allow Yumbah to continue operating. These must be more comprehensively addressed.



“Initially, 16 different options at 12 potential locations and sites were evaluated to determine their suitability for use as a deep-water export facility. A shortlist of four options was chosen for more detailed evaluation … in terms of distance to deep water from shore, the topography of the coastal environment, the ability to establish a multi-user, multi-cargo operation (physical), the impact on sensitive receptors (environmental), potential impacts on neighbours (social



73

• This location also provides KIPT with the option to move the development just 100m to the north, which would allow for a multi-user facility with a significantly reduced coastline gradient.

• Despite KIPT’s claims, the nearest private vessel mooring is located 3km away.

• KIPT uses the oyster lease/s just south of this site is an argument against this location, however the oyster leases are located 2km south of Ballast Head.

• The draft EIS also mentions residential development (American River) located south-west from the site. However, this township is 3km from Ballast Head with no direct line of sight.

Cape Dutton

Draft EIS Summary:

• The coastline is banded by a strip of vegetation, with agricultural land directly behind it (Figure 1, Appendix C).

• Consists of very steep cliffs, dropping from a height of almost 75 m down to the water's surface in just over 250m with a maximum slope of -36.3 per cent (Figure 3, Appendix C).

• Marine vegetation and rock exists close to shore, before dropping to a 20m depth (Figure 4, Appendix C).

• On a regional scale, the coastline vegetation is somewhat interconnected with other areas of vegetation but surrounded by agricultural lands (Figure 2, Appendix C).

• A significant decline to the water's surface exists, with a maximum slope of -36.3% and elevation loss of 75m just over 350m.

• Majority of the coastline in this area is steeply sloping to the ocean floor, as shown in Figure 5 and Figure 6 (Appendix C).

• Depth data shows that the coast is lined with marine vegetation and rocky outcroppings, followed by a drop to a 20m depth.

A more thorough overview of the site would reveal:

• A site inspection of Cape Dutton shows a clear path to the most suitable location, with a land elevation of only 10m from the shore in the valley.

• The location is close to KIPT’s plantations and would be ideal for conveyor or jetty construction due to the deep-water close to shore – with no dredging required.

• Cape Dutton offers a very large area for the development and is located adjacent to a DPTI approved and Council operated quarry which would provide cost savings for KIPT’s construction.

• There is minimal tourism interaction on the roads around Cape Dutton, with no township in direct line of sight.


72

accuracy of KIPT’s desktop assessment). With the application of local knowledge and physical site evaluations, the viability of the alternative sites dramatically changes.

The responses below question KIPT’s assumptions, highlight considerations for other sites on Kangaroo Island and illustrate why Smith Bay is not the best location for the seaport.

ALTERNATIVE LOCATIONS ASSESSMENT

Ballast Head Draft EIS Summary:

• Location of an old gypsum export facility.

• Historic clearing (still visible).

• Vegetation abuts the site.

• Cleared (potentially agricultural) land and interconnected pockets of vegetation exists a distance away from the location.

• Private vessels moor within the protected waters south-west of the location (Figure 5, Appendix B).

• Cross-section shows a steep decline from the top of the site, with a max slope of -28 per cent and an elevation loss of 69m (Figure 3, Appendix B).

• Nearby oyster lease/s can be seen in shallow (3.6m) waters just south of Ballast Head (Figure 4, Appendix B).

35 https://www.businesskangarooisland.com.au/single-post/2015/11/03/Forestry-Industry-New-Forests 36 https://www.asx.com.au/asxpdf/20161021/pdf/43c5jpszc79w9w.pdf

• Significant amount of residential development (American River) exists to the south-west in the region, (Figure 5, Appendix B).


• KIPT currently own the Ballast Head site

• Ballast Head is an existing deep-water port, close to shore, which is ideally suited for woodchip export due to the easy access to a ship loading conveyer.

• New Forests, after ranking eight options, selected Ballast Head as its preferred wharf proposal site35. Their Forestry Investment trust estate (now owned by KIPT) comprised of 10,700 acres of hardwood and 8,300 acres of softwood36. Clearly New Forests had a compelling business case sustaining both log and woodchip export from Ballast Head.

• As the site was used by bulk carriers from the mid ‘50s until 1986, the site is already contaminated with exotic marine pests, and therefore KIPT’s development doesn’t pose a significant biosecurity risk.

• This is the most sheltered deep-water location on Kangaroo Island, and has been earmarked as a port on the DPTI development plan for KI since the 1940s.



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• This location also provides KIPT with the option to move the development just 100m to the north, which would allow for a multi-user facility with a significantly reduced coastline gradient.

• Despite KIPT’s claims, the nearest private vessel mooring is located 3km away.

• KIPT uses the oyster lease/s just south of this site is an argument against this location, however the oyster leases are located 2km south of Ballast Head.

• The draft EIS also mentions residential development (American River) located south-west from the site. However, this township is 3km from Ballast Head with no direct line of sight.

Cape Dutton

Draft EIS Summary:

• The coastline is banded by a strip of vegetation, with agricultural land directly behind it (Figure 1, Appendix C).

• Consists of very steep cliffs, dropping from a height of almost 75 m down to the water's surface in just over 250m with a maximum slope of -36.3 per cent (Figure 3, Appendix C).

• Marine vegetation and rock exists close to shore, before dropping to a 20m depth (Figure 4, Appendix C).

• On a regional scale, the coastline vegetation is somewhat interconnected with other areas of vegetation but surrounded by agricultural lands (Figure 2, Appendix C).

• A significant decline to the water's surface exists, with a maximum slope of -36.3% and elevation loss of 75m just over 350m.

• Majority of the coastline in this area is steeply sloping to the ocean floor, as shown in Figure 5 and Figure 6 (Appendix C).

• Depth data shows that the coast is lined with marine vegetation and rocky outcroppings, followed by a drop to a 20m depth.


• A site inspection of Cape Dutton shows a clear path to the most suitable location, with a land elevation of only 10m from the shore in the valley.

• The location is close to KIPT’s plantations and would be ideal for conveyor or jetty construction due to the deep-water close to shore – with no dredging required.

• Cape Dutton offers a very large area for the development and is located adjacent to a DPTI approved and Council operated quarry which would provide cost savings for KIPT’s construction.

• There is minimal tourism interaction on the roads around Cape Dutton, with no township in direct line of sight.


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accuracy of KIPT’s desktop assessment). With the application of local knowledge and physical site evaluations, the viability of the alternative sites dramatically changes.

The responses below question KIPT’s assumptions, highlight considerations for other sites on Kangaroo Island and illustrate why Smith Bay is not the best location for the seaport.

ALTERNATIVE LOCATIONS ASSESSMENT

Ballast Head Draft EIS Summary:

• Location of an old gypsum export facility.

• Historic clearing (still visible).

• Vegetation abuts the site.

• Cleared (potentially agricultural) land and interconnected pockets of vegetation exists a distance away from the location.

• Private vessels moor within the protected waters south-west of the location (Figure 5, Appendix B).

• Cross-section shows a steep decline from the top of the site, with a max slope of -28 per cent and an elevation loss of 69m (Figure 3, Appendix B).

• Nearby oyster lease/s can be seen in shallow (3.6m) waters just south of Ballast Head (Figure 4, Appendix B).

35 https://www.businesskangarooisland.com.au/single-post/2015/11/03/Forestry-Industry-New-Forests 36 https://www.asx.com.au/asxpdf/20161021/pdf/43c5jpszc79w9w.pdf

• Significant amount of residential development (American River) exists to the south-west in the region, (Figure 5, Appendix B).


• KIPT currently own the Ballast Head site

• Ballast Head is an existing deep-water port, close to shore, which is ideally suited for woodchip export due to the easy access to a ship loading conveyer.

• New Forests, after ranking eight options, selected Ballast Head as its preferred wharf proposal site35. Their Forestry Investment trust estate (now owned by KIPT) comprised of 10,700 acres of hardwood and 8,300 acres of softwood36. Clearly New Forests had a compelling business case sustaining both log and woodchip export from Ballast Head.

• As the site was used by bulk carriers from the mid ‘50s until 1986, the site is already contaminated with exotic marine pests, and therefore KIPT’s development doesn’t pose a significant biosecurity risk.

• This is the most sheltered deep-water location on Kangaroo Island, and has been earmarked as a port on the DPTI development plan for KI since the 1940s.



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• A development at Vivonne Bay could utilise the existing jetty located just south of the assessed area, which was once used to service the defence force in deep-water. The jetty could be extended to its original length out to deep-water which would remove the need for any dredging.

• This location would be the closest to KIPT’s plantations, and the infrastructure could also be utilised by the local fishing fleet.

• Vivonne Bay is the most utilised location on Kangaroo Island for its local fishing industry, and would be ideal for other users including cruise ships – due to its proximity to Kangaroo Island national parks.

KIPT’s draft EIS also conducted assessments of American River, De Mole River, Kangaroo Head and Penneshaw. Yumbah Aquaculture agrees these sites are unsuitable for this development.

In its draft EIS for a Smith Bay seaport, KIPT states:


KIPT is less confident with the Ballast Head site option where the EIS states that compensation of the oyster leaseholder located 3km away may be necessary.

37 EIS Executive Summary p17

It begs the question why KIPT thinks it necessary to compensate oyster lease holders 3km from the seaport when it is happy to place a port within metres of an established land-based abalone farm.

ROAD COSTS

KIPT estimates “road upgrade costs” of $5 million to $7.5 million for any site (table 3-3 of the Project Alternatives) to be paid for by government. KIPT states it requires a contribution from government of $22.5 - $27 million to make the other options “viable” as compared to $5 million needed for Smith Bay. However, there is no explanation or substance supplied to back up these estimates.

Cape Dutton, for example, has deep water close to shore which would alleviate dredging costs and a DPTI-controlled quarry which could reduce construction costs. This site already manages industrial elements including dust, noise and other intrusions currently not present at Smith Bay. An independent detailed costing should be supplied.

OTHER ERRORS AND OMISSIONS

• The site at Smith Bay is also cleared and degraded, and there are no material conflicts with tourism or marine parks.37

This is categorically untrue, with tourism ventures such as KI Marine Adventures and Molly’s Run clearly conflicted by this proposal.


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Kingscote

Draft EIS Summary:

• Significant residential and commercial development and a jetty and associated infrastructure exists (Figure 1, Appendix F)

• Slightly sloping with a total elevation loss of 29m and a maximum slope of -6.6 per cent, that presents as a consistent decline from about 250m to the 1.1km point (Figure 3, Appendix F)

• On a regional scale, the location is at the end of a low headland on the southern side of Bay of Shoals, with a large sand bar providing protection from ocean swell and agricultural land extending a distance away from the coast (Figure Z, Appendix F)

• Public foreshore infrastructure such as walking tracks, ocean pool and parkland visible along the coastline.

Port Morrison

Draft EIS Summary:

• Cleared agricultural land with two visible residential dwellings (Figure 1, Appendix H) (Appendix B – Desktop visual assessment of locations 8).

• Surrounded by agricultural land, disconnected stand of vegetation (to the south-east) and vegetation can be seen adjacent to the coastline and throughout agricultural areas (Figure 2, Appendix H).

• Cross-sectional data shows a steady decline of 63m and a maximum slope of-11.5 per cent, from approximately 100 m through to the 1.04km point, where the water's surface is encountered (Figure 3, Appendix H).

• Coastal imagery confirms the slight decline to the water's edge, with depth data showing a gradual decline in water depth to the 9.9m mark and sand pockets marked close to the central location marker.


• This would the ideal location for land-based infrastructure and a multi-user port. The site offers access to deep-water close to land.

• Port Morrison is located away from existing aquatic industries, and is close to areas already contaminated with exotic marine pests.

Vivonne Bay

Draft EIS Summary:

• Highly vegetated coastal area with some residential development and a river entering the bay.

• Agricultural land beyond the vegetated coastline (Figure Z, Appendix K).

• Large naturally vegetated areas to both the east and west of the location.

• Cross-section information shows a total elevation loss of 21m with a maximum slope of-7.4 per cent, that shows small rises in elevation at three points (Figure 3, Appendix K).

• Depth data shows shallow marine vegetation, followed by almost immediate water depth of 9.5 m (Figure 4, Appendix K).



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• A development at Vivonne Bay could utilise the existing jetty located just south of the assessed area, which was once used to service the defence force in deep-water. The jetty could be extended to its original length out to deep-water which would remove the need for any dredging.

• This location would be the closest to KIPT’s plantations, and the infrastructure could also be utilised by the local fishing fleet.

• Vivonne Bay is the most utilised location on Kangaroo Island for its local fishing industry, and would be ideal for other users including cruise ships – due to its proximity to Kangaroo Island national parks.

KIPT’s draft EIS also conducted assessments of American River, De Mole River, Kangaroo Head and Penneshaw. Yumbah Aquaculture agrees these sites are unsuitable for this development.

In its draft EIS for a Smith Bay seaport, KIPT states:


KIPT is less confident with the Ballast Head site option where the EIS states that compensation of the oyster leaseholder located 3km away may be necessary.


It begs the question why KIPT thinks it necessary to compensate oyster lease holders 3km from the seaport when it is happy to place a port within metres of an established land-based abalone farm.

ROAD COSTS

KIPT estimates “road upgrade costs” of $5 million to $7.5 million for any site (table 3-3 of the Project Alternatives) to be paid for by government. KIPT states it requires a contribution from government of $22.5 - $27 million to make the other options “viable” as compared to $5 million needed for Smith Bay. However, there is no explanation or substance supplied to back up these estimates.

Cape Dutton, for example, has deep water close to shore which would alleviate dredging costs and a DPTI-controlled quarry which could reduce construction costs. This site already manages industrial elements including dust, noise and other intrusions currently not present at Smith Bay. An independent detailed costing should be supplied.


• The site at Smith Bay is also cleared and degraded, and there are no material conflicts with tourism or marine parks.37

This is categorically untrue, with tourism ventures such as KI Marine Adventures and Molly’s Run clearly conflicted by this proposal.


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Kingscote

Draft EIS Summary:

• Significant residential and commercial development and a jetty and associated infrastructure exists (Figure 1, Appendix F)

• Slightly sloping with a total elevation loss of 29m and a maximum slope of -6.6 per cent, that presents as a consistent decline from about 250m to the 1.1km point (Figure 3, Appendix F)

• On a regional scale, the location is at the end of a low headland on the southern side of Bay of Shoals, with a large sand bar providing protection from ocean swell and agricultural land extending a distance away from the coast (Figure Z, Appendix F)

• Public foreshore infrastructure such as walking tracks, ocean pool and parkland visible along the coastline.

Port Morrison

Draft EIS Summary:

• Cleared agricultural land with two visible residential dwellings (Figure 1, Appendix H) (Appendix B – Desktop visual assessment of locations 8).

• Surrounded by agricultural land, disconnected stand of vegetation (to the south-east) and vegetation can be seen adjacent to the coastline and throughout agricultural areas (Figure 2, Appendix H).

• Cross-sectional data shows a steady decline of 63m and a maximum slope of-11.5 per cent, from approximately 100 m through to the 1.04km point, where the water's surface is encountered (Figure 3, Appendix H).

• Coastal imagery confirms the slight decline to the water's edge, with depth data showing a gradual decline in water depth to the 9.9m mark and sand pockets marked close to the central location marker.


• This would the ideal location for land-based infrastructure and a multi-user port. The site offers access to deep-water close to land.

• Port Morrison is located away from existing aquatic industries, and is close to areas already contaminated with exotic marine pests.

Vivonne Bay

Draft EIS Summary:

• Highly vegetated coastal area with some residential development and a river entering the bay.

• Agricultural land beyond the vegetated coastline (Figure Z, Appendix K).

• Large naturally vegetated areas to both the east and west of the location.

• Cross-section information shows a total elevation loss of 21m with a maximum slope of-7.4 per cent, that shows small rises in elevation at three points (Figure 3, Appendix K).

• Depth data shows shallow marine vegetation, followed by almost immediate water depth of 9.5 m (Figure 4, Appendix K).



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On this alone, the proposal is in direct conflict with the natural attributes of the Coastal Conservation Zone of Smith Bay and is an industrial activity incompatible with existing land uses.

The wharf location is in front of a public road which has traditionally provided access to a rocky beach that the local community frequently accesses. Locals were promised a boat ramp and fishing wharf. These have been “descoped” 38 along with the promise of servicing cruise ships. As such, the infrastructure proposed in the seaport has no net benefit to the community.

38 KIPT Executive Summary p 11

The draft EIS talks of a “Marine Exclusion Zone” and diagrams of the seaport published to local media show security fences extending into the water making the traversal of the Smith Bay foreshore along the beach or by sea impossible.

Figure 6 – Early impressionist wharf image showing "descoped" public access


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GUIDELINE 7:

ALTERNATIVE STRUCTURES (IN WATER)

DESCRIPTION:

The proposal includes the construction of a solid causeway that will extend approximately 200m into the ocean for the purpose of loading the timber products onto the ships at the attached floating berth. A solid causeway, as proposed, is likely to inhibit the natural water flow within Smith Bay, and potentially lead to pooling of water upstream. The nature and level of impacts of the proposed causeway on the marine environment (including water temperature), and the ecosystems, recreational and commercial operations reliant upon the waters of Smith Bay, have not been detailed. Merits of alternative in-water structures (including a jetty) should be investigated to determine the most appropriate structure for the area and operation.

RESPONSE SUMMARY

• Minimising cost is the primary determinant driving KIPT to choose a solid causeway in Smith Bay

o Proponent summarily eliminates all other options

o Location and seaport fail to consider wider negative social, economic and environmental implications

o Proponent crafts a flawed catchment model to build a misleading case that a cheap solid causeway would be beneficial for Yumbah KI

o Acknowledges environmental impact could be reduced, but refuses to pay to do so

• Draft EIS does not consider revised proposal and circumstances

o Causeway in new design 50m longer than stipulated in DAC Guidelines

IMPACTS ON ECOSYSTEMS, RECREATIONAL AND COMMERCIAL OPERATIONS

KIPT’s EPBC referral of proposed action, dated July 2016, states:

”The Smith Bay site is within the Coastal Conservation Zone of the KIDP (Kangaroo Island Development Plan), which means that the proposed development is non-complying. Under this plan, non-complying developments are not prohibited per se, but must be considered on their merits.”



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On this alone, the proposal is in direct conflict with the natural attributes of the Coastal Conservation Zone of Smith Bay and is an industrial activity incompatible with existing land uses.

The wharf location is in front of a public road which has traditionally provided access to a rocky beach that the local community frequently accesses. Locals were promised a boat ramp and fishing wharf. These have been “descoped” 38 along with the promise of servicing cruise ships. As such, the infrastructure proposed in the seaport has no net benefit to the community.

38 KIPT Executive Summary p 11

The draft EIS talks of a “Marine Exclusion Zone” and diagrams of the seaport published to local media show security fences extending into the water making the traversal of the Smith Bay foreshore along the beach or by sea impossible.

Figure 6 – Early impressionist wharf image showing "descoped" public access


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GUIDELINE 7:

ALTERNATIVE STRUCTURES (IN WATER)

DESCRIPTION:

The proposal includes the construction of a solid causeway that will extend approximately 200m into the ocean for the purpose of loading the timber products onto the ships at the attached floating berth. A solid causeway, as proposed, is likely to inhibit the natural water flow within Smith Bay, and potentially lead to pooling of water upstream. The nature and level of impacts of the proposed causeway on the marine environment (including water temperature), and the ecosystems, recreational and commercial operations reliant upon the waters of Smith Bay, have not been detailed. Merits of alternative in-water structures (including a jetty) should be investigated to determine the most appropriate structure for the area and operation.

RESPONSE SUMMARY

• Minimising cost is the primary determinant driving KIPT to choose a solid causeway in Smith Bay

o Proponent summarily eliminates all other options

o Location and seaport fail to consider wider negative social, economic and environmental implications

o Proponent crafts a flawed catchment model to build a misleading case that a cheap solid causeway would be beneficial for Yumbah KI

o Acknowledges environmental impact could be reduced, but refuses to pay to do so

• Draft EIS does not consider revised proposal and circumstances

o Causeway in new design 50m longer than stipulated in DAC Guidelines

IMPACTS ON ECOSYSTEMS, RECREATIONAL AND COMMERCIAL OPERATIONS

KIPT’s EPBC referral of proposed action, dated July 2016, states:

”The Smith Bay site is within the Coastal Conservation Zone of the KIDP (Kangaroo Island Development Plan), which means that the proposed development is non-complying. Under this plan, non-complying developments are not prohibited per se, but must be considered on their merits.”



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The photo below depicts the magnitude of wrack accumulation at the Emu Bay boat ramp. This structure is minute and extends a few metres offshore. The solid causeway proposed by KIPT at Smith Bay will extend 250m offshore.

The significant risk of wrack accumulation on the quality of the source waters to Yumbah KI’s abalone farm is critically lacking and needs to be addressed as a priority, particularly given the close proximity of the proposed solid causeway to the inlet pipes.

Seagrass wrack accumulation has the potential to impact Yumbah KI’s intakes.

Coastal structure (e.g. groynes, causeways) often cause the accumulation of seagrass wrack and degradation of seawater quality that did not occur prior to their placement. The proximity of the causeway to the Yumbah KI facility’s intakes may cause wrack accumulation and water quality degradation of source water entering the abalone farm.

The report by Romero (2019) (Appendix 1) shows the draft EIS Appendix G is lacking the information to address the potential impacts of seagrass wrack on the abalone farm.

Figure 7 - Seagrass wrack at nearby Emu Bay


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WRACK ISSUES

The draft EIS reports that accumulated drift seagrass and macroalgae (wrack) will occur as a consequence of the construction of the causeway. This potential accumulation is absolutely unacceptable as it has the potential to significantly impact Yumbah KI’s intakes and abalone health.

Accumulation of drift seagrass and other macroalgae will clog intake pipes and degrade water quality. The extent of degradation and potential impacts on Yumbah KI and Smith Bay are lacking in the EIS, and Romero (2019) has highlighted the need for additional information, including:




• Amendments to the risk assessment. Though risk reference item 8 in Table 4-1 of EIS Appendix G identifies the hazard, modification to seagrass wrack accumulation, the basis for a consequence of ‘minor’ and likelihood of ‘possible’ is not supported. Further, mitigation measures only change the residual likelihood and not the residual consequence (note this comment also applies to reference item 6 in Table 4-1, and it is uncertain why changes in residual likelihoods to references 2 and 3 are included with no [nil] mitigation measures noted). The inherent and residual risk for seagrass wrack accumulation is not supported.

The draft EIS admits issues will be prevalent around the causeway “Drift seagrass and macroalgae (wrack) may sometimes accumulate against the causeway in response to prevailing winds and currents, but is likely to disperse naturally. The situation would be monitored and managed if and when required”. Where will it disperse if a big solid eyesore of a causeway is blocking its natural passage? Will it dissolve or disappear into thin air? What situation will be monitored and how will it be managed? How much wrack needs to accumulate before it becomes a problem for KIPT? Who will be responsible for the continuous cleaning of the beaches?



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The photo below depicts the magnitude of wrack accumulation at the Emu Bay boat ramp. This structure is minute and extends a few metres offshore. The solid causeway proposed by KIPT at Smith Bay will extend 250m offshore.

The significant risk of wrack accumulation on the quality of the source waters to Yumbah KI’s abalone farm is critically lacking and needs to be addressed as a priority, particularly given the close proximity of the proposed solid causeway to the inlet pipes.

Seagrass wrack accumulation has the potential to impact Yumbah KI’s intakes.

Coastal structure (e.g. groynes, causeways) often cause the accumulation of seagrass wrack and degradation of seawater quality that did not occur prior to their placement. The proximity of the causeway to the Yumbah KI facility’s intakes may cause wrack accumulation and water quality degradation of source water entering the abalone farm.

The report by Romero (2019) (Appendix 1) shows the draft EIS Appendix G is lacking the information to address the potential impacts of seagrass wrack on the abalone farm.

Figure 7 - Seagrass wrack at nearby Emu Bay


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WRACK ISSUES

The draft EIS reports that accumulated drift seagrass and macroalgae (wrack) will occur as a consequence of the construction of the causeway. This potential accumulation is absolutely unacceptable as it has the potential to significantly impact Yumbah KI’s intakes and abalone health.

Accumulation of drift seagrass and other macroalgae will clog intake pipes and degrade water quality. The extent of degradation and potential impacts on Yumbah KI and Smith Bay are lacking in the EIS, and Romero (2019) has highlighted the need for additional information, including:




• Amendments to the risk assessment. Though risk reference item 8 in Table 4-1 of EIS Appendix G identifies the hazard, modification to seagrass wrack accumulation, the basis for a consequence of ‘minor’ and likelihood of ‘possible’ is not supported. Further, mitigation measures only change the residual likelihood and not the residual consequence (note this comment also applies to reference item 6 in Table 4-1, and it is uncertain why changes in residual likelihoods to references 2 and 3 are included with no [nil] mitigation measures noted). The inherent and residual risk for seagrass wrack accumulation is not supported.

The draft EIS admits issues will be prevalent around the causeway “Drift seagrass and macroalgae (wrack) may sometimes accumulate against the causeway in response to prevailing winds and currents, but is likely to disperse naturally. The situation would be monitored and managed if and when required”. Where will it disperse if a big solid eyesore of a causeway is blocking its natural passage? Will it dissolve or disappear into thin air? What situation will be monitored and how will it be managed? How much wrack needs to accumulate before it becomes a problem for KIPT? Who will be responsible for the continuous cleaning of the beaches?



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FAR FROM BENEFICIAL

In Yumbah’s view it is misleading to claim the causeway will somehow benefit Yumbah KI as the draft EIS suggests.

KIPT purports the causeway will aid Yumbah KI by creating an impermeable wall, physically blocking Smith Creek’s flows to the west and isolating flows from the farm’s intake pipes.

Construction of the causeway is an escalated threat to Yumbah because it is an impermeable wall blocking oceanic currents, reducing mixing in the receiving environment and subsequently elevating water temperatures and reducing water quality.

Yumbah KI has been successfully operating at Smith Bay since 1995 with negligible impact from Smith Creek. One exception is a limited number of storms in 2016.

Romero (2019) (Appendix 1) reviewed the opinions in the draft EIS attempting to justify a solid causeway. It concluded the catchment model used in the draft EIS to predict the impacts of flood plumes from Smith Creek on the marine waters near Yumbah’s seawater intakes is flawed.

The suggested benefit to Yumbah KI, notably reducing water turbidity near the inlet pipes created by a very infrequent 1:10 storm39 at Smith Bay does not justify the causeway’s construction.

According to Romero (2019), the catchment modelling is designed to demonstrate how the causeway reduces suspended sediments created by flooding in Smith Creek. The simulated large

39 AEP states a storm that created this issues in 2016 are 1:10 and as such, extremely rare.

discharge and sediment loads are not verifiable.

The modelling of smaller storms is required to demonstrate accurately the frequency, magnitude and duration of any suggested benefit.

The repeated misuse of modelling data in the draft EIS discounts claims across the entire document.

CHEAPEST ISN’T BEST

The draft EIS presents findings from an evaluation of alternative structures (in-water).

The preference for the solid causeway combined with a suspended deck is described as:

“… the most cost-effective option for the causeway to approximately eight metre depth, after which a suspended deck in deeper water would be more cost-effective”.

The EIS Main report (page 43) discusses the evaluation of:

“… twelve possible combinations of approach structure (three alternatives) and berth face (four alternatives), and a wide range of approach lengths, giving rise to considerable variation in the resulting dredge volume. The main considerations in the evaluation were the anticipated environmental impact and the expected construction cost”.

It considers environmental and economic factors as relevant, yet ignores the existence of Yumbah’s abalone farm immediately adjacent.


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Yumbah’s response to Guideline 6 notes alternative locations for this infrastructure with a more positive outcome for community and reduced environmental impact.

Kangaroo Island Council, as the representative body of the KI community, agrees.

The alternative locations have a combination of existing and adaptable infrastructure including port facilities, safer road networks, proximity to KIPT’s plantations and greater linkages to workforce and community hubs.

By contrast, Smith Bay is remote, requires considerable and unfunded upgrades to roads and transport routes, and is within a Coastal Conservation Zone and Rural Living Zone.

THE EVER-CHANGING CAUSEWAY

The proposed in-water infrastructure involves construction of a 250m long solid causeway - not 200m as in the Guidelines. This increased length has not been accounted for in modelling and dredging tests.

The causeway is extended with a linkspan bridge to a floating pontoon for vessel mooring and timber loading. It is Yumbah’s view that this scale and intrusion is clearly at odds with the coastal landscape of Smith Bay.

The causeway will reduce ocean currents by an estimated 30-40 per cent, which, in turn, will elevate water temperatures, reduce mixing of oceanic water, accumulate drift seaweed (wrack) and compromise oceanic conditions.

These are all prerequisite and currently stable conditions for Yumbah KI’s ongoing operation.



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FAR FROM BENEFICIAL

In Yumbah’s view it is misleading to claim the causeway will somehow benefit Yumbah KI as the draft EIS suggests.

KIPT purports the causeway will aid Yumbah KI by creating an impermeable wall, physically blocking Smith Creek’s flows to the west and isolating flows from the farm’s intake pipes.

Construction of the causeway is an escalated threat to Yumbah because it is an impermeable wall blocking oceanic currents, reducing mixing in the receiving environment and subsequently elevating water temperatures and reducing water quality.

Yumbah KI has been successfully operating at Smith Bay since 1995 with negligible impact from Smith Creek. One exception is a limited number of storms in 2016.

Romero (2019) (Appendix 1) reviewed the opinions in the draft EIS attempting to justify a solid causeway. It concluded the catchment model used in the draft EIS to predict the impacts of flood plumes from Smith Creek on the marine waters near Yumbah’s seawater intakes is flawed.

The suggested benefit to Yumbah KI, notably reducing water turbidity near the inlet pipes created by a very infrequent 1:10 storm39 at Smith Bay does not justify the causeway’s construction.

According to Romero (2019), the catchment modelling is designed to demonstrate how the causeway reduces suspended sediments created by flooding in Smith Creek. The simulated large

39 AEP states a storm that created this issues in 2016 are 1:10 and as such, extremely rare.

discharge and sediment loads are not verifiable.

The modelling of smaller storms is required to demonstrate accurately the frequency, magnitude and duration of any suggested benefit.

The repeated misuse of modelling data in the draft EIS discounts claims across the entire document.

CHEAPEST ISN’T BEST

The draft EIS presents findings from an evaluation of alternative structures (in-water).

The preference for the solid causeway combined with a suspended deck is described as:

“… the most cost-effective option for the causeway to approximately eight metre depth, after which a suspended deck in deeper water would be more cost-effective”.

The EIS Main report (page 43) discusses the evaluation of:

“… twelve possible combinations of approach structure (three alternatives) and berth face (four alternatives), and a wide range of approach lengths, giving rise to considerable variation in the resulting dredge volume. The main considerations in the evaluation were the anticipated environmental impact and the expected construction cost”.

It considers environmental and economic factors as relevant, yet ignores the existence of Yumbah’s abalone farm immediately adjacent.


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Yumbah’s response to Guideline 6 notes alternative locations for this infrastructure with a more positive outcome for community and reduced environmental impact.

Kangaroo Island Council, as the representative body of the KI community, agrees.

The alternative locations have a combination of existing and adaptable infrastructure including port facilities, safer road networks, proximity to KIPT’s plantations and greater linkages to workforce and community hubs.

By contrast, Smith Bay is remote, requires considerable and unfunded upgrades to roads and transport routes, and is within a Coastal Conservation Zone and Rural Living Zone.

THE EVER-CHANGING CAUSEWAY

The proposed in-water infrastructure involves construction of a 250m long solid causeway - not 200m as in the Guidelines. This increased length has not been accounted for in modelling and dredging tests.

The causeway is extended with a linkspan bridge to a floating pontoon for vessel mooring and timber loading. It is Yumbah’s view that this scale and intrusion is clearly at odds with the coastal landscape of Smith Bay.

The causeway will reduce ocean currents by an estimated 30-40 per cent, which, in turn, will elevate water temperatures, reduce mixing of oceanic water, accumulate drift seaweed (wrack) and compromise oceanic conditions.

These are all prerequisite and currently stable conditions for Yumbah KI’s ongoing operation.



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GUIDELINE 8:

COMMUNITY

DESCRIPTION:

The proposal is likely to lead to a change in the Kangaroo Island population (short-term and long-term) both during the construction and operational phases of the proposed development. This will lead to a change in demand for various services, infrastructure and accommodation needs on the Island at various times.

RESPONSE SUMMARY

• Yumbah has been operating at Smith Bay since 1995

o 100 per cent Australian-owned and operated

o employs more than 100 full-time staff across regional Australia

o annual combined revenue of about $30 million

• Investment freeze on KI

o Smith Bay is an optimum site for onshore aquaculture

o threat of KIPT “seaport” has stalled investment, with other states set to benefit

• A good corporate citizen

o Yumbah has always employed more than 20 people on KI

o Develops staff skills and expertise o Supports local professionals and

tradespeople

o Advance aquaculture as a positive, sustainable export business for KI and the State

o Contribute to business and community development groups on KI

o Generous with financial and other support to sports and community interests

• KIPT’s proposed seaport

o A mortal threat to Yumbah KI

CLOSEST NEIGHBOUR

Yumbah KI’s abalone farm is the closest neighbour to the proposed KIPT seaport. It shares a fence with the site owned by KIPT, and the wharf is proposed at some 300m from Yumbah’s seawater intake pipes.

Each of Yumbah’s four farms is tailored for the environment in which it has been established and operates in accordance with respective licences and permits.

Smith Bay was selected for the quality of its water, appropriate tidal flow, the structure of Smith Bay’s sea floor, remoteness, freedom from marine pests and other threats to sensitive receptors like abalone, and a welcoming community.


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The draft EIS (page 44) states:

The most favoured structure (a combined approach with a causeway leading to a suspended deck jetty and floating pontoon) would also be the least expensive to construct and would have relatively low environmental impact. A significant and unjustified increase in construction cost would be required to reduce the environmental impact any further.

It is Yumbah’s view that KIPT could reduce the impact on the environment, it just doesn’t want to pay the bill.

EFFECTS ON OTHER BUSINESSES

Beyond the massive threat to Yumbah’s operation, the visual amenity of KIPT’s seaport proposal will also have major impacts on the nearby luxury bed and breakfast, Molly’s Run located just 750m from the proposed seaport.

Molly’s Run has operated at Smith Bay for the past seven years, and hosts around 1,000 guests every year. This proposal will have a significant effect on this tourism business, and no amount of buffer vegetation, or blending colours will prevent the major loss of view for tourists who stay as Molly’s Run.

BETTER THAN A CAUSEWAY

The suggestion of open culverts or bridge sections with the causeway provides little advantage.

The only option to protect coastal currents is an open-piled jetty with the berth pocket extended further offshore.

Reducing the solid nature of the seaport will assist also with reducing the incidence of marine biofouling of invasive marine species and concentration of disease agents such as toxic dinoflagellates within the nearshore environment.

However, the argument of the draft EIS makes inadequate consideration of Yumbah KI’s needs, and discounts without due consideration both alternative sites and alternative structures in water.



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GUIDELINE 8:

COMMUNITY

DESCRIPTION:

The proposal is likely to lead to a change in the Kangaroo Island population (short-term and long-term) both during the construction and operational phases of the proposed development. This will lead to a change in demand for various services, infrastructure and accommodation needs on the Island at various times.

RESPONSE SUMMARY

• Yumbah has been operating at Smith Bay since 1995

o 100 per cent Australian-owned and operated

o employs more than 100 full-time staff across regional Australia

o annual combined revenue of about $30 million

• Investment freeze on KI

o Smith Bay is an optimum site for onshore aquaculture

o threat of KIPT “seaport” has stalled investment, with other states set to benefit

• A good corporate citizen

o Yumbah has always employed more than 20 people on KI

o Develops staff skills and expertise o Supports local professionals and

tradespeople

o Advance aquaculture as a positive, sustainable export business for KI and the State

o Contribute to business and community development groups on KI

o Generous with financial and other support to sports and community interests

• KIPT’s proposed seaport

o A mortal threat to Yumbah KI

CLOSEST NEIGHBOUR

Yumbah KI’s abalone farm is the closest neighbour to the proposed KIPT seaport. It shares a fence with the site owned by KIPT, and the wharf is proposed at some 300m from Yumbah’s seawater intake pipes.

Each of Yumbah’s four farms is tailored for the environment in which it has been established and operates in accordance with respective licences and permits.

Smith Bay was selected for the quality of its water, appropriate tidal flow, the structure of Smith Bay’s sea floor, remoteness, freedom from marine pests and other threats to sensitive receptors like abalone, and a welcoming community.


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The draft EIS (page 44) states:

The most favoured structure (a combined approach with a causeway leading to a suspended deck jetty and floating pontoon) would also be the least expensive to construct and would have relatively low environmental impact. A significant and unjustified increase in construction cost would be required to reduce the environmental impact any further.

It is Yumbah’s view that KIPT could reduce the impact on the environment, it just doesn’t want to pay the bill.

EFFECTS ON OTHER BUSINESSES

Beyond the massive threat to Yumbah’s operation, the visual amenity of KIPT’s seaport proposal will also have major impacts on the nearby luxury bed and breakfast, Molly’s Run located just 750m from the proposed seaport.

Molly’s Run has operated at Smith Bay for the past seven years, and hosts around 1,000 guests every year. This proposal will have a significant effect on this tourism business, and no amount of buffer vegetation, or blending colours will prevent the major loss of view for tourists who stay as Molly’s Run.

BETTER THAN A CAUSEWAY

The suggestion of open culverts or bridge sections with the causeway provides little advantage.

The only option to protect coastal currents is an open-piled jetty with the berth pocket extended further offshore.

Reducing the solid nature of the seaport will assist also with reducing the incidence of marine biofouling of invasive marine species and concentration of disease agents such as toxic dinoflagellates within the nearshore environment.

However, the argument of the draft EIS makes inadequate consideration of Yumbah KI’s needs, and discounts without due consideration both alternative sites and alternative structures in water.



85

KIPT IN OPEN ‘LAWFARE’ AGAINST YUMBAH

KIPT’s draft EIS indicates that the Smith Bay site has “… several recognised easements and its wharf infrastructure has been designed to ensure the rights conferred by these easements are not compromised” (draft EIS Main report, page 110).

However, the draft EIS omits details of the easement rights detailed on the full Certificates of Title as can be seen in Appendix 7. One easement referred to in the draft EIS is a drainage easement in favour of Yumbah. This gives Yumbah rights to access the easement at any time to:

“… break the surface of, dig, open up and use” the easement for “the purpose of laying down, fixing, taking up, repairing, re-laying or examining pipes thereon and for the purpose of transferring water to and the storage of water in a dam thereon, affixing thereon and maintaining pumps and electrical switch gear and of using and maintaining those pipe pumps and electrical switch gear for water supply purposes.”

41 https://www.asx.com.au/asxpdf/20180309/pdf/43sb28v6nl7cf0.pdf

In 9 March 2018 KIPT disclosed to the ASX:41

“… none of the easements affecting the company’s land prevents it from proceeding with the development”

Further, the company declared it:

“… does not believe any of the matters are material.”

KIPT has spent a year waging expensive legal action in the South Australian Supreme Court in an attempt to strip Yumbah of these easement rights.

The as yet unanswered question is: if these easement rights have no impact on this proposed development, why is the company spending shareholders’ funds and diverting senior management resources at this time in its development to pursue unnecessary legal action?


84

This environment is threatened and trust has been destroyed by the arrival of KIPT as an aggressive, careless neighbour willing to litigate without pause to negotiate for a “shared” understanding and benefit40.

YUMBAH AQUACULTURE

Yumbah is the only Australian abalone producer to own and control every aspect of its operations, from breeding, on-growing and feed production through to processing/value adding, marketing and sales.

More than 70 per cent of the 700 tonnes of abalone grown annually by Yumbah is exported to Southeast Asia, North America and Europe.

In recognition of Yumbah’s commitment to cultivating premium abalone, Yumbah Aquaculture received the 2017 National Agribusiness Award at the Australian Export Awards. The company also won the Governor of Victoria Export Awards (GOVEA) in 2017.

SUSTAINABILITY

Responsible aquaculture is caring for the environment by reducing harvest pressure on wild fish stocks. As with so many of the ocean’s fish species, wild abalone has been exploited to near extinction in many countries across the globe.

40 Whilst professing a desire to co-exist with its neighbor KIPT have launched action in the Supreme Court of South Australia whose impact, if successful, will strip Yumbah of some of its ability to carry out its fundamental business of abalone aquaculture.

Yumbah reduces this pressure by breeding from internal farm broodstock to produce juvenile abalone which are grown to market size using a controlled but natural production system.

Yumbah utilises seawater pumped from the open ocean, which flows over the tanks and delivers oxygen to the abalone before returning to the ocean. Abalone are reliant on fresh, high quality seawater and are sensitive to changes in water quality. Alterations in water quality such as elevation in temperature, increased nutrients, anthropogenic contaminants and suspended fine sediment can have lethal consequence and at sub-lethal levels compromise health and growth.


Yumbah KI operates under two Crown land licenses issued by the previous South Australian Department for Environment and Water. Yumbah KI owns Allotments 50, I2, 200. It has two current licences for pump and pipeline purposes, Licence # OL022375 (Crown lands 467 and 361) and Licence # OL21749 (Crown lands 471 and 362).

Yumbah holds land based Aquaculture licences not only for a range of Abalone species but also for Bream, Flounder, Kingfish, Lobster, Mulloway, Oysters, Scallops, Sea Urchin, Seahorse, Snapper, Brown and Rainbow Trout and Whiting. The draft EIS is silent on the impact of the Seaport on the cultivation of these species.



85

KIPT IN OPEN ‘LAWFARE’ AGAINST YUMBAH

KIPT’s draft EIS indicates that the Smith Bay site has “… several recognised easements and its wharf infrastructure has been designed to ensure the rights conferred by these easements are not compromised” (draft EIS Main report, page 110).

However, the draft EIS omits details of the easement rights detailed on the full Certificates of Title as can be seen in Appendix 7. One easement referred to in the draft EIS is a drainage easement in favour of Yumbah. This gives Yumbah rights to access the easement at any time to:

“… break the surface of, dig, open up and use” the easement for “the purpose of laying down, fixing, taking up, repairing, re-laying or examining pipes thereon and for the purpose of transferring water to and the storage of water in a dam thereon, affixing thereon and maintaining pumps and electrical switch gear and of using and maintaining those pipe pumps and electrical switch gear for water supply purposes.”

41 https://www.asx.com.au/asxpdf/20180309/pdf/43sb28v6nl7cf0.pdf

In 9 March 2018 KIPT disclosed to the ASX:41

“… none of the easements affecting the company’s land prevents it from proceeding with the development”

Further, the company declared it:

“… does not believe any of the matters are material.”

KIPT has spent a year waging expensive legal action in the South Australian Supreme Court in an attempt to strip Yumbah of these easement rights.

The as yet unanswered question is: if these easement rights have no impact on this proposed development, why is the company spending shareholders’ funds and diverting senior management resources at this time in its development to pursue unnecessary legal action?


84

This environment is threatened and trust has been destroyed by the arrival of KIPT as an aggressive, careless neighbour willing to litigate without pause to negotiate for a “shared” understanding and benefit40.

YUMBAH AQUACULTURE

Yumbah is the only Australian abalone producer to own and control every aspect of its operations, from breeding, on-growing and feed production through to processing/value adding, marketing and sales.

More than 70 per cent of the 700 tonnes of abalone grown annually by Yumbah is exported to Southeast Asia, North America and Europe.

In recognition of Yumbah’s commitment to cultivating premium abalone, Yumbah Aquaculture received the 2017 National Agribusiness Award at the Australian Export Awards. The company also won the Governor of Victoria Export Awards (GOVEA) in 2017.

SUSTAINABILITY

Responsible aquaculture is caring for the environment by reducing harvest pressure on wild fish stocks. As with so many of the ocean’s fish species, wild abalone has been exploited to near extinction in many countries across the globe.

40 Whilst professing a desire to co-exist with its neighbor KIPT have launched action in the Supreme Court of South Australia whose impact, if successful, will strip Yumbah of some of its ability to carry out its fundamental business of abalone aquaculture.

Yumbah reduces this pressure by breeding from internal farm broodstock to produce juvenile abalone which are grown to market size using a controlled but natural production system.

Yumbah utilises seawater pumped from the open ocean, which flows over the tanks and delivers oxygen to the abalone before returning to the ocean. Abalone are reliant on fresh, high quality seawater and are sensitive to changes in water quality. Alterations in water quality such as elevation in temperature, increased nutrients, anthropogenic contaminants and suspended fine sediment can have lethal consequence and at sub-lethal levels compromise health and growth.


Yumbah KI operates under two Crown land licenses issued by the previous South Australian Department for Environment and Water. Yumbah KI owns Allotments 50, I2, 200. It has two current licences for pump and pipeline purposes, Licence # OL022375 (Crown lands 467 and 361) and Licence # OL21749 (Crown lands 471 and 362).

Yumbah holds land based Aquaculture licences not only for a range of Abalone species but also for Bream, Flounder, Kingfish, Lobster, Mulloway, Oysters, Scallops, Sea Urchin, Seahorse, Snapper, Brown and Rainbow Trout and Whiting. The draft EIS is silent on the impact of the Seaport on the cultivation of these species.



87

KIPT LAND USE

The draft EIS makes no comment on future uses of the 225ha of land KIPT owns at Smith Bay.

On 4 September 2018 KIPT announced an option to acquire 41ha south of and adjoining its existing land at Smith Bay. It told the ASX the control of this land gave it flexibility to:

• Change intersection geometry at the turn-off from the main road to accommodate high productivity vehicles,

• Create a truck parking and driver rest area or an additional pine log storage; and

• Realign the heavy vehicle route from the main road to the KI Seaport

• Possibly dispose of some surplus land and seek to acquire other land parcels in the area

Despite disclosures to the market, the draft EIS is silent on these matters.

KIPT’S TRUE INTENTION?

Did KIPT buy these parcels to make an approved Smith Bay project attractive to a foreign bidder?

Is this Major Development Process simply a play to offload an approved infrastructure project to a third party?

Why would the company require such large parcels of land around Smith Bay, when according to its draft EIS the development will be fully contained in the 11ha parcel of land directly adjacent to Yumbah?

The draft EIS attempts to raise a robust argument diminishing potential environmental consequences of a timber export seaport built on Yumbah KI’s doorstep. The significant and undisclosed risks of further establishing a multi-use port cannot be ignored in an EIS – but they are in this draft EIS.

KIPT CLAIMS AGAINST YUMBAH

KIPT claims it is a significant contributor to the economic viability of Kangaroo Island and provided optimistic forecasts of jobs, and economic activity associated with its proposal.

To support its case, KIPT has made many claims about Yumbah in private and in the public domain.

It hasn’t hesitated to work to dirty Yumbah’s standing with Government and community.

It has raised red herring arguments about Yumbah KI’s survival at Smith Bay.

It has argued Yumbah’s failure to invest is (1) an indication of a struggling business, and the action of investing in site maintenance and (2) an indication Yumbah is confident it can prosper with KIPT as its overshadowing neighbour.

KIPT has even postulated Yumbah faces impending closure thanks to climate change impact.

The real and absolute threat to Yumbah KI is KIPT.


86

Figure 8 - Rendering of KIPT proposal at Smith Bay showing Yumbah’s easement rights



87

KIPT LAND USE

The draft EIS makes no comment on future uses of the 225ha of land KIPT owns at Smith Bay.

On 4 September 2018 KIPT announced an option to acquire 41ha south of and adjoining its existing land at Smith Bay. It told the ASX the control of this land gave it flexibility to:

• Change intersection geometry at the turn-off from the main road to accommodate high productivity vehicles,

• Create a truck parking and driver rest area or an additional pine log storage; and

• Realign the heavy vehicle route from the main road to the KI Seaport

• Possibly dispose of some surplus land and seek to acquire other land parcels in the area

Despite disclosures to the market, the draft EIS is silent on these matters.

KIPT’S TRUE INTENTION?

Did KIPT buy these parcels to make an approved Smith Bay project attractive to a foreign bidder?

Is this Major Development Process simply a play to offload an approved infrastructure project to a third party?

Why would the company require such large parcels of land around Smith Bay, when according to its draft EIS the development will be fully contained in the 11ha parcel of land directly adjacent to Yumbah?

The draft EIS attempts to raise a robust argument diminishing potential environmental consequences of a timber export seaport built on Yumbah KI’s doorstep. The significant and undisclosed risks of further establishing a multi-use port cannot be ignored in an EIS – but they are in this draft EIS.

KIPT CLAIMS AGAINST YUMBAH

KIPT claims it is a significant contributor to the economic viability of Kangaroo Island and provided optimistic forecasts of jobs, and economic activity associated with its proposal.

To support its case, KIPT has made many claims about Yumbah in private and in the public domain.

It hasn’t hesitated to work to dirty Yumbah’s standing with Government and community.

It has raised red herring arguments about Yumbah KI’s survival at Smith Bay.

It has argued Yumbah’s failure to invest is (1) an indication of a struggling business, and the action of investing in site maintenance and (2) an indication Yumbah is confident it can prosper with KIPT as its overshadowing neighbour.

KIPT has even postulated Yumbah faces impending closure thanks to climate change impact.

The real and absolute threat to Yumbah KI is KIPT.


86

Figure 8 - Rendering of KIPT proposal at Smith Bay showing Yumbah’s easement rights



89

GUIDELINE 9:

NATIVE VEGETATION AND FAUNA

DESCRIPTION:

The proposed site is in an area that is mostly cleared of native vegetation, however patches of vegetation remain, and although fragmented these may provide critical habitat for fauna. Investigation into vegetation on surrounding properties and within the adjacent marine environment should also be undertaken to determine if the proposed development and associated activities will impact upon these habitat areas and the species, including migratory species, that may be reliant upon them.

RESPONSE SUMMARY

• A single ecological survey conducted over one day in 2016 is not sufficient

• KIPT has not considered behavioural impacts on white bellied sea-eagles or southern right whales

• The arguments in the draft EIS appear to be based on personal judgement, not an evidence-based scientific conclusion

44 Effects of human disturbance on productivity of White-bellied Sea-Eagles (Haliaeetus leucogaster), Terry E. Dennis A D, Rebecca R. McIntosh B and Peter D. Shaughnessy C - http://www.publish.csiro.au/mu/mu10044

NOTHING TO SEE HERE

Despite the ecological riches of Smith Bay and the native vegetation and fauna guidelines above, plus its responsibility to satisfy the needs of an EPBC Act referral, KIPT’s draft EIS is premised on just one ecological survey over one day in 2016.

Its conclusion from a walk-past is that there is nothing to see, nothing to manage or protect at Smith Bay.

As example, a patch of the Kangaroo Island Narrow-leaved Mallee (Eucalyptus cneorifolia) Woodland Ecological Community on the adjacent southern property fence line has potential to meet the size category for a threatened community.

Likewise, no observation of the daily flight of the magnificent White-bellied Sea Eagle across the subject development site. High-disturbance developments have been shown to affect fledgling outcomes of this endangered species.44

And having even further understated the nature of what is in the marine environment, the proponents lists shortfall mitigation measures, some of which Yumbah responds to below.


88



An estimated population increase of 330 suggests workers will bring their families with them. With 20 per cent utilisation of infrastructure and seasonal work programs, the bulk of these will turn out to be low-skilled contractors on fly-in/fly-out engagement


• A Marine Activity Zone (MAZ) would be prescribed for the Smith Bay site during construction to warn the public to avoid a clearly defined area to reduce navigational risks.43

How will Yumbah operate in what KIPT will seek to have declared a ‘Marine Activity Zone’ with temporary exclusion zones? How will KIPT respect the licences and easements that Yumbah holds, some of which intersect and surround the wharf site?



89

GUIDELINE 9:

NATIVE VEGETATION AND FAUNA

DESCRIPTION:

The proposed site is in an area that is mostly cleared of native vegetation, however patches of vegetation remain, and although fragmented these may provide critical habitat for fauna. Investigation into vegetation on surrounding properties and within the adjacent marine environment should also be undertaken to determine if the proposed development and associated activities will impact upon these habitat areas and the species, including migratory species, that may be reliant upon them.

RESPONSE SUMMARY

• A single ecological survey conducted over one day in 2016 is not sufficient

• KIPT has not considered behavioural impacts on white bellied sea-eagles or southern right whales

• The arguments in the draft EIS appear to be based on personal judgement, not an evidence-based scientific conclusion

44 Effects of human disturbance on productivity of White-bellied Sea-Eagles (Haliaeetus leucogaster), Terry E. Dennis A D, Rebecca R. McIntosh B and Peter D. Shaughnessy C - http://www.publish.csiro.au/mu/mu10044

NOTHING TO SEE HERE

Despite the ecological riches of Smith Bay and the native vegetation and fauna guidelines above, plus its responsibility to satisfy the needs of an EPBC Act referral, KIPT’s draft EIS is premised on just one ecological survey over one day in 2016.

Its conclusion from a walk-past is that there is nothing to see, nothing to manage or protect at Smith Bay.

As example, a patch of the Kangaroo Island Narrow-leaved Mallee (Eucalyptus cneorifolia) Woodland Ecological Community on the adjacent southern property fence line has potential to meet the size category for a threatened community.

Likewise, no observation of the daily flight of the magnificent White-bellied Sea Eagle across the subject development site. High-disturbance developments have been shown to affect fledgling outcomes of this endangered species.44

And having even further understated the nature of what is in the marine environment, the proponents lists shortfall mitigation measures, some of which Yumbah responds to below.


88



An estimated population increase of 330 suggests workers will bring their families with them. With 20 per cent utilisation of infrastructure and seasonal work programs, the bulk of these will turn out to be low-skilled contractors on fly-in/fly-out engagement


• A Marine Activity Zone (MAZ) would be prescribed for the Smith Bay site during construction to warn the public to avoid a clearly defined area to reduce navigational risks.43

How will Yumbah operate in what KIPT will seek to have declared a ‘Marine Activity Zone’ with temporary exclusion zones? How will KIPT respect the licences and easements that Yumbah holds, some of which intersect and surround the wharf site?



• There is no reasonable or foreseeable possibility that construction of the wharf at Smith Bay would fragment or decrease the size of populations of any species of pipefish, affect their critical habitat or disrupt their breeding cycles. It is concluded that the project proses no credible risk to the viability of pipefish on the north coast.48 –

A “reasonable or foreseeable possibility” is that dredging, disturbance, noise, water quality loss and a suite of other short-term and perpetual interferences in Smith Bay by KIPT will have immeasurable impact on pipefish – and many other native fauna and flora.

• The seagrasses Posidonia sinuosa and Amphibolis spp. (A. antarctica and A. griflithi1), which are long-lived and considered to be particularly important ecologically, grow in patches among rock bottom in depths up to 9 metres, and continuously over a mixed substrate of sand, pebble and shell fragment at depths of 9-15 metres.49

Posidonia sp. is a seagrass the EPA is particularly predisposed to protecting.

In Yumbah’s experience, if KIPT was proposing an aquaculture venture and Posidonia sp. was present, South Australia’s peak environmental regulator would not support the proposal.

48 EIS Appendix I1 p 27 49 EIS Appendix I1 p11 50 EIS Appendix 11 p26 51 EIS Appendix 12 p5

The proponent would be directed to relocate to a site where Posidonia sp. was absent.

Are the rules for “seaports” different to those for aquaculture?

• It is concluded that the project poses no credible risk to any of the threatened marine species.50

The method for determining that there is “no credible risk” is a personal judgement in support of the proponent, not an evidence-based scientific conclusion.

• Noise interference sources include some types of dredging, infrastructure construction and operation (particularly pile driving and explosives) and vessel noise (including tender activity), but the cumulative impacts of all sources of noise interference need to be considered.51

There is no further mention at all of any noise impacts on marine fauna. It’s understood that underwater noise modelling was undertaken for the draft EIS but this has not been incorporated into the marine ecology analysis despite the identification of this issue in Appendix 12.



• A medium level of risk associated with

impact piling potentially resulting in permanent hearing damage to southern right whales within 900 metres of the piling, and temporary hearing damage within 6.5 km of piling.45

How has KIPT reached the prognosis that hearing loss will be permanent or temporary?

Consideration is only given to the physical damage that close-proximity to noise generating sources may cause. There is no discussion of the behavioural impacts of exposure to noise at levels below that causing physical damage.

There is much recent literature about these impacts particularly on behavioural changes resulting from exposure to piling activities. This should be discussed in this draft EIS; it is not.

• Shipping activity (approximately 10–20 vessels per annum) to and from Smith Bay is unlikely to result in an increase in whale strikes.46

If we’re to believe KIPT, it’s seaport will operate at just 20 per cent capacity.

We don’t know what it will do, what shipping will be required, or what other changes are needed to accommodate the other 80 per cent capacity it’s reasonably expected an ASX-listed company’s shareholders will pursue.

45 EIS Executive Summary p41 46 EIS Main Document p40 47 EIS Executive Summary p50

How many more ships or other vessels will berth? What sorts of vessels? What cargo? What impacts? What mitigation and management?

No answers in the draft EIS.

• The construction of a causeway (0.95 ha) and the dredging of the berthing pocket and approaches (9.2 ha) would result in the direct loss of about 10 ha of mixed habitat, including the seagrasses Posidonia sinuosa, Amphibolis antarctica and A. griffithii, and associated invertebrate communities.47

Confirmed sea grass loss, best practice biosecurity does not eradicate the risk.

By the tone of this draft EIS, losing seagrass is okay because there is more along Kangaroo Island’s north coast and animals can move there. But sites like Smith Bay have niche ecosystems specific to site, and the variation and ongoing discovery of what Smith Bay is and has continues with the work of citizen science organisations like AusOcean.

On a specific point, the draft EIS fails to mention the severe impact on the critically endangered pipefish, with estimated elimination of 5000 Syngnathid spp. as a result of the seaport construction.



• There is no reasonable or foreseeable possibility that construction of the wharf at Smith Bay would fragment or decrease the size of populations of any species of pipefish, affect their critical habitat or disrupt their breeding cycles. It is concluded that the project proses no credible risk to the viability of pipefish on the north coast.48 –

A “reasonable or foreseeable possibility” is that dredging, disturbance, noise, water quality loss and a suite of other short-term and perpetual interferences in Smith Bay by KIPT will have immeasurable impact on pipefish – and many other native fauna and flora.

• The seagrasses Posidonia sinuosa and Amphibolis spp. (A. antarctica and A. griflithi1), which are long-lived and considered to be particularly important ecologically, grow in patches among rock bottom in depths up to 9 metres, and continuously over a mixed substrate of sand, pebble and shell fragment at depths of 9-15 metres.49

Posidonia sp. is a seagrass the EPA is particularly predisposed to protecting.

In Yumbah’s experience, if KIPT was proposing an aquaculture venture and Posidonia sp. was present, South Australia’s peak environmental regulator would not support the proposal.

48 EIS Appendix I1 p 27 49 EIS Appendix I1 p11 50 EIS Appendix 11 p26 51 EIS Appendix 12 p5

The proponent would be directed to relocate to a site where Posidonia sp. was absent.

Are the rules for “seaports” different to those for aquaculture?

• It is concluded that the project poses no credible risk to any of the threatened marine species.50

The method for determining that there is “no credible risk” is a personal judgement in support of the proponent, not an evidence-based scientific conclusion.

• Noise interference sources include some types of dredging, infrastructure construction and operation (particularly pile driving and explosives) and vessel noise (including tender activity), but the cumulative impacts of all sources of noise interference need to be considered.51

There is no further mention at all of any noise impacts on marine fauna. It’s understood that underwater noise modelling was undertaken for the draft EIS but this has not been incorporated into the marine ecology analysis despite the identification of this issue in Appendix 12.



• A medium level of risk associated with

impact piling potentially resulting in permanent hearing damage to southern right whales within 900 metres of the piling, and temporary hearing damage within 6.5 km of piling.45

How has KIPT reached the prognosis that hearing loss will be permanent or temporary?

Consideration is only given to the physical damage that close-proximity to noise generating sources may cause. There is no discussion of the behavioural impacts of exposure to noise at levels below that causing physical damage.

There is much recent literature about these impacts particularly on behavioural changes resulting from exposure to piling activities. This should be discussed in this draft EIS; it is not.

• Shipping activity (approximately 10–20 vessels per annum) to and from Smith Bay is unlikely to result in an increase in whale strikes.46

If we’re to believe KIPT, it’s seaport will operate at just 20 per cent capacity.

We don’t know what it will do, what shipping will be required, or what other changes are needed to accommodate the other 80 per cent capacity it’s reasonably expected an ASX-listed company’s shareholders will pursue.

45 EIS Executive Summary p41 46 EIS Main Document p40 47 EIS Executive Summary p50

How many more ships or other vessels will berth? What sorts of vessels? What cargo? What impacts? What mitigation and management?

No answers in the draft EIS.

• The construction of a causeway (0.95 ha) and the dredging of the berthing pocket and approaches (9.2 ha) would result in the direct loss of about 10 ha of mixed habitat, including the seagrasses Posidonia sinuosa, Amphibolis antarctica and A. griffithii, and associated invertebrate communities.47

Confirmed sea grass loss, best practice biosecurity does not eradicate the risk.

By the tone of this draft EIS, losing seagrass is okay because there is more along Kangaroo Island’s north coast and animals can move there. But sites like Smith Bay have niche ecosystems specific to site, and the variation and ongoing discovery of what Smith Bay is and has continues with the work of citizen science organisations like AusOcean.

On a specific point, the draft EIS fails to mention the severe impact on the critically endangered pipefish, with estimated elimination of 5000 Syngnathid spp. as a result of the seaport construction.



INCREASED TRAFFIC ISSUES

Timber haulage will see A-Double trucks – semi-trailers with two trailers – driving continuously on KI roads 24 hours a day, seven days a week. At peak production, a truck would be expected to pass along the transport route in each direction approximately every 22 minutes. These heavy vehicles will increase surface wear on unpaved and poor conditioned roads unsuitable for this kind of heavy, consistent traffic. Yet KIPT says it has no idea who will pay for the constant road maintenance and upgrades – assuming it will be council ratepayers or taxpayers through government funding.

The EIS states:

“During the construction phase, the increase in traffic (up to about 10 vehicle movements a day over the 15-month construction period) is likely to be indistinguishable from existing volumes.”52

This EIS does not reveal the traffic baseline so it is impossible to evaluate the nature of the increase in traffic – it simply cannot be defined or dismissed as “indistinguishable”.


The EIS states:

“During the operational phase, heavy vehicle movements are likely to reach a daily maximum of about 130 and an average of about 85.”53

The EIS also states:

“The proportion of heavy vehicles using the roads would increase from the existing 6 to 15 per cent up to approximately 11 to 22 per cent near the major population centres, and up to 28 per cent on Playford Highway.54

This effectively doubles the proportion of heavy vehicles using KI roads. Meanwhile, the exact nature of the heavy vehicles is yet to be defined nor has the exact route taken nor the specific activities these vehicles will be carrying out.


GUIDELINE 10:

TRAFFIC & TRANSPORT

DESCRIPTION:

The proposed port, and associated infrastructure, will generate traffic, in particular for the export of timber. The proponent estimates that there will be approximately 14 shipments of harvested timber per year from KIPT operated land, and that the wharf will be used 50-75 days per annum in total for all Kangaroo Island timber exports (including from other timber operators on the Island). As it is proposed to be a multi-user wharf, traffic will also be generated from a range of potential other uses including, but not limited to, agricultural exports and tourist and/or cruise ships. – DAC Guidelines.

RESPONSE SUMMARY

A-Double trucks, also known as a short road train 30m long carrying up to 60 tonnes, will haul timber on KI roads, 24 hours a day, seven days a week. At peak production, a truck is expected to pass along KIPT’s transport route to Smith Bay, in each direction, every 22 minutes. This huge volume of traffic will travel on roads not fit for purpose, in areas not accustomed to dealing with timber haulage vehicles, among tourists and school buses.

The impact on KI and its residents will be massive, and to date there is no information as to who will pay for the necessary road upgrades and maintenance, the inevitable road trauma, or the effect on native fauna.

• Timber haulage vehicles will increase wear on poor roads that are not built to carry heavy traffic. Yet there is no established plan as to who will pay for the constant road maintenance and upgrades. KIPT says it won’t pay. That leaves KI ratepayers or South Australian taxpayers footing the bill.

• The impact and heightened risk of such careless planning on road safety, community amenity and public infrastructure is a matter of record in The Green Triangle plantation region.

• Road safety guidelines will be required, to reduce, but notably not eliminate, the increased number of accidents that will occur on KI roads due to timber haulage. Again, there is no suggestion as to who will pay and who will implement these.

• In pursuing Smith Bay for its seaport, KIPT is forcing timber haulage vehicles to drive further than necessary, given there are suitable wharf sites closer to its timber plantations.



INCREASED TRAFFIC ISSUES

Timber haulage will see A-Double trucks – semi-trailers with two trailers – driving continuously on KI roads 24 hours a day, seven days a week. At peak production, a truck would be expected to pass along the transport route in each direction approximately every 22 minutes. These heavy vehicles will increase surface wear on unpaved and poor conditioned roads unsuitable for this kind of heavy, consistent traffic. Yet KIPT says it has no idea who will pay for the constant road maintenance and upgrades – assuming it will be council ratepayers or taxpayers through government funding.

The EIS states:

“During the construction phase, the increase in traffic (up to about 10 vehicle movements a day over the 15-month construction period) is likely to be indistinguishable from existing volumes.”52

This EIS does not reveal the traffic baseline so it is impossible to evaluate the nature of the increase in traffic – it simply cannot be defined or dismissed as “indistinguishable”.


The EIS states:

“During the operational phase, heavy vehicle movements are likely to reach a daily maximum of about 130 and an average of about 85.”53

The EIS also states:

“The proportion of heavy vehicles using the roads would increase from the existing 6 to 15 per cent up to approximately 11 to 22 per cent near the major population centres, and up to 28 per cent on Playford Highway.54

This effectively doubles the proportion of heavy vehicles using KI roads. Meanwhile, the exact nature of the heavy vehicles is yet to be defined nor has the exact route taken nor the specific activities these vehicles will be carrying out.


GUIDELINE 10:

TRAFFIC & TRANSPORT

DESCRIPTION:

The proposed port, and associated infrastructure, will generate traffic, in particular for the export of timber. The proponent estimates that there will be approximately 14 shipments of harvested timber per year from KIPT operated land, and that the wharf will be used 50-75 days per annum in total for all Kangaroo Island timber exports (including from other timber operators on the Island). As it is proposed to be a multi-user wharf, traffic will also be generated from a range of potential other uses including, but not limited to, agricultural exports and tourist and/or cruise ships. – DAC Guidelines.

RESPONSE SUMMARY

A-Double trucks, also known as a short road train 30m long carrying up to 60 tonnes, will haul timber on KI roads, 24 hours a day, seven days a week. At peak production, a truck is expected to pass along KIPT’s transport route to Smith Bay, in each direction, every 22 minutes. This huge volume of traffic will travel on roads not fit for purpose, in areas not accustomed to dealing with timber haulage vehicles, among tourists and school buses.

The impact on KI and its residents will be massive, and to date there is no information as to who will pay for the necessary road upgrades and maintenance, the inevitable road trauma, or the effect on native fauna.

• Timber haulage vehicles will increase wear on poor roads that are not built to carry heavy traffic. Yet there is no established plan as to who will pay for the constant road maintenance and upgrades. KIPT says it won’t pay. That leaves KI ratepayers or South Australian taxpayers footing the bill.

• The impact and heightened risk of such careless planning on road safety, community amenity and public infrastructure is a matter of record in The Green Triangle plantation region.

• Road safety guidelines will be required, to reduce, but notably not eliminate, the increased number of accidents that will occur on KI roads due to timber haulage. Again, there is no suggestion as to who will pay and who will implement these.

• In pursuing Smith Bay for its seaport, KIPT is forcing timber haulage vehicles to drive further than necessary, given there are suitable wharf sites closer to its timber plantations.



NATIVE FLORA AND FAUNA

The EIS estimates up to 21 endangered Kangaroo Island echidnas will be killed each year as a result of the timber haulage, while other animals including the southern brown bandicoot and the hooded plover will also be affected. By building the seaport at a location closer to the tree plantations, the distances travelled by timber trucks would be reduced and, as a result, the impact on native fauna would also be reduced.

The EIS provides no plans or specifications for the road upgrades that will be necessary to support the traffic from construction vehicles and timber haulage trucks. It is therefore not possible to estimate the impact on roadside vegetation and the extent to which any such upgrades would comply with or be denied by the KIC Roadside Vegetation Management Plan55 (KICRVMP) which operates under the legislative framework of the Local Government Act, Native Vegetation Act and the Environment Protection and Biodiversity Conservation Act. Key considerations listed by the KICRVMP for managing roadside vegetation include:

55http://www.kangarooisland.sa.gov.au/webdata/resources/files/KIC%20Roadside%20Vegetation%20Management%20Plan%202007.pdf 56 EIS Executive Summary p21

• Managing the spread of Phytopthora (a soil based root fungus)

• Preserving threatened species (15 EPBC identified Nationally threatened plant species)

The EIS is silent on these issues.


• The EIS states the exact nature of the traffic on KI and the number of

“vessels visiting each year depends on the sequence of plantation harvesting, commodity prices and availability of shipping.”56 The economic viability of the proposed seaport depends entirely on the sequence of plantation harvesting, commodity prices and availability of ships, none of which is in the control of KIPT.


TRAFFIC SAFETY ISSUES

KIPT says it will need:

“A set of road safety guidelines developed by the University of Adelaide’s Centre for Automotive Safety Research for KIPT, to improve the safety of the timber haulage operations, through safer roads and speeds, driver competency and training and in-vehicle technological aids”. This is a dangerous operation. Timber haulage vehicle near misses, incidents

and collisions will be a consistent annoyance to life on Kangaroo Island.

The EIS states:

“training and safety initiatives”

will be required to minimise incidents, noting that there is absolutely nothing anyone can do to stop them if the seaport is constructed. There is no discussion regarding who is going to implement any “initiatives”, who will ensure they happen and who will pay for these.

Figure 9 - Image from www.kangarooisland.sa.gov.au/vegetation

























TRAFFIC SAFETY ISSUES

KIPT says it will need:

“A set of road safety guidelines developed by the University of Adelaide’s Centre for Automotive Safety Research for KIPT, to improve the safety of the timber haulage operations, through safer roads and speeds, driver competency and training and in-vehicle technological aids”. This is a dangerous operation. Timber haulage vehicle near misses, incidents

and collisions will be a consistent annoyance to life on Kangaroo Island.

The EIS states:

“training and safety initiatives”

will be required to minimise incidents, noting that there is absolutely nothing anyone can do to stop them if the seaport is constructed. There is no discussion regarding who is going to implement any “initiatives”, who will ensure they happen and who will pay for these.

Figure 9 - Image from www.kangarooisland.sa.gov.au/vegetation














97

WATER IS CRITICAL

Water availability is critical on Kangaroo Island. Smith Bay has no access to reticulated water from SA Water and groundwater is highly saline, which means the project will rely on capturing and reusing surface water.

The only water supply for its immediate neighbour, Yumbah KI, is obtained from rainfall captured into a dam. The silence of the draft EIS on the matter of sourcing a water supply seems, ignorantly, to assume the availability of a metropolitan, city level, supply of water to remote Smith Bay.

Water is required for:

• Dust suppression

• Dredge spoil watering

• Hazard reduction (woodchips and logs)

• Fire suppression (emergency)

• Potable supplies for staff amenities

The draft EIS states water is required for:

• Mitigation measures to reduce emissions during construction and operations, including using water sprinklers on cleared areas before infrastructure construction during periods of adverse (hot and windy) weather57

• Using water sprays on bare timber during hot and windy weather and using water sprays during woodchip and log handling and loading58


• Watering unpaved roads during construction and operation and cleared areas during construction/land clearing activities59

But where is the water coming from, and in what volumes, requiring what treatment to make it fit for purpose?

The draft EIS reports ongoing water demands to be:

• (enough to spray) up to approximately 0.5ha of roadways and up to 5ha of timber storage areas requiring a peak of approximately 10,000 litres per day

• fire suppression water only required in emergencies and training/readiness drills

• up to approximately 500 litres per day of potable water associated with staff ablutions and drinking water

The draft EIS offers storage of up to 54,000 litres of dust suppression water (in addition to storage within the site retention basin) in a high-density polyethylene tank (or series of tanks), with separate firewater storage.

Using the utilisation figures above, this means KIPT will hold enough water for just 5.4 days of spraying the timber storage area.

What happens after this?

The amount of water available for dust suppression and firefighting is most likely inadequate.


96

GUIDELINE 11:

WATER

DESCRIPTION:

Water availability and use is a critical issue on Kangaroo Island and is fundamental to the livelihood and sustainability of the community and local industry. SA Water supplies reticulated water to some areas on the island, however Kangaroo Island is heavily reliant on the capture and reuse of surface water. The proponent should indicate how it is intended to source, reuse and treat water for, and at, the proposed site, to minimise impact on existing water resources and quality.

RESPONSE SUMMARY

• KIPT will needs massive volumes of water during construction and ongoing operations

o Draft EIS has no information about water sources, rights or licensing

o There is no information about who will pay for water delivery and removal infrastructure

• Spray run-off is a contaminant risk for

Yumbah KI

o Draft EIS is silent on water treatment and containment on-site

o The reasonable assumption is that contaminated water will go either back to the water table or to pollute Smith Bay

• KIPT will need water for dust suppression, fire hazard reduction and firefighting

o The source of this reliable supply is not known

o Water for dust suppression will be contaminated with dust, chemicals and organic matter that will negatively affect Yumbah

• Such contaminated water may find its

way into groundwater or Smith Bay

o There is evidence the groundwater is connected to the marine environment

• KIPT’s proposed industrial stormwater

ponds are 125m from Smith Bay

o EPA requires wastewater lagoons to be at least 500m from a high tide mark



97

WATER IS CRITICAL

Water availability is critical on Kangaroo Island. Smith Bay has no access to reticulated water from SA Water and groundwater is highly saline, which means the project will rely on capturing and reusing surface water.

The only water supply for its immediate neighbour, Yumbah KI, is obtained from rainfall captured into a dam. The silence of the draft EIS on the matter of sourcing a water supply seems, ignorantly, to assume the availability of a metropolitan, city level, supply of water to remote Smith Bay.

Water is required for:

• Dust suppression

• Dredge spoil watering

• Hazard reduction (woodchips and logs)

• Fire suppression (emergency)

• Potable supplies for staff amenities

The draft EIS states water is required for:

• Mitigation measures to reduce emissions during construction and operations, including using water sprinklers on cleared areas before infrastructure construction during periods of adverse (hot and windy) weather57

• Using water sprays on bare timber during hot and windy weather and using water sprays during woodchip and log handling and loading58


• Watering unpaved roads during construction and operation and cleared areas during construction/land clearing activities59

But where is the water coming from, and in what volumes, requiring what treatment to make it fit for purpose?

The draft EIS reports ongoing water demands to be:

• (enough to spray) up to approximately 0.5ha of roadways and up to 5ha of timber storage areas requiring a peak of approximately 10,000 litres per day

• fire suppression water only required in emergencies and training/readiness drills

• up to approximately 500 litres per day of potable water associated with staff ablutions and drinking water

The draft EIS offers storage of up to 54,000 litres of dust suppression water (in addition to storage within the site retention basin) in a high-density polyethylene tank (or series of tanks), with separate firewater storage.

Using the utilisation figures above, this means KIPT will hold enough water for just 5.4 days of spraying the timber storage area.

What happens after this?

The amount of water available for dust suppression and firefighting is most likely inadequate.


96

GUIDELINE 11:

WATER

DESCRIPTION:

Water availability and use is a critical issue on Kangaroo Island and is fundamental to the livelihood and sustainability of the community and local industry. SA Water supplies reticulated water to some areas on the island, however Kangaroo Island is heavily reliant on the capture and reuse of surface water. The proponent should indicate how it is intended to source, reuse and treat water for, and at, the proposed site, to minimise impact on existing water resources and quality.

RESPONSE SUMMARY

• KIPT will needs massive volumes of water during construction and ongoing operations

o Draft EIS has no information about water sources, rights or licensing

o There is no information about who will pay for water delivery and removal infrastructure

• Spray run-off is a contaminant risk for

Yumbah KI

o Draft EIS is silent on water treatment and containment on-site

o The reasonable assumption is that contaminated water will go either back to the water table or to pollute Smith Bay

• KIPT will need water for dust suppression, fire hazard reduction and firefighting

o The source of this reliable supply is not known

o Water for dust suppression will be contaminated with dust, chemicals and organic matter that will negatively affect Yumbah

• Such contaminated water may find its

way into groundwater or Smith Bay

o There is evidence the groundwater is connected to the marine environment

• KIPT’s proposed industrial stormwater

ponds are 125m from Smith Bay

o EPA requires wastewater lagoons to be at least 500m from a high tide mark



99

HIGHLY SALINE

The use of groundwater and seawater as potential emergency water supplies should be prohibited due to elevated salinity in both sources.


“groundwater is unlikely to be in use in the immediate Smith Bay region and there is no intent to use groundwater for site activities”.

“Unlikely” suggests “possibility” and must be confirmed or denied. If there is possibility, there is intent to extract groundwater for on-site activities, and a hence a comprehensive groundwater assessment is required.

NEGATIVE EFFECTS ON GROUNDWATER

Potential impacts of site activities to groundwater below the site and connectivity with regional aquifers demands further investigation.

A single grab sample taken towards the northern boundary of the site identified the groundwater to be 1.65m below ground level (BGL) (Appendix L, Section 4.3).

The total dissolved solid (TDS) concentration was 18,000 mg/L, indicative of saline conditions, inferring that groundwater is potentially connected to the marine environment. Contaminants including iron, lead, cobalt, copper, sulphate and nitrite were measured in the sampled groundwater. This single sample is scientifically insufficient to adequately characterise baseline groundwater quality at the site.

The potential impact on groundwater from stormwater management and industrial water reused for dust suppression and landscape watering must be further investigated.


98

FIREFIGHTING AND DUST SUPPRESSION INADEQUATE

Dust generation and combustion of stockpiled timber or woodchips at the seaport will present a new threat to Yumbah KI, particularly given its primarily “down-wind” positioning from the sources of these threats.

The impact of fire is exacerbated by Smith Bay’s isolation and the absence of readily available local emergency services.

Kangaroo Island is experiencing more frequent extreme weather conditions where summer temperatures consistently reach mid-40s for extended periods. Under these scenarios, there is no guarantee a reliable water supply will be available for firefighting.

The draft EIS reports:

“…. timber log and woodchip storage yards are isolated from the general stormwater system. Each yard will drain via a concrete forebay to intercept sediment and debris. Stormwater will then enter the retention basin (holding pond)”60.

Water from the retention basin will be:

“used for irrigation of adjacent landscape buffer (where contaminants will biodegrade) and for dust suppression (within wood storage areas)”61.

Dust suppression using industrial stormwater will likely involve spraying timber stockpiles, which means airborne water mist extending to Yumbah’s adjacent sensitive receptors.

60 Main report pg.73 61 Main report pg.371

The proposed use of contaminated industrial stormwater for landscape watering and dust suppression gives no consideration to the threat of this activity to the ongoing operations of Yumbah KI.

WATER FOR DUST SUPRESSION INNAPROPRIATE

The draft EIS fails to provide adequate understanding of potential contamination of the captured stormwater and timber leachate generated within the hard stand areas of the seaport.

Logs and woodchips (without additional chemical treatment) can leach high organic matter and correspondingly high chemical oxygen demand (COD), both of which are known to decrease oxygen levels in receiving waters. They can also leach phosphorous, nitrogen, phenols, resin acids and ammonium and alter soil and water pH.

Of the organic compounds extracted from softwood, those of greatest concern as likely contributors to toxic runoff include tannins, lignins, phenols, tropolones, volatile fatty acids and resin acids. Increased irrigation intensities and pollutants can exceed the infiltration absorption and degradation capacity of soil, resulting in leaching to groundwater.

An ecotoxicological analysis of the stormwater must be conducted to understand the effect of any proposed reuse.



99

HIGHLY SALINE

The use of groundwater and seawater as potential emergency water supplies should be prohibited due to elevated salinity in both sources.


“groundwater is unlikely to be in use in the immediate Smith Bay region and there is no intent to use groundwater for site activities”.

“Unlikely” suggests “possibility” and must be confirmed or denied. If there is possibility, there is intent to extract groundwater for on-site activities, and a hence a comprehensive groundwater assessment is required.

NEGATIVE EFFECTS ON GROUNDWATER

Potential impacts of site activities to groundwater below the site and connectivity with regional aquifers demands further investigation.

A single grab sample taken towards the northern boundary of the site identified the groundwater to be 1.65m below ground level (BGL) (Appendix L, Section 4.3).

The total dissolved solid (TDS) concentration was 18,000 mg/L, indicative of saline conditions, inferring that groundwater is potentially connected to the marine environment. Contaminants including iron, lead, cobalt, copper, sulphate and nitrite were measured in the sampled groundwater. This single sample is scientifically insufficient to adequately characterise baseline groundwater quality at the site.

The potential impact on groundwater from stormwater management and industrial water reused for dust suppression and landscape watering must be further investigated.


98

FIREFIGHTING AND DUST SUPPRESSION INADEQUATE

Dust generation and combustion of stockpiled timber or woodchips at the seaport will present a new threat to Yumbah KI, particularly given its primarily “down-wind” positioning from the sources of these threats.

The impact of fire is exacerbated by Smith Bay’s isolation and the absence of readily available local emergency services.

Kangaroo Island is experiencing more frequent extreme weather conditions where summer temperatures consistently reach mid-40s for extended periods. Under these scenarios, there is no guarantee a reliable water supply will be available for firefighting.

The draft EIS reports:

“…. timber log and woodchip storage yards are isolated from the general stormwater system. Each yard will drain via a concrete forebay to intercept sediment and debris. Stormwater will then enter the retention basin (holding pond)”60.

Water from the retention basin will be:

“used for irrigation of adjacent landscape buffer (where contaminants will biodegrade) and for dust suppression (within wood storage areas)”61.

Dust suppression using industrial stormwater will likely involve spraying timber stockpiles, which means airborne water mist extending to Yumbah’s adjacent sensitive receptors.

60 Main report pg.73 61 Main report pg.371

The proposed use of contaminated industrial stormwater for landscape watering and dust suppression gives no consideration to the threat of this activity to the ongoing operations of Yumbah KI.

WATER FOR DUST SUPRESSION INNAPROPRIATE

The draft EIS fails to provide adequate understanding of potential contamination of the captured stormwater and timber leachate generated within the hard stand areas of the seaport.

Logs and woodchips (without additional chemical treatment) can leach high organic matter and correspondingly high chemical oxygen demand (COD), both of which are known to decrease oxygen levels in receiving waters. They can also leach phosphorous, nitrogen, phenols, resin acids and ammonium and alter soil and water pH.

Of the organic compounds extracted from softwood, those of greatest concern as likely contributors to toxic runoff include tannins, lignins, phenols, tropolones, volatile fatty acids and resin acids. Increased irrigation intensities and pollutants can exceed the infiltration absorption and degradation capacity of soil, resulting in leaching to groundwater.

An ecotoxicological analysis of the stormwater must be conducted to understand the effect of any proposed reuse.



101

GUIDELINE 12:

NOISE & LIGHT

DESCRIPTION:

It is expected that both underwater and terrestrial noise pollution will occur during the construction phase as a result of securing the mooring and retaining structures to the seabed, the use of earthmoving equipment and physical construction of the structures. Post construction, the movement of vehicles to and from the proposed site, stockpiling and ship-loading operations onsite at Smith Bay will also generate noise. If construction and/or operations are to occur at night there will also be light pollution impacts on the surrounding area.

RESPONSE SUMMARY

The lighting required for the proposed seaport to operate safely and commercially is not compatible with the operations of an adjacent onshore abalone farm, nor for guests at high-end accommodation who stay at Smith Bay for its peaceful isolation. Further, escalated noise levels during construction and operations, both on land and in the Smith Bay marine environment, will have a negative effect on amenity, on native species – and the wellbeing of highly sensitive abalone.

• KIPT claims the major source of artificial lighting at Smith Bay is associated with the existing land-based aquaculture operation which is continuously lit at night. This “major source” at the abalone farm consists of two single outdoor lights for security purposes

• The two security lights are minimal and shielded from abalone production

• Abalone feed predominantly at night, and onshore production mimics natural cycles by ensuring darkness at feeding times

• Light spill expected from the port construction and ongoing operation will further jeopardise Yumbah’s ongoing business in Smith Bay

KIPT agree that construction may cause permanent hearing damage to whales that come within one kilometre of the wharf, and temporary damage for those that come within 6.5km.

• There is no existing regulatory

requirement regarding underwater noise to drive standards and compliance by KIPT

• KIPT admits that there will be significant underwater noise during the construction phase


100

STORMWATER PONDS: TOO CLOSE FOR COMFORT

SA EPA509/19 Wastewater lagoon construction guidelines state:

“To minimise the impacts of odour, the risk of leakage to groundwater and the risk of polluting groundwater or surface waters, the construction of wastewater lagoons should be avoided … within 500 m of a high tide mark.

The draft EIS proposes industrial stormwater be ponded 125 metres from Smith Bay. The draft EIS Appendix C3 identifies this location due to the low topography of the land.

The location of this contaminated stormwater storage presents risk to both Smith Bay and groundwater beneath the site, and is just metres of Yumbah KI’s grow-out tanks (see Figure 10).

NOT THE SOLUTION: MORE TRUCKS

It has been suggested fresh water be brought to the site by a third-party to supplement short supply.

Further, reclaimed seawater may be used during extended periods without rainfall. This brings even more trucks to an incapable road network – and has not been considered by the draft EIS traffic impact assessment.

Figure 10 – Graphic from KIPT’s draft EIS showing the locations of contaminated stormwater storage



101

GUIDELINE 12:

NOISE & LIGHT

DESCRIPTION:

It is expected that both underwater and terrestrial noise pollution will occur during the construction phase as a result of securing the mooring and retaining structures to the seabed, the use of earthmoving equipment and physical construction of the structures. Post construction, the movement of vehicles to and from the proposed site, stockpiling and ship-loading operations onsite at Smith Bay will also generate noise. If construction and/or operations are to occur at night there will also be light pollution impacts on the surrounding area.

RESPONSE SUMMARY

The lighting required for the proposed seaport to operate safely and commercially is not compatible with the operations of an adjacent onshore abalone farm, nor for guests at high-end accommodation who stay at Smith Bay for its peaceful isolation. Further, escalated noise levels during construction and operations, both on land and in the Smith Bay marine environment, will have a negative effect on amenity, on native species – and the wellbeing of highly sensitive abalone.

• KIPT claims the major source of artificial lighting at Smith Bay is associated with the existing land-based aquaculture operation which is continuously lit at night. This “major source” at the abalone farm consists of two single outdoor lights for security purposes

• The two security lights are minimal and shielded from abalone production

• Abalone feed predominantly at night, and onshore production mimics natural cycles by ensuring darkness at feeding times

• Light spill expected from the port construction and ongoing operation will further jeopardise Yumbah’s ongoing business in Smith Bay

KIPT agree that construction may cause permanent hearing damage to whales that come within one kilometre of the wharf, and temporary damage for those that come within 6.5km.

• There is no existing regulatory

requirement regarding underwater noise to drive standards and compliance by KIPT

• KIPT admits that there will be significant underwater noise during the construction phase


100

STORMWATER PONDS: TOO CLOSE FOR COMFORT

SA EPA509/19 Wastewater lagoon construction guidelines state:

“To minimise the impacts of odour, the risk of leakage to groundwater and the risk of polluting groundwater or surface waters, the construction of wastewater lagoons should be avoided … within 500 m of a high tide mark.

The draft EIS proposes industrial stormwater be ponded 125 metres from Smith Bay. The draft EIS Appendix C3 identifies this location due to the low topography of the land.

The location of this contaminated stormwater storage presents risk to both Smith Bay and groundwater beneath the site, and is just metres of Yumbah KI’s grow-out tanks (see Figure 10).

NOT THE SOLUTION: MORE TRUCKS

It has been suggested fresh water be brought to the site by a third-party to supplement short supply.

Further, reclaimed seawater may be used during extended periods without rainfall. This brings even more trucks to an incapable road network – and has not been considered by the draft EIS traffic impact assessment.

Figure 10 – Graphic from KIPT’s draft EIS showing the locations of contaminated stormwater storage



103

ABALONE FEEDING

Abalone are disturbed by light, they actively feed at night and are sedentary during the day. Any light emitted by the seaport will compromise their feeding behaviour, significantly reducing animal health, compromising welfare, and reducing the productivity and viability of Yumbah KI.

The draft EIS states

“The major source of artificial lighting at Smith Bay is associated with the existing land-based aquaculture operation, which is continuously lit at night, illuminating the beachfront north of the facility and the abalone tanks, and the western side of the facility.”

This opinion, like so much of the opinion offered by KIPT in the draft EIS, is partially true in some way, but simply incorrect in context.

There are at this point in time no lights at Smith Bay other than security lighting on the Yumbah KI office building to illuminate a small area of the farm for security purposes.

Figure 12 - Drone photo of Yumbah KI at night.


102

LIGHT

KIPT claims that the wharf will be lit similarly to the abalone farm. Apart from small external security lights Yumbah KI does not emit light at night. Light from the seaport however will be emitted continuously at night, and it is expected large flood lights will brightly illuminate the entire port area pre-dusk to post-dawn for safety and ongoing operations.

Abalone are extremely sensitive and largely intolerant to night-time light. Literature indicating abalone’s sensitivity to light is missing from the draft EIS.

The most viable comparison is a night photo of the woodchip/wharf area at the Port of Portland in Victoria whose activities would be subject to similar OH&S requirements as the proposed KI wharf.

The amenity that sustains the nearby premium accommodation business, Molly’s Run, will be ruined which currently invites guests to “enjoy beautiful night skies, sunsets, dawns”.

Figure 11 - Port of Portland at night.



103

ABALONE FEEDING

Abalone are disturbed by light, they actively feed at night and are sedentary during the day. Any light emitted by the seaport will compromise their feeding behaviour, significantly reducing animal health, compromising welfare, and reducing the productivity and viability of Yumbah KI.

The draft EIS states

“The major source of artificial lighting at Smith Bay is associated with the existing land-based aquaculture operation, which is continuously lit at night, illuminating the beachfront north of the facility and the abalone tanks, and the western side of the facility.”

This opinion, like so much of the opinion offered by KIPT in the draft EIS, is partially true in some way, but simply incorrect in context.

There are at this point in time no lights at Smith Bay other than security lighting on the Yumbah KI office building to illuminate a small area of the farm for security purposes.

Figure 12 - Drone photo of Yumbah KI at night.


102

LIGHT

KIPT claims that the wharf will be lit similarly to the abalone farm. Apart from small external security lights Yumbah KI does not emit light at night. Light from the seaport however will be emitted continuously at night, and it is expected large flood lights will brightly illuminate the entire port area pre-dusk to post-dawn for safety and ongoing operations.

Abalone are extremely sensitive and largely intolerant to night-time light. Literature indicating abalone’s sensitivity to light is missing from the draft EIS.

The most viable comparison is a night photo of the woodchip/wharf area at the Port of Portland in Victoria whose activities would be subject to similar OH&S requirements as the proposed KI wharf.

The amenity that sustains the nearby premium accommodation business, Molly’s Run, will be ruined which currently invites guests to “enjoy beautiful night skies, sunsets, dawns”.

Figure 11 - Port of Portland at night.



105

The high proportion of quiescent behaviour displayed by greenlip abalone during the light period in the study of Buss et al. (2015) may be an evolutionary response to increased vulnerability to predation on active wild abalone during daylight hours (Shepherd 1973; Hahn 1989; Jenkins 2004). Feed ration and photoperiod had far greater impacts on the feeding behaviour of abalone than diet type (Buss et al. 2015). In regards to photoperiod, greenlip abalone exhibited the most movement and feeding behaviour during darkness, supporting the notion that nocturnal feeding is preferred (Buss et al. 2015).

So, the conclusions in Appendix H Section 4.3.2 should indeed state that light at night will decrease feeding as the abalone do not feed during daylight. This will consequently have a debilitating decrease in abalone growth and farm productivity. Extraneous night-time light will cause changes in behaviour and movement as the abalone are active only during dark conditions. Abalone will become stressed when the photoperiod becomes a 24-hour period of intensified light, as is the potential from the seaport. Oxygen consumption and ammonia excretion rates are higher under light versus dark conditions, indicating that environmental alterations will have physiological effects (Ahmed et al., 2008).

The published findings are consistent with the observations of Yumbah’s hatchery manager and the practice of reducing light to optimise feeding and growth in the farming of abalone. Light has a demonstrable and adverse effect on feeding and growth of abalone.

NOISE

A number of misleading and erroneous statements are suggested throughout the Main Report and Appendix N that purport Yumbah as a significant noise source through its stationery equipment and heavy vehicles movements.

The very nature of abalone farming creates minimal noise, equivalent to ambient in the marine environment and does not impact amenity. There are a number of noise sources within an abalone farm that create isolated noise within close proximity to the source, but generally noise is comparable to background.

Heavy vehicle movements do not occur with abalone farming. The operational noise sources particularly bulldozers, chippers, woodchip stackers (to name a few) that will be operating constantly for 24 hour 7 days within the seaport will create significant operational noise that cannot be compared to the benign activity of growing abalone.

The statement that there is “no established special need for quiet at the Yumbah Aquaculture site” in Appendix N (pg 21) is pure negligence and offensive. KIPT continue to show complete disregard for Yumbah’s staff and its operations. Yumbah KI operates in a Coastal Conservation Zone with a negligible environmental footprint and the environmental values and health of its staff require protection.

Yumbah engaged GHD to complete a technical review of the predicted noise and vibration impacts of the seaport. The review has focused primarily on Appendix N of the draft EIS.

GHD’s findings in the Smith Bay Aquaculture Assessment Noise & Vibration Review (Lenchine, 2019) have been included in Appendix 8 of this submission.


104

McShane (2019) confirms that light-spill onto the abalone farm from KIPT’s proposed infrastructure in the hard-standing area and along the wharf/causeway as well as from transport vehicles will create significant difficulties for Yumbah KI.

The vague and misleading assessment regarding abalone tolerance to extraneous light attempts to relate abalone’s propensity to preferring dark environments as their defence mechanism to avoiding predation. Abalone are cryptic gastropods, preferring to hide in crevices and against ledges. They are nocturnal feeders and feeding rates decrease in the presence of light (e.g. Ebert & Houk 1984; Tutschulte & Connell 1988; Tahil & Juino-Menez 1999; Garcia-Esquivel et al. 2007; Searcy-Bernal & Gorrostieta-Hurtado 2007; Lloyd & Bates 2008).

If an accurate interpretation of literature was indeed conducted for extraneous light impacts to abalone, Section 4.3.2 of Appendix H would otherwise have accurately presented the evidence to conclude night-time light is detrimental to abalone in a farming environment.

Appendix H concludes that in a study by Alter et al. (2004) there was no measurable effect of light vs dark conditions on the oxygen consumption rates (used as a direct index of stress) for these animals. The outcomes of this study were blatantly misrepresented, tests were conducted on abalone larvae in a hatchery.

Reference to Pereira et al (2007) is misleading. The results of the experiment were inconclusive as to which light regime was most favourable when considering the growth patterns and comparative mortality rates within the systems.

The time of feed introduction and light intensity have also been shown to affect abalone feeding behaviour, with darkness stimulating both higher grazing and growth rates compared to light exposure for post-larvae, six-day-old red abalone (Haliotis rufescens) in static conditions (Searcy-Bernal & Gorrostieta-Hurtado 2007).

Feed intake and growth rates have been reported to increase by 24 and 260 per cent, respectively, for red abalone juveniles (40mm) when cultivated in complete darkness (Ebert & Houk 1984).

No feeding activity was observed during daylight hours in ass’s ear abalone (Haliotis asinina). The highest feeding activity occurred during darkness between 1800 and 0200 h and ceased entirely before sunrise (Tahil & Juino-Menez 1999).

Quiescent behaviour was dominant in all greenlip abalone (Haliotis laevigata) from 0400 h until the following evening (Buss et al. 2015). The cessation of movement during this period has previously been noted for other Haliotis spp. (Shepherd 1973; Tutschulte & Connell 1988; Tahil & Juino-Menez 1999; Pereira et al. 2007; Lloyd & Bates 2008), demonstrating that as daytime approaches, the presence or absence of food has minimal effect on abalone movement.

Juvenile abalone, in particular, have been reported to follow this trend, displaying quiescent behaviour during daylight, actively feeding during darkness and resuming quiescent behaviour before dawn (Tutschulte & Connell 1988; Pereira et al. 2007).



105

The high proportion of quiescent behaviour displayed by greenlip abalone during the light period in the study of Buss et al. (2015) may be an evolutionary response to increased vulnerability to predation on active wild abalone during daylight hours (Shepherd 1973; Hahn 1989; Jenkins 2004). Feed ration and photoperiod had far greater impacts on the feeding behaviour of abalone than diet type (Buss et al. 2015). In regards to photoperiod, greenlip abalone exhibited the most movement and feeding behaviour during darkness, supporting the notion that nocturnal feeding is preferred (Buss et al. 2015).

So, the conclusions in Appendix H Section 4.3.2 should indeed state that light at night will decrease feeding as the abalone do not feed during daylight. This will consequently have a debilitating decrease in abalone growth and farm productivity. Extraneous night-time light will cause changes in behaviour and movement as the abalone are active only during dark conditions. Abalone will become stressed when the photoperiod becomes a 24-hour period of intensified light, as is the potential from the seaport. Oxygen consumption and ammonia excretion rates are higher under light versus dark conditions, indicating that environmental alterations will have physiological effects (Ahmed et al., 2008).

The published findings are consistent with the observations of Yumbah’s hatchery manager and the practice of reducing light to optimise feeding and growth in the farming of abalone. Light has a demonstrable and adverse effect on feeding and growth of abalone.

NOISE

A number of misleading and erroneous statements are suggested throughout the Main Report and Appendix N that purport Yumbah as a significant noise source through its stationery equipment and heavy vehicles movements.

The very nature of abalone farming creates minimal noise, equivalent to ambient in the marine environment and does not impact amenity. There are a number of noise sources within an abalone farm that create isolated noise within close proximity to the source, but generally noise is comparable to background.

Heavy vehicle movements do not occur with abalone farming. The operational noise sources particularly bulldozers, chippers, woodchip stackers (to name a few) that will be operating constantly for 24 hour 7 days within the seaport will create significant operational noise that cannot be compared to the benign activity of growing abalone.

The statement that there is “no established special need for quiet at the Yumbah Aquaculture site” in Appendix N (pg 21) is pure negligence and offensive. KIPT continue to show complete disregard for Yumbah’s staff and its operations. Yumbah KI operates in a Coastal Conservation Zone with a negligible environmental footprint and the environmental values and health of its staff require protection.

Yumbah engaged GHD to complete a technical review of the predicted noise and vibration impacts of the seaport. The review has focused primarily on Appendix N of the draft EIS.

GHD’s findings in the Smith Bay Aquaculture Assessment Noise & Vibration Review (Lenchine, 2019) have been included in Appendix 8 of this submission.


104

McShane (2019) confirms that light-spill onto the abalone farm from KIPT’s proposed infrastructure in the hard-standing area and along the wharf/causeway as well as from transport vehicles will create significant difficulties for Yumbah KI.

The vague and misleading assessment regarding abalone tolerance to extraneous light attempts to relate abalone’s propensity to preferring dark environments as their defence mechanism to avoiding predation. Abalone are cryptic gastropods, preferring to hide in crevices and against ledges. They are nocturnal feeders and feeding rates decrease in the presence of light (e.g. Ebert & Houk 1984; Tutschulte & Connell 1988; Tahil & Juino-Menez 1999; Garcia-Esquivel et al. 2007; Searcy-Bernal & Gorrostieta-Hurtado 2007; Lloyd & Bates 2008).

If an accurate interpretation of literature was indeed conducted for extraneous light impacts to abalone, Section 4.3.2 of Appendix H would otherwise have accurately presented the evidence to conclude night-time light is detrimental to abalone in a farming environment.

Appendix H concludes that in a study by Alter et al. (2004) there was no measurable effect of light vs dark conditions on the oxygen consumption rates (used as a direct index of stress) for these animals. The outcomes of this study were blatantly misrepresented, tests were conducted on abalone larvae in a hatchery.

Reference to Pereira et al (2007) is misleading. The results of the experiment were inconclusive as to which light regime was most favourable when considering the growth patterns and comparative mortality rates within the systems.

The time of feed introduction and light intensity have also been shown to affect abalone feeding behaviour, with darkness stimulating both higher grazing and growth rates compared to light exposure for post-larvae, six-day-old red abalone (Haliotis rufescens) in static conditions (Searcy-Bernal & Gorrostieta-Hurtado 2007).

Feed intake and growth rates have been reported to increase by 24 and 260 per cent, respectively, for red abalone juveniles (40mm) when cultivated in complete darkness (Ebert & Houk 1984).

No feeding activity was observed during daylight hours in ass’s ear abalone (Haliotis asinina). The highest feeding activity occurred during darkness between 1800 and 0200 h and ceased entirely before sunrise (Tahil & Juino-Menez 1999).

Quiescent behaviour was dominant in all greenlip abalone (Haliotis laevigata) from 0400 h until the following evening (Buss et al. 2015). The cessation of movement during this period has previously been noted for other Haliotis spp. (Shepherd 1973; Tutschulte & Connell 1988; Tahil & Juino-Menez 1999; Pereira et al. 2007; Lloyd & Bates 2008), demonstrating that as daytime approaches, the presence or absence of food has minimal effect on abalone movement.

Juvenile abalone, in particular, have been reported to follow this trend, displaying quiescent behaviour during daylight, actively feeding during darkness and resuming quiescent behaviour before dawn (Tutschulte & Connell 1988; Pereira et al. 2007).



107

The draft EIS reports that underwater noise impact is likely to be high during the construction phase of the project. As KIPT’s draft EIS does not provide detailed information about the nature of its construction activities, the effect of underwater noise and any vibration to marine species cannot be estimated. A much more considered approached is warranted.

ADDITIONAL ERRORS AND OMMISIONS

• The major source of artificial lighting at Smith Bay is associated with the existing land-based aquaculture operation, which is continuously lit at night, illuminating the beachfront north of the facility and the abalone tanks, and the western side of the facility.62

Manifestly incorrect. Yumbah is the only present light source, comprising two small security lights.

62 Draft EIS Executive Summary p40 63 Draft EIS Executive Summary p41

The proposed lighting system at the new facility is likely to be similar to existing lighting from the nearby onshore aquaculture facility. The KI Seaport’s lights would likely blend into the existing lighting of the abalone farm and thus the cumulative impact of additional lighting is expected to be low63.

Comparing the proposed operational seaport’s expected flood of light – evidenced by the operations at the Port of Portland – to the small security lights of Yumbah is disingenuous. In the claimed accumulation of impact, the baseline is zero, and the cumulative effect is all KIPT.


106

The findings highlight concerns with the assessment of noise and vibration in the draft EIS, including:

• Assessment of construction noise has not been completed. The lack of this demands KIPT take the impact of its proposal on neighbours, amenity and environment more seriously

• An assessment of the efficiency of proposed noise mitigation measures is necessary

• Information in the main report contradicts the recommendations of the acoustic report regarding what noise mitigation measures should be implemented to meet the relevant noise criteria for the nearest residential receivers

• Noise from the development is not expected to meet the applicable criteria for Yumbah’s abalone farm. The acoustic report in the draft EIS does not adequately explain why it is not practicable to achieve the criteria and how this will affect the abalone farm

• Local meteorological conditions, particularly background conditions, have not been adequately considered in the assessment. The criteria under SA Noise EPP does not depend on the pre-existing background level but rather on the zoning of the noise source and the relevant receivers

• The main report in the draft EIS summarises a traffic noise assessment, yet data on traffic inputs relevant to predicting noise impact are not provided. The draft EIS simply claims traffic noise complies with requirements in the DPTI Road Traffic Noise Guidelines. But the proponent fails to present the method of its traffic noise predictions, locations of affected receivers and predicted traffic noise levels

• More information is required to validate KIPT’s assumptions

UNDERWATER NOISE

An underwater noise assessment forms part of KIPT’s acoustic report (Appendix N). However, there are no regulatory documents applicable to the company’s assessment that establish standards for compliance.

The South Australian Government’s Underwater Piling Noise Guidelines 2012 report provides details on pile driving noise. Underwater vibration assessment is not mandated by any regulatory documents, and guidance on this kind of impact is lacking. Therefore, it does not form part of the submitted draft EIS.

The acoustic report details an underwater background noise assessment. Levels typical for the current environment are around 90-120 dB depending on weather conditions and other environmental factors.



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The draft EIS reports that underwater noise impact is likely to be high during the construction phase of the project. As KIPT’s draft EIS does not provide detailed information about the nature of its construction activities, the effect of underwater noise and any vibration to marine species cannot be estimated. A much more considered approached is warranted.

ADDITIONAL ERRORS AND OMMISIONS

• The major source of artificial lighting at Smith Bay is associated with the existing land-based aquaculture operation, which is continuously lit at night, illuminating the beachfront north of the facility and the abalone tanks, and the western side of the facility.62

Manifestly incorrect. Yumbah is the only present light source, comprising two small security lights.

62 Draft EIS Executive Summary p40 63 Draft EIS Executive Summary p41

The proposed lighting system at the new facility is likely to be similar to existing lighting from the nearby onshore aquaculture facility. The KI Seaport’s lights would likely blend into the existing lighting of the abalone farm and thus the cumulative impact of additional lighting is expected to be low63.

Comparing the proposed operational seaport’s expected flood of light – evidenced by the operations at the Port of Portland – to the small security lights of Yumbah is disingenuous. In the claimed accumulation of impact, the baseline is zero, and the cumulative effect is all KIPT.


106

The findings highlight concerns with the assessment of noise and vibration in the draft EIS, including:

• Assessment of construction noise has not been completed. The lack of this demands KIPT take the impact of its proposal on neighbours, amenity and environment more seriously

• An assessment of the efficiency of proposed noise mitigation measures is necessary

• Information in the main report contradicts the recommendations of the acoustic report regarding what noise mitigation measures should be implemented to meet the relevant noise criteria for the nearest residential receivers

• Noise from the development is not expected to meet the applicable criteria for Yumbah’s abalone farm. The acoustic report in the draft EIS does not adequately explain why it is not practicable to achieve the criteria and how this will affect the abalone farm

• Local meteorological conditions, particularly background conditions, have not been adequately considered in the assessment. The criteria under SA Noise EPP does not depend on the pre-existing background level but rather on the zoning of the noise source and the relevant receivers

• The main report in the draft EIS summarises a traffic noise assessment, yet data on traffic inputs relevant to predicting noise impact are not provided. The draft EIS simply claims traffic noise complies with requirements in the DPTI Road Traffic Noise Guidelines. But the proponent fails to present the method of its traffic noise predictions, locations of affected receivers and predicted traffic noise levels

• More information is required to validate KIPT’s assumptions

UNDERWATER NOISE

An underwater noise assessment forms part of KIPT’s acoustic report (Appendix N). However, there are no regulatory documents applicable to the company’s assessment that establish standards for compliance.

The South Australian Government’s Underwater Piling Noise Guidelines 2012 report provides details on pile driving noise. Underwater vibration assessment is not mandated by any regulatory documents, and guidance on this kind of impact is lacking. Therefore, it does not form part of the submitted draft EIS.

The acoustic report details an underwater background noise assessment. Levels typical for the current environment are around 90-120 dB depending on weather conditions and other environmental factors.



109

The adverse consequences of increased water temperature on abalone are acknowledged in Appendix H: “Likely increases in water temperature accentuated by recirculation of Yumbah effluent water will also have a harmful effect on abalone. Data collected for the EIS throughout 2017, using moored data buoys that were equipped with a suite of water quality and hydrodynamic sensors (detailed in Chapter 10), show that mean seawater temperature during the monitoring period at Smith Bay within 300 m of shore during summer was around 21-22oC but there were spikes up to 25oC recorded during heatwaves (see Chapter 9) (Appendix H, Page 27). As Cheshire (2018) further notes: many farms across South Australia have reported substantial mortality events at much lower temperatures (22-23oC; Vandepeer 2006).”

STORMWATER MANAGEMENT NOT UP TO THE TASK

The setback of stormwater retention ponds in the draft EIS is not adequate to protect against storm events and sea-level rise. The influence of interconnectivity of Smith Bay with shallow groundwater aquifers beneath the site may impact stormwater retention ponds.

ABALONE ARE “SENSITIVE RECEPTORS”

Abalone are adaptive and will evolve with expected increases in temperature projected at 0.5°C by 2030, and by 0.2°C and 2.2°C by 2090 under the intermediate- and high-emissions scenario, respectively. Genetic selection of broodstock to tolerate higher temperatures and improvements in husbandry and diet are expected to improve tolerance to warming average temperatures.

Abalone are less adaptive to sudden changes in water temperature which is more likely with the impact of the solid causeway on mixing and circulation of water close to Yumbah KI’s intake pipes.


KIPT’S strident advocacy for a Smith Bay seaport is more unusual for the fact that it is the most remote site of all those on offer, far away from the timber plantations. For a company intent on being a “green” industry, KIPT is imposing on itself an unnecessary carbon debt from transport emissions.

Its choice of Smith Bay does not support the principles of resource efficiency and sustainability.

A seaport closer to the timber resource, and connected to the electricity grid, would produce fewer direct greenhouse gas emissions, cut the fuel bill (and emissions) from KIPT’s round-number estimate of 500 000 litres of diesel. This is an estimate that assumes no connection to the electricity grid and generators being the primary power supply.

COASTAL BLUE CARBON ECOSYSTEMS

The term ‘coastal blue carbon ecosystems’ refers to three main types of vegetated coastal habitats: mangroves, tidal marshes and seagrasses.

In recent years, there has been significant development in the science – with associated policy development – to understand the role of the intertidal marine ecosystems of seagrasses, mangroves and saltmarshes and their contribution


108

GUIDELINE 13:

CLIMATE CHANGE & SUSTAINABILITY

DESCRIPTION:

Climate change is of State, National and global importance. This proposal includes elements adjacent to, and within, the coast and seabed. Measures need to be taken to both protect the proposed infrastructure in the longer term from the impacts of a changing climate and reduce any greenhouse gas emissions associated with its construction and use.

RESPONSE SUMMARY

• The proposed solid causeway will produce a “Climate Change” event for Yumbah KI

• Yumbah is expert on Smith Bay

o Yumbah manages climate risks for its own operation

o Water temperature and quality are under a continuous monitoring regime

o Increased frequency of storm events and tidal extremities is noted

o Infrastructure is built and upgraded to meet conditions

• KIPT is the greatest and immediate

threat to Yumbah

o Climate change presents a global threat

o Yumbah tracks change and factors this in its daily operations and long-term planning

o KIPT is the immediate, mortal threat to Smith Bay environment and business

Yumbah has observed climatic variability in Smith Bay over more than 20 years. It holds water quality data from the start of its operations, with correlating weather, tide and storm event information and observations.

It’s clear Yumbah knows Smith Bay. KIPT does not.

Climate change won’t force Yumbah out of business. The accumulated shocks and massive risk profile of KIPT being granted a green light for its proposed Smith Bay project will force Yumbah KI out of business and irrevocably damage Smith Bay on land, sea and in the air.

The draft EIS provides further self-serving commentary by KIPT in relation to climate change.

SOLID CAUSWAY IMPACTS

The predicted modelled effects of the proposal on water circulation, flushing and water temperatures are provided in KIPT’s draft EIS Appendix G (Coastal Processes). According to Romero (2019) KIPT’s proposed construction of a 250m causeway will substantially affect nearshore water movement in Smith Bay. The draft EIS indicates that reduction in current speed at Yumbah’s westerly seawater intake will be about 30–40 per cent (Appendix H, page 65): this will coincide with an increase in ambient seawater temperature (Appendix G, page 23).



109

The adverse consequences of increased water temperature on abalone are acknowledged in Appendix H: “Likely increases in water temperature accentuated by recirculation of Yumbah effluent water will also have a harmful effect on abalone. Data collected for the EIS throughout 2017, using moored data buoys that were equipped with a suite of water quality and hydrodynamic sensors (detailed in Chapter 10), show that mean seawater temperature during the monitoring period at Smith Bay within 300 m of shore during summer was around 21-22oC but there were spikes up to 25oC recorded during heatwaves (see Chapter 9) (Appendix H, Page 27). As Cheshire (2018) further notes: many farms across South Australia have reported substantial mortality events at much lower temperatures (22-23oC; Vandepeer 2006).”

STORMWATER MANAGEMENT NOT UP TO THE TASK

The setback of stormwater retention ponds in the draft EIS is not adequate to protect against storm events and sea-level rise. The influence of interconnectivity of Smith Bay with shallow groundwater aquifers beneath the site may impact stormwater retention ponds.

ABALONE ARE “SENSITIVE RECEPTORS”

Abalone are adaptive and will evolve with expected increases in temperature projected at 0.5°C by 2030, and by 0.2°C and 2.2°C by 2090 under the intermediate- and high-emissions scenario, respectively. Genetic selection of broodstock to tolerate higher temperatures and improvements in husbandry and diet are expected to improve tolerance to warming average temperatures.

Abalone are less adaptive to sudden changes in water temperature which is more likely with the impact of the solid causeway on mixing and circulation of water close to Yumbah KI’s intake pipes.


KIPT’S strident advocacy for a Smith Bay seaport is more unusual for the fact that it is the most remote site of all those on offer, far away from the timber plantations. For a company intent on being a “green” industry, KIPT is imposing on itself an unnecessary carbon debt from transport emissions.

Its choice of Smith Bay does not support the principles of resource efficiency and sustainability.

A seaport closer to the timber resource, and connected to the electricity grid, would produce fewer direct greenhouse gas emissions, cut the fuel bill (and emissions) from KIPT’s round-number estimate of 500 000 litres of diesel. This is an estimate that assumes no connection to the electricity grid and generators being the primary power supply.

COASTAL BLUE CARBON ECOSYSTEMS

The term ‘coastal blue carbon ecosystems’ refers to three main types of vegetated coastal habitats: mangroves, tidal marshes and seagrasses.

In recent years, there has been significant development in the science – with associated policy development – to understand the role of the intertidal marine ecosystems of seagrasses, mangroves and saltmarshes and their contribution


108

GUIDELINE 13:

CLIMATE CHANGE & SUSTAINABILITY

DESCRIPTION:

Climate change is of State, National and global importance. This proposal includes elements adjacent to, and within, the coast and seabed. Measures need to be taken to both protect the proposed infrastructure in the longer term from the impacts of a changing climate and reduce any greenhouse gas emissions associated with its construction and use.

RESPONSE SUMMARY

• The proposed solid causeway will produce a “Climate Change” event for Yumbah KI

• Yumbah is expert on Smith Bay

o Yumbah manages climate risks for its own operation

o Water temperature and quality are under a continuous monitoring regime

o Increased frequency of storm events and tidal extremities is noted

o Infrastructure is built and upgraded to meet conditions

• KIPT is the greatest and immediate

threat to Yumbah

o Climate change presents a global threat

o Yumbah tracks change and factors this in its daily operations and long-term planning

o KIPT is the immediate, mortal threat to Smith Bay environment and business

Yumbah has observed climatic variability in Smith Bay over more than 20 years. It holds water quality data from the start of its operations, with correlating weather, tide and storm event information and observations.

It’s clear Yumbah knows Smith Bay. KIPT does not.

Climate change won’t force Yumbah out of business. The accumulated shocks and massive risk profile of KIPT being granted a green light for its proposed Smith Bay project will force Yumbah KI out of business and irrevocably damage Smith Bay on land, sea and in the air.

The draft EIS provides further self-serving commentary by KIPT in relation to climate change.

SOLID CAUSWAY IMPACTS

The predicted modelled effects of the proposal on water circulation, flushing and water temperatures are provided in KIPT’s draft EIS Appendix G (Coastal Processes). According to Romero (2019) KIPT’s proposed construction of a 250m causeway will substantially affect nearshore water movement in Smith Bay. The draft EIS indicates that reduction in current speed at Yumbah’s westerly seawater intake will be about 30–40 per cent (Appendix H, page 65): this will coincide with an increase in ambient seawater temperature (Appendix G, page 23).



111

GUIDELINE 14:

RISKS & HAZARDS

DESCRIPTION:

The Kangaroo Island Development Plan, and the South Australian Planning Strategy promote development, including infrastructure, to be located away from areas that are vulnerable to the risk of hazards for both the protection of human health and the environment. Given the location of the proposed development, the following hazards include, but are not limited to: spills (including oil), flooding, fire (in particular heavy vehicle, timber yard and bushfire), site contamination, storage and movement of hazardous materials and landslip/coastal erosion. All risks and hazards need to be detailed and consideration given to how these risks and hazards will be avoided and managed.

RESPONSE SUMMARY

The risks and hazards associated with a seaport at Smith Bay are many - and potentially devastating. Chemical spills and fuel spills are an inevitable part of seaport operations, timber fumigation is a standard feature of ports handling logs, as is chemical leaching from timber used in construction or stored at the port. The draft EIS suggests mitigation of some of these risks but acknowledges there is nothing that can be done to eliminate them.

It’s curious and worrying that the draft EIS expects timber exporting at KIPT’s seaport to account for just 20 per cent of the seaport’s capacity.

Obviously, for KIPT shareholders to earn a commercial return, KIPT will have to identify and cater for alternative uses for the port.

But on these alternative uses, the draft EIS is silent.

KIPT and the draft EIS fail to reveal, identify or consider the risks and hazards associated with other uses for its multi-use facility.

• Chemical spills

o KIPT admits that fuel/oil and chemical spills will be an inevitable part of the development

o The company suggests it will be able to minimise these with “standards and protocols”, but not stop them

o Who sets the standards and protocols? Who agrees, who monitors them, who assumes responsibility and accounts for risk when things go wrong?

• Alternative uses of the port

o KIPT admits timber exporting from the seaport will put the port at 20 per cent capacity

o There is vague mention in the draft EIS that the seaport design has capacity for additional vessels and associated cargo

o The infrastructure will be established for the timber industry and will be inappropriate for other uses.

o Yet it – and the company arguing its case in the draft EIS – is silent on what these other uses may be, meaning any subsequent economic, social and


110

to carbon dioxide bio-sequestration and emissions reduction64.

Improved management of carbon rich ecosystems can also improve fisheries and increase resilience of coasts to rising sea levels and storm surges.

Intertidal habitats, particularly seagrass meadows, are recognised globally as having the greatest carbon sequestration potential, far greater than sequestration potential by terrestrial forests.

The draft EIS’s intent to remove 10 hectares of seagrass and create trails of sediment in Smith Bay will contribute large amounts of CO2 into the atmosphere. which will continue into a future well beyond that which KIPT foresees.

The seagrass meadow cannot be replanted in the hope of acting as a new carbon sink.

As part of a more comprehensive and accountable EIS than the existing draft, KIPT must assess the carbon sequestration of their timber plantation compared with the carbon capture potential in the seabed it proposes to dredge.

64 https://www.environment.gov.au/climate-change/government/australia-work-on-blue-carbon 65 EIS Executive Summary p42


• The total carbon sequestration of the KIPT-managed plantations is conservatively estimated to be approximately 6.8 million tonnes of CO2 -e.

As individual plantations are expected to be replanted or coppiced following first harvest, this amount of sequestration would remain relatively constant over the life of the operation.65



111

GUIDELINE 14:

RISKS & HAZARDS

DESCRIPTION:

The Kangaroo Island Development Plan, and the South Australian Planning Strategy promote development, including infrastructure, to be located away from areas that are vulnerable to the risk of hazards for both the protection of human health and the environment. Given the location of the proposed development, the following hazards include, but are not limited to: spills (including oil), flooding, fire (in particular heavy vehicle, timber yard and bushfire), site contamination, storage and movement of hazardous materials and landslip/coastal erosion. All risks and hazards need to be detailed and consideration given to how these risks and hazards will be avoided and managed.

RESPONSE SUMMARY

The risks and hazards associated with a seaport at Smith Bay are many - and potentially devastating. Chemical spills and fuel spills are an inevitable part of seaport operations, timber fumigation is a standard feature of ports handling logs, as is chemical leaching from timber used in construction or stored at the port. The draft EIS suggests mitigation of some of these risks but acknowledges there is nothing that can be done to eliminate them.

It’s curious and worrying that the draft EIS expects timber exporting at KIPT’s seaport to account for just 20 per cent of the seaport’s capacity.

Obviously, for KIPT shareholders to earn a commercial return, KIPT will have to identify and cater for alternative uses for the port.

But on these alternative uses, the draft EIS is silent.

KIPT and the draft EIS fail to reveal, identify or consider the risks and hazards associated with other uses for its multi-use facility.

• Chemical spills

o KIPT admits that fuel/oil and chemical spills will be an inevitable part of the development

o The company suggests it will be able to minimise these with “standards and protocols”, but not stop them

o Who sets the standards and protocols? Who agrees, who monitors them, who assumes responsibility and accounts for risk when things go wrong?

• Alternative uses of the port

o KIPT admits timber exporting from the seaport will put the port at 20 per cent capacity

o There is vague mention in the draft EIS that the seaport design has capacity for additional vessels and associated cargo

o The infrastructure will be established for the timber industry and will be inappropriate for other uses.

o Yet it – and the company arguing its case in the draft EIS – is silent on what these other uses may be, meaning any subsequent economic, social and


110

to carbon dioxide bio-sequestration and emissions reduction64.

Improved management of carbon rich ecosystems can also improve fisheries and increase resilience of coasts to rising sea levels and storm surges.

Intertidal habitats, particularly seagrass meadows, are recognised globally as having the greatest carbon sequestration potential, far greater than sequestration potential by terrestrial forests.

The draft EIS’s intent to remove 10 hectares of seagrass and create trails of sediment in Smith Bay will contribute large amounts of CO2 into the atmosphere. which will continue into a future well beyond that which KIPT foresees.

The seagrass meadow cannot be replanted in the hope of acting as a new carbon sink.

As part of a more comprehensive and accountable EIS than the existing draft, KIPT must assess the carbon sequestration of their timber plantation compared with the carbon capture potential in the seabed it proposes to dredge.

64 https://www.environment.gov.au/climate-change/government/australia-work-on-blue-carbon 65 EIS Executive Summary p42


• The total carbon sequestration of the KIPT-managed plantations is conservatively estimated to be approximately 6.8 million tonnes of CO2 -e.

As individual plantations are expected to be replanted or coppiced following first harvest, this amount of sequestration would remain relatively constant over the life of the operation.65



113

o Vehicle strikes already kill on average 35 Kangaroo Island Echidnas each year, this number will increase significantly with increased traffic from timber transport to Smith Bay

o Whales have the potential to be severely impacted by the seaport, with predicted behavioural changes in response to noise, including construction and vessel noise if in a proximal location

UNACCEPTABLE HAZARDS AND RISKS

Safe Work Australia describes hazards and risks as66:

• Hazards – Situations or things that have the potential to harm

• Risks – The possibility that harm might occur when exposed to a hazard

The multiple hazards – some known, many unknown – in establishing and operating KIPT’s proposed seaport at Smith Bay directly adjacent to Yumbah KI cannot be satisfactorily addressed to provide confidence for Yumbah to confidently continue its business.

KIPT’s draft EIS is negligent in assessments of social, economic and environmental risks of its proposed seaport at Smith Bay. The company’s draft EIS consideration and respect of potential hazards and subsequent risks to Yumbah KI is patchwork, disorganised and routinely presents misleading opinion as science.

66 https://www.safeworkaustralia.gov.au/glossary#risks 67 https://www.abc.net.au/news/2017-03-10/timber-company-ordered-to-stop-drilling-off-kangaroo-island/8342338

Yumbah KI is already compatible and well-aligned with the Rural Living Zone. Its footprint and proven performance over more than 20 years have had no impact on the Coastal Conservation Zone that makes Smith Bay such an idyllic location.

To justify its dogma on Smith Bay as the only location it will consider on KI, KIPT argues for this location, infrastructure, construction methodology, operational conditions and apparent benefits in a Risk Assessment as Appendix T in its draft EIS.

Fundamentally, this risk assessment does not accurately nor adequately reflect actual and perceived risks and hazards of its Smith Bay proposal. The Risk Assessment does not align with the details and conclusions of the technical assessments in the draft EIS, and proposed risk mitigation and management measures are negligent and unconvincing.

A POOR TRACK RECORD

The consequences of a realised risk from KIPT’s seaport constitute an overwhelming economic threat to the existing business of Yumbah KI.

Put simply, mitigation and management measures are not always effective. In the case of KIPT, it has already set an exceedingly low bar in in preparing its draft EIS.

In 2017, KIPT was issued a “cease and desist” order from the South Australian Government after it failed to obtain the required approvals to drill in Smith Bay67. When the company later managed to gain the required approval, its activities caused significant damage to the seagrass floor of


112

environmental impact or implications for KI are also absent

o A credible business has a Plan B and a Plan C

o In the absence of a complete business case for this seaport, there is no means of testing the environmental impact of this proposal running at 20 per cent capacity

o It simply doesn’t stack up particularly when KIPT now owns a significant 225ha of coastal land abutting Smith Bay

• Woodchip mill/QA

screening/bioenergy

o KIPT’s Project Description says “…woodchipping may be undertaken at an off-plantation woodchipping facility located along the core transport route between the plantation and Smith Bay”

o It may argue such a development would be subject to other planning measures

o The seaport proposal has already morphed into something different to that addressed in the draft EIS

o Whether this possible woodchip mill is off Smith Bay or on Smith Bay, it must be detailed and assessed in this draft EIS

o KIPT’s Project Description says, “Woodchip quality control processes may be undertaken at the plantation following primary woodchipping, or at an intermediate facility”

o As above, particularly if this activity is to be at Smith Bay, it should be detailed in the draft EIS

o KIPT and Kangaroo Island Council have discussed using timber by-product in a bioenergy plant

o A responsible proponent would include this possibility in its draft EIS, detailing the project itself, its location – especially if at Smith Bay, and its impact, particularly a traffic and air/land pollution analysis • Leaching from treated timber used

in construction

o The draft EIS fails to address the impacts of treated timber used in wharf construction

o KIPT has not accounted for any chemical leaching from timber stored at the seaport

o The concentration of leachate discharged stormwater retention basins into the marine environment is unknown

• Fumigation at the port

o Will the port handle raw timber or is there a treatment process prior to export?

o Will KIPT fumigate logs in future as occurs at other ports around the country?

o These create additional significant risks to Smith Bay’s integrity and the operations of Yumbah KI

o What approvals or permits are required if future fumigation is considered?

o What is KIPT’s plan for consultation with regulators, neighbours and wider community?

o These are neither mentioned nor acknowledged in KIPT’s draft EIS

• MNES

o Impacts to MNES, namely southern right whales and echidnas, are of paramount concern to the wider community



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o Vehicle strikes already kill on average 35 Kangaroo Island Echidnas each year, this number will increase significantly with increased traffic from timber transport to Smith Bay

o Whales have the potential to be severely impacted by the seaport, with predicted behavioural changes in response to noise, including construction and vessel noise if in a proximal location

UNACCEPTABLE HAZARDS AND RISKS

Safe Work Australia describes hazards and risks as66:

• Hazards – Situations or things that have the potential to harm

• Risks – The possibility that harm might occur when exposed to a hazard

The multiple hazards – some known, many unknown – in establishing and operating KIPT’s proposed seaport at Smith Bay directly adjacent to Yumbah KI cannot be satisfactorily addressed to provide confidence for Yumbah to confidently continue its business.

KIPT’s draft EIS is negligent in assessments of social, economic and environmental risks of its proposed seaport at Smith Bay. The company’s draft EIS consideration and respect of potential hazards and subsequent risks to Yumbah KI is patchwork, disorganised and routinely presents misleading opinion as science.

66 https://www.safeworkaustralia.gov.au/glossary#risks 67 https://www.abc.net.au/news/2017-03-10/timber-company-ordered-to-stop-drilling-off-kangaroo-island/8342338

Yumbah KI is already compatible and well-aligned with the Rural Living Zone. Its footprint and proven performance over more than 20 years have had no impact on the Coastal Conservation Zone that makes Smith Bay such an idyllic location.

To justify its dogma on Smith Bay as the only location it will consider on KI, KIPT argues for this location, infrastructure, construction methodology, operational conditions and apparent benefits in a Risk Assessment as Appendix T in its draft EIS.

Fundamentally, this risk assessment does not accurately nor adequately reflect actual and perceived risks and hazards of its Smith Bay proposal. The Risk Assessment does not align with the details and conclusions of the technical assessments in the draft EIS, and proposed risk mitigation and management measures are negligent and unconvincing.

A POOR TRACK RECORD

The consequences of a realised risk from KIPT’s seaport constitute an overwhelming economic threat to the existing business of Yumbah KI.

Put simply, mitigation and management measures are not always effective. In the case of KIPT, it has already set an exceedingly low bar in in preparing its draft EIS.

In 2017, KIPT was issued a “cease and desist” order from the South Australian Government after it failed to obtain the required approvals to drill in Smith Bay67. When the company later managed to gain the required approval, its activities caused significant damage to the seagrass floor of


112

environmental impact or implications for KI are also absent

o A credible business has a Plan B and a Plan C

o In the absence of a complete business case for this seaport, there is no means of testing the environmental impact of this proposal running at 20 per cent capacity

o It simply doesn’t stack up particularly when KIPT now owns a significant 225ha of coastal land abutting Smith Bay

• Woodchip mill/QA

screening/bioenergy

o KIPT’s Project Description says “…woodchipping may be undertaken at an off-plantation woodchipping facility located along the core transport route between the plantation and Smith Bay”

o It may argue such a development would be subject to other planning measures

o The seaport proposal has already morphed into something different to that addressed in the draft EIS

o Whether this possible woodchip mill is off Smith Bay or on Smith Bay, it must be detailed and assessed in this draft EIS

o KIPT’s Project Description says, “Woodchip quality control processes may be undertaken at the plantation following primary woodchipping, or at an intermediate facility”

o As above, particularly if this activity is to be at Smith Bay, it should be detailed in the draft EIS

o KIPT and Kangaroo Island Council have discussed using timber by-product in a bioenergy plant

o A responsible proponent would include this possibility in its draft EIS, detailing the project itself, its location – especially if at Smith Bay, and its impact, particularly a traffic and air/land pollution analysis • Leaching from treated timber used

in construction

o The draft EIS fails to address the impacts of treated timber used in wharf construction

o KIPT has not accounted for any chemical leaching from timber stored at the seaport

o The concentration of leachate discharged stormwater retention basins into the marine environment is unknown

• Fumigation at the port

o Will the port handle raw timber or is there a treatment process prior to export?

o Will KIPT fumigate logs in future as occurs at other ports around the country?

o These create additional significant risks to Smith Bay’s integrity and the operations of Yumbah KI

o What approvals or permits are required if future fumigation is considered?

o What is KIPT’s plan for consultation with regulators, neighbours and wider community?

o These are neither mentioned nor acknowledged in KIPT’s draft EIS

• MNES

o Impacts to MNES, namely southern right whales and echidnas, are of paramount concern to the wider community



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marine species, including endangered and threatened species

• Economic – significant economic implications exist with the proximity of the seaport to Yumbah KI and the operations of many adjacent and Smith Bay-dependent small business

• Biosecurity – KIPT’s actions at Smith Bay will inevitably introduce invasive marine pests and disease agents that will immediately jeopardise Yumbah KI’s operations

• Suspended solids – the zone of influence (i.e. extent of detectable plumes with no predicted ecological impact) is predicted to extend east and west along the coastline for approximately 5–6km for the expected case and approximately 8km for the worst case

• Oceanic circulation – causeway construction will significantly impact sea currents and the accumulation of wrack

• Contamination – potential to likely contamination of the environment from stored logs and woodchip piles

• Reliance on third parties – KIPT alleges it has secured supply chain partnerships that effectively outsource many of the accountabilities that would be assumed by a responsible entity. There is no accommodation of this third-party dependence in the draft EIS, which seems more than an oversight given so much risk in

construction and operations is being off-shored by KIPT

MISSING DREDGE MANAGEMENT PLAN

The draft EIS clearly recognises that there are no clear environmental windows that offer the opportunity to significantly reduce impacts associated with dredging. Further recognition is granted to that although dredging during winter rather than summer would avoid sensitive periods for the reproduction of seagrasses and invertebrates, it would not benefit macroalgae, which reproduces in winter, and southern right whales, which may visit the area during winter. Consequently, the draft EIS concludes there are no persuasive ecological arguments for dredging during a particular season.

How can a Dredge Management Plan consider the risks that will result at varying degrees no matter what time of the year this hazardous activity will be performed? A Dredge Management Plan has been excluded from KIPT’s draft EIS. This is a major concern for Yumbah given KIPT’s deficient performance during what should have been straightforward sediment investigations in 2017.

Yumbah has no confidence, nor does it believe should the South Australian and Australian Governments, in the potential performance of this proponent.

RISK OF PROJECT FAILURE IN EITHER THE CONSTRUCTION OR OPERATION PHASE

If the Seaport project fails financially in either the construction or operation phase there is the real prospect of a dangerous and unmaintained shipwreck wharf structure posing a physical hazard to those who work and recreate in Smith Bay. The


114

Smith Bay68 apparently because its contractors were using “the wrong type of anchor”.

With this incident alone as its starting point, we have no confidence this company can meet even its own commitments on risk management.

Further, all management measures would need to be effective in perpetuity as the risks posed to Yumbah KI by this seaport are perpetual to Yumbah.

This is a high bar even for the best proponent.

For a proponent with no experience of the infrastructure it plans and deliberately ignorant of the highly-specialised business it most threatens – Yumbah – it’s an impossible ask.

For a company that outsources its forestry operation, has agreements with Mitsui to run its port operation, has separated its wharf assets to facilitate an easy sale and wants others to assist it with managing biosecurity risks, it is far from clear who will be around to clean up the mess caused by the manifestation of risk and who will be held accountable.

To set and to comply with, and simply aspiring to, best practice is no remedy.

Saying “sorry” for destruction of an existing successful, growing business through a management oversight will be costly.

The very high probability of catastrophic consequence from a seaport at Smith Bay is the result of KIPT’s failure to prove that the task of removing its trees from Kangaroo Island cannot be achieved at

68 https://www.theislanderonline.com.au/story/5659505/commercial-fishermen-voice-concerns-over-proposed-smith-bay-seaport/

69 EIS Main Report, Page 18 70 EIS Main Report, Page 32 71 EIS Main Report, Page 5.

another of the many appropriate and available locations on an island with 500km of coastline.

KIPT admits that a “chips only” operation can be established at three alternative sites other than Smith Bay69.

KIPT says 80 per cent of its plantation estate is hardwood and 20 per cent softwood70, with just a small proportion of softwood to be exported as logs71.

If woodchips are where the business is, and other sites are possible and available – then why is there such intent to make Yumbah KI unviable and, with it, Smith Bay?

HAZARDS FOR YUMBAH

Yumbah has identified multiple hazards posed to its operations by KIPT’s Smith Bay seaport proposal. Below is not an exhaustive list, and detail is addressed elsewhere in this document. The list would likely be longer if KIPT’s actual intent was known, and its draft EIS considered more recent expansions of its plans for Smith Bay.

• Preferred location – a seaport at Smith Bay presents social, economic and environmental risks that may be catastrophic to human health and the environment

• Environment – as a Coastal Conservation Zone, the environment of Smith Bay is populated with terrestrial and



115

marine species, including endangered and threatened species

• Economic – significant economic implications exist with the proximity of the seaport to Yumbah KI and the operations of many adjacent and Smith Bay-dependent small business

• Biosecurity – KIPT’s actions at Smith Bay will inevitably introduce invasive marine pests and disease agents that will immediately jeopardise Yumbah KI’s operations

• Suspended solids – the zone of influence (i.e. extent of detectable plumes with no predicted ecological impact) is predicted to extend east and west along the coastline for approximately 5–6km for the expected case and approximately 8km for the worst case

• Oceanic circulation – causeway construction will significantly impact sea currents and the accumulation of wrack

• Contamination – potential to likely contamination of the environment from stored logs and woodchip piles

• Reliance on third parties – KIPT alleges it has secured supply chain partnerships that effectively outsource many of the accountabilities that would be assumed by a responsible entity. There is no accommodation of this third-party dependence in the draft EIS, which seems more than an oversight given so much risk in

construction and operations is being off-shored by KIPT

MISSING DREDGE MANAGEMENT PLAN

The draft EIS clearly recognises that there are no clear environmental windows that offer the opportunity to significantly reduce impacts associated with dredging. Further recognition is granted to that although dredging during winter rather than summer would avoid sensitive periods for the reproduction of seagrasses and invertebrates, it would not benefit macroalgae, which reproduces in winter, and southern right whales, which may visit the area during winter. Consequently, the draft EIS concludes there are no persuasive ecological arguments for dredging during a particular season.

How can a Dredge Management Plan consider the risks that will result at varying degrees no matter what time of the year this hazardous activity will be performed? A Dredge Management Plan has been excluded from KIPT’s draft EIS. This is a major concern for Yumbah given KIPT’s deficient performance during what should have been straightforward sediment investigations in 2017.

Yumbah has no confidence, nor does it believe should the South Australian and Australian Governments, in the potential performance of this proponent.

RISK OF PROJECT FAILURE IN EITHER THE CONSTRUCTION OR OPERATION PHASE

If the Seaport project fails financially in either the construction or operation phase there is the real prospect of a dangerous and unmaintained shipwreck wharf structure posing a physical hazard to those who work and recreate in Smith Bay. The


114

Smith Bay68 apparently because its contractors were using “the wrong type of anchor”.

With this incident alone as its starting point, we have no confidence this company can meet even its own commitments on risk management.

Further, all management measures would need to be effective in perpetuity as the risks posed to Yumbah KI by this seaport are perpetual to Yumbah.

This is a high bar even for the best proponent.

For a proponent with no experience of the infrastructure it plans and deliberately ignorant of the highly-specialised business it most threatens – Yumbah – it’s an impossible ask.

For a company that outsources its forestry operation, has agreements with Mitsui to run its port operation, has separated its wharf assets to facilitate an easy sale and wants others to assist it with managing biosecurity risks, it is far from clear who will be around to clean up the mess caused by the manifestation of risk and who will be held accountable.

To set and to comply with, and simply aspiring to, best practice is no remedy.

Saying “sorry” for destruction of an existing successful, growing business through a management oversight will be costly.

The very high probability of catastrophic consequence from a seaport at Smith Bay is the result of KIPT’s failure to prove that the task of removing its trees from Kangaroo Island cannot be achieved at

68 https://www.theislanderonline.com.au/story/5659505/commercial-fishermen-voice-concerns-over-proposed-smith-bay-seaport/

69 EIS Main Report, Page 18 70 EIS Main Report, Page 32 71 EIS Main Report, Page 5.

another of the many appropriate and available locations on an island with 500km of coastline.

KIPT admits that a “chips only” operation can be established at three alternative sites other than Smith Bay69.

KIPT says 80 per cent of its plantation estate is hardwood and 20 per cent softwood70, with just a small proportion of softwood to be exported as logs71.

If woodchips are where the business is, and other sites are possible and available – then why is there such intent to make Yumbah KI unviable and, with it, Smith Bay?

HAZARDS FOR YUMBAH

Yumbah has identified multiple hazards posed to its operations by KIPT’s Smith Bay seaport proposal. Below is not an exhaustive list, and detail is addressed elsewhere in this document. The list would likely be longer if KIPT’s actual intent was known, and its draft EIS considered more recent expansions of its plans for Smith Bay.

• Preferred location – a seaport at Smith Bay presents social, economic and environmental risks that may be catastrophic to human health and the environment

• Environment – as a Coastal Conservation Zone, the environment of Smith Bay is populated with terrestrial and



117

GUIDELINE 15:

INFRASTRUCTURE

DESCRIPTION:

The construction and operation of a port and wharf, such as that proposed at Smith Bay, will require specific infrastructure, equipment and utility needs. These need to be identified and consideration given to how these requirements will be met, and how any increased demand will impact upon existing users.

RESPONSE SUMMARY

• Yumbah Aquaculture pre-existing infrastructure

o Draft EIS fails to recognise highly-specialised abalone farm infrastructure

• Causeway incompatible with Yumbah KI operation

o Seaport proposal includes a rock-armoured solid causeway extending 250m offshore – longer than that originally proposed to the DAC

o Causeway construction proposes materials derived from dredging. Draft EIS fails to understand what materials are in Smith Bay to dredge

o Causeway impact will be perpetual, not just a construction issue

• Impermeable barrier will block, change oceanic currents

o Current directions periodically alternate between the dominant directions of easterly during flood tides and westerly during ebb tides

o Draft EIS says currents will reduce by 30-40 per cent

o Changed ocean mixing and flushing increase water temperature

• Draft EIS proposes ineffective mitigation, says it’s “unnecessary”

o Draft EIS indicates causeway gates or culverts will help water exchange

o Proponent doesn’t provide detail – but further indicates it doesn’t support this


116

draft EIS is silent on reserving funding to guarantee the decommission of the wharf and the return of the coast and the seabed to its former condition.

QUESTIONABLE EXPERT OPINION

Yumbah knows its highly specialised business. Yumbah has grave concerns about KIPT’s knowledge of such a highly specialised area, and the knowledge of its advisors, including its employment of Professor Anthony Cheshire as the author of sections of the draft EIS.

Professor Cheshire does not have recognised expertise in contemporary onshore abalone farming which is clear from the numerous mistakes and flawed assumptions contained in his report 72. His role advising a collapsed offshore abalone farm investment is well known. The impacts of this venture are still being felt by investors, community and a jailed former chief executive.

In this draft EIS, his contribution should not be regarded as any better than personal observation.

72 See AAGA document

A RE-ASSESSMENT IS REQUIRED

KIPT’s draft EIS emphasises tangible risks to Yumbah KI if a seaport is established at Smith Bay. KIPT’s claim it will provide a net benefit to Yumbah KI is fanciful and uninformed.

A more detailed, accurate risk assessment of actual construction and operations must be demanded of KIPT with consideration of Yumbah KI’s review of the inadequate risk assessment in the draft EIS.

The risk assessment and corresponding matrix in Appendix T are problematic. Inclusion of rudimentary mitigation and management measures often result in reductions to residual likelihood and consequence. However, management measures can only reduce residual likelihood, not residual consequence. As such the residual risks are misleading and do not reflect the actual risk level.

Several mitigation and management measures have been specified that are unlikely to be firm commitments of KIPT.

In its current format, particularly the outcomes based on the risk categorisation, the draft EIS cannot be relied on to inform the project.



117

GUIDELINE 15:

INFRASTRUCTURE

DESCRIPTION:

The construction and operation of a port and wharf, such as that proposed at Smith Bay, will require specific infrastructure, equipment and utility needs. These need to be identified and consideration given to how these requirements will be met, and how any increased demand will impact upon existing users.

RESPONSE SUMMARY

• Yumbah Aquaculture pre-existing infrastructure

o Draft EIS fails to recognise highly-specialised abalone farm infrastructure

• Causeway incompatible with Yumbah KI operation

o Seaport proposal includes a rock-armoured solid causeway extending 250m offshore – longer than that originally proposed to the DAC

o Causeway construction proposes materials derived from dredging. Draft EIS fails to understand what materials are in Smith Bay to dredge

o Causeway impact will be perpetual, not just a construction issue

• Impermeable barrier will block, change oceanic currents

o Current directions periodically alternate between the dominant directions of easterly during flood tides and westerly during ebb tides

o Draft EIS says currents will reduce by 30-40 per cent

o Changed ocean mixing and flushing increase water temperature

• Draft EIS proposes ineffective mitigation, says it’s “unnecessary”

o Draft EIS indicates causeway gates or culverts will help water exchange

o Proponent doesn’t provide detail – but further indicates it doesn’t support this


116

draft EIS is silent on reserving funding to guarantee the decommission of the wharf and the return of the coast and the seabed to its former condition.

QUESTIONABLE EXPERT OPINION

Yumbah knows its highly specialised business. Yumbah has grave concerns about KIPT’s knowledge of such a highly specialised area, and the knowledge of its advisors, including its employment of Professor Anthony Cheshire as the author of sections of the draft EIS.

Professor Cheshire does not have recognised expertise in contemporary onshore abalone farming which is clear from the numerous mistakes and flawed assumptions contained in his report 72. His role advising a collapsed offshore abalone farm investment is well known. The impacts of this venture are still being felt by investors, community and a jailed former chief executive.

In this draft EIS, his contribution should not be regarded as any better than personal observation.

72 See AAGA document

A RE-ASSESSMENT IS REQUIRED

KIPT’s draft EIS emphasises tangible risks to Yumbah KI if a seaport is established at Smith Bay. KIPT’s claim it will provide a net benefit to Yumbah KI is fanciful and uninformed.

A more detailed, accurate risk assessment of actual construction and operations must be demanded of KIPT with consideration of Yumbah KI’s review of the inadequate risk assessment in the draft EIS.

The risk assessment and corresponding matrix in Appendix T are problematic. Inclusion of rudimentary mitigation and management measures often result in reductions to residual likelihood and consequence. However, management measures can only reduce residual likelihood, not residual consequence. As such the residual risks are misleading and do not reflect the actual risk level.

Several mitigation and management measures have been specified that are unlikely to be firm commitments of KIPT.

In its current format, particularly the outcomes based on the risk categorisation, the draft EIS cannot be relied on to inform the project.



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WHAT IS KIPT HIDING?

KIPT claims superiority for land use at Smith Bay and assumes the activity of a seaport is a compatible land use in this Rural Living Zone and Coastal Conservation Zone. KIPT has implied that Yumbah KI and our established business and associated infrastructure is not compatible by making the following statement in Section 6.3 Appendix N (pg 21) “Land use at the Yumbah Aquaculture site is generally consistent with Primary Production or Rural Industry. The land use is not consistent with the type of development envisaged in the Coastal Conservation Zone, or with typical activities associated with the Rural Living land use category.”

The significant risks that KIPT present with not only developing a timber export seaport but also further establishing a multi-use port adjacent to the proposed timber export seaport cannot be ignored. Lack of information relating to additional future uses further compounds the risks to Yumbah and the community.

Section 7.3.1 of Stakeholder Consultation and Engagement (draft EIS Main Report) states “KIPT acknowledges the importance of being an active member of Kangaroo Island’s community and is committed to developing a sustainable timber business that considers and responds to community needs.” Why won’t KIPT disclose intentions now as part of this EIS process?

73 https://finance.nine.com.au/business-news/kipt-buys-additional-land-at-smith-bay/e3b0f43a-f4f0-43b6-91b3-aeb927052ee2

KIPT has purchased an additional 173 hectares of land to the west that adjoins the 12-hectare site purchased in 2014. What are the true intentions of KIPT? KIPT continue to hide their true intentions for the seaport and surrounding lands.

An article in Business News states The additional land provides the company with greater flexibility in the layout and capability of its onshore facilities and in managing the actual and perceived impacts of its proposed development. It also gives room for the facility to expand in the future, should this be required. All these benefits are subject to government consent73.

The deceit displayed by KIPT to the community and misrepresentation of information is endemic behaviour. KIPT was described in the South Australian Parliament on 16 November 2016 as having “… fed out a fair degree of spin and rubbish….” in its overt promotion of this proposal.

KIPT has unknown, unreported long-term plans for future expansion of the seaport with the purchase of significantly large tracts of land to the west.

KIPT cannot and will not provide any details about other potential multi-users of the seaport. The DAC EIS Guidelines states The construction and operation of a port and wharf, such as that proposed at Smith Bay, will require specific infrastructure, equipment and utility needs. These need to be identified and consideration given to how these requirements will be met, and how any increased demand will impact upon existing users.


118

INFRASTRUCTURE

The DAC Guidelines require KIPT to present comprehensive information on the infrastructure proposed at the seaport. Information requested by DAC is quite extensive and is requested to add value and articulate the ‘nuts and bolts’ of the design.

Unfortunately, information is lacking which is not surprising as this is the general theme of the draft EIS.

Issues exist with the infrastructure proposed for the seaport. KIPT is not applying best practice principles to the design of the seaport. The infrastructure, equipment and utilities proposed have been based on KIPT’s own selfish agenda and have only focussed on their own corporate profitability of the project and have ignored social and environment elements. They have ignored those that intrinsically rely heavily on the values that exist at Smith Bay. These values will be destroyed by the seaport.

Infrastructure concerns have been discussed in more detail throughout Yumbah’s submission, and these include:

• Causeway

• Wastewater retention and detention basins

• Lighting

• Potable water

• Firefighting and dust suppression water

• Road networks and transit routes

YUMBAH’S INFRASTRUCTURE WILL STAY

KIPT claim to be a significant contributor to the economic viability of Kangaroo Island and have questioned the long-term viability of abalone farming in South Australia. They have insolently raised questions of Yumbah KI’s survival at Smith Bay and impending closure due to futuristic climate change impacts.

Yumbah KI is a permanent fixture at Smith Bay, now and for years to come. We have a long and prosperous future at the existing site irrespective of the modelled impacts of climate change, with exciting plans for future expansion.

Unfortunately, Yumbah has suspended significant upgrades and growth of its KI farm due to the impending prospect of a seaport at Smith Bay.

The seaport presents risks that are potentially catastrophic to Yumbah KI’s infrastructure and business.



119

WHAT IS KIPT HIDING?

KIPT claims superiority for land use at Smith Bay and assumes the activity of a seaport is a compatible land use in this Rural Living Zone and Coastal Conservation Zone. KIPT has implied that Yumbah KI and our established business and associated infrastructure is not compatible by making the following statement in Section 6.3 Appendix N (pg 21) “Land use at the Yumbah Aquaculture site is generally consistent with Primary Production or Rural Industry. The land use is not consistent with the type of development envisaged in the Coastal Conservation Zone, or with typical activities associated with the Rural Living land use category.”

The significant risks that KIPT present with not only developing a timber export seaport but also further establishing a multi-use port adjacent to the proposed timber export seaport cannot be ignored. Lack of information relating to additional future uses further compounds the risks to Yumbah and the community.

Section 7.3.1 of Stakeholder Consultation and Engagement (draft EIS Main Report) states “KIPT acknowledges the importance of being an active member of Kangaroo Island’s community and is committed to developing a sustainable timber business that considers and responds to community needs.” Why won’t KIPT disclose intentions now as part of this EIS process?

73 https://finance.nine.com.au/business-news/kipt-buys-additional-land-at-smith-bay/e3b0f43a-f4f0-43b6-91b3-aeb927052ee2

KIPT has purchased an additional 173 hectares of land to the west that adjoins the 12-hectare site purchased in 2014. What are the true intentions of KIPT? KIPT continue to hide their true intentions for the seaport and surrounding lands.

An article in Business News states The additional land provides the company with greater flexibility in the layout and capability of its onshore facilities and in managing the actual and perceived impacts of its proposed development. It also gives room for the facility to expand in the future, should this be required. All these benefits are subject to government consent73.

The deceit displayed by KIPT to the community and misrepresentation of information is endemic behaviour. KIPT was described in the South Australian Parliament on 16 November 2016 as having “… fed out a fair degree of spin and rubbish….” in its overt promotion of this proposal.

KIPT has unknown, unreported long-term plans for future expansion of the seaport with the purchase of significantly large tracts of land to the west.

KIPT cannot and will not provide any details about other potential multi-users of the seaport. The DAC EIS Guidelines states The construction and operation of a port and wharf, such as that proposed at Smith Bay, will require specific infrastructure, equipment and utility needs. These need to be identified and consideration given to how these requirements will be met, and how any increased demand will impact upon existing users.


118

INFRASTRUCTURE

The DAC Guidelines require KIPT to present comprehensive information on the infrastructure proposed at the seaport. Information requested by DAC is quite extensive and is requested to add value and articulate the ‘nuts and bolts’ of the design.

Unfortunately, information is lacking which is not surprising as this is the general theme of the draft EIS.

Issues exist with the infrastructure proposed for the seaport. KIPT is not applying best practice principles to the design of the seaport. The infrastructure, equipment and utilities proposed have been based on KIPT’s own selfish agenda and have only focussed on their own corporate profitability of the project and have ignored social and environment elements. They have ignored those that intrinsically rely heavily on the values that exist at Smith Bay. These values will be destroyed by the seaport.

Infrastructure concerns have been discussed in more detail throughout Yumbah’s submission, and these include:

• Causeway

• Wastewater retention and detention basins

• Lighting

• Potable water

• Firefighting and dust suppression water

• Road networks and transit routes

YUMBAH’S INFRASTRUCTURE WILL STAY

KIPT claim to be a significant contributor to the economic viability of Kangaroo Island and have questioned the long-term viability of abalone farming in South Australia. They have insolently raised questions of Yumbah KI’s survival at Smith Bay and impending closure due to futuristic climate change impacts.

Yumbah KI is a permanent fixture at Smith Bay, now and for years to come. We have a long and prosperous future at the existing site irrespective of the modelled impacts of climate change, with exciting plans for future expansion.

Unfortunately, Yumbah has suspended significant upgrades and growth of its KI farm due to the impending prospect of a seaport at Smith Bay.

The seaport presents risks that are potentially catastrophic to Yumbah KI’s infrastructure and business.



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GUIDELINE 16:

ABORIGINAL & OTHER HERITAGE

DESCRIPTION:

Aboriginal and other heritage can include matters such as archaeological sites and Aboriginal remains, Aboriginal sites and objects of significance according to Aboriginal tradition, archaeology, anthropology or history, caves, mines, volcanic features, geological sites, fossils, historical buildings and monuments, relics of agricultural and industrial heritage, shipwrecks, lighthouses, whaling stations, wilderness and coastlines.

Coastal areas in particular are prone to discovery of items of Aboriginal heritage and significance.

All development should consider the impacts it may have upon Aboriginal and other heritage matters (land and marine).

RESPONSE SUMMARY

• No credible site assessment for draft EIS

o No intrusive site assessment for site identified by its own experts as worthy of “high risk” status

o Only this would determine Indigenous, European and maritime archaeological significance

o Dependence on desktop without site assessment a defining characteristic of draft EIS

• No record of communication, consultation, negotiation

o Recognised Aboriginal Representative Body of Smith Bay not referenced

o Potential violation of South Australian heritage law

o No contact with long-term adjacent landholder, Yumbah, on its understanding of site cultural heritage

• Known European heritage sites not valued

o Significant sites are known widely but disregarded in draft EIS

• Draft EIS considers a previous wharf proposal, not the current proposal

o Underwater heritage study must be resubmitted for KIPT’s revised, larger wharf

o Raises questions about veracity of proposed Heritage Management Plan

ABORIGINAL AND OTHER HERITAGE

Yumbah Aquaculture recognises and appreciates the history of Kangaroo Island and both the indigenous and European archaeological significance that is prevalent across the whole island.

Information relating to heritage is included in the draft EIS Main Report Chapter 24 and Appendix S.

It is disappointing and somewhat perplexing why KIPT has not completed an


120

The draft EIS does not include future prospects for KIPT’s additional freehold land equating to 173ha west of the proposed seaport. The acquisition of this land is likely part of a long-term plan to expand the seaport and or establish associated port related infrastructure on the additional land to the west of the seaport.

The proposed seaport extending offshore with infrastructure including the solid causeway is solely for the timber export business of KIPT. The infrastructure proposed for the seaport will be exclusive for woodchip and timber log handling. The infrastructure will not be functional for any other maritime use other than the timber industry. This is of vital relevance and raises concerns about the degree of disclosure or rather, significant lack of disclosure by KIPT on future plans for the wider environs of Smith Bay.

The introductory page to section 20 Economic Environment of the draft EIS Main Report states

“The potential for the facility to be a multi-user facility is acknowledged and remains an integral feature of the proposed development. However, following discussions with DPTI, it has been agreed the requirement to analyse the potential impacts of such other users and uses is not required.”

KIPT has not detailed in the draft EIS any consultations with the community on future freight and cargo opportunities, and likely infrastructure that may be required. This is a significant issue and any potential expansion at Smith Bay has serious implications to the community, the environment and Yumbah.

Prospective plans for multi-users need to be presented now. This information is critical to determining the applicability of Smith Bay as the preferred location.

Questions that need to be answered include:

What is the long-term plan for the additional 173ha? What will the site look like if it is developed? What infrastructure will be extending through the increasingly wider Coastal Conservation Zone that separates the freehold 173ha from the marine foreshore? What infrastructure will extend into the marine environment? How far will infrastructure extend into the sea? What are the baseline characteristics of the seabed? What ecological values are present on land and in the marine environment? What will be the impact to the native flora and fauna? What depth will be required for the approaching vessels? How many more hundreds of thousand cubic meters of dredging will be required? What are the characteristics of the sediment? Where will the sediment be dumped? The list goes on …

There is confusion in Section 4.8 of the Main Report regarding power sources at the seaport. A statement that the electricity supply strategy for the development would consist of a connection to the mains electricity system for the delivery of grid-source electricity. Then the section follows by referring to a primary and backup generator for the materials handling infrastructure. Solar panels will be fitted for staff amenities. It is unclear if grid sourced electricity will be supplying the power for the site.


The causeway crest would be wide enough for one-way vehicular access, with two passing areas along the causeway length.1

Causeway road to be 5m wide, but it’s to have two passing areas alongside it. The two areas need to be 10m wide. This cannot be seen on the current plans.



121

GUIDELINE 16:

ABORIGINAL & OTHER HERITAGE

DESCRIPTION:

Aboriginal and other heritage can include matters such as archaeological sites and Aboriginal remains, Aboriginal sites and objects of significance according to Aboriginal tradition, archaeology, anthropology or history, caves, mines, volcanic features, geological sites, fossils, historical buildings and monuments, relics of agricultural and industrial heritage, shipwrecks, lighthouses, whaling stations, wilderness and coastlines.

Coastal areas in particular are prone to discovery of items of Aboriginal heritage and significance.

All development should consider the impacts it may have upon Aboriginal and other heritage matters (land and marine).

RESPONSE SUMMARY

• No credible site assessment for draft EIS

o No intrusive site assessment for site identified by its own experts as worthy of “high risk” status

o Only this would determine Indigenous, European and maritime archaeological significance

o Dependence on desktop without site assessment a defining characteristic of draft EIS

• No record of communication, consultation, negotiation

o Recognised Aboriginal Representative Body of Smith Bay not referenced

o Potential violation of South Australian heritage law

o No contact with long-term adjacent landholder, Yumbah, on its understanding of site cultural heritage

• Known European heritage sites not valued

o Significant sites are known widely but disregarded in draft EIS

• Draft EIS considers a previous wharf proposal, not the current proposal

o Underwater heritage study must be resubmitted for KIPT’s revised, larger wharf

o Raises questions about veracity of proposed Heritage Management Plan

ABORIGINAL AND OTHER HERITAGE

Yumbah Aquaculture recognises and appreciates the history of Kangaroo Island and both the indigenous and European archaeological significance that is prevalent across the whole island.

Information relating to heritage is included in the draft EIS Main Report Chapter 24 and Appendix S.

It is disappointing and somewhat perplexing why KIPT has not completed an


120

The draft EIS does not include future prospects for KIPT’s additional freehold land equating to 173ha west of the proposed seaport. The acquisition of this land is likely part of a long-term plan to expand the seaport and or establish associated port related infrastructure on the additional land to the west of the seaport.

The proposed seaport extending offshore with infrastructure including the solid causeway is solely for the timber export business of KIPT. The infrastructure proposed for the seaport will be exclusive for woodchip and timber log handling. The infrastructure will not be functional for any other maritime use other than the timber industry. This is of vital relevance and raises concerns about the degree of disclosure or rather, significant lack of disclosure by KIPT on future plans for the wider environs of Smith Bay.

The introductory page to section 20 Economic Environment of the draft EIS Main Report states

“The potential for the facility to be a multi-user facility is acknowledged and remains an integral feature of the proposed development. However, following discussions with DPTI, it has been agreed the requirement to analyse the potential impacts of such other users and uses is not required.”

KIPT has not detailed in the draft EIS any consultations with the community on future freight and cargo opportunities, and likely infrastructure that may be required. This is a significant issue and any potential expansion at Smith Bay has serious implications to the community, the environment and Yumbah.

Prospective plans for multi-users need to be presented now. This information is critical to determining the applicability of Smith Bay as the preferred location.

Questions that need to be answered include:

What is the long-term plan for the additional 173ha? What will the site look like if it is developed? What infrastructure will be extending through the increasingly wider Coastal Conservation Zone that separates the freehold 173ha from the marine foreshore? What infrastructure will extend into the marine environment? How far will infrastructure extend into the sea? What are the baseline characteristics of the seabed? What ecological values are present on land and in the marine environment? What will be the impact to the native flora and fauna? What depth will be required for the approaching vessels? How many more hundreds of thousand cubic meters of dredging will be required? What are the characteristics of the sediment? Where will the sediment be dumped? The list goes on …

There is confusion in Section 4.8 of the Main Report regarding power sources at the seaport. A statement that the electricity supply strategy for the development would consist of a connection to the mains electricity system for the delivery of grid-source electricity. Then the section follows by referring to a primary and backup generator for the materials handling infrastructure. Solar panels will be fitted for staff amenities. It is unclear if grid sourced electricity will be supplying the power for the site.


The causeway crest would be wide enough for one-way vehicular access, with two passing areas along the causeway length.1

Causeway road to be 5m wide, but it’s to have two passing areas alongside it. The two areas need to be 10m wide. This cannot be seen on the current plans.



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“To further manage heritage risk, KIPT / EP may wish to engage with the relevant Aboriginal group(s) to monitor earthworks.”

As due respect, the report should at least have named who the relevant Aboriginal group(s) are, and correctly referred to the group as Recognised Aboriginal Representative Body(ies) in Appendix S1 and the Main Report.

HISTORY OF EUROPEAN SETTLEMENT

The European history of Smith Bay is presented in Appendix S2. This document outlines the history of Smith Bay, the region and the site. This report does not outline the physical features that are known to be present on site. A number of heritage values do exist on the site of the proposed seaport. These include the ruins of the original house of Harry Smith and one of the few historic European residences at Kangaroo Island. A second associated ruin is also present on the proposed development site, known as the Jacka family home ruin.

The Main report (p522) states neither of these ruins will be affected by the proposal.

It is of high concern that these heritage sites were reported anonymously to the South Australian government in early July 2017 sometime after KIPT had purchased the development site. It begs the question what other heritage values exist on the site that have yet to be reported by KIPT.

The lack of site investigation creates significant doubt about the extent of heritage that may remain unreported.

The history of KIPT and already proven failings to conduct its operation both ethically and within the confines of law, and the obvious propensity to present misleading and flawed technical information further compounds the ability

to trust KIPT in its protection of heritage values on site.

UNDERWATER CULTURAL HERITAGE

Underwater cultural heritage is reported in Appendix S3. The objective of the reported desktop investigation is to assess the potential for any impact on any actual or potential sites. The existence and location of underwater cultural heritage is unknown prior to development works.

The report states:

“This report has looked for the possibility of historic shipwrecks being within 500m of the development impact area. The 500m distance reflects the required distance by the relevant Acts, which is sufficient to protect against indirect impacts.”

A flaw in this report is the design and footprint of the seaport, and its alignment in Smith Bay is incorrect. It appears the footprint may be the previous seaport design. Hence the findings in this investigation that were to understand the possibility of wrecks do not correctly capture 500 meters of the study area.

“The outcome of this investigation will be used to assess the Governmental heritage needs before consent is granted for work to be initiated.”

As the investigation has been conducted for a development footprint that does not exist, this report cannot be relied on for the consent. A revised report is required reflecting the actual seaport development footprint and an investigation within the actual 500 m development impact area.

“In terms of known cultural heritage, the planning application may be made more robust with the provision of evidence rather than assumptions.”


122

intrusive site assessment to determine the extent of Indigenous, European and maritime archaeological significance that may be present across the proposed development site.

INDIGENOUS HERITAGE

To inform the draft EIS, a desktop indigenous heritage assessment has been completed and is presented as Appendix S1. This report is what can only be described as significantly lacking, and inadequate. This document presents little, if any, valid information to delineate the likelihood of Aboriginal archaeological sites across the site.

Appendix S1 does not acknowledge the Recognised Aboriginal Representative Body of Smith Bay, and whether there has been any communication, consultation, negotiation or agreement with the recognised body. This appears to be a violation of South Australian Aboriginal Heritage Act 1988 and significant disrespect for the Traditional Owners of the land.

In its scant and lacking content, Appendix S1 states:

“Cultural Heritage sites are often found to be associated with very specific environmental features.”

The site is bounded to the north by an extensive marine foreshore. Smith Creek runs through the site. These landforms are very specific environmental features and commonly sites of archaeological significance. Why was an intrusive site assessment to survey the likely presence of Indigenous significance not completed?

The proposed project is located in an area with no recorded/registered Aboriginal sites. There is insufficient information on the archaeology of Kangaroo Island to clearly delineate areas of risk, and as such

the area should be treated as a 'high risk area' to manage heritage risk.

An intrusive site assessment should be conducted on this high-risk area to identify whether archaeological significance is present in order to adequately manage any heritage risk. How can you manage a risk when you do not even know it is present?

Archaeologists can monitor changes in soil profiles to assess the likelihood of works encountering Aboriginal heritage sites.

How can an Archaeologist monitor minute changes in soil lithology and identity potential Indigenous heritage sites when bulk earthworks will be occurring with large front-end loads, excavators, bulldozers, trenchers (to name a few) will be ripping up the site at an unprecedented rate?

The following recommendations are provided in Appendix S1 Heritage:

“No Aboriginal heritage sites are 'damaged, disturbed, or interfered' with as part of the proposed works.”

How can you know if you are damaging, disturbing or interfering with an Indigenous heritage site when you do not even know it is there?

“All workers should remain vigilant as any work into previously undisturbed soils has the potential to impact insitu cultural heritage. A heritage induction may be beneficial to ensure contractors are aware of what to look for in regards to heritage.”

Realistically, a driver or controller of bulk earthworks equipment will be concerned with maximum productivity and health and safety of themselves and colleagues. Unfortunately, their last priority will be keeping watch for minute changes and characteristics of soil lithology that could indicate presence of Indigenous cultural significance.



123

“To further manage heritage risk, KIPT / EP may wish to engage with the relevant Aboriginal group(s) to monitor earthworks.”

As due respect, the report should at least have named who the relevant Aboriginal group(s) are, and correctly referred to the group as Recognised Aboriginal Representative Body(ies) in Appendix S1 and the Main Report.

HISTORY OF EUROPEAN SETTLEMENT

The European history of Smith Bay is presented in Appendix S2. This document outlines the history of Smith Bay, the region and the site. This report does not outline the physical features that are known to be present on site. A number of heritage values do exist on the site of the proposed seaport. These include the ruins of the original house of Harry Smith and one of the few historic European residences at Kangaroo Island. A second associated ruin is also present on the proposed development site, known as the Jacka family home ruin.

The Main report (p522) states neither of these ruins will be affected by the proposal.

It is of high concern that these heritage sites were reported anonymously to the South Australian government in early July 2017 sometime after KIPT had purchased the development site. It begs the question what other heritage values exist on the site that have yet to be reported by KIPT.

The lack of site investigation creates significant doubt about the extent of heritage that may remain unreported.

The history of KIPT and already proven failings to conduct its operation both ethically and within the confines of law, and the obvious propensity to present misleading and flawed technical information further compounds the ability

to trust KIPT in its protection of heritage values on site.

UNDERWATER CULTURAL HERITAGE

Underwater cultural heritage is reported in Appendix S3. The objective of the reported desktop investigation is to assess the potential for any impact on any actual or potential sites. The existence and location of underwater cultural heritage is unknown prior to development works.

The report states:

“This report has looked for the possibility of historic shipwrecks being within 500m of the development impact area. The 500m distance reflects the required distance by the relevant Acts, which is sufficient to protect against indirect impacts.”

A flaw in this report is the design and footprint of the seaport, and its alignment in Smith Bay is incorrect. It appears the footprint may be the previous seaport design. Hence the findings in this investigation that were to understand the possibility of wrecks do not correctly capture 500 meters of the study area.

“The outcome of this investigation will be used to assess the Governmental heritage needs before consent is granted for work to be initiated.”

As the investigation has been conducted for a development footprint that does not exist, this report cannot be relied on for the consent. A revised report is required reflecting the actual seaport development footprint and an investigation within the actual 500 m development impact area.

“In terms of known cultural heritage, the planning application may be made more robust with the provision of evidence rather than assumptions.”


122

intrusive site assessment to determine the extent of Indigenous, European and maritime archaeological significance that may be present across the proposed development site.

INDIGENOUS HERITAGE

To inform the draft EIS, a desktop indigenous heritage assessment has been completed and is presented as Appendix S1. This report is what can only be described as significantly lacking, and inadequate. This document presents little, if any, valid information to delineate the likelihood of Aboriginal archaeological sites across the site.

Appendix S1 does not acknowledge the Recognised Aboriginal Representative Body of Smith Bay, and whether there has been any communication, consultation, negotiation or agreement with the recognised body. This appears to be a violation of South Australian Aboriginal Heritage Act 1988 and significant disrespect for the Traditional Owners of the land.

In its scant and lacking content, Appendix S1 states:

“Cultural Heritage sites are often found to be associated with very specific environmental features.”

The site is bounded to the north by an extensive marine foreshore. Smith Creek runs through the site. These landforms are very specific environmental features and commonly sites of archaeological significance. Why was an intrusive site assessment to survey the likely presence of Indigenous significance not completed?

The proposed project is located in an area with no recorded/registered Aboriginal sites. There is insufficient information on the archaeology of Kangaroo Island to clearly delineate areas of risk, and as such

the area should be treated as a 'high risk area' to manage heritage risk.

An intrusive site assessment should be conducted on this high-risk area to identify whether archaeological significance is present in order to adequately manage any heritage risk. How can you manage a risk when you do not even know it is present?

Archaeologists can monitor changes in soil profiles to assess the likelihood of works encountering Aboriginal heritage sites.

How can an Archaeologist monitor minute changes in soil lithology and identity potential Indigenous heritage sites when bulk earthworks will be occurring with large front-end loads, excavators, bulldozers, trenchers (to name a few) will be ripping up the site at an unprecedented rate?

The following recommendations are provided in Appendix S1 Heritage:

“No Aboriginal heritage sites are 'damaged, disturbed, or interfered' with as part of the proposed works.”

How can you know if you are damaging, disturbing or interfering with an Indigenous heritage site when you do not even know it is there?

“All workers should remain vigilant as any work into previously undisturbed soils has the potential to impact insitu cultural heritage. A heritage induction may be beneficial to ensure contractors are aware of what to look for in regards to heritage.”

Realistically, a driver or controller of bulk earthworks equipment will be concerned with maximum productivity and health and safety of themselves and colleagues. Unfortunately, their last priority will be keeping watch for minute changes and characteristics of soil lithology that could indicate presence of Indigenous cultural significance.



125

GUIDELINE 17:

GEOLOGY & SOILS

DESCRIPTION:

The proposal will require the construction of structures on and/or adjacent to coastal geological formation, this may have impacts on those formations and their natural processes.

RESPONSE SUMMARY

• Contradictions between KIPT’s claims

and draft EIS “science” and local knowledge raise questions about the thoroughness of proponent’s investigations

Locals know that Smith Bay is shallow and the seabed is hard.

o Continued misrepresentation of a flat coastline that continues into a shallow bay as being deep

o Continued inaccurate reference to the seabed being a “mixture of cobbles and sediment”75

o Claims that there is “no indication that hard rock is present at depths that would cause concern in the area that will form the berth pocket” contradicted by evidence of core refusal in the draft EIS76

75 https://www.asx.com.au/asxpdf/20180221/pdf/43rrfmyt34xfc4.pdf 76 https://www.asx.com.au/asxpdf/20180221/pdf/43rrfmyt34xfc4.pdf

• Water contamination likely

o Further investigations of the potential impacts to groundwater are required, including likely groundwater contour flows and connectivity to Smith Bay

o The condition and quantity of groundwater resources seems unlikely satisfy the high-intensity water demand necessary to achieve site construction and operational management and mitigation described in the draft EIS

• Causeway impact on

coastal processes

o The causeway will reduce ocean

currents by an estimated 30-40 per cent, which, in turn, will bring elevated water temperatures, reduced mixing of oceanic water, accumulation of drift seaweed (wrack) and compromised oceanic conditions.


124

This is the only sensical statement in all of Appendix S. Yes, evidence is required to be collected by completing intrusive field work to substantiate the extent of all potential heritage across the entire development footprint.

“Below low water mark, Smith Bay is considered to be within Commonwealth jurisdiction, indicating any historic shipwrecks and associated relics in the bay are covered by the Commonwealth Historic Shipwrecks Act 1976.

Section 13 of the Commonwealth Act prohibits damage or destruction of historic shipwrecks or relics. This also prohibits any interference, or removal or disposal of objects. A breach as such will incur substantial fines.”

The relevant Government authority regarding underwater cultural heritage on or within the seabed of Smith Bay is Department of Environment and Energy. The outcomes of the investigation in Appendix S3 have concluded that “in view of the nearby historic major sea lane in Investigator Strait, the high degree of local shipping traffic historically and the current lack of relevant heritage data about the development footprint and surroundings, the presence of such heritage materials cannot be ruled out completely.”

KIPT has no idea if historic shipwrecks or relics are present within the direct dredge area or the 500 m wider radius that may be influenced by indirect impacts.

KIPT cannot irrevocably confirm that damage, destruction, interference, removal, or disposal of objects of historic shipwrecks or relics will not occur as part of the construction and operation of the seaport.


“The shipwreck databases show four points indicating known wrecks from the historic records in the vicinity of Smith Bay.”

However, none of the four sites have been marked as 'found'.

Figure 3 in Appendix S3 indicates the shipwreck Chum is on land.

The development footprint is in Investigator Strait. Appendix S3 (pg 15) recognises that from the middle of the 19th century Investigator Strait has played an important part in the trade and communications network of South Australia as a natural route for shipping.

As stated in Appendix S3 (page 2), characteristics of the environment, although not ideal for preservation, do not exclude the chance for heritage materials having survived. The disturbance of sediment using the cutter suction dredge will likely remove any maritime cultural heritage material before discovery. It is vital that the history of Smith Bay is better understood, and not merely by using reports that present reports with invalidated and vague conclusions.


• A Heritage Management Plan would be developed and implemented during construction (including dredging) to ensure that workers remained on the lookout for heritage items, particularly during earthmoving and excavation activities. The Plan would prescribe the procedures to be followed in the event of potential heritage items being discovered.74 – When it comes to the area’s heritage, KPT is going to make plans up on the fly.



125

GUIDELINE 17:

GEOLOGY & SOILS

DESCRIPTION:

The proposal will require the construction of structures on and/or adjacent to coastal geological formation, this may have impacts on those formations and their natural processes.

RESPONSE SUMMARY

• Contradictions between KIPT’s claims

and draft EIS “science” and local knowledge raise questions about the thoroughness of proponent’s investigations

Locals know that Smith Bay is shallow and the seabed is hard.

o Continued misrepresentation of a flat coastline that continues into a shallow bay as being deep

o Continued inaccurate reference to the seabed being a “mixture of cobbles and sediment”75

o Claims that there is “no indication that hard rock is present at depths that would cause concern in the area that will form the berth pocket” contradicted by evidence of core refusal in the draft EIS76

75 https://www.asx.com.au/asxpdf/20180221/pdf/43rrfmyt34xfc4.pdf 76 https://www.asx.com.au/asxpdf/20180221/pdf/43rrfmyt34xfc4.pdf

• Water contamination likely

o Further investigations of the potential impacts to groundwater are required, including likely groundwater contour flows and connectivity to Smith Bay

o The condition and quantity of groundwater resources seems unlikely satisfy the high-intensity water demand necessary to achieve site construction and operational management and mitigation described in the draft EIS

• Causeway impact on

coastal processes

o The causeway will reduce ocean

currents by an estimated 30-40 per cent, which, in turn, will bring elevated water temperatures, reduced mixing of oceanic water, accumulation of drift seaweed (wrack) and compromised oceanic conditions.


124

This is the only sensical statement in all of Appendix S. Yes, evidence is required to be collected by completing intrusive field work to substantiate the extent of all potential heritage across the entire development footprint.

“Below low water mark, Smith Bay is considered to be within Commonwealth jurisdiction, indicating any historic shipwrecks and associated relics in the bay are covered by the Commonwealth Historic Shipwrecks Act 1976.

Section 13 of the Commonwealth Act prohibits damage or destruction of historic shipwrecks or relics. This also prohibits any interference, or removal or disposal of objects. A breach as such will incur substantial fines.”

The relevant Government authority regarding underwater cultural heritage on or within the seabed of Smith Bay is Department of Environment and Energy. The outcomes of the investigation in Appendix S3 have concluded that “in view of the nearby historic major sea lane in Investigator Strait, the high degree of local shipping traffic historically and the current lack of relevant heritage data about the development footprint and surroundings, the presence of such heritage materials cannot be ruled out completely.”

KIPT has no idea if historic shipwrecks or relics are present within the direct dredge area or the 500 m wider radius that may be influenced by indirect impacts.

KIPT cannot irrevocably confirm that damage, destruction, interference, removal, or disposal of objects of historic shipwrecks or relics will not occur as part of the construction and operation of the seaport.


“The shipwreck databases show four points indicating known wrecks from the historic records in the vicinity of Smith Bay.”

However, none of the four sites have been marked as 'found'.

Figure 3 in Appendix S3 indicates the shipwreck Chum is on land.

The development footprint is in Investigator Strait. Appendix S3 (pg 15) recognises that from the middle of the 19th century Investigator Strait has played an important part in the trade and communications network of South Australia as a natural route for shipping.

As stated in Appendix S3 (page 2), characteristics of the environment, although not ideal for preservation, do not exclude the chance for heritage materials having survived. The disturbance of sediment using the cutter suction dredge will likely remove any maritime cultural heritage material before discovery. It is vital that the history of Smith Bay is better understood, and not merely by using reports that present reports with invalidated and vague conclusions.


• A Heritage Management Plan would be developed and implemented during construction (including dredging) to ensure that workers remained on the lookout for heritage items, particularly during earthmoving and excavation activities. The Plan would prescribe the procedures to be followed in the event of potential heritage items being discovered.74 – When it comes to the area’s heritage, KPT is going to make plans up on the fly.



127

GEOTECHNICAL ANALYSIS FALLS SHORT

Sub-Appendix C1 (Geotechnical Investigation Report) provides no interpretation of the geotechnical cores and the geotechnical integrity. It presents only the core logs.

The proposed material to be dredged has not been aptly characterised due to core refusal above design dredge depths and the anecdotal information that hard rock obstructed drilling.

The draft EIS Main Report (page 367) refers to sediment depth overlaying the hard sea floor ranging from zero to 140 centimetres.

Conclusions about the geotechnical properties of the sediment that was sampled, the potential nature of the hard substrate below the unconsolidated upper layers of sediment, and its ultimate applicability for construction of the proposed causeway, has been based on just 13 core samples extracted for geotechnical analysis, of which only five are in the actual dredge pocket.

WHAT IF THE SEAFLOOR IS HARD?

The draft EIS has not addressed the likelihood or consequences of encountering the hard sea floor, otherwise referred to as Class 3 unconsolidated sediment elsewhere in this document. It does not account for the risk of not achieving the desired dredge depth of three metres.

ARE DREDGE VOLUMES ADEQUATE FOR THE CAUSEWAY?

Estimated dredge volumes are from 100 000m3 to 200 000m3, but the actual minimum volume of spoil required to construct a causeway 250m long and five metres high is not quantified.

There is risk that volumes of dredged spoil may not be enough to construct the causeway. Alternatively, surplus spoil may be dredged in excess of causeway construction requirements.

What is the intention if either of these scenarios is encountered?

This weakness in the draft EIS demands further exploration and requires an adequate understanding of the sediment characteristics, which is yet to be achieved.

PAST PERFORMANCE AN INDICATOR OF FUTURE PERFORMANCE?

Yumbah is intimately aware of previous geotechnical investigations in Smith Bay.

During October 2017 KIPT commissioned a drill barge to conduct seabed sampling to inform the draft EIS. Yumbah closely observed these activities and remained on high alert to what was considered an extreme risk to business continuity.

During this time, it was obvious the vessel and drill rig were experiencing problems.

Following extended periods of heavy grinding, a loud bang was often heard, followed by the extraction of the drilling equipment and a lengthy delay prior to the activity re commencing.


126

GROUNDWATER HIGHLY SALINE, LOW YIELD

The draft EIS assessment notes a single grab sample towards the northern boundary of the site identified depth to groundwater at 1.65 metres below ground level (BGL) (Appendix L, Section 4.3).

Total dissolved solid (TDS) concentration was 18 000mg/L, indicative of saline conditions, inferring that groundwater is potentially connected to the marine environment. Contaminants including iron, lead, cobalt, copper, sulphate and nitrite were measured in sampled groundwater.

It must be stressed that:

“The results did not suggest that previous site activities had caused groundwater contamination and detected concentrations were considered to be background levels for saline water.”

The results from groundwater assessment suggest the shallow aquifer has little beneficial use due to high salinity and low yield.

DEPTH TO GROUNDWATER

Depth to groundwater is also of concern, as KIPT’s site footprint involves considerable bulk earthworks to create benches across the site, form storage areas, build stormwater management infrastructure (settlement ponds), dredge spoil dewatering ponds and cut access roads.

The interception of the shallow groundwater table presents risks to Yumbah KI and the adjacent marine environment.

The draft EIS is lacking in describing the groundwater flow contours and connectivity of aquifers across the region. The risk is contaminated stormwater and leachate leaking from proposed storage ponds, dredge spoil dewatering ponds, and settlement ponds into groundwater.

This would likely create additional contamination of the nearshore environment as groundwater flows are inferred towards Smith Bay.

Further investigations of the potential impacts to groundwater are required, including likely groundwater contour flows and connectivity to Smith Bay.

CAUSEWAY CAUSES MANY PROBLEMS

Yumbah has many concerns – expressed throughout this document - and the negative impacts of the proposed 250 metre causeway: its construction, its integrity and its impact on coastal processes.

The draft EIS proposes that dredge spoil will be stockpiled on land, dewatered and used to construct the 250-metre causeway. But there are gaps in the information KIPT relies upon in its geotechnical assessment of the dredge material.

These gaps preclude an adequate understanding of the geotechnical properties of the dredge spoil and confirmation of whether the material will even support the causeway, the proposed rock armouring and be able to withstand constant oceanic impacts the causeway will be exposed to.

It is unknown if the sediment sampling previously conducted attempted to characterise the dredge material to ascertain the suitability of dredge spoil for use as onshore fill and/or material for the causeway’s core.



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GEOTECHNICAL ANALYSIS FALLS SHORT

Sub-Appendix C1 (Geotechnical Investigation Report) provides no interpretation of the geotechnical cores and the geotechnical integrity. It presents only the core logs.

The proposed material to be dredged has not been aptly characterised due to core refusal above design dredge depths and the anecdotal information that hard rock obstructed drilling.

The draft EIS Main Report (page 367) refers to sediment depth overlaying the hard sea floor ranging from zero to 140 centimetres.

Conclusions about the geotechnical properties of the sediment that was sampled, the potential nature of the hard substrate below the unconsolidated upper layers of sediment, and its ultimate applicability for construction of the proposed causeway, has been based on just 13 core samples extracted for geotechnical analysis, of which only five are in the actual dredge pocket.

WHAT IF THE SEAFLOOR IS HARD?

The draft EIS has not addressed the likelihood or consequences of encountering the hard sea floor, otherwise referred to as Class 3 unconsolidated sediment elsewhere in this document. It does not account for the risk of not achieving the desired dredge depth of three metres.

ARE DREDGE VOLUMES ADEQUATE FOR THE CAUSEWAY?

Estimated dredge volumes are from 100 000m3 to 200 000m3, but the actual minimum volume of spoil required to construct a causeway 250m long and five metres high is not quantified.

There is risk that volumes of dredged spoil may not be enough to construct the causeway. Alternatively, surplus spoil may be dredged in excess of causeway construction requirements.

What is the intention if either of these scenarios is encountered?

This weakness in the draft EIS demands further exploration and requires an adequate understanding of the sediment characteristics, which is yet to be achieved.

PAST PERFORMANCE AN INDICATOR OF FUTURE PERFORMANCE?

Yumbah is intimately aware of previous geotechnical investigations in Smith Bay.

During October 2017 KIPT commissioned a drill barge to conduct seabed sampling to inform the draft EIS. Yumbah closely observed these activities and remained on high alert to what was considered an extreme risk to business continuity.

During this time, it was obvious the vessel and drill rig were experiencing problems.

Following extended periods of heavy grinding, a loud bang was often heard, followed by the extraction of the drilling equipment and a lengthy delay prior to the activity re commencing.


126

GROUNDWATER HIGHLY SALINE, LOW YIELD

The draft EIS assessment notes a single grab sample towards the northern boundary of the site identified depth to groundwater at 1.65 metres below ground level (BGL) (Appendix L, Section 4.3).

Total dissolved solid (TDS) concentration was 18 000mg/L, indicative of saline conditions, inferring that groundwater is potentially connected to the marine environment. Contaminants including iron, lead, cobalt, copper, sulphate and nitrite were measured in sampled groundwater.

It must be stressed that:

“The results did not suggest that previous site activities had caused groundwater contamination and detected concentrations were considered to be background levels for saline water.”

The results from groundwater assessment suggest the shallow aquifer has little beneficial use due to high salinity and low yield.

DEPTH TO GROUNDWATER

Depth to groundwater is also of concern, as KIPT’s site footprint involves considerable bulk earthworks to create benches across the site, form storage areas, build stormwater management infrastructure (settlement ponds), dredge spoil dewatering ponds and cut access roads.

The interception of the shallow groundwater table presents risks to Yumbah KI and the adjacent marine environment.

The draft EIS is lacking in describing the groundwater flow contours and connectivity of aquifers across the region. The risk is contaminated stormwater and leachate leaking from proposed storage ponds, dredge spoil dewatering ponds, and settlement ponds into groundwater.

This would likely create additional contamination of the nearshore environment as groundwater flows are inferred towards Smith Bay.

Further investigations of the potential impacts to groundwater are required, including likely groundwater contour flows and connectivity to Smith Bay.

CAUSEWAY CAUSES MANY PROBLEMS

Yumbah has many concerns – expressed throughout this document - and the negative impacts of the proposed 250 metre causeway: its construction, its integrity and its impact on coastal processes.

The draft EIS proposes that dredge spoil will be stockpiled on land, dewatered and used to construct the 250-metre causeway. But there are gaps in the information KIPT relies upon in its geotechnical assessment of the dredge material.

These gaps preclude an adequate understanding of the geotechnical properties of the dredge spoil and confirmation of whether the material will even support the causeway, the proposed rock armouring and be able to withstand constant oceanic impacts the causeway will be exposed to.

It is unknown if the sediment sampling previously conducted attempted to characterise the dredge material to ascertain the suitability of dredge spoil for use as onshore fill and/or material for the causeway’s core.



129


• The sediment load in the dewatering discharge from the dredge slurry potentially could be high if not managed effectively.77

“If not managed effectively”. It’s a phrase repeated through the draft EIS, relied upon by an accident-prone proponent to support its case for an ill-founded, poorly-planned investment in the wrong place.

The question for the proponent is:

“Who ensures effective management?”



128

In a conversation between Yumbah senior site management and the drill operator following a day’s drilling, the operator shared the problem:

“It’s just straight stone, so hard the drill heads were getting stuck and snapping off.”

The drill operator said drilling would be delayed while they sourced a different drill head. He expressed frustration and commented that usually when solid rock is hit the location is changed, but his instructions were to persist regardless of any difficulties.

Irrespective of these significant limitations to sampling and analysis in this draft EIS KIPT is attempting to build an argument on inaccurate, flawed data.

For Yumbah – and, we expect, for regulators and the science they should be able to rely on - this is a serious breach of corporate and ethical responsibility.

DREDGING PILES UNKNOWNS ON UNKNOWNS

The proponent has a patchy record on dredge sampling that only raises doubt about its information and its claimed capabilities.

There can be no guarantee over the accuracy of suggested volumes likely to be dredged in Smith Bay, nor the likelihood of effectively dredging to the required three metre dredge depth because of core refusal during geotechnical investigations in 2017.

KIPT has not presented plans to dredge to the required three metres with the assumed presence of 1.6 m of the seabed being hard sea floor.

Its 2017 drilling rig sediment sampling survey conducted for core acquisition via 10 tonnes of drilling hydraulic pressure yielded low penetrations prior to core refusal consistently below one metre for all samples except for site SB7.2 (Appendix F) which was sampled to 1.4 metres below the seabed.

The interpretation of the geotechnical/borehole data cannot be confirmed for >1-3 metres of marine sediments due to core refusal by the hard sea floor.

The presence of a very hard substrate (possibly consolidated material) underlying a veneer of unconsolidated sediments that may require Cutter Suction Dredge (CSD) grinding, and subsequently a better understanding of this third class (Class 3) of dredge material.

The CSD has the potential to generate very fine particles from the dredge-header grinding the hard substrate into material and small particle diameters. This will lead to a greater dispersion of fine sediment beyond the current Impact Zones reported throughout the draft EIS.



129


• The sediment load in the dewatering discharge from the dredge slurry potentially could be high if not managed effectively.77

“If not managed effectively”. It’s a phrase repeated through the draft EIS, relied upon by an accident-prone proponent to support its case for an ill-founded, poorly-planned investment in the wrong place.

The question for the proponent is:

“Who ensures effective management?”



128

In a conversation between Yumbah senior site management and the drill operator following a day’s drilling, the operator shared the problem:

“It’s just straight stone, so hard the drill heads were getting stuck and snapping off.”

The drill operator said drilling would be delayed while they sourced a different drill head. He expressed frustration and commented that usually when solid rock is hit the location is changed, but his instructions were to persist regardless of any difficulties.

Irrespective of these significant limitations to sampling and analysis in this draft EIS KIPT is attempting to build an argument on inaccurate, flawed data.

For Yumbah – and, we expect, for regulators and the science they should be able to rely on - this is a serious breach of corporate and ethical responsibility.

DREDGING PILES UNKNOWNS ON UNKNOWNS

The proponent has a patchy record on dredge sampling that only raises doubt about its information and its claimed capabilities.

There can be no guarantee over the accuracy of suggested volumes likely to be dredged in Smith Bay, nor the likelihood of effectively dredging to the required three metre dredge depth because of core refusal during geotechnical investigations in 2017.

KIPT has not presented plans to dredge to the required three metres with the assumed presence of 1.6 m of the seabed being hard sea floor.

Its 2017 drilling rig sediment sampling survey conducted for core acquisition via 10 tonnes of drilling hydraulic pressure yielded low penetrations prior to core refusal consistently below one metre for all samples except for site SB7.2 (Appendix F) which was sampled to 1.4 metres below the seabed.

The interpretation of the geotechnical/borehole data cannot be confirmed for >1-3 metres of marine sediments due to core refusal by the hard sea floor.

The presence of a very hard substrate (possibly consolidated material) underlying a veneer of unconsolidated sediments that may require Cutter Suction Dredge (CSD) grinding, and subsequently a better understanding of this third class (Class 3) of dredge material.

The CSD has the potential to generate very fine particles from the dredge-header grinding the hard substrate into material and small particle diameters. This will lead to a greater dispersion of fine sediment beyond the current Impact Zones reported throughout the draft EIS.



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BUILT FORM

The DPTI EIS Guidelines acknowledge that the seaport is proposed in a relatively remote coastal landscape that is natural in appearance. The KIPT EPBC referral of proposed action from July 2016 states: “The Smith Bay site is within the Coastal Conservation Zone of the KIDP (Kangaroo Island Development Plan), which means that the proposed development is non-complying. Under this plan, non-complying developments are not prohibited per se, but must be considered on their merits.”

The built form and design proposed is in jarring contrast to the natural landscape of the Coastal Conservation Zone of Smith Bay.

78https://www.dpti.sa.gov.au/__data/assets/pdf_file/0009/249975/Kangaroo_Island_Council_Development_Plan.pdf

Kangaroo Island is one of Australia’s largest off-shore islands. Due to its relative isolation from the rest of the State it faces unique economic, environmental and social circumstances, challenges and opportunities78. In 2011, the Kangaroo Island Plan1 was created as a statutory policy document to guide the type of development in the Kangaroo Island Council Area.

The Plan outlines strategic land use directions to better align with priorities of the Kangaroo Island Futures Authority (KIFA) to provide an overarching framework for sustainability. The Plan is supported by a number of other documents developed to inform future development opportunities on the Island.

Figure 13 - Actual Pontoon to be used for the Seaport


130

GUIDELINE 18:

BUILT FORM & DESIGN

DESCRIPTION:

The development is proposed in an area that is a relatively remote coastal landscape that is natural in appearance. There are no other developments of this scale or type situated along this portion of coastline. The proposed development will establish a prominent visual feature along the coastline. Kangaroo Island is internationally known for its natural beauty and this must be considered in the built form and design of the proposed development.

RESPONSE SUMMARY

Kangaroo Island is one of Australia’s largest off-shore islands. Due to its relative isolation from the rest of the State it faces unique economic, environmental and social circumstances, challenges and opportunities. In a strategic plan created for Kangaroo Island, development proposals are required to reflect the importance of retaining economic benefits on the island, balanced with the protection of the island’s natural resources.

• The built form and design proposed is in direct contrast to the natural landscape of Smith Bay, and will negatively affect the widely-distributed economic benefits of Yumbah Aquaculture

• Suitable port and marina infrastructure and port opportunities already exist on Kangaroo Island that would provide greater benefit when establishing a seaport for KIPT to export trees



131

BUILT FORM

The DPTI EIS Guidelines acknowledge that the seaport is proposed in a relatively remote coastal landscape that is natural in appearance. The KIPT EPBC referral of proposed action from July 2016 states: “The Smith Bay site is within the Coastal Conservation Zone of the KIDP (Kangaroo Island Development Plan), which means that the proposed development is non-complying. Under this plan, non-complying developments are not prohibited per se, but must be considered on their merits.”

The built form and design proposed is in jarring contrast to the natural landscape of the Coastal Conservation Zone of Smith Bay.

78https://www.dpti.sa.gov.au/__data/assets/pdf_file/0009/249975/Kangaroo_Island_Council_Development_Plan.pdf

Kangaroo Island is one of Australia’s largest off-shore islands. Due to its relative isolation from the rest of the State it faces unique economic, environmental and social circumstances, challenges and opportunities78. In 2011, the Kangaroo Island Plan1 was created as a statutory policy document to guide the type of development in the Kangaroo Island Council Area.

The Plan outlines strategic land use directions to better align with priorities of the Kangaroo Island Futures Authority (KIFA) to provide an overarching framework for sustainability. The Plan is supported by a number of other documents developed to inform future development opportunities on the Island.

Figure 13 - Actual Pontoon to be used for the Seaport


130

GUIDELINE 18:

BUILT FORM & DESIGN

DESCRIPTION:

The development is proposed in an area that is a relatively remote coastal landscape that is natural in appearance. There are no other developments of this scale or type situated along this portion of coastline. The proposed development will establish a prominent visual feature along the coastline. Kangaroo Island is internationally known for its natural beauty and this must be considered in the built form and design of the proposed development.

RESPONSE SUMMARY

Kangaroo Island is one of Australia’s largest off-shore islands. Due to its relative isolation from the rest of the State it faces unique economic, environmental and social circumstances, challenges and opportunities. In a strategic plan created for Kangaroo Island, development proposals are required to reflect the importance of retaining economic benefits on the island, balanced with the protection of the island’s natural resources.

• The built form and design proposed is in direct contrast to the natural landscape of Smith Bay, and will negatively affect the widely-distributed economic benefits of Yumbah Aquaculture

• Suitable port and marina infrastructure and port opportunities already exist on Kangaroo Island that would provide greater benefit when establishing a seaport for KIPT to export trees



133

control potential conflicts of use and/or the environmental impacts that can arise from use and development in marine and coastal areas82.

Planning for Kangaroo Island has a focus to:

• encourage sustainable growth particularly in Kingscote, Penneshaw, Parndana and American River and make the best use of their existing and expanded infrastructure

• reinforce the expanded role of Kingscote and Penneshaw as the main passenger and freight gateways to the Island

• incorporate high-quality design to protect coastal landscapes

The Kangaroo Island Council Development Plan (September 2015) states an objective for Aquaculture Development as Marine aquaculture development in marine waters that ensures fair and equitable sharing of marine and coastal resources and minimises conflict with water-based and land-based uses.

Aquaculture in South Australia is afforded protection from conflicting and incompatible land use activities. The activities of ports are widely recognised as a conflicting land use with aquaculture.

Section 6.3 Appendix N (pg 21) of the draft EIS states Land use at the Yumbah Aquaculture site is generally consistent with Primary Production or Rural Industry. The land use is not consistent with the type of development envisaged in the

82 https://www.pc.gov.au/research/completed/aquaculture/aquaculture.pdf 83Spark, E., Roberts, S., Deveney, M., Bradley, T., Dang, C., Wronski, E., Walker, M., and Savva, N., PIRSA Fisheries and Aquaculture, 2018. National Biosecurity Plan Guidelines for the Land Based Abalone Industry. Department of Agriculture and Water Resources, Canberra August 2018. CC BY 3.0 84https://www.theislanderonline.com.au/story/6126068/ki-council-rejects-smith-bay-as-location-for-kipt-port/ 85https://www.kangarooisland.sa.gov.au/webdata/resources/minutesAgendas/20190515%20Council%20Minutes.pdf

Coastal Conservation Zone, or with typical activities associated with the Rural Living land use category.

This is again purely remiss of KIPT and ignores that the aquaculture farm has been established within the planning framework and is an activity consistent with Rural Living and the Coastal Conservation Zone.

The seaport is clearly at odds with this zoning.

Ports are widely recognised as an industrial activity and ‘high risk’ for aquaculture, especially when planned to be built less than a few hundred metres from a long-standing, successful aquaculture business.

The National Biosecurity Plan Guidelines for the Australian land-based abalone industry83 explicitly refers to ‘ports’ as high risk in relation to farm locality and features.

The Kangaroo Island Council at its meeting on May 15, 2019 strongly opposed Smith Bay as the location for KI Plantation Timbers' proposed timber exporting port8485. At that meeting, Councillors – as elected representatives of their community – made their position very clear. Yumbah Aquaculture is an industry that fits well with the image of Kangaroo Island, supporting the seafood, primary production and food industry sectors of the island.


132

A major thread in these strategic plans for Kangaroo Island is the importance of retaining economic benefits on the island, balanced with the protection of the island’s natural resources. Diversification and value-adding is required across the Island in relation to tourism and agriculture that ensure sustainable coastal development and protect natural and industry assets.

The Island’s economic base continues to expand and is targeting increased tourism and new industries in the areas of horticulture, aquaculture and renewable energy.

The island’s clean, green reputation underpins these industries.79

DESIGN

The many strategic plans for Kangaroo Island observe that developments should be appropriately located, sited and designed to fit in with and be subservient to the environment and not to compromise the scenic and landscape experience or the Island’s natural assets.

Smith Bay is one such location on Kangaroo Island that should be afforded better protection.

From the sea Smith Bay is the coda to the environmental ballet danced along the North Coast which attracts tourists who, on a three-hour journey ending in Smith Bay80, see seals, dolphins, sea eagles and possibly whales. That ending will be forever destroyed by the surprise of a wharf reaching out hundreds of metres into Smith Bay overshadowed by a woodchip mountain as you enter the Bay.

79 https://www.sa.gov.au/__data/assets/pdf_file/0019/72802/DOCS_AND_FILES-8251751-v5-Formatted_Kangaroo_Island_Plan_Addendum_January_2014_low_res.PDF 80 https://kimarineadventures.com.au/ 81 https://www.sa.gov.au/__data/assets/pdf_file/0019/72802/DOCS_AND_FILES-8251751-v5-Formatted_Kangaroo_Island_Plan_Addendum_January_2014_low_res.PDF

On land the Yumbah KI abalone farm has been at Smith Bay since 1995 and with its low profile, quiet operations and barely registered presence at night, it blends well with topography and natural land, and marine assets.

The Kangaroo Island Plan Addendum (January 2014)81 notes that the ability for commercial forestry to contribute to the Island’s international reputation by providing value-added opportunities, farm-gate experiences and local employment is low in comparison with other agricultural uses, thus providing lower social and economic benefits to the Island.

The Plan confirms that further expansion of forestry on the Island should be restricted and replacement of forestry with other farming and horticultural land uses should be encouraged, especially where located on land with high capability to support such uses.

It also notes that a clear hierarchy of environmental areas to be protected from or used for development should be developed and existing infrastructure assets should be utilised instead of expanding areas used for forestry.

This must be considered for the proposed seaport at Smith Bay, since port and marina infrastructure and port opportunities already exist across the Island that would provide a greater benefit when establishing a wharf from which KIPT can export logs and potentially woodchips.

Governments have an important role in resource planning for marine and coastal areas. The rationale for Government intervention stems from the need to



133

control potential conflicts of use and/or the environmental impacts that can arise from use and development in marine and coastal areas82.

Planning for Kangaroo Island has a focus to:

• encourage sustainable growth particularly in Kingscote, Penneshaw, Parndana and American River and make the best use of their existing and expanded infrastructure

• reinforce the expanded role of Kingscote and Penneshaw as the main passenger and freight gateways to the Island

• incorporate high-quality design to protect coastal landscapes

The Kangaroo Island Council Development Plan (September 2015) states an objective for Aquaculture Development as Marine aquaculture development in marine waters that ensures fair and equitable sharing of marine and coastal resources and minimises conflict with water-based and land-based uses.

Aquaculture in South Australia is afforded protection from conflicting and incompatible land use activities. The activities of ports are widely recognised as a conflicting land use with aquaculture.

Section 6.3 Appendix N (pg 21) of the draft EIS states Land use at the Yumbah Aquaculture site is generally consistent with Primary Production or Rural Industry. The land use is not consistent with the type of development envisaged in the

82 https://www.pc.gov.au/research/completed/aquaculture/aquaculture.pdf 83Spark, E., Roberts, S., Deveney, M., Bradley, T., Dang, C., Wronski, E., Walker, M., and Savva, N., PIRSA Fisheries and Aquaculture, 2018. National Biosecurity Plan Guidelines for the Land Based Abalone Industry. Department of Agriculture and Water Resources, Canberra August 2018. CC BY 3.0 84https://www.theislanderonline.com.au/story/6126068/ki-council-rejects-smith-bay-as-location-for-kipt-port/ 85https://www.kangarooisland.sa.gov.au/webdata/resources/minutesAgendas/20190515%20Council%20Minutes.pdf

Coastal Conservation Zone, or with typical activities associated with the Rural Living land use category.

This is again purely remiss of KIPT and ignores that the aquaculture farm has been established within the planning framework and is an activity consistent with Rural Living and the Coastal Conservation Zone.

The seaport is clearly at odds with this zoning.

Ports are widely recognised as an industrial activity and ‘high risk’ for aquaculture, especially when planned to be built less than a few hundred metres from a long-standing, successful aquaculture business.

The National Biosecurity Plan Guidelines for the Australian land-based abalone industry83 explicitly refers to ‘ports’ as high risk in relation to farm locality and features.

The Kangaroo Island Council at its meeting on May 15, 2019 strongly opposed Smith Bay as the location for KI Plantation Timbers' proposed timber exporting port8485. At that meeting, Councillors – as elected representatives of their community – made their position very clear. Yumbah Aquaculture is an industry that fits well with the image of Kangaroo Island, supporting the seafood, primary production and food industry sectors of the island.


132

A major thread in these strategic plans for Kangaroo Island is the importance of retaining economic benefits on the island, balanced with the protection of the island’s natural resources. Diversification and value-adding is required across the Island in relation to tourism and agriculture that ensure sustainable coastal development and protect natural and industry assets.

The Island’s economic base continues to expand and is targeting increased tourism and new industries in the areas of horticulture, aquaculture and renewable energy.

The island’s clean, green reputation underpins these industries.79

DESIGN

The many strategic plans for Kangaroo Island observe that developments should be appropriately located, sited and designed to fit in with and be subservient to the environment and not to compromise the scenic and landscape experience or the Island’s natural assets.

Smith Bay is one such location on Kangaroo Island that should be afforded better protection.

From the sea Smith Bay is the coda to the environmental ballet danced along the North Coast which attracts tourists who, on a three-hour journey ending in Smith Bay80, see seals, dolphins, sea eagles and possibly whales. That ending will be forever destroyed by the surprise of a wharf reaching out hundreds of metres into Smith Bay overshadowed by a woodchip mountain as you enter the Bay.

79 https://www.sa.gov.au/__data/assets/pdf_file/0019/72802/DOCS_AND_FILES-8251751-v5-Formatted_Kangaroo_Island_Plan_Addendum_January_2014_low_res.PDF 80 https://kimarineadventures.com.au/ 81 https://www.sa.gov.au/__data/assets/pdf_file/0019/72802/DOCS_AND_FILES-8251751-v5-Formatted_Kangaroo_Island_Plan_Addendum_January_2014_low_res.PDF

On land the Yumbah KI abalone farm has been at Smith Bay since 1995 and with its low profile, quiet operations and barely registered presence at night, it blends well with topography and natural land, and marine assets.

The Kangaroo Island Plan Addendum (January 2014)81 notes that the ability for commercial forestry to contribute to the Island’s international reputation by providing value-added opportunities, farm-gate experiences and local employment is low in comparison with other agricultural uses, thus providing lower social and economic benefits to the Island.

The Plan confirms that further expansion of forestry on the Island should be restricted and replacement of forestry with other farming and horticultural land uses should be encouraged, especially where located on land with high capability to support such uses.

It also notes that a clear hierarchy of environmental areas to be protected from or used for development should be developed and existing infrastructure assets should be utilised instead of expanding areas used for forestry.

This must be considered for the proposed seaport at Smith Bay, since port and marina infrastructure and port opportunities already exist across the Island that would provide a greater benefit when establishing a wharf from which KIPT can export logs and potentially woodchips.

Governments have an important role in resource planning for marine and coastal areas. The rationale for Government intervention stems from the need to



135

GUIDELINE 19:

CONSTRUCTION & OPERATION

DESCRIPTION:

During the construction and operation of a large infrastructure project, such as what is proposed at Smith Bay, there will be a range of standard impacts that can occur. Many of these can be adequately managed through construction and operational environmental management plans. As the wharf is proposed to be multi-user, information is needed on who the other potential users may be and how often it is anticipated to be used for other purposes.

RESPONSE SUMMARY

The draft EIS does not profile the potential users of the wharf. In fact, it simply describes a major customer often promoted in earlier misleading press releases namely the cruise ship industry as being “out of scope”. Furthermore, the environmental impact and business impact of “other potential users” is ignored in the draft EIS. As the draft EIS proposes that only 20% utilisation is being provided by the timber operation this means that 80% of the potential wharf usage is left conveniently unexamined by the draft EIS.

"Trust us" does not cut it

Further discrepancies between draft EIS Main report and Appendices (see below) o Missing documentation prevents

review and consideration of the actual proposal

o “Monitoring” is not managing

o Unacceptable hazards and risks

o Smith Bay is an inappropriate location

for the KIPT’s proposed seaport

o Poor quality of draft EIS gives no confidence Construction and Operation impacts are considered adequately

o Track record of proponent a primary

consideration o Unlicensed test drilling in Smith Bay

sets a precedent

o Destruction of seagrass raises flag on proponent’s ability and appetite to build or operate complex infrastructure in a sensitive environment


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Council also confirmed its view that it was not feasible to have a single-use port at Smith Bay and that the Yumbah abalone farm and KIPT should both be allowed to exist without compromise or dispute. On top of this, Councillors said the proposed port was not hidden and its location on North Coast Road would impact on tourism and locals in that region of the Island.

It should therefore, according to Council representatives, not proceed at Smith Bay.



135

GUIDELINE 19:

CONSTRUCTION & OPERATION

DESCRIPTION:

During the construction and operation of a large infrastructure project, such as what is proposed at Smith Bay, there will be a range of standard impacts that can occur. Many of these can be adequately managed through construction and operational environmental management plans. As the wharf is proposed to be multi-user, information is needed on who the other potential users may be and how often it is anticipated to be used for other purposes.

RESPONSE SUMMARY

The draft EIS does not profile the potential users of the wharf. In fact, it simply describes a major customer often promoted in earlier misleading press releases namely the cruise ship industry as being “out of scope”. Furthermore, the environmental impact and business impact of “other potential users” is ignored in the draft EIS. As the draft EIS proposes that only 20% utilisation is being provided by the timber operation this means that 80% of the potential wharf usage is left conveniently unexamined by the draft EIS.

"Trust us" does not cut it

Further discrepancies between draft EIS Main report and Appendices (see below) o Missing documentation prevents

review and consideration of the actual proposal

o “Monitoring” is not managing

o Unacceptable hazards and risks

o Smith Bay is an inappropriate location

for the KIPT’s proposed seaport

o Poor quality of draft EIS gives no confidence Construction and Operation impacts are considered adequately

o Track record of proponent a primary

consideration o Unlicensed test drilling in Smith Bay

sets a precedent

o Destruction of seagrass raises flag on proponent’s ability and appetite to build or operate complex infrastructure in a sensitive environment


134

Council also confirmed its view that it was not feasible to have a single-use port at Smith Bay and that the Yumbah abalone farm and KIPT should both be allowed to exist without compromise or dispute. On top of this, Councillors said the proposed port was not hidden and its location on North Coast Road would impact on tourism and locals in that region of the Island.

It should therefore, according to Council representatives, not proceed at Smith Bay.



137

Similarly, a Traffic Management Plan will be required as a condition of any approvals document.

The Site Control Plan is not yet completed, and so strategies to apply across the entire Smith Bay project footprint have not been developed. Supporting appendices for quality control, reporting and continuous improvement procedures don’t exist.

These missing links limit the capacity to properly review and comment on this EIS; their absence should also preclude the South Australian Government accepting this is a valid document on which to base such a significant decision.

INCONSISTENCY BETWEEN DRAFT EIS DOCUMENTS

Concerns have been identified in the CEMP that are inconsistent with the content of the draft EIS and its supporting technical assessment. These include:

• An objective of Land Disturbance on page 5 of the draft CEMP

o No introduction of new weeds or pests, nor material increase in the abundance or area of existing weed or pest species. No loss of abundance or diversity of native vegetation. This objective should be applied for biosecurity and marine disturbance

o No disturbance to Aboriginal or

European heritage items (unless prior approval obtained from relevant legislation).

o How can this disturbance be avoided without a comprehensive assessment

86 https://kipt.com.au/2017/07/05/harry-smiths-ruins-not-listed-heritage-site/

of the site for archaeological significance?

o Where in the EIS is proper regard for the original dwelling of Harry Smith the resident for which Smith Bay was named. The ruins of his house, one of the first dwellings on Kangaroo Island, are remnant on the site proposed for the wharf development. KIPT’s website records their intention to respect this site:

““The ruins of Harry Smith’s cottage were nominated as a heritage place. The Heritage Council of SA decided at its July meeting not to list the ruins as a heritage place after an investigation and site visit by its officers. Kangaroo Island Plantation Timbers will consider its site plans to assess whether the ruins can be preserved.”86

o Sadly, that respect has not extended to even the smallest reference in the draft EIS which bulldozers this heritage relic.

• Potential impacts of marine disturbance

o Loss of small area of pipefish habitat and some individuals of ring-backed pipefish

o This reference to some equates to >10 hectares, plus a 500m radius of the dredging site. This is estimated to destroy the habitat of 5000 pipefish (Appendix 9).


136

TRACK RECORD LEAVES PROPONENT’S CAPABILITY EXPOSED

In considering Appendix U - Environmental Management of the draft EIS, it’s impossible to ignore the previous actions of the proponent:

• disregarding licence conditions, undertaking illegal drilling in Smith Bay

• demonstrable miscommunication between field operators and management leading to mass destruction of seagrass in Smith Bay

• incomplete dredging analysis

• incomplete information about dredge spoil utilisation

• over-stated beneficial claims regarding Smith Creek

• demonstrable ignorance about the operations of a successful onshore abalone farm

• failure to professionally consider alternative sites that meet the purpose of this infrastructure

The list is longer than the points above, but these accumulate to the point of no confidence that the proponent could capably manage the detailed processes listed in the Appendix, when it cannot competently manage the demands of an EIS process.

PROPONENT FAILS TO COMPLY WITH DAC REQUIREMENTS

The draft EIS attempts to present information that corresponds with what’s required of the EIS guidelines, but fails to meet this challenge.

The information requested must be re-assessed and compiled correctly as a set of comprehensive and all-encompassing management plans to be rigorously reviewed prior to any project approvals.

The DAC EIS guidelines require Construction (CEMP) and Operational Environmental Management Plans (OEMP) for all components of the proposed development.

The draft EIS includes a draft CEMP and OEMP but these are inadequate considering the Risk Assessment does not sufficiently reflect the full extent of the hazards associated with the construction and operation of the seaport.

The potential for interaction with Smith Bay’s shallow groundwater table during bulk earthworks is not considered adequately in either EMP. The CEMP includes groundwater and surface water subheadings as Management Measures tables, but the corresponding measures are not relevant to groundwater protection.

The EMP shows impact to Yumbah KI during both construction and operation, but the extent and duration of impact cannot be adequately quantified. Hence, any potential impact is completely unacceptable to Yumbah KI.

A Dredge Management Plan (DMP) is referenced throughout the draft EIS with some supporting technical documents, but this critical plan is not provided to show activity and associated management considerations Yumbah must confront.



137

Similarly, a Traffic Management Plan will be required as a condition of any approvals document.

The Site Control Plan is not yet completed, and so strategies to apply across the entire Smith Bay project footprint have not been developed. Supporting appendices for quality control, reporting and continuous improvement procedures don’t exist.

These missing links limit the capacity to properly review and comment on this EIS; their absence should also preclude the South Australian Government accepting this is a valid document on which to base such a significant decision.

INCONSISTENCY BETWEEN DRAFT EIS DOCUMENTS

Concerns have been identified in the CEMP that are inconsistent with the content of the draft EIS and its supporting technical assessment. These include:

• An objective of Land Disturbance on page 5 of the draft CEMP

o No introduction of new weeds or pests, nor material increase in the abundance or area of existing weed or pest species. No loss of abundance or diversity of native vegetation. This objective should be applied for biosecurity and marine disturbance

o No disturbance to Aboriginal or

European heritage items (unless prior approval obtained from relevant legislation).

o How can this disturbance be avoided without a comprehensive assessment

86 https://kipt.com.au/2017/07/05/harry-smiths-ruins-not-listed-heritage-site/

of the site for archaeological significance?

o Where in the EIS is proper regard for the original dwelling of Harry Smith the resident for which Smith Bay was named. The ruins of his house, one of the first dwellings on Kangaroo Island, are remnant on the site proposed for the wharf development. KIPT’s website records their intention to respect this site:

““The ruins of Harry Smith’s cottage were nominated as a heritage place. The Heritage Council of SA decided at its July meeting not to list the ruins as a heritage place after an investigation and site visit by its officers. Kangaroo Island Plantation Timbers will consider its site plans to assess whether the ruins can be preserved.”86

o Sadly, that respect has not extended to even the smallest reference in the draft EIS which bulldozers this heritage relic.

• Potential impacts of marine disturbance

o Loss of small area of pipefish habitat and some individuals of ring-backed pipefish

o This reference to some equates to >10 hectares, plus a 500m radius of the dredging site. This is estimated to destroy the habitat of 5000 pipefish (Appendix 9).


136

TRACK RECORD LEAVES PROPONENT’S CAPABILITY EXPOSED

In considering Appendix U - Environmental Management of the draft EIS, it’s impossible to ignore the previous actions of the proponent:

• disregarding licence conditions, undertaking illegal drilling in Smith Bay

• demonstrable miscommunication between field operators and management leading to mass destruction of seagrass in Smith Bay

• incomplete dredging analysis

• incomplete information about dredge spoil utilisation

• over-stated beneficial claims regarding Smith Creek

• demonstrable ignorance about the operations of a successful onshore abalone farm

• failure to professionally consider alternative sites that meet the purpose of this infrastructure

The list is longer than the points above, but these accumulate to the point of no confidence that the proponent could capably manage the detailed processes listed in the Appendix, when it cannot competently manage the demands of an EIS process.

PROPONENT FAILS TO COMPLY WITH DAC REQUIREMENTS

The draft EIS attempts to present information that corresponds with what’s required of the EIS guidelines, but fails to meet this challenge.

The information requested must be re-assessed and compiled correctly as a set of comprehensive and all-encompassing management plans to be rigorously reviewed prior to any project approvals.

The DAC EIS guidelines require Construction (CEMP) and Operational Environmental Management Plans (OEMP) for all components of the proposed development.

The draft EIS includes a draft CEMP and OEMP but these are inadequate considering the Risk Assessment does not sufficiently reflect the full extent of the hazards associated with the construction and operation of the seaport.

The potential for interaction with Smith Bay’s shallow groundwater table during bulk earthworks is not considered adequately in either EMP. The CEMP includes groundwater and surface water subheadings as Management Measures tables, but the corresponding measures are not relevant to groundwater protection.

The EMP shows impact to Yumbah KI during both construction and operation, but the extent and duration of impact cannot be adequately quantified. Hence, any potential impact is completely unacceptable to Yumbah KI.

A Dredge Management Plan (DMP) is referenced throughout the draft EIS with some supporting technical documents, but this critical plan is not provided to show activity and associated management considerations Yumbah must confront.



139

a contaminating activity into a Coastal Conservation Zone?

• Drivers would be encouraged to report native fauna vehicle strikes during timber haulage.

o Encouraged?

• If a hooded plover nest was discovered in Smith Bay during operations, a protection zone (determined in consultation with DEW) would be imposed around the location for the entire breeding season.

o Is this irrespective of location and impact to the productivity of the seaport?

o Nowhere in the EIS is any consideration given to the nesting endangered white bellied sea eagles, which fly over the wharf site each day.


138

• Interactions with terrestrial fauna recognise there will be impact on echidnas that occasionally forage on site.

DRAFT OEMP DOES NOT PROTECT YUMBAH

KIPT’s draft OEMP cannot protect Yumbah KI from the risks of this seaport in Smith Bay. The raft of management and mitigation measures suggested in the plan cannot guarantee risks will be prevented, and so Yumbah cannot have confidence in the security of its Smith Bay business.

The draft OEMP includes details of possible alterations to the causeway, reluctantly if necessary to minimise the interruption of tidal currents (Draft OEMP, page 23). Are these measures proposed as a reactive measure once the causeway is constructed? What will be the trigger for redesigning a causeway once it is deemed this 250-metre tidal barrier does indeed create a critical issue for Yumbah? How much stock must Yumbah lose to trigger remedial action by KIPT? Who will direct KIPT to re-engineer and reconfigure the causeway? What legal protection will Yumbah have, to ensure that action is taken and future threat is removed? What reassurance does Yumbah have that the KIPT will have the financial resources to remedy any damage caused by the manifestation of the many risks posed by the wharf development and operation?

Inclusions in the draft OEMP cannot be enforced and reduce the responsibility KIPT bears to manage the multiple impacts of its operation:

• Other than in exceptional circumstances, vessels would discharge foreign-sourced ballast water on the high seas (that is, further than 200 nautical miles from the

Australian shoreline) before entering the Australian EEZ, in conformance with the Biosecurity Act 2015.

o What are the exceptional circumstances? Who will control these? Who is responsible for any damage caused by the “exceptional circumstance”? Where in the EIS is an estimation of frequency for such exceptional circumstance?

• All vessels using the KI Seaport would be required to comply with state policies relevant to the management of biofouling and pollution prevention ((SA EPA Code of Practice for vessel and facility maintenance (marine and inland waters) 2017)).

o Who will mandate these?

• If a new (including suspected) exotic organism was identified during operation, the marine biosecurity response procedure would be implemented (see Appendix S2 – OEMP for further detail). The organism would be reported to the relevant authorities via the Fishwatch 24-hour hotline and all directions issued by PIRSA would be followed. If there was a biosecurity incident, PIRSA would take over the on-ground management of the incident, including any information that would be provided to the media.

o Too little too late. Given the fuzzy chain of responsibility evidenced by KIPT outsourcing and looking to sell off operational aspects of their project where exactly “does the buck stop?”.

o Where is the legal liability of KIPT and corporate responsibility of introducing



139

a contaminating activity into a Coastal Conservation Zone?

• Drivers would be encouraged to report native fauna vehicle strikes during timber haulage.

o Encouraged?

• If a hooded plover nest was discovered in Smith Bay during operations, a protection zone (determined in consultation with DEW) would be imposed around the location for the entire breeding season.

o Is this irrespective of location and impact to the productivity of the seaport?

o Nowhere in the EIS is any consideration given to the nesting endangered white bellied sea eagles, which fly over the wharf site each day.


138

• Interactions with terrestrial fauna recognise there will be impact on echidnas that occasionally forage on site.

DRAFT OEMP DOES NOT PROTECT YUMBAH

KIPT’s draft OEMP cannot protect Yumbah KI from the risks of this seaport in Smith Bay. The raft of management and mitigation measures suggested in the plan cannot guarantee risks will be prevented, and so Yumbah cannot have confidence in the security of its Smith Bay business.

The draft OEMP includes details of possible alterations to the causeway, reluctantly if necessary to minimise the interruption of tidal currents (Draft OEMP, page 23). Are these measures proposed as a reactive measure once the causeway is constructed? What will be the trigger for redesigning a causeway once it is deemed this 250-metre tidal barrier does indeed create a critical issue for Yumbah? How much stock must Yumbah lose to trigger remedial action by KIPT? Who will direct KIPT to re-engineer and reconfigure the causeway? What legal protection will Yumbah have, to ensure that action is taken and future threat is removed? What reassurance does Yumbah have that the KIPT will have the financial resources to remedy any damage caused by the manifestation of the many risks posed by the wharf development and operation?

Inclusions in the draft OEMP cannot be enforced and reduce the responsibility KIPT bears to manage the multiple impacts of its operation:

• Other than in exceptional circumstances, vessels would discharge foreign-sourced ballast water on the high seas (that is, further than 200 nautical miles from the

Australian shoreline) before entering the Australian EEZ, in conformance with the Biosecurity Act 2015.

o What are the exceptional circumstances? Who will control these? Who is responsible for any damage caused by the “exceptional circumstance”? Where in the EIS is an estimation of frequency for such exceptional circumstance?

• All vessels using the KI Seaport would be required to comply with state policies relevant to the management of biofouling and pollution prevention ((SA EPA Code of Practice for vessel and facility maintenance (marine and inland waters) 2017)).

o Who will mandate these?

• If a new (including suspected) exotic organism was identified during operation, the marine biosecurity response procedure would be implemented (see Appendix S2 – OEMP for further detail). The organism would be reported to the relevant authorities via the Fishwatch 24-hour hotline and all directions issued by PIRSA would be followed. If there was a biosecurity incident, PIRSA would take over the on-ground management of the incident, including any information that would be provided to the media.

o Too little too late. Given the fuzzy chain of responsibility evidenced by KIPT outsourcing and looking to sell off operational aspects of their project where exactly “does the buck stop?”.

o Where is the legal liability of KIPT and corporate responsibility of introducing


APPENDICES

APPENDIX 1

APPENDIX 2

APPENDIX 3

APPENDIX 4

APPENDIX 5

APPENDIX 6

APPENDIX 7

APPENDIX 8

APPENDIX 9

Review of Predicted Water Quality Impacts

Global Marine Resource Management Response to EIS

Australian Abalone Growers Association (AAGA) Submission

Marine Biosecurity Review

Economic Impact Statement

Review of Air Quality Impacts

Easements - Certificates of Title

Review of Noise and Vibration

AusOcean Marine Ecology Report

APPENDICES


APPENDICES

APPENDIX 1

APPENDIX 2

APPENDIX 3

APPENDIX 4

APPENDIX 5

APPENDIX 6

APPENDIX 7

APPENDIX 8

APPENDIX 9


Global Marine Resource Management Response to EIS

Australian Abalone Growers Association (AAGA) Submission


Economic Impact Statement

Review of Air Quality Impacts

Easements - Certificates of Title

Review of Noise and Vibration

AusOcean Marine Ecology Report


22 May 2019

David Connell

General Manager


Our ref: 6137616-98313Your ref:

Dear David

KIPT Smith Bay Wharf Draft EIS


1 Introduction

Yumbah Kangaroo Island (Yumbah KI) requested a review of the predicted water quality impacts of the

Smith Bay Wharf Draft Environmental Impact Statement (KIPT 2019, hereafter referred to as EIS). This

review has focused primarily on Appendix F of the EIS. Appendix F is organised into the following four

(4) sections:

F1 – Assessment of Marine Sediments.

F2 - Hydrodynamic Modelling.

F3 – Marine Water Quality Baseline and Impact Assessment.

F4 – External Hydrodynamic Modelling Peer Review.

Additionally, review comments/observations are provided on Appendix G (Coastal Processes) and

Appendix T (Risk Assessment). The EIS Main Report was not reviewed in this commission, but any

salient review comments here regarding the EIS appendices ought to be considered relevant for review

of the content of the Main Report. The Main Report is a summation of the technical reports presented as

the appendices in the EIS. This review has identified a number of issues and concerns with the reports

primarily presented in Appendix F. Those of primary importance have been underlined further within this

document.

2 Sub-Appendix F1 – Assessment of Marine Sediments

2.1 SAP and SAP Implementation Information (Section 2)

The assessment of marine sediments proposed for the dredging footprint is a significant contributor to a

number of studies that form the EIS. The sampling and analysis of the seabed is deficient and does not

provide an adequate description of the sediments to allow an assessment of the potential impacts of its

disturbance. In short, there is a lack of information regarding the sediment sampling and analysis plan

(SAP) and its implementation. The SAP is lacking in important information, including:

Justification for the spatial arrangement and the number of sampling sites. Typically, this is based on

the National Assessment Guidelines for Dredging (NAGD 2009). The National Acid Sulfate Soils

Guidance (Commonwealth of Australia 2018) for guidelines for the dredging of acid sulfate soil

sediments and associated dredge spoil management defaults on these matters to NAGD. The NAGD

recommends that the locations should be randomly selected within the dredge pocket rather than the

structured grid implemented here.

APPENDIX 1 –

REVIEW OF PREDICTED WATER QUALITY IMPACTSRomero

2019


22 May 2019

David Connell

General Manager


Our ref: 6137616-98313Your ref:

Dear David

KIPT Smith Bay Wharf Draft EIS


1 Introduction

Yumbah Kangaroo Island (Yumbah KI) requested a review of the predicted water quality impacts of the

Smith Bay Wharf Draft Environmental Impact Statement (KIPT 2019, hereafter referred to as EIS). This

review has focused primarily on Appendix F of the EIS. Appendix F is organised into the following four

(4) sections:

F1 – Assessment of Marine Sediments.

F2 - Hydrodynamic Modelling.

F3 – Marine Water Quality Baseline and Impact Assessment.

F4 – External Hydrodynamic Modelling Peer Review.

Additionally, review comments/observations are provided on Appendix G (Coastal Processes) and

Appendix T (Risk Assessment). The EIS Main Report was not reviewed in this commission, but any

salient review comments here regarding the EIS appendices ought to be considered relevant for review

of the content of the Main Report. The Main Report is a summation of the technical reports presented as

the appendices in the EIS. This review has identified a number of issues and concerns with the reports

primarily presented in Appendix F. Those of primary importance have been underlined further within this

document.

2 Sub-Appendix F1 – Assessment of Marine Sediments

2.1 SAP and SAP Implementation Information (Section 2)

The assessment of marine sediments proposed for the dredging footprint is a significant contributor to a

number of studies that form the EIS. The sampling and analysis of the seabed is deficient and does not

provide an adequate description of the sediments to allow an assessment of the potential impacts of its

disturbance. In short, there is a lack of information regarding the sediment sampling and analysis plan

(SAP) and its implementation. The SAP is lacking in important information, including:

Justification for the spatial arrangement and the number of sampling sites. Typically, this is based on

the National Assessment Guidelines for Dredging (NAGD 2009). The National Acid Sulfate Soils

Guidance (Commonwealth of Australia 2018) for guidelines for the dredging of acid sulfate soil

sediments and associated dredge spoil management defaults on these matters to NAGD. The NAGD

recommends that the locations should be randomly selected within the dredge pocket rather than the

structured grid implemented here.

36137616/6137616-LET-0_Review of KIPT EIS Water QualityPredictions_JRR Final (22-May-2019)

material. This has implications for the construction modelling inputs and also determination of the

suitability of dredge spoil as onshore fill and the causeway’s core material.

2.3 Core SB.7 and Setteability Measurements (Section 3.2)

The sediment classification in Figure 7 provides SB7.1 and SB7.2 PSD results, but there is no

information on the depth intervals of these samples from the core. Figure 8 shows that sample SB7.2 has

much smaller characteristic particle diameters than any of the other samples. Presumably this is a

sample from the deeper portion of the SB7.2 core. Sample SB7.2 is potentially the only sample to

characterise pockets of unconsolidated sediment that extend to similar depths. Site SB7 is outside of the

revised dredge area (see Section 8.1) and it may not be indicative of the deeper sediment in the actual

dredge footprint.

Setteability reported in Table 2 is on the basis of four shallow sediment samples with penetration depths

of 20-25 cm (SB3 and SB11) (via the drill rig) to ~60 cm (ZZ4 and ZZ9) (via SCUBA). The settleability of

the sediment cannot be confirmed based on limited shallow samples collected from both within and

outside of the dredge footprint. Settleability needs to consider the deeper unconsolidated and

consolidated (noting that small particle sizes are likely to be generated during CSD grinding) sediment

horizons. Setteability measurements should have been reported, as a minimum, on sample SB7.2 to

ascertain the lower bound of measurements for the deeper unconsolidated sediments. Further,

setteability of deeper consolidated sediments are not characterised due to no acquisition of samples

(note these latter sediments would need to be treated to simulate CSD grinding). In short, settleability

testing is required across the full depth of dredging, not just to 60 cm, which is only 25% of the proposed

maximum dredge depth.

3 Sub-Appendix F2 – Hydrodynamic Modelling

3.1 Catchment Modelling and Smith Creek Flow Scenario (Sections 2.7 and 6.5)

Catchment modelling of a 1:10 AEP storm event is described in Section 2.7 of Sub-Appendix F1. The

objective of the catchment modelling in the context of the EIS is for impact prediction of flood plumes

from Smith Creek into the proximal marine waters with an emphasis on the effect to the Yumbah KI

seawater intakes.

Yumbah has been operating successfully with minimal impact to operation with the exception of a limited

number of storm events in 2016. The following issues are identified with the catchment model:

The use of a 1:10 AEP storm event does not provide a realistic representation of the impact of Smith

Creek to Yumbah KI. A smaller design event on a more frequent basis is considered more

representative if benefits are being claimed for Yumbah KI intake water.

The even split between clay and silt for such a large event and the exclusion of coarser size

fractions to comprise the TSS model input concentration of 140 mg/L is not justified.

The sizeable peak flow rates (30-55 m3/s) of the 1:10 AEP storm event are unverifiable.

Appendix B of the Draft EIS Sub-Appendix F2 provides the nearbed TSS time series for the 1:10 AEP

storm event during summer and winter conditions, which predict with the modelling input uncertainty

highlighted above that:

For the winter simulation peak TSS at the western and middle intakes is substantially greater, but of

shorter duration, for the existing case (30-45 mg/L, 12 hours) than the proposed causeway


Target core / sediment acquisition depths required to describe the sediment quality and PSD of the

proposed material to be dredged. As per NAGD, the full depth of dredging needs to be characterised

Details/justification of change in the sediment sampling acquisition methodology from drilling (original

dredge footprint) to SCUBA (revised dredged footprint),

The following is also of concern in Appendix F1:

Split sediment samples for the first drill-core acquisition event were done for QA/QC to test within

sample variability, but not for the second SCUBA-core acquisition event. However, no replicate

samples were collected to evaluate within site variability. Justification for the reliability of the SCUBA-

core acquisition samples is purely based on a comparison with the previous sampling event.

It is unknown if the sampling was also meant to ascertain the suitability of the sediments for use as

onshore fill and/or material for the causeway’s core. Sub-Appendix C1 (Geotechnical Investigation

Report) does not provide any interpretation of the geotechnical cores and thereby their geotechnical

integrity, and only presents the core logs. There is no information that reports if the dredged material

is suitable for onshore infill and/or the causeway’s core material. The proposed material to be

dredged has not been aptly characterised due to core refusal above design dredge depths.

2.2 Core Penetration Depths and Worst Case Uncertainty Implications (Section 3.1, Table 1)

The proposed maximum dredge depth is approximately 3m. Sediment was only sampled to a maximum

depth of 80 cm, with one sample extracted from 140 cm. Core penetration depths ranged from:

~60 cm at sites ZZ3-ZZ8 (presumably via diver during second survey).

8 of 12 sites during the first survey were ≤25 cm.

3 of 12 sites during the first survey 50-80 cm

1 of 12 sites (site SB7) during the first survey had a penetration depth >1 m (140 cm).

During the first survey with core acquisition via 10 tonnes of drilling hydraulic pressure yielded low

penetrations prior to core refusal. This indicates a very hard substrate underlying a veneer of

unconsolidated sediments that may require Cutter Suction Dredge (CSD) grinding. The CSD has the

potential to generate very fine particles from the dredge header grinding the hard substrate into material

with small particle diameters and thereby a propensity to remain suspended in the water column for a

longer duration than the settling velocities measured for the overlying veneer of unconsolidated

sediment.

Sediment has not been characterised to the extent of dredging depth estimated at 3 m. There is also

considerable uncertainty in regards to the Particle Size Distribution (PSD) (and settling velocities) of the

material that would be generated by the CSD. The PSD of the sediments released into the marine

waters will potentially pose a much greater impact/risk in terms of a worst case scenario than the

duration and amount of dredging. A potential CSD grinding of consolidated sediments scenario may lead

to greater dredging related turbidity than predicted in the EIS, and will potentially have greater impacts on

primary producer benthic habitat (e.g. light reduction to proximal seagrass) and Yumbah KI’s inlet water.

The sediment has been poorly characterised, particularly the hard substrate (consolidated) strata

beneath the well characterised veneer of unconsolidated-weakly consolidated sediments. Due to the

poor characterisation of the extent of sediment to be dredged, the worst case for PSD and settling

velocity estimates should be further explored with additional sediment sampling and modelling.

In summary, the low core penetration depths of the sediment and the lack of adequate characterisation

of the full dredge depth, introduce uncertainty in the characterisation of PSD of the proposed dredge


material. This has implications for the construction modelling inputs and also determination of the

suitability of dredge spoil as onshore fill and the causeway’s core material.

2.3 Core SB.7 and Setteability Measurements (Section 3.2)

The sediment classification in Figure 7 provides SB7.1 and SB7.2 PSD results, but there is no

information on the depth intervals of these samples from the core. Figure 8 shows that sample SB7.2 has

much smaller characteristic particle diameters than any of the other samples. Presumably this is a

sample from the deeper portion of the SB7.2 core. Sample SB7.2 is potentially the only sample to

characterise pockets of unconsolidated sediment that extend to similar depths. Site SB7 is outside of the

revised dredge area (see Section 8.1) and it may not be indicative of the deeper sediment in the actual

dredge footprint.

Setteability reported in Table 2 is on the basis of four shallow sediment samples with penetration depths

of 20-25 cm (SB3 and SB11) (via the drill rig) to ~60 cm (ZZ4 and ZZ9) (via SCUBA). The settleability of

the sediment cannot be confirmed based on limited shallow samples collected from both within and

outside of the dredge footprint. Settleability needs to consider the deeper unconsolidated and

consolidated (noting that small particle sizes are likely to be generated during CSD grinding) sediment

horizons. Setteability measurements should have been reported, as a minimum, on sample SB7.2 to

ascertain the lower bound of measurements for the deeper unconsolidated sediments. Further,

setteability of deeper consolidated sediments are not characterised due to no acquisition of samples

(note these latter sediments would need to be treated to simulate CSD grinding). In short, settleability

testing is required across the full depth of dredging, not just to 60 cm, which is only 25% of the proposed

maximum dredge depth.

3 Sub-Appendix F2 – Hydrodynamic Modelling

3.1 Catchment Modelling and Smith Creek Flow Scenario (Sections 2.7 and 6.5)

Catchment modelling of a 1:10 AEP storm event is described in Section 2.7 of Sub-Appendix F1. The

objective of the catchment modelling in the context of the EIS is for impact prediction of flood plumes

from Smith Creek into the proximal marine waters with an emphasis on the effect to the Yumbah KI

seawater intakes.

Yumbah has been operating successfully with minimal impact to operation with the exception of a limited

number of storm events in 2016. The following issues are identified with the catchment model:

The use of a 1:10 AEP storm event does not provide a realistic representation of the impact of Smith

Creek to Yumbah KI. A smaller design event on a more frequent basis is considered more

representative if benefits are being claimed for Yumbah KI intake water.

The even split between clay and silt for such a large event and the exclusion of coarser size

fractions to comprise the TSS model input concentration of 140 mg/L is not justified.

The sizeable peak flow rates (30-55 m3/s) of the 1:10 AEP storm event are unverifiable.

Appendix B of the Draft EIS Sub-Appendix F2 provides the nearbed TSS time series for the 1:10 AEP

storm event during summer and winter conditions, which predict with the modelling input uncertainty

highlighted above that:

For the winter simulation peak TSS at the western and middle intakes is substantially greater, but of

shorter duration, for the existing case (30-45 mg/L, 12 hours) than the proposed causeway


Target core / sediment acquisition depths required to describe the sediment quality and PSD of the

proposed material to be dredged. As per NAGD, the full depth of dredging needs to be characterised

Details/justification of change in the sediment sampling acquisition methodology from drilling (original

dredge footprint) to SCUBA (revised dredged footprint),

The following is also of concern in Appendix F1:

Split sediment samples for the first drill-core acquisition event were done for QA/QC to test within

sample variability, but not for the second SCUBA-core acquisition event. However, no replicate

samples were collected to evaluate within site variability. Justification for the reliability of the SCUBA-

core acquisition samples is purely based on a comparison with the previous sampling event.

It is unknown if the sampling was also meant to ascertain the suitability of the sediments for use as

onshore fill and/or material for the causeway’s core. Sub-Appendix C1 (Geotechnical Investigation

Report) does not provide any interpretation of the geotechnical cores and thereby their geotechnical

integrity, and only presents the core logs. There is no information that reports if the dredged material

is suitable for onshore infill and/or the causeway’s core material. The proposed material to be

dredged has not been aptly characterised due to core refusal above design dredge depths.

2.2 Core Penetration Depths and Worst Case Uncertainty Implications (Section 3.1, Table 1)

The proposed maximum dredge depth is approximately 3m. Sediment was only sampled to a maximum

depth of 80 cm, with one sample extracted from 140 cm. Core penetration depths ranged from:

~60 cm at sites ZZ3-ZZ8 (presumably via diver during second survey).

8 of 12 sites during the first survey were ≤25 cm.

3 of 12 sites during the first survey 50-80 cm

1 of 12 sites (site SB7) during the first survey had a penetration depth >1 m (140 cm).

During the first survey with core acquisition via 10 tonnes of drilling hydraulic pressure yielded low

penetrations prior to core refusal. This indicates a very hard substrate underlying a veneer of

unconsolidated sediments that may require Cutter Suction Dredge (CSD) grinding. The CSD has the

potential to generate very fine particles from the dredge header grinding the hard substrate into material

with small particle diameters and thereby a propensity to remain suspended in the water column for a

longer duration than the settling velocities measured for the overlying veneer of unconsolidated

sediment.

Sediment has not been characterised to the extent of dredging depth estimated at 3 m. There is also

considerable uncertainty in regards to the Particle Size Distribution (PSD) (and settling velocities) of the

material that would be generated by the CSD. The PSD of the sediments released into the marine

waters will potentially pose a much greater impact/risk in terms of a worst case scenario than the

duration and amount of dredging. A potential CSD grinding of consolidated sediments scenario may lead

to greater dredging related turbidity than predicted in the EIS, and will potentially have greater impacts on

primary producer benthic habitat (e.g. light reduction to proximal seagrass) and Yumbah KI’s inlet water.

The sediment has been poorly characterised, particularly the hard substrate (consolidated) strata

beneath the well characterised veneer of unconsolidated-weakly consolidated sediments. Due to the

poor characterisation of the extent of sediment to be dredged, the worst case for PSD and settling

velocity estimates should be further explored with additional sediment sampling and modelling.

In summary, the low core penetration depths of the sediment and the lack of adequate characterisation

of the full dredge depth, introduce uncertainty in the characterisation of PSD of the proposed dredge


development (5-15 mg/L, 24 hours). Hence, there is a trade-off between intensity of impact and

duration.

There is a clearer benefit during the summer case, generally with higher TSS levels and longer

duration for the existing versus proposed development cases, although the intensity of impact as

indexed by peak TSS levels (7-9 mg/L for existing case and 4-7 mg/L for proposed causeway) is

substantially less than for the winter case.

The predicted benefit to Yumbah KI’s inlet turbidity reduction from such very infrequent 1:10 AEP Smith

Creek storm events does not justify the causeway’s construction. In summary, the objective of the

catchment modelling is seemingly to demonstrate the reduction in Smith Creek flood-derived suspended

sediments into Yumbah KI’s intakes from the proposed causeway. The simulated large discharge and

sediment loads are not verifiable. The modelling of smaller storm events is required to demonstrate the

frequency, magnitude and duration of any suggested benefit.

3.2 Model Validation of Temperature and PAR (Sections 4.3.3. and 4.4)

Statistics (as with Figures 4-1 to 4-3, 4-5) and/or scatter plots (Figure 4-4) of simulated versus measured

values are lacking for temperature (Figure 4-6) and PAR (Figure 4-7). These statistics and plots

characterise the model’s skill in predicting these key marine impact parameters.

3.3 Dredge Material Specifications for Modelling (Section 5.2.1)

The dredge material is not sufficiently characterised to adequately configure the simulation inputs and

thereby to simulate the intensity and extent of sediment plumes from the dredge activity. On the basis of

the CMW Geosciences Geotechnical Investigation Report (Appendix C1) and the WGA Borehole

Investigation Summary, in Section 5.2.1 it is stated that ‘generally there is 1-3 m of marine sediments

and sands overlying deeper strata consisting of cobbles, conglomerates, mudstones and silt/clay/sands.

Generally the deeper strata were below the design dredging depth (-12.0-13.0 CD), which indicates that

the majority of sediment to be removed will be surface marine sediments.’

On the basis of this interpretation, two dredge material sediment classes were configured as dredging

simulation inputs. Class 1, comprising of 75% of the total simulation dredge volume, was representative

PSD of all sediment samples reported in Sub-Appendix F1 except for sample SB7.2. Class 2, comprising

the other 25% of the total simulation dredge volume, was based on the relatively deep sample of SB7.2

(sediment depth interval unknown, refer to previous comments regarding Sub-Appendix F2).

The issues in regards to the interpretation of the sediment sampling and analysis include:

This review’s Section 8.1 and attachment (Sediment and Borehole Sampling Locations) show that

much of the sediment characterisation data is for locations outside of the dredge area, and thereby

does not provide an accurate characterisation of the sediments to be dredged (particularly in regards

to the consolidated component), and thereby the ability to predict its behaviour during dredging.

Uncertainties highlighted in this review’s Section 2 in regards to the sediment sampling core depths

and extrapolation to the dredge depth (core refusal generally <60 cm), and the inclusion of sediment

characteristics outside the dredge area, the assigned volumes of 75% and 25% for class 1 (primarily

sand) and class 2 (greater proportion of clay and silt) cannot be relied on.

Following on from this, the purported hydraulic pressure of the drill was 10 tonnes, yet core refusal

was consistently well below 1 m for all samples except for site SB7.2. The interpretation of the

geotechnical/borehole data in Section 5.2 cannot be confirmed for >1 - 3 m of marine sediments


because the core refusal depths were well less than 1 m (except for SB7.2 outside of the dredge

pocket) during the drilling rig sediment sampling survey.

An alternative interpretation on the basis of the core refusal depth evidence is that a relatively thin

veneer of marine sediments (primarily sand) with perhaps some scattered relatively deeper pockets

of finer material (e.g. site SB7.2) occurs, and the underlying sediments are comprised of a harder

substrate (consolidated material?). If so, then this would support a third class (class 3) of dredge

material.

If the alternative interpretation is plausible, a worst case third class of dredge material for a

reasonable worst case estimate is valid given the information available and potential interactions

between the CSD and the harder (consolidated) sediments of the deeper strata of the dredge area.

This requires additional modelling for a worst case dredge material characterisation that includes

worst case estimates from dredging of the third class and worst case dredge volume allocations to

the three classes.

In summary, the characterisation of the sediments to be dredged has considerable uncertainty in terms

of the potential PSD composition of the deeper sediments, which ought to be a third class of sediments

that has not been modelled. The evidence indicates this a strongly consolidated deeper layer supported

by the core refusal observations from a drill rig with 10 tonnes of hydraulic pressure. All of the dredge

material modelled to date has assumed unconsolidated or weakly consolidated material from samples

within the dredge pocket at shallow depth. The dredge modelling predictions do not correctly describe

the worst case in terms of PSD uncertainty. There is uncertainty in the PSD characterisation of the

deeper sediments that has not been adequately characterised. These deeper, uncharacterised

sediments potentially yield greater dredge-related turbidity impacts than modelled to date.

3.4 DMPA Tailwater Discharge (Section 5.2.3)

A 50 mg/ TSS concentrations is modelled for the DMPA tailwater discharge. This model input parameter

sets the degree of impact at the confluence of discharge with the marine environment. Hence, it is

assumed that the 50 mg/L TSS tailwater discharge will be a construction commitment by KIPT.

3.5 Impact Assessment Framework (Section 5.2.6.3)

The dredge plume modelling assessment has assessed impact prediction variability by considering an

ensemble of simulations to address different physical environmental conditions and to a lesser degree

different dredging scenarios, which is commended. Predictive variability associated with different

dredging scenarios is likely most impacted by the uncertainty in the PSD characterisation of the Class 3

dredge material (underlying harder [consolidated?] substrate under a veneer of marine sediments)

described previously in this review in Section 3.3, which ought to be addressed. This dredging scenario

factor of Class 3 PSD uncertainty is likely to have greater impact than variations in the dredging volume-

footprint-duration as a 30-day assessment window is used. Hence, the assessment with a 30-day

window does not materially change with the same dredge plant over a longer duration dredging program

and relatively minor change to the dredge footprint.

3.6 Current Field Impacts (Section 6.3.2)

Current speed measurements by Yumbah KI in the shallow waters in front of the abalone farm range 4-

13 cm/s across the 10th to 90th percentiles over a period of 6 months measurements from 24 August

2018 to 25 February 2019 (see Section 8.2 of this review). Material changes to the nearshore current


development (5-15 mg/L, 24 hours). Hence, there is a trade-off between intensity of impact and

duration.

There is a clearer benefit during the summer case, generally with higher TSS levels and longer

duration for the existing versus proposed development cases, although the intensity of impact as

indexed by peak TSS levels (7-9 mg/L for existing case and 4-7 mg/L for proposed causeway) is

substantially less than for the winter case.

The predicted benefit to Yumbah KI’s inlet turbidity reduction from such very infrequent 1:10 AEP Smith

Creek storm events does not justify the causeway’s construction. In summary, the objective of the

catchment modelling is seemingly to demonstrate the reduction in Smith Creek flood-derived suspended

sediments into Yumbah KI’s intakes from the proposed causeway. The simulated large discharge and

sediment loads are not verifiable. The modelling of smaller storm events is required to demonstrate the

frequency, magnitude and duration of any suggested benefit.

3.2 Model Validation of Temperature and PAR (Sections 4.3.3. and 4.4)

Statistics (as with Figures 4-1 to 4-3, 4-5) and/or scatter plots (Figure 4-4) of simulated versus measured

values are lacking for temperature (Figure 4-6) and PAR (Figure 4-7). These statistics and plots

characterise the model’s skill in predicting these key marine impact parameters.

3.3 Dredge Material Specifications for Modelling (Section 5.2.1)

The dredge material is not sufficiently characterised to adequately configure the simulation inputs and

thereby to simulate the intensity and extent of sediment plumes from the dredge activity. On the basis of

the CMW Geosciences Geotechnical Investigation Report (Appendix C1) and the WGA Borehole

Investigation Summary, in Section 5.2.1 it is stated that ‘generally there is 1-3 m of marine sediments

and sands overlying deeper strata consisting of cobbles, conglomerates, mudstones and silt/clay/sands.

Generally the deeper strata were below the design dredging depth (-12.0-13.0 CD), which indicates that

the majority of sediment to be removed will be surface marine sediments.’

On the basis of this interpretation, two dredge material sediment classes were configured as dredging

simulation inputs. Class 1, comprising of 75% of the total simulation dredge volume, was representative

PSD of all sediment samples reported in Sub-Appendix F1 except for sample SB7.2. Class 2, comprising

the other 25% of the total simulation dredge volume, was based on the relatively deep sample of SB7.2

(sediment depth interval unknown, refer to previous comments regarding Sub-Appendix F2).

The issues in regards to the interpretation of the sediment sampling and analysis include:

This review’s Section 8.1 and attachment (Sediment and Borehole Sampling Locations) show that

much of the sediment characterisation data is for locations outside of the dredge area, and thereby

does not provide an accurate characterisation of the sediments to be dredged (particularly in regards

to the consolidated component), and thereby the ability to predict its behaviour during dredging.

Uncertainties highlighted in this review’s Section 2 in regards to the sediment sampling core depths

and extrapolation to the dredge depth (core refusal generally <60 cm), and the inclusion of sediment

characteristics outside the dredge area, the assigned volumes of 75% and 25% for class 1 (primarily

sand) and class 2 (greater proportion of clay and silt) cannot be relied on.

Following on from this, the purported hydraulic pressure of the drill was 10 tonnes, yet core refusal

was consistently well below 1 m for all samples except for site SB7.2. The interpretation of the

geotechnical/borehole data in Section 5.2 cannot be confirmed for >1 - 3 m of marine sediments


4.4 Residual Impacts and Assessment Summary (Section 5)

In terms of capital dredging mitigation measures, the following mitigation measure is a suggestion in

Sub-Appendix F3 Section 4, not a recommendation, and hence should not be considered in the Risk

Assessment Summary unless it is a firm pre-approval KIPT commitment:

Dredging should be limited from October to March to limit impacts to ecological receptors and

Yumbah KI’s intake water.

If not a firm commitment, remove this measure from the risk assessment and reassess the residual

likelihood.

The Ballast Water hazard risk assessment and the inherent and residual consequence rating of minor

should be assessed with consideration of Yumbah KI’s review on biosecurity by Prof. Chad Hewitt and

Prof. Marnie Campbell.

The risk assessment should include the changes to Smith Bay nearshore circulation and flushing from

the proposed development and the potential impacts to increased recirculation of outlet to inlet waters of

the Yumbah KI facility.

5 Sub-Appendix F4 – External Hydrodynamic Modelling Peer Review

This reviewer concurs for the most part with the external reviewer’s assessment. The primary issue is

with the configuration of the model, in particular the uncertainty of the PSD characterisation of the

proposed dredged material and the respective volumes of the existing Class 1 and Class 2 sediment

types, and suggested need for modelling of a Class 3 sediment type. The difficulty in confirming the

adequacy of the modelled outputs aligns with the limited characterisation of the deeper sediment strata

during the two surveys of the superficial sediments in or in proximity to the dredge pocket.

6 Appendix G – Coastal Processes

This reviewer has the following comments on EIS Appendix G in regards to coastal processes in relation

to Section 4 – Residual Impacts and Assessment Summary, which are:

Please refer to this review’s Sections 3.6 and 4.3 for Yumbah KI’s view on potential changes to

‘nearshore’ flushing and currents, and potential implications for recirculation of the aquaculture

facility’s outlet water to the intakes. The statement ‘Coastal circulation impacts are not expected to

result in reduced flushing of Smith Bay waters’ needs to be demonstrated.

Seagrass wrack accumulation has the potential to impact Yumbah KI’s intakes. Coastal structure

(e.g. groynes, causeways) often cause the accumulation of seagrass wrack and degradation of

seawater quality that did not occur prior to their placement. The proximity of the causeway to the

Yumbah KI facility’s intakes may cause wrack accumulation and water quality degradation of source

waters to its abalone farm. EIS Appendix G is lacking the following information to address the

potential impacts of seagrass wrack on the abalone farm:

o A description of the seagrass wrack dynamics of Smith Bay.

o Predictions of the effect of the proposed development on the seagrass wrack dynamics

of Smith Bay.

o Impacts of the predicted changes of seagrass wrack dynamics on the source waters to

Yumbah KI’s abalone farm.

o Though risk reference item 8 in Table 4-1 of EIS Appendix G identifies the hazard,

modification to seagrass wrack accumulation, the basis for a consequence of ‘minor’ and


regime may have potential implications to the flushing of Yumbah KI’s outlet waters into the nearshore

waters and potentially increased recirculation into the facility’s intakes, which is of concern to Yumbah KI.

It is recognised that this section addresses coastal processes, so please refer to Section 4.3 for further

comments on this operational risk/impact associated with the proposed causeway. As this is the only

section in the Draft EIS where current field impacts are addressed, for the purposes of assessing

predicted changes in the proximal location to the Yumbah KI inlets and outlets. The close-up figures of

the differences in current velocities in the region of the aquaculture facility are not adequate as finer

current velocity intervals of 1-2 cm/s rather than 10 cm/s intervals (bottom panels of Figures 6-8 and 6-9)

is more representative and should instead be applied.

4 Sub-Appendix F3 – Marine Water Quality Baseline and Impact Assessment

4.1 Impact Thresholds (Section 3.2.1)

The use of 10 (Zone of High Impact) and 5 (Zone of Low to Moderate Impact) standard deviations

above the 50th and 80th percentile means to define ecological impact thresholds from turbidity are

unjustified. There is no ecological basis for these criteria. This does not address seasonality in biotic

receptors. It has been demonstrated that ambient turbidity is highly correlated to wave climate in Smith

Bay (Figure 2-10 in Sub-Appendix F2).

Peak seasonal insolation (mid-spring to mid-autumn) corresponds to a seasonally low wave climate

(Figure 3-3 in Sub-Appendix F2) with resultant low seasonal ambient turbidity (again Figure 2-10 in Sub-

Appendix F2). This is a sensitive period for benthic primary producers (e.g. seagrass) with seasonal

maxima in benthic PAR harvesting. The approach to define the impact thresholds does not seemingly

account for this sensitive period (mid-spring to mid-autumn), which from a benthic primary producer

perspective is the worst case timing to carry out the dredge program.

4.2 Plume Modelling Scenarios (Section 3.4.1.1)

The draft EIS considered variations in the location of the dredge footprint and the environmental

conditions. It was concluded that design of the dredge footprint does not have a substantive effect on

predicted construction impacts, and that environmental conditions do so. The PSD uncertainty of the

proposed sediment material to be dredged has been addressed previously in this review (Sections 3.3

and 3.5). The TSS impact assessment is questionable as there is considerable uncertainty in the PSD of

the dredge material, and the need for deeper sediment understanding, particularly to confirm the

presence of a Class 3 sediment of consolidated material.

4.3 Lack of Nearshore Flushing and Yumbah KI Intake-Outlet Recirculation Assessment(Section 3.5)

No impacts to the flushing of Smith Bay and effects on recirculation of the aquaculture’s outflows to the

intakes were evaluated as indicated in Section 3.6 of this review. The placement of a solid causeway to

the east has the potential to alter the typical flushing patterns with a potential to increase the recirculation

of the facility’s outlet waters to the inlets. The potential for changes to the very nearshore flushing of

Yumbah KI’s outlet waters due to the presence of the proposed causeway and any impacts/risks in terms

of recirculation of the outlet waters into the Yumbah KI facility’s intakes has not been addressed.


4.4 Residual Impacts and Assessment Summary (Section 5)

In terms of capital dredging mitigation measures, the following mitigation measure is a suggestion in

Sub-Appendix F3 Section 4, not a recommendation, and hence should not be considered in the Risk

Assessment Summary unless it is a firm pre-approval KIPT commitment:

Dredging should be limited from October to March to limit impacts to ecological receptors and

Yumbah KI’s intake water.

If not a firm commitment, remove this measure from the risk assessment and reassess the residual

likelihood.

The Ballast Water hazard risk assessment and the inherent and residual consequence rating of minor

should be assessed with consideration of Yumbah KI’s review on biosecurity by Prof. Chad Hewitt and

Prof. Marnie Campbell.

The risk assessment should include the changes to Smith Bay nearshore circulation and flushing from

the proposed development and the potential impacts to increased recirculation of outlet to inlet waters of

the Yumbah KI facility.

5 Sub-Appendix F4 – External Hydrodynamic Modelling Peer Review

This reviewer concurs for the most part with the external reviewer’s assessment. The primary issue is

with the configuration of the model, in particular the uncertainty of the PSD characterisation of the

proposed dredged material and the respective volumes of the existing Class 1 and Class 2 sediment

types, and suggested need for modelling of a Class 3 sediment type. The difficulty in confirming the

adequacy of the modelled outputs aligns with the limited characterisation of the deeper sediment strata

during the two surveys of the superficial sediments in or in proximity to the dredge pocket.

6 Appendix G – Coastal Processes

This reviewer has the following comments on EIS Appendix G in regards to coastal processes in relation

to Section 4 – Residual Impacts and Assessment Summary, which are:

Please refer to this review’s Sections 3.6 and 4.3 for Yumbah KI’s view on potential changes to

‘nearshore’ flushing and currents, and potential implications for recirculation of the aquaculture

facility’s outlet water to the intakes. The statement ‘Coastal circulation impacts are not expected to

result in reduced flushing of Smith Bay waters’ needs to be demonstrated.

Seagrass wrack accumulation has the potential to impact Yumbah KI’s intakes. Coastal structure

(e.g. groynes, causeways) often cause the accumulation of seagrass wrack and degradation of

seawater quality that did not occur prior to their placement. The proximity of the causeway to the

Yumbah KI facility’s intakes may cause wrack accumulation and water quality degradation of source

waters to its abalone farm. EIS Appendix G is lacking the following information to address the

potential impacts of seagrass wrack on the abalone farm:

o A description of the seagrass wrack dynamics of Smith Bay.

o Predictions of the effect of the proposed development on the seagrass wrack dynamics

of Smith Bay.

o Impacts of the predicted changes of seagrass wrack dynamics on the source waters to

Yumbah KI’s abalone farm.

o Though risk reference item 8 in Table 4-1 of EIS Appendix G identifies the hazard,

modification to seagrass wrack accumulation, the basis for a consequence of ‘minor’ and


regime may have potential implications to the flushing of Yumbah KI’s outlet waters into the nearshore

waters and potentially increased recirculation into the facility’s intakes, which is of concern to Yumbah KI.

It is recognised that this section addresses coastal processes, so please refer to Section 4.3 for further

comments on this operational risk/impact associated with the proposed causeway. As this is the only

section in the Draft EIS where current field impacts are addressed, for the purposes of assessing

predicted changes in the proximal location to the Yumbah KI inlets and outlets. The close-up figures of

the differences in current velocities in the region of the aquaculture facility are not adequate as finer

current velocity intervals of 1-2 cm/s rather than 10 cm/s intervals (bottom panels of Figures 6-8 and 6-9)

is more representative and should instead be applied.

4 Sub-Appendix F3 – Marine Water Quality Baseline and Impact Assessment

4.1 Impact Thresholds (Section 3.2.1)

The use of 10 (Zone of High Impact) and 5 (Zone of Low to Moderate Impact) standard deviations

above the 50th and 80th percentile means to define ecological impact thresholds from turbidity are

unjustified. There is no ecological basis for these criteria. This does not address seasonality in biotic

receptors. It has been demonstrated that ambient turbidity is highly correlated to wave climate in Smith

Bay (Figure 2-10 in Sub-Appendix F2).

Peak seasonal insolation (mid-spring to mid-autumn) corresponds to a seasonally low wave climate

(Figure 3-3 in Sub-Appendix F2) with resultant low seasonal ambient turbidity (again Figure 2-10 in Sub-

Appendix F2). This is a sensitive period for benthic primary producers (e.g. seagrass) with seasonal

maxima in benthic PAR harvesting. The approach to define the impact thresholds does not seemingly

account for this sensitive period (mid-spring to mid-autumn), which from a benthic primary producer

perspective is the worst case timing to carry out the dredge program.

4.2 Plume Modelling Scenarios (Section 3.4.1.1)

The draft EIS considered variations in the location of the dredge footprint and the environmental

conditions. It was concluded that design of the dredge footprint does not have a substantive effect on

predicted construction impacts, and that environmental conditions do so. The PSD uncertainty of the

proposed sediment material to be dredged has been addressed previously in this review (Sections 3.3

and 3.5). The TSS impact assessment is questionable as there is considerable uncertainty in the PSD of

the dredge material, and the need for deeper sediment understanding, particularly to confirm the

presence of a Class 3 sediment of consolidated material.

4.3 Lack of Nearshore Flushing and Yumbah KI Intake-Outlet Recirculation Assessment(Section 3.5)

No impacts to the flushing of Smith Bay and effects on recirculation of the aquaculture’s outflows to the

intakes were evaluated as indicated in Section 3.6 of this review. The placement of a solid causeway to

the east has the potential to alter the typical flushing patterns with a potential to increase the recirculation

of the facility’s outlet waters to the inlets. The potential for changes to the very nearshore flushing of

Yumbah KI’s outlet waters due to the presence of the proposed causeway and any impacts/risks in terms

of recirculation of the outlet waters into the Yumbah KI facility’s intakes has not been addressed.


site was ~32 cm/s on 21 November 2018, coinciding with a storm event that moved through the region.

The climate statistics for Kingscote, South Australia, obtained from the Bureau of Meteorology indicate

maximum wind gusts of 94 km/h on this day, which would have a significant influence on current speeds

in these shallow coastal waters.

Current directions at the site periodically alternate between the dominant directions of easterly during

flood tides and westerly during ebb tides (Figure 1). Further, the minimum current speed of ~2 cm/s is

sufficient to transport a turbid plume from the proposed port to the western intake of Yumbah KI’s facility,

a distance of approximately 300 m.

Current roses for the site are presented in Figure 2 for the entire data record and the selected five lunar

cycles. Westerly currents are slightly more frequent than easterly currents. In total, currents with an

easterly component make up 44% of the measurements over the five lunar cycles compared to 56% of

currents with a westerly component. With reference to the proposed construction of the woodchip port to

the west of Yumbah’s facility, the high frequency (44%) of easterly currents provides a mechanism by

which suspended sediments and pollutants generated at the port may enter the seawater intakes of the

aquaculture facility.

Figure 3 shows the probability distribution of the inshore currents over the 6 month deployment. The 10th,

20th, 50th, 80th and 90th current speed percentiles are approximately 4, 6, 8, 12 and 13 cm/s.


likelihood of ‘possible’ is not supported. Further, mitigation measures only change the

residual likelihood and not the residual consequence (note this comment also applies to

reference item 6 in Table 4-1, and it is uncertain why changes in residual likelihoods to

references 2 and 3 are included with no [nil] mitigation measures noted). The inherent

and residual risk for seagrass wrack accumulation is not supported.

o The risk of seagrass wrack accumulation on the quality of the source waters to Yumbah

KI’s abalone farm is lacking and needs to be addressed, particularly given the close

proximity of the proposed development to the inlets.

7 Appendix T – Risk Assessment

The following is noted in regards to the Appendix T Risk Assessment.

Appendix T would benefit from descriptors of the consequence and likelihood, and a risk matrix

table.

The risk assessment is problematic in many instances in that mitigation measures have often

resulted in reductions to the residual likelihood and residual consequence. Management measures

can only reduce the residual likelihood, not the residual consequence. Please revise the risk

assessment accordingly.

8 Supporting Information

8.1 Sediment Sampling Locations

Attachment 1 overlays the following locations that comprise the sediment sampling:

The revised dredging footprint.

The bore holes OSBHDs. Only 5 of the 13 bore holes are within the revised dredge footprint.

The drill rig sediment sampling locations (SB1-SB12). Only 5 of the 12 drill rig sediment sampling

sites are within the revised dredge footprint. Note that site SB7.2, a critical sampling site in the

PSD characterisation for modelling inputs, lies outside of the dredge footprint. Thus, this location

cannot be relied on as an accurate interpretation of the sediment characteristics particularly in

the deeper profile.

The SCUBA sediment sampling locations (ZZ3-ZZ7), which are along the northern periphery of

the dredge footprint, which presumably characterises only a small portion of the proposed

dredge volume.

The sediment sampling locations do not adequately characterise the sediment to be dredged

8.2 Inshore Tilt Meter Measurements

Yumbah KI recently deployed a tilt meter in the nearshore waters of their facility in order to characterise

the current regime at the site just offshore from the western intakes in approximately 8 m water depth

over approximately 6 months from 24 August 2018 to 25 February 2019. The tilt meter recorded current

speeds and directions at 2-minute intervals.

Measured current speeds and directions over the duration of the deployment are displayed in Figure 1,

which also presents the predicted tides at Emu Bay. Current speeds typically ranged between 2 to 15

cm/s during neap tides and 2 to 20 cm/s during spring tides. The highest current speed recorded at the


site was ~32 cm/s on 21 November 2018, coinciding with a storm event that moved through the region.

The climate statistics for Kingscote, South Australia, obtained from the Bureau of Meteorology indicate

maximum wind gusts of 94 km/h on this day, which would have a significant influence on current speeds

in these shallow coastal waters.

Current directions at the site periodically alternate between the dominant directions of easterly during

flood tides and westerly during ebb tides (Figure 1). Further, the minimum current speed of ~2 cm/s is

sufficient to transport a turbid plume from the proposed port to the western intake of Yumbah KI’s facility,

a distance of approximately 300 m.

Current roses for the site are presented in Figure 2 for the entire data record and the selected five lunar

cycles. Westerly currents are slightly more frequent than easterly currents. In total, currents with an

easterly component make up 44% of the measurements over the five lunar cycles compared to 56% of

currents with a westerly component. With reference to the proposed construction of the woodchip port to

the west of Yumbah’s facility, the high frequency (44%) of easterly currents provides a mechanism by

which suspended sediments and pollutants generated at the port may enter the seawater intakes of the

aquaculture facility.

Figure 3 shows the probability distribution of the inshore currents over the 6 month deployment. The 10th,

20th, 50th, 80th and 90th current speed percentiles are approximately 4, 6, 8, 12 and 13 cm/s.


likelihood of ‘possible’ is not supported. Further, mitigation measures only change the

residual likelihood and not the residual consequence (note this comment also applies to

reference item 6 in Table 4-1, and it is uncertain why changes in residual likelihoods to

references 2 and 3 are included with no [nil] mitigation measures noted). The inherent

and residual risk for seagrass wrack accumulation is not supported.

o The risk of seagrass wrack accumulation on the quality of the source waters to Yumbah

KI’s abalone farm is lacking and needs to be addressed, particularly given the close

proximity of the proposed development to the inlets.

7 Appendix T – Risk Assessment

The following is noted in regards to the Appendix T Risk Assessment.

Appendix T would benefit from descriptors of the consequence and likelihood, and a risk matrix

table.

The risk assessment is problematic in many instances in that mitigation measures have often

resulted in reductions to the residual likelihood and residual consequence. Management measures

can only reduce the residual likelihood, not the residual consequence. Please revise the risk

assessment accordingly.

8 Supporting Information

8.1 Sediment Sampling Locations

Attachment 1 overlays the following locations that comprise the sediment sampling:

The revised dredging footprint.

The bore holes OSBHDs. Only 5 of the 13 bore holes are within the revised dredge footprint.

The drill rig sediment sampling locations (SB1-SB12). Only 5 of the 12 drill rig sediment sampling

sites are within the revised dredge footprint. Note that site SB7.2, a critical sampling site in the

PSD characterisation for modelling inputs, lies outside of the dredge footprint. Thus, this location

cannot be relied on as an accurate interpretation of the sediment characteristics particularly in

the deeper profile.

The SCUBA sediment sampling locations (ZZ3-ZZ7), which are along the northern periphery of

the dredge footprint, which presumably characterises only a small portion of the proposed

dredge volume.

The sediment sampling locations do not adequately characterise the sediment to be dredged

8.2 Inshore Tilt Meter Measurements

Yumbah KI recently deployed a tilt meter in the nearshore waters of their facility in order to characterise

the current regime at the site just offshore from the western intakes in approximately 8 m water depth

over approximately 6 months from 24 August 2018 to 25 February 2019. The tilt meter recorded current

speeds and directions at 2-minute intervals.

Measured current speeds and directions over the duration of the deployment are displayed in Figure 1,

which also presents the predicted tides at Emu Bay. Current speeds typically ranged between 2 to 15

cm/s during neap tides and 2 to 20 cm/s during spring tides. The highest current speed recorded at the


Figure 2 Current roses for the western site for the full data record (left) and the five lunar cycle

assessment period (right)

Figure 3 Probability distribution of current vector magnitudes

Sincerely

Jose Romero

Team Leader, Marine and Aquatic Services

+61 8 6222 8992


Figure 1 Time series of current speeds (top), directions (middle) at the western site and

predicted tides at Emu Bay (bottom)


Figure 2 Current roses for the western site for the full data record (left) and the five lunar cycle

assessment period (right)

Figure 3 Probability distribution of current vector magnitudes

Sincerely

Jose Romero

Team Leader, Marine and Aquatic Services

+61 8 6222 8992


Figure 1 Time series of current speeds (top), directions (middle) at the western site and

predicted tides at Emu Bay (bottom)

Smith Bay Seaport

Response to Draft Environmental Impact Statement


Professor Paul McShane

Global Marine Resource Management Pty Ltd.

May 2019

APPENDIX 2 –

GLOBAL MARINE RESOURCE MANAGEMENT RESPONSE TO EISMcShane

2019


Smith Bay Seaport

Response to Draft Environmental Impact Statement



Global Marine Resource Management Pty Ltd.

May 2019

Page 3 of 17

Global Marine Resource Management Pty Ltd


© Global Marine Resource Management Pty Ltd

All rights reserved Smith Bay Seaport Response to Draft Environmental Impact Statement Kangaroo Island Plantation Timbers

May 2019.

www.globalmarineresourcemanagement.com.au

About the author

Professor Paul McShane (BSc (hons); MSc; MBA; PhD; GAICD) is principal of Global Marine Resource Management Pty Ltd, based in Tasmania and serving a national and international client base requiring specialist knowledge in marine and coastal resource assessment with an emphasis on ecologically sustainable development. Professor McShane is also currently a Professorial Research Fellow (Aquaculture) in the College of Science and Engineering, James Cook University.

His past roles include:

• Research Fellow, School of Social Sciences, Faculty of Arts, Monash University; • Chief Research Officer, Monash Sustainability Institute, Monash University; • Director Australian Fisheries Research and Development Corporation; • Vice-President, International and Development and Professor of Marine Sciences, Australian Maritime

College; • Director Fisheries and Marine Environment, Australian Maritime College; • Program Leader, South Australian Research and Development Institute; • Program Leader, New Zealand National Institute of Water and Atmospheric Research Ltd.

Professor McShane has published more than 80 peer-reviewed book chapters, papers and technical reports, plus more than 120 popular articles, contract reports and conference papers.

He has been a director of a number of entities focused on fisheries, seafood and marine science research, management, training and governance, and has a global standing that sees him in demand for expert opinion on marine science, including in Australia, New Zealand, Canada, Japan and the United States.

Page 2 of 17


Disclaimer

The author does not accept any form of liability, be it contractual, tortious, or otherwise, for the contents of this document or for any consequences arising from its use or any reliance placed upon it. The information, opinions and advice contained in this document may not relate, or be relevant, to a reader’s particular circumstances.

Cover photograph

Looking north from Yumbah Aquaculture Smith Bay

Photo: Paul McShane

Page 3 of 17



© Global Marine Resource Management Pty Ltd

All rights reserved Smith Bay Seaport Response to Draft Environmental Impact Statement Kangaroo Island Plantation Timbers

May 2019.

www.globalmarineresourcemanagement.com.au

About the author

Professor Paul McShane (BSc (hons); MSc; MBA; PhD; GAICD) is principal of Global Marine Resource Management Pty Ltd, based in Tasmania and serving a national and international client base requiring specialist knowledge in marine and coastal resource assessment with an emphasis on ecologically sustainable development. Professor McShane is also currently a Professorial Research Fellow (Aquaculture) in the College of Science and Engineering, James Cook University.

His past roles include:

• Research Fellow, School of Social Sciences, Faculty of Arts, Monash University; • Chief Research Officer, Monash Sustainability Institute, Monash University; • Director Australian Fisheries Research and Development Corporation; • Vice-President, International and Development and Professor of Marine Sciences, Australian Maritime

College; • Director Fisheries and Marine Environment, Australian Maritime College; • Program Leader, South Australian Research and Development Institute; • Program Leader, New Zealand National Institute of Water and Atmospheric Research Ltd.

Professor McShane has published more than 80 peer-reviewed book chapters, papers and technical reports, plus more than 120 popular articles, contract reports and conference papers.

He has been a director of a number of entities focused on fisheries, seafood and marine science research, management, training and governance, and has a global standing that sees him in demand for expert opinion on marine science, including in Australia, New Zealand, Canada, Japan and the United States.

Page 2 of 17


Disclaimer

The author does not accept any form of liability, be it contractual, tortious, or otherwise, for the contents of this document or for any consequences arising from its use or any reliance placed upon it. The information, opinions and advice contained in this document may not relate, or be relevant, to a reader’s particular circumstances.

Cover photograph

Looking north from Yumbah Aquaculture Smith Bay

Photo: Paul McShane

Page 5 of 17


INTRODUCTION

Smith Bay is a shallow coastal embayment located within a Coastal Conservation Zone (Department of Planning, Transport and Infrastructure 2015) off Kangaroo Island, South Australia. Kangaroo Island Plantation Timbers (ASX: KPT) proposes to develop a log or chip export facility, including a sea port at Smith Bay capable of accommodating large bulk carriers (www.kipt.com.au). The proposed seaport is less than 500 metres from Yumbah Aquaculture and presents a number of unacceptable risks to the viability of the abalone farm through construction and operation of the seaport. In response to legislative requirements and issues of concern that have been raised, KPT has produced a draft environmental impact statement (KIPT 2019).

This report builds on previous work which identified and characterised the likely impacts of, and extant risks associated with, the proposed seaport (McShane 2017). It addresses issues raised in the draft Environmental Impact Statement (EIS) released in March 2019. It focuses on key hazards and extant risks to the Smith Bay coastal ecosystem and, by extension, the viability of Yumbah’s abalone (among other species that could be farmed at Smith Bay) aquaculture operation (consistent with Yumbah’s existing licences). This report does not address other risks presented by the proposed seaport including terrestrial impacts (e.g. endangered species, dust, noise, traffic, visual amenity).

In relation to the coastal ecosystem of Smith Bay and the continuing viability of Yumbah’s aquaculture operation, major risks arising from the proposed seaport include:

1. Mobilisation of fine sediments from the construction of a 250 m causeway, capital dredging program of an unconfirmed volume of spoil, tailwater discharges from dewatering of sediments on land, maintenance dredging and shipping operations. Apart from likely sub-lethal and potentially lethal impacts on farmed abalone, these proposed activities all have the potential to adversely affect the subtidal ecosystems and associated fauna and flora, including beneficial benthic diatoms (required for farmed abalone nutrition).

2. Changes to the light environment, reduced circulation of nearshore waters and elevated water temperatures will increase the risk of harmful algal blooms at Smith Bay with potential catastrophic impacts on Yumbah’s farmed abalone.

3. Light-spill onto the abalone farm emanating from proposed infrastructure in the hard-standing area and along the seaport/causeway as well as from transport vehicles. Light adversely affects feeding and growth of abalone.

4. Changes in coastal processes (primarily associated with the construction of the causeway) that would impact on nearshore circulation with the potential to:

a. Increase the temperature of Yumbah’s intake water due to reduced mixing in the vicinity of the causeway with potential lethal impact on farmed abalone, and

b. Changed sedimentation and resuspension processes due to changes in benthic sheer stress in the vicinity of the causeway and in the dredged areas.

5. General impact to marine ecology in the Smith Bay environment including seagrasses and species listed under the EPBC Act.

Environmental impacts of dredging on coastal ecosystems are pervasive and well documented (Essink 1999, Wilber and Clark 2001, Bolam and Rees 2003, Bray 2008) including studies of South Australian ecosystems (Westphalen et al. 2004). Specific impacts relating to Smith Bay and to the Yumbah abalone farm are described below. Extant risks are evaluated given the information contained in the draft EIS report (KIPT 2019), relevant publications and reports, and the available evidence based on an evaluation of existing information. Much of the specific information relevant to the following risks is contained in Appendices to the Main report of the draft Environmental Impact Statement (KIPT 2019). These are referenced where applicable.

Page 4 of 17


CONTENTS

Introduction ................................................................................................................................................................ 5

Fine sediment in the context of impacts on abalone................................................................................................. 6

Abalone and their natural environment .................................................................................................................... 6

Review of sediment impacts on abalone ................................................................................................................... 7

Lack of ecotoxicological tests ..................................................................................................................................... 9

Fine sediment effects on abalone .............................................................................................................................. 9

Adverse temperature effects on abalone: likely consequences of reduced local currents .................................... 11

Sediment impacts on diatoms and risk of harmful algal blooms ............................................................................. 11

Extraneous light impacts on abalone ....................................................................................................................... 12

Marine ecological impacts: seagrasses and listed marine species .......................................................................... 12

References ................................................................................................................................................................ 13

Page 5 of 17


INTRODUCTION

Smith Bay is a shallow coastal embayment located within a Coastal Conservation Zone (Department of Planning, Transport and Infrastructure 2015) off Kangaroo Island, South Australia. Kangaroo Island Plantation Timbers (ASX: KPT) proposes to develop a log or chip export facility, including a sea port at Smith Bay capable of accommodating large bulk carriers (www.kipt.com.au). The proposed seaport is less than 500 metres from Yumbah Aquaculture and presents a number of unacceptable risks to the viability of the abalone farm through construction and operation of the seaport. In response to legislative requirements and issues of concern that have been raised, KPT has produced a draft environmental impact statement (KIPT 2019).

This report builds on previous work which identified and characterised the likely impacts of, and extant risks associated with, the proposed seaport (McShane 2017). It addresses issues raised in the draft Environmental Impact Statement (EIS) released in March 2019. It focuses on key hazards and extant risks to the Smith Bay coastal ecosystem and, by extension, the viability of Yumbah’s abalone (among other species that could be farmed at Smith Bay) aquaculture operation (consistent with Yumbah’s existing licences). This report does not address other risks presented by the proposed seaport including terrestrial impacts (e.g. endangered species, dust, noise, traffic, visual amenity).

In relation to the coastal ecosystem of Smith Bay and the continuing viability of Yumbah’s aquaculture operation, major risks arising from the proposed seaport include:

1. Mobilisation of fine sediments from the construction of a 250 m causeway, capital dredging program of an unconfirmed volume of spoil, tailwater discharges from dewatering of sediments on land, maintenance dredging and shipping operations. Apart from likely sub-lethal and potentially lethal impacts on farmed abalone, these proposed activities all have the potential to adversely affect the subtidal ecosystems and associated fauna and flora, including beneficial benthic diatoms (required for farmed abalone nutrition).

2. Changes to the light environment, reduced circulation of nearshore waters and elevated water temperatures will increase the risk of harmful algal blooms at Smith Bay with potential catastrophic impacts on Yumbah’s farmed abalone.

3. Light-spill onto the abalone farm emanating from proposed infrastructure in the hard-standing area and along the seaport/causeway as well as from transport vehicles. Light adversely affects feeding and growth of abalone.

4. Changes in coastal processes (primarily associated with the construction of the causeway) that would impact on nearshore circulation with the potential to:

a. Increase the temperature of Yumbah’s intake water due to reduced mixing in the vicinity of the causeway with potential lethal impact on farmed abalone, and

b. Changed sedimentation and resuspension processes due to changes in benthic sheer stress in the vicinity of the causeway and in the dredged areas.

5. General impact to marine ecology in the Smith Bay environment including seagrasses and species listed under the EPBC Act.

Environmental impacts of dredging on coastal ecosystems are pervasive and well documented (Essink 1999, Wilber and Clark 2001, Bolam and Rees 2003, Bray 2008) including studies of South Australian ecosystems (Westphalen et al. 2004). Specific impacts relating to Smith Bay and to the Yumbah abalone farm are described below. Extant risks are evaluated given the information contained in the draft EIS report (KIPT 2019), relevant publications and reports, and the available evidence based on an evaluation of existing information. Much of the specific information relevant to the following risks is contained in Appendices to the Main report of the draft Environmental Impact Statement (KIPT 2019). These are referenced where applicable.

Page 4 of 17


CONTENTS

Introduction ................................................................................................................................................................ 5

Fine sediment in the context of impacts on abalone................................................................................................. 6

Abalone and their natural environment .................................................................................................................... 6

Review of sediment impacts on abalone ................................................................................................................... 7

Lack of ecotoxicological tests ..................................................................................................................................... 9

Fine sediment effects on abalone .............................................................................................................................. 9

Adverse temperature effects on abalone: likely consequences of reduced local currents .................................... 11

Sediment impacts on diatoms and risk of harmful algal blooms ............................................................................. 11

Extraneous light impacts on abalone ....................................................................................................................... 12

Marine ecological impacts: seagrasses and listed marine species .......................................................................... 12

References ................................................................................................................................................................ 13

Page 7 of 17


dredging operations to the abalone farm intakes because the coarser, heavier particles, would settle more rapidly and will not remain in suspension long enough to reach the seawater intakes.

Not surprisingly, there are relatively few studies which explore impacts of fine sediments on abalone as these are rarely, if ever, encountered in the natural habitat of abalone and have not, until now, been considered as an imminent risk to abalone. Indeed, this is also acknowledged in the draft EIS (Appendix H, page 33). The paucity of papers detailing negative effects of suspended sediments on sub-adult through to adult animals is likely because such impacts rarely occur in the natural environment. This statement is further qualified by Cheshire (2018): Most southern Australian abalone species (with the exception of H. cyclobates), live in environments where they are frequently exposed to high levels of suspended sediments (Appendix H, Pages 33,34). Yet these “sediments” are coarse particles (seaweed fragments and sand), much larger than those typically encountered in dredge spoil (Thomas and Ridd 2004, Blott and Pye 2012). This is acknowledged by Cheshire (2018): Abalone have evolved to live in an environment where, in order to feed and grow, they need to be able to deal with the associated suspension of sand and other forms of detritus (see e.g. Melville-Smith et al. 2017) (Appendix H, Page 38).

REVIEW OF SEDIMENT IMPACTS ON ABALONE

Table H-7 of Appendix H, reproduced below, purports to show a relatively benign effect of suspended solids on abalone. Most of the studies cited expose abalone to high total suspended solid concentrations, but few studies examine the specific impact of fine sediments. Such impacts are directly relevant to the evaluation of fine sediment impacts on farmed abalone at Yumbah. Those studies that do examine fine sediments (e.g. Chung et al. 1993) indicate a relationship between concentration (fine sediment loads) and exposure. Many experimental studies of sediment impacts examine concentration (of sediment) alone and duration of exposure is not considered. Acute exposure (48 h) of Haliotis discus to 50 mg/l fine sediments caused no mortality whereas longer exposure for 96h) caused 7.5% of the exposed population (Chung et al. 1993). Similarly, concentration alone correlated poorly with the response of salmonid fish to suspended solids whereas duration was more strongly associated with fish response (Wilber and Clark 2001).

Construction of the causeway and the dredging of the berthing basin will collectively entail more than six months of exposure to fine sediment loads in Smith Bay (KIPT 2019 main report, page 52). Fine sediment emanating from dredge spoil and construction debris will enter Yumbah’s seawater intakes. This presents an unacceptable risk and will significantly compromise the continuing viability of abalone farming at Yumbah, Smith Bay. Thus, risks of the seaport on abalone should be evaluated in terms of concentration (likely fine sediment loads) and exposure to the hazard (duration). This has not been done in the draft EIS (KIPT 2019).

Extremely high concentrations of fine sediment (1,000 mg/l) caused substantial mortality (> 80%) in abalone (Chung et al. 1993). Stringer (2018a) draws attention to the lack of controls and replication of many of the studies cited in Table H-7 but notes greater rigor in the design of Yoon and Park (2011). However, Yoon and Park’s (2001) study did not examine specific impacts of fine sediments and, as Stringer (2018a) points out, may have little relevance to likely impacts on H. laevigata (… further investigation is required before any guideline value is derived for greenlip abalone).

Stringer (2018a) citing Cheshire (2018) claims that the ANZECC (2000) trigger value of 10 mg/l total suspended solids for aquaculture is overly conservative for abalone. They attempt to justify a new guideline value of 25 mg/l: suspended sediment levels are not expected to exceed values the defined threshold (25 mg/l) at which no chronic or acute effects are likely (Appendix H, Page 69). Given that there is no evidence presented in the EIS regarding chronic effects of fine sediment on abalone, and their own claim that further investigation is required (see above), there is no objective basis for setting trigger values higher than the aquaculture guideline of <10m/L. ANZECC (2000) states that Guideline trigger values are concentrations that, if exceeded, will indicate a potential environmental problem, and so ‘trigger’ further investigation. The investigation aims to both assess

Page 6 of 17


FINE SEDIMENT IN THE CONTEXT OF IMPACTS ON ABALONE

The EIS guidelines (DAC 2017) require the proponents to: outline impacts that dredging may have on sediment loads and the neighbouring commercial land-based aquaculture operation. Detail measures for managing these impacts, including management of dredge spoil (Guideline No. 2.7, Table H-1, Appendix H, Page 13).

Due to the proximity of the proposed seaport to Yumbah Kangaroo Island (KI), there will be detrimental impacts of increased suspended sediments arising from the construction and operation of the proposed seaport on Yumbah’s abalone farming activities. The draft EIS has recognised that impact is likely. The capital dredging program has the potential to affect water quality, principally suspended sediment loads, at the Yumbah seawater intakes under some dredging scenarios (Appendix H, Page 9).

Furthermore, in relation to the potential ecotoxicity of suspended sediments: Sediments used in the test were obtained from Smith Bay but were dried and then sieved through a 64 µm sieve to ensure that the material used for testing comprised only the finer sediment fraction which would both remain in suspension (i.e. not settle out) and has a particle size that is more likely to have an adverse effect on animals exposed to the sediments. These finer sediments are also representative of the fraction that would be transported from the dredging operations to the abalone farm intakes because the coarser, heavier particles, would settle more rapidly and will not remain in suspension long enough to reach the seawater intakes (Appendix H, Page 47).

There are a number of statements throughout Appendix H (Cheshire 2018) and elsewhere throughout the EIS that state that abalone are well adapted to high sediment loads in their natural habitat. These references are inflated and misleading. In fact, abalone are demonstrably not well adapted to fine sediments (silt and clay particles). Again, this finding is reinforced by Cheshire (2018). Such resilience (of abalone to high suspended sediment loads) is likely to be skewed towards the coarser sediment fractions because, in the abalone’s natural environment, finer materials would be winnowed out of the system (Appendix H, Page 42).

ABALONE AND THEIR NATURAL ENVIRONMENT

There are numerous statements in the EIS that suggest abalone (including Haliotis laevigata) are well adapted to high suspended sediment loads because they live in high energy subtidal coastal environments which provide suspended material such as seaweed particles upon which abalone rely on for food (McShane et al. 1994). Yet Cheshire (2018) consistently understates that the tolerance is only to larger suspended matter unrepresentative of fine sediments characteristic of dredge spoil.

It is true that abalone are well adapted to high energy coastal environments (Tissot 1992, Shepherd 1973). As marine gastropods in their natural environment, abalone cling to rocky substrata and aggregate in areas where seaweed particles accumulate (Shepherd 1973). Tissot’s (1992) study, quoted extensively by Cheshire (2018), presents some adaptative strategies of various abalone species to tolerate high water movement (i.e. to mitigate shear stress in adhering to reef surfaces). This is not evidence of tolerance to high suspended sediment loads as claimed by Cheshire (2018). Rather, such adaptations relate to withstanding the sheer stress created by wave-induced turbulence in typical coastal subtidal habitat. The ability of abalone to maintain adherence to rocky substrata, feed and avoid predation require such adaptation (Tissot 1992, Naylor and McShane 1997). Furthermore, abalone’s inability to actively ventilate their gills requires a dependence on passive water movement (Ragg and Taylor 2006, Voltzow 2015). Thus, abalone are poorly adapted to low water movement (Tissot 1992): conditions in which fine sediment fractions accumulate (Airoldi 2003, Blott and Pye 2012).

Under turbulent conditions typical of sub littoral coastal environments, only large particles are found among suspended solids in seawater (Thomas and Ridd 2004, Blott and Pye 2012) including the drift seaweed particles favoured by abalone as food (Shepherd 1973). Indeed, this is acknowledged by the Cheshire (2018) (Appendix H, page 47): These finer sediments are also representative of the fraction that would be transported from the

Page 7 of 17


dredging operations to the abalone farm intakes because the coarser, heavier particles, would settle more rapidly and will not remain in suspension long enough to reach the seawater intakes.

Not surprisingly, there are relatively few studies which explore impacts of fine sediments on abalone as these are rarely, if ever, encountered in the natural habitat of abalone and have not, until now, been considered as an imminent risk to abalone. Indeed, this is also acknowledged in the draft EIS (Appendix H, page 33). The paucity of papers detailing negative effects of suspended sediments on sub-adult through to adult animals is likely because such impacts rarely occur in the natural environment. This statement is further qualified by Cheshire (2018): Most southern Australian abalone species (with the exception of H. cyclobates), live in environments where they are frequently exposed to high levels of suspended sediments (Appendix H, Pages 33,34). Yet these “sediments” are coarse particles (seaweed fragments and sand), much larger than those typically encountered in dredge spoil (Thomas and Ridd 2004, Blott and Pye 2012). This is acknowledged by Cheshire (2018): Abalone have evolved to live in an environment where, in order to feed and grow, they need to be able to deal with the associated suspension of sand and other forms of detritus (see e.g. Melville-Smith et al. 2017) (Appendix H, Page 38).

REVIEW OF SEDIMENT IMPACTS ON ABALONE

Table H-7 of Appendix H, reproduced below, purports to show a relatively benign effect of suspended solids on abalone. Most of the studies cited expose abalone to high total suspended solid concentrations, but few studies examine the specific impact of fine sediments. Such impacts are directly relevant to the evaluation of fine sediment impacts on farmed abalone at Yumbah. Those studies that do examine fine sediments (e.g. Chung et al. 1993) indicate a relationship between concentration (fine sediment loads) and exposure. Many experimental studies of sediment impacts examine concentration (of sediment) alone and duration of exposure is not considered. Acute exposure (48 h) of Haliotis discus to 50 mg/l fine sediments caused no mortality whereas longer exposure for 96h) caused 7.5% of the exposed population (Chung et al. 1993). Similarly, concentration alone correlated poorly with the response of salmonid fish to suspended solids whereas duration was more strongly associated with fish response (Wilber and Clark 2001).

Construction of the causeway and the dredging of the berthing basin will collectively entail more than six months of exposure to fine sediment loads in Smith Bay (KIPT 2019 main report, page 52). Fine sediment emanating from dredge spoil and construction debris will enter Yumbah’s seawater intakes. This presents an unacceptable risk and will significantly compromise the continuing viability of abalone farming at Yumbah, Smith Bay. Thus, risks of the seaport on abalone should be evaluated in terms of concentration (likely fine sediment loads) and exposure to the hazard (duration). This has not been done in the draft EIS (KIPT 2019).

Extremely high concentrations of fine sediment (1,000 mg/l) caused substantial mortality (> 80%) in abalone (Chung et al. 1993). Stringer (2018a) draws attention to the lack of controls and replication of many of the studies cited in Table H-7 but notes greater rigor in the design of Yoon and Park (2011). However, Yoon and Park’s (2001) study did not examine specific impacts of fine sediments and, as Stringer (2018a) points out, may have little relevance to likely impacts on H. laevigata (… further investigation is required before any guideline value is derived for greenlip abalone).

Stringer (2018a) citing Cheshire (2018) claims that the ANZECC (2000) trigger value of 10 mg/l total suspended solids for aquaculture is overly conservative for abalone. They attempt to justify a new guideline value of 25 mg/l: suspended sediment levels are not expected to exceed values the defined threshold (25 mg/l) at which no chronic or acute effects are likely (Appendix H, Page 69). Given that there is no evidence presented in the EIS regarding chronic effects of fine sediment on abalone, and their own claim that further investigation is required (see above), there is no objective basis for setting trigger values higher than the aquaculture guideline of <10m/L. ANZECC (2000) states that Guideline trigger values are concentrations that, if exceeded, will indicate a potential environmental problem, and so ‘trigger’ further investigation. The investigation aims to both assess

Page 6 of 17


FINE SEDIMENT IN THE CONTEXT OF IMPACTS ON ABALONE

The EIS guidelines (DAC 2017) require the proponents to: outline impacts that dredging may have on sediment loads and the neighbouring commercial land-based aquaculture operation. Detail measures for managing these impacts, including management of dredge spoil (Guideline No. 2.7, Table H-1, Appendix H, Page 13).

Due to the proximity of the proposed seaport to Yumbah Kangaroo Island (KI), there will be detrimental impacts of increased suspended sediments arising from the construction and operation of the proposed seaport on Yumbah’s abalone farming activities. The draft EIS has recognised that impact is likely. The capital dredging program has the potential to affect water quality, principally suspended sediment loads, at the Yumbah seawater intakes under some dredging scenarios (Appendix H, Page 9).

Furthermore, in relation to the potential ecotoxicity of suspended sediments: Sediments used in the test were obtained from Smith Bay but were dried and then sieved through a 64 µm sieve to ensure that the material used for testing comprised only the finer sediment fraction which would both remain in suspension (i.e. not settle out) and has a particle size that is more likely to have an adverse effect on animals exposed to the sediments. These finer sediments are also representative of the fraction that would be transported from the dredging operations to the abalone farm intakes because the coarser, heavier particles, would settle more rapidly and will not remain in suspension long enough to reach the seawater intakes (Appendix H, Page 47).

There are a number of statements throughout Appendix H (Cheshire 2018) and elsewhere throughout the EIS that state that abalone are well adapted to high sediment loads in their natural habitat. These references are inflated and misleading. In fact, abalone are demonstrably not well adapted to fine sediments (silt and clay particles). Again, this finding is reinforced by Cheshire (2018). Such resilience (of abalone to high suspended sediment loads) is likely to be skewed towards the coarser sediment fractions because, in the abalone’s natural environment, finer materials would be winnowed out of the system (Appendix H, Page 42).

ABALONE AND THEIR NATURAL ENVIRONMENT

There are numerous statements in the EIS that suggest abalone (including Haliotis laevigata) are well adapted to high suspended sediment loads because they live in high energy subtidal coastal environments which provide suspended material such as seaweed particles upon which abalone rely on for food (McShane et al. 1994). Yet Cheshire (2018) consistently understates that the tolerance is only to larger suspended matter unrepresentative of fine sediments characteristic of dredge spoil.

It is true that abalone are well adapted to high energy coastal environments (Tissot 1992, Shepherd 1973). As marine gastropods in their natural environment, abalone cling to rocky substrata and aggregate in areas where seaweed particles accumulate (Shepherd 1973). Tissot’s (1992) study, quoted extensively by Cheshire (2018), presents some adaptative strategies of various abalone species to tolerate high water movement (i.e. to mitigate shear stress in adhering to reef surfaces). This is not evidence of tolerance to high suspended sediment loads as claimed by Cheshire (2018). Rather, such adaptations relate to withstanding the sheer stress created by wave-induced turbulence in typical coastal subtidal habitat. The ability of abalone to maintain adherence to rocky substrata, feed and avoid predation require such adaptation (Tissot 1992, Naylor and McShane 1997). Furthermore, abalone’s inability to actively ventilate their gills requires a dependence on passive water movement (Ragg and Taylor 2006, Voltzow 2015). Thus, abalone are poorly adapted to low water movement (Tissot 1992): conditions in which fine sediment fractions accumulate (Airoldi 2003, Blott and Pye 2012).

Under turbulent conditions typical of sub littoral coastal environments, only large particles are found among suspended solids in seawater (Thomas and Ridd 2004, Blott and Pye 2012) including the drift seaweed particles favoured by abalone as food (Shepherd 1973). Indeed, this is acknowledged by the Cheshire (2018) (Appendix H, page 47): These finer sediments are also representative of the fraction that would be transported from the

Page 9 of 17


LACK OF ECOTOXICOLOGICAL TESTS

The likely consequences of dredging activities in Smith Bay are captured in Page 51 of Appendix H: These estimates of suspended sediment loads do not provide specific predictions on the likely composition of the suspended material in relation to the particle size distribution (PSD). Ambient sediment loads are likely to show changes through time in PSD with coarser particles being found during and immediately after storm induced resuspension events (e.g. periods of rough weather). The same is not true of the sediment plume generated by dredging operations. At the point of dredging the plume will likely be comprised of the full range of coarse and fine sediment particles but as the suspended material moves further away from the dredging site the coarser particles will settle more rapidly and hence, at a greater distance, the material remaining in suspension will be dominated by the finer size classes of sediment (consistent with those tested in the ecotoxicology studies).

The findings presented by Stringer (2018b) do not constitute an ecotoxicological evaluation of fine sediments on abalone. Short term exposure of wild juvenile H. laevigata to fine sediments (24 h at 250 mg/l) revealed no mortality (Springer 2018b). However, as the short-term tests revealed no mortalities (after 24 h exposure and 48 h recovery), these results do not constitute an ecotoxicological assessment. Acute and chronic impacts were not observed (e.g. feeding rates, respiration). Furthermore, abalone cultivated at Yumbah Kangaroo Island have been selectively bred for Yumbah’s farming conditions from brood stock that have been genetically selected for optimal farming conditions. Juvenile abalone exposed to sediment in the laboratory test described by Springer (2018b) were sourced from wild populations and their behaviour cannot be directly compared to farmed abalone due to the genetic optimisation of Yumbah’s farmed stock. Springer (2018b) notes that only a limited number of juvenile abalone were able to be obtained from the wild.

Despite the obvious limitations presented above and a demonstrably inadequate ecotoxicological assessment, Cheshire (2018) concludes: This result demonstrates that for a 24-h exposure juvenile greenlip abalone have a NOEC of at least 250 mg/l against which a ten times safety factor has been applied to account for acute vs chronic effects. This provides a water quality guideline of 25 mg/l at which neither chronic nor acute effects would be expected (Appendix H, Page 47). There is no objective basis for this conclusion including the arbitrary assignment of a water quality guideline for suspended sediment, derived from one bioassay that exposes abalone to a given concentration for a limited duration that is unrelated to the actual exposure that will result from dredging.

FINE SEDIMENT EFFECTS ON ABALONE

There are several lines of evidence that support harmful consequences of exposure of abalone to fine sediments. Abalone are primitive gastropods retaining a bipectinate gill structure which is relatively inefficient at extracting oxygen from seawater compared with more advanced molluscs (Wanichanon et al. 2004, Ragg and Taylor 2006, Morash and Alter 2016). Abalone have weak capacity to actively ventilate their gills and, instead, rely on passive water movement in their natural habitat (Tissot 1992, Ragg and Taylor 2006). Water movement across the perforated shell of abalone drives water into the brachial chambers and to the mantle cavity (Ragg and Taylor 2006, Morash and Alter 2016). Thus, abalone typically inhabit high energy sublittoral environments where water movement generated by waves and tide provide for the necessary gill ventilation. The shells of abalone are adapted to reduce drag (and therefore shear forces which could remove them from reef substrata) and to provide for gill/mantle ventilation (Tissot 1992).

Associated with the gills of abalone is a hypobranchial gland which functions to produce mucus to keep the gills and the mantle cavity clean (Wanichanon et al. 2004). When foreign particles from turbid water enter the mantle cavity, the mucus cells bind particles that can be expelled through the ciliary action of the epithelial cells. Abalone have limited capacity to clear fine sediment and associated mucus. Exposure to fine sediment can therefore have an adverse impact on abalone health (Ragg 2014), as has been demonstrated for farmed H. laevigata at Yumbah KI (see below). Similar adverse effects of fine sediments have been found in other shellfish

Page 8 of 17


whether exceedance of a trigger value will result in environmental harm and refine a guideline value, by accounting for environmental factors that can modify the effect of the chemical. Although in some cases this will require more work, it will result in much more realistic goals for management and therefore has the potential to reduce both costs for industry and confrontation. This invalidates the risk assessment relating to potential dredge impacts on abalone (Appendix H, Table H-12, Page 71) which assumes a threshold suspended solids concentration of 25 mg/l. ANZECC (2000) explicitly states that thorough assessments are required that are site specific and that consider all environmental factors.

Table H-7 is reproduced below with comments added. It purports to present acute impacts of suspended solids on abalone and other marine fauna. Additional tests by Springer (2018b) are also added to the Table originally published in Appendix H (KIPT 2019).

Species Treatments Period Finding Source Comment

Haliotis discus hannai

TSS at: 0, 1000,1500 and 2000 mg/l

96 h No effect on mortality. Decrease in glycogen content over 1500 mg/l

Lee 2008 Unrepresentative impact as does not examine fine sediment effects

H. diversicolor TSS at: 100, 200, 300, 400 mg/l

96 h No effect on mortality, weaker motility at higher concentrations

Wang et al. 2007

Unrepresentative impact as does not examine fine sediment effects

H. discus TSS (silt and clay): 50 mg/l

48 h No effect on mortality

Chung et al. 1993

Provides evidence of mortality effects for longer exposure (see below)


72 h

96 h

0-1.25% mortality

0-7.5% mortality

Chung et al. 1993

Evidence of exposure/concentration effects


96 h Up to 82.5% mortality

Chung et al. 1993

Evidence of concentration effects

H. discus hannai

TSS at: 250, 500, 1000, 2000, and 4000 mg/l

7 d LOEC = 500 mg/l

LC50 = 1888 mg/l

Yoon and Park 2011

No information provided on particle size distribution

Tigriopus japonicas (copepod)

TSS at: 250, 500, 1000, 2000, and 4000 mg/l

7 d LOEC = 31 mg/l

LC50 = 61 mg/l

Yoon and Park 2011

Evidence of exposure/concentration effects.

Unrelated species.

Paralichthys olivaceus (flounder fry)

TSS at: 250, 500, 1000, 2000, and 4000 mg/l

7 d LOEC = 125 mg/l

LC50 = 157 mg/l

Yoon and Park 2011

Evidence of exposure/concentration effects. Unrelated species.

H. iris Synthetic particles 100 mg/l

No significant effect on mortality

Allen et al. 2006


H. laevigata TSS (< 63 µm) 250 mg/l


Springer 2018b

Short term exposure only. No examination of sublethal impacts. Not representative ecotoxicity test

Page 9 of 17


LACK OF ECOTOXICOLOGICAL TESTS

The likely consequences of dredging activities in Smith Bay are captured in Page 51 of Appendix H: These estimates of suspended sediment loads do not provide specific predictions on the likely composition of the suspended material in relation to the particle size distribution (PSD). Ambient sediment loads are likely to show changes through time in PSD with coarser particles being found during and immediately after storm induced resuspension events (e.g. periods of rough weather). The same is not true of the sediment plume generated by dredging operations. At the point of dredging the plume will likely be comprised of the full range of coarse and fine sediment particles but as the suspended material moves further away from the dredging site the coarser particles will settle more rapidly and hence, at a greater distance, the material remaining in suspension will be dominated by the finer size classes of sediment (consistent with those tested in the ecotoxicology studies).

The findings presented by Stringer (2018b) do not constitute an ecotoxicological evaluation of fine sediments on abalone. Short term exposure of wild juvenile H. laevigata to fine sediments (24 h at 250 mg/l) revealed no mortality (Springer 2018b). However, as the short-term tests revealed no mortalities (after 24 h exposure and 48 h recovery), these results do not constitute an ecotoxicological assessment. Acute and chronic impacts were not observed (e.g. feeding rates, respiration). Furthermore, abalone cultivated at Yumbah Kangaroo Island have been selectively bred for Yumbah’s farming conditions from brood stock that have been genetically selected for optimal farming conditions. Juvenile abalone exposed to sediment in the laboratory test described by Springer (2018b) were sourced from wild populations and their behaviour cannot be directly compared to farmed abalone due to the genetic optimisation of Yumbah’s farmed stock. Springer (2018b) notes that only a limited number of juvenile abalone were able to be obtained from the wild.

Despite the obvious limitations presented above and a demonstrably inadequate ecotoxicological assessment, Cheshire (2018) concludes: This result demonstrates that for a 24-h exposure juvenile greenlip abalone have a NOEC of at least 250 mg/l against which a ten times safety factor has been applied to account for acute vs chronic effects. This provides a water quality guideline of 25 mg/l at which neither chronic nor acute effects would be expected (Appendix H, Page 47). There is no objective basis for this conclusion including the arbitrary assignment of a water quality guideline for suspended sediment, derived from one bioassay that exposes abalone to a given concentration for a limited duration that is unrelated to the actual exposure that will result from dredging.

FINE SEDIMENT EFFECTS ON ABALONE

There are several lines of evidence that support harmful consequences of exposure of abalone to fine sediments. Abalone are primitive gastropods retaining a bipectinate gill structure which is relatively inefficient at extracting oxygen from seawater compared with more advanced molluscs (Wanichanon et al. 2004, Ragg and Taylor 2006, Morash and Alter 2016). Abalone have weak capacity to actively ventilate their gills and, instead, rely on passive water movement in their natural habitat (Tissot 1992, Ragg and Taylor 2006). Water movement across the perforated shell of abalone drives water into the brachial chambers and to the mantle cavity (Ragg and Taylor 2006, Morash and Alter 2016). Thus, abalone typically inhabit high energy sublittoral environments where water movement generated by waves and tide provide for the necessary gill ventilation. The shells of abalone are adapted to reduce drag (and therefore shear forces which could remove them from reef substrata) and to provide for gill/mantle ventilation (Tissot 1992).

Associated with the gills of abalone is a hypobranchial gland which functions to produce mucus to keep the gills and the mantle cavity clean (Wanichanon et al. 2004). When foreign particles from turbid water enter the mantle cavity, the mucus cells bind particles that can be expelled through the ciliary action of the epithelial cells. Abalone have limited capacity to clear fine sediment and associated mucus. Exposure to fine sediment can therefore have an adverse impact on abalone health (Ragg 2014), as has been demonstrated for farmed H. laevigata at Yumbah KI (see below). Similar adverse effects of fine sediments have been found in other shellfish

Page 8 of 17


whether exceedance of a trigger value will result in environmental harm and refine a guideline value, by accounting for environmental factors that can modify the effect of the chemical. Although in some cases this will require more work, it will result in much more realistic goals for management and therefore has the potential to reduce both costs for industry and confrontation. This invalidates the risk assessment relating to potential dredge impacts on abalone (Appendix H, Table H-12, Page 71) which assumes a threshold suspended solids concentration of 25 mg/l. ANZECC (2000) explicitly states that thorough assessments are required that are site specific and that consider all environmental factors.

Table H-7 is reproduced below with comments added. It purports to present acute impacts of suspended solids on abalone and other marine fauna. Additional tests by Springer (2018b) are also added to the Table originally published in Appendix H (KIPT 2019).

Species Treatments Period Finding Source Comment

Haliotis discus hannai

TSS at: 0, 1000,1500 and 2000 mg/l

96 h No effect on mortality. Decrease in glycogen content over 1500 mg/l

Lee 2008 Unrepresentative impact as does not examine fine sediment effects

H. diversicolor TSS at: 100, 200, 300, 400 mg/l

96 h No effect on mortality, weaker motility at higher concentrations

Wang et al. 2007




Chung et al. 1993

Provides evidence of mortality effects for longer exposure (see below)


72 h

96 h

0-1.25% mortality

0-7.5% mortality

Chung et al. 1993

Evidence of exposure/concentration effects


96 h Up to 82.5% mortality

Chung et al. 1993

Evidence of concentration effects

H. discus hannai

TSS at: 250, 500, 1000, 2000, and 4000 mg/l

7 d LOEC = 500 mg/l

LC50 = 1888 mg/l

Yoon and Park 2011

No information provided on particle size distribution

Tigriopus japonicas (copepod)

TSS at: 250, 500, 1000, 2000, and 4000 mg/l

7 d LOEC = 31 mg/l

LC50 = 61 mg/l

Yoon and Park 2011

Evidence of exposure/concentration effects.

Unrelated species.

Paralichthys olivaceus (flounder fry)

TSS at: 250, 500, 1000, 2000, and 4000 mg/l

7 d LOEC = 125 mg/l

LC50 = 157 mg/l

Yoon and Park 2011

Evidence of exposure/concentration effects. Unrelated species.

H. iris Synthetic particles 100 mg/l

No significant effect on mortality

Allen et al. 2006


H. laevigata TSS (< 63 µm) 250 mg/l


Springer 2018b

Short term exposure only. No examination of sublethal impacts. Not representative ecotoxicity test

Page 11 of 17


ADVERSE TEMPERATURE EFFECTS ON ABALONE: LIKELY CONSEQUENCES OF REDUCED LOCAL CURRENTS

Proposed construction of a 250 m causeway will substantially affect nearshore water movement in Smith Bay. The draft EIS indicates that reduction in current speed at Yumbah’s westerly seawater intake will be about 30-40% (Appendix H, page 65): this will coincide with an increase in ambient seawater temperature (Appendix G, page 23).

The adverse consequences of increased water temperature on abalone are acknowledged by Cheshire (2018): Likely increases in water temperature accentuated by recirculation of Yumbah effluent water will also have a harmful effect on abalone. Data collected for the EIS throughout 2017, using moored data buoys that were equipped with a suite of water quality and hydrodynamic sensors (detailed in Chapter 10), show that mean seawater temperature during the monitoring period at Smith Bay within 300 m of shore during summer was around 21-22o C but there were spikes up to 25 o C recorded during heatwaves (see Chapter 9) (Appendix H, Page 27). As Cheshire (2018) further notes: many farms across South Australia have reported substantial mortality events at much lower temperatures (22-23o C; Vandepeer 2006).

SEDIMENT IMPACTS ON DIATOMS AND RISK OF HARMFUL ALGAL BLOOMS

Diatoms are unicellular non-motile phytoplankton important in the diet of abalone farmed at Yumbah (McShane 2017). Dredge spoil presents a risk to the viability of diatoms in the subtidal environment of Smith Bay by decreasing available light and affecting light quality. Several unsubstantiated claims are made in Appendix H in relation to diatoms and dredge effects (Pages 18, 54, and 67):

• Diatoms are only important in diet of early stages of abalone; • Algae exhibit a high level of plasticity in their adaptation to ambient light environments allowing

adjustments to adverse light climate; • Changes in turbidity at shallow depths are small and will not have an adverse effect on diatom

production; • Conditions that would promote harmful algal blooms (red tides) are not likely to occur in Smith Bay.

In fact, advice from Yumbah KI’s hatchery manager reveals that diatoms are important dietary supplements across all life-history stages of the farm operation. My previous report (McShane 2017) drew attention to likely negative impacts of fine sediment dispersal on diatom growth. Fine sediments, particularly clay particles, selectively absorb blue light negatively impacting on diatom growth (Prieur and Sathyendranath 1981). Although diatoms have accessory pigments that can harvest other spectral components e.g. green light (Vesk and Jeffrey 1977, Humphrey 1983), carbon metabolism and growth of diatoms is favoured under conditions of blue light (Mercado et al. 2004, Cao et al. 2013, Lockhart 2013, Lawrenz and Richardson 2017, Baldisserotto et al. 2019).

The benthic diatoms preferred as food for farmed abalone lack the motility to migrate to surface waters where the full spectrum of photosynthetically active radiation (PAR) is available (Ault 2000). Thus, motile organisms such as dinoflagellates including red tide species, may be favoured over diatoms in suboptimal light regimes (low- or poor-quality light) (Ault 2000; Park et al. 2001; Smayda and Reynolds 2001; Peperzak 2003, Shikata et al. 2013, 2015, 2017; Zhou et al. 2017) or low nutrient conditions (Charles et al. 2005). Thus, attenuation of light through suspension of fine sediments during construction of the proposed seaport and during maintenance dredging activities will have a deleterious effect on those benthic diatoms favoured in the diet of abalone farmed at Yumbah. Further to this, changes to light climate in Smith Bay coupled with the potential introduction of exotic dinoflagellates (via ballast water) increases the risk harmful algal blooms (e.g. Park et al. 2001, see also Dowsett et al. 2011 for H. laevigata).

Page 10 of 17


e.g. scallops (Stevens 1987). Pumping rates of the gills of bivalves is reduced by more than 90% in the presence of fine sediment (80 mg/l). Lateral cilia in bivalves lack the capacity to clear particles which accumulate at the leading edge of the gills causing frictional drag (Stevens 1987, Yang et al. 2017). Fine suspended silt (< 5 µm) was found to be more deleterious to bivalves than coarser (5-25 µm particles) (Stevens 1987). Unsurprisingly, when present in aquaria, abalone avoid fine sediment: fine sediment adversely affects the righting response (Chew et al. 2013).

Such findings are consistent with observed mortalities of H. laevigata at Yumbah KI (McShane 2017). Following severe storms at Smith Bay during September 2016, mortalities of farmed abalone were observed. Similar impacts were observed following a less intense storm during October of the same year (David Connell Yumbah, personal communication). Abalone appeared moribund 2 days after the storm and mortality occurred over 6 weeks following initial impact (storm suspension of fine sediment). Histopathological analysis by Dr Richmond Loh, an aquatic animal health specialist, revealed the following (Letter to David Connell 28th March 2017): Mortalities were worst in 3 to 4-year old group (harvest class), though 1-year olds were also affected. Clinical signs reported in abalone include swollen head, swollen foot, and difficulty holding onto substrate, and death within 2 days of showing clinical signs. Storms and abalone deaths coincided with higher frequency of clogging of their 1 µm water filters (in their hatchery).

Microscopic examination of 20 abalone showed consistent lesions, the most significant being gill damage.

Changes in the surface mucus layer observed in H. laevigata may be caused by changes in:

• Viscosity of the mucus (dilution) • Reduced production of mucus • Degradation by enzymes, or • Increased loss of mucus.

We suspect that the breakdown of their mucus barrier and damage to the epithelium of the gills and skin, may lead to electrolyte disturbances and dehydration – and death ensues.

The sick abalone all had inflammation and oedema, varying from moderate to marked, varying between organs in its severity. I did not see any clear evidence of bacteria such as vibrio or flavobacteria.

Similar observations were recorded by Dr Celia Hooper (letter to David Connell 17th November 2016):

Normal gills were apparent from specimens sampled for histopathological examination 5 months after the storm event (February 2017): I examined abalone from KIAB sent to Gribbles Veterinary Pathology on 6th September, following severe storm weather.

Following the poor weather, abalone from this property became ill with puffy heads, swollen feet, difficulty holding onto the autosubstrate and death. Signs were seen two days before death. Losses had occurred over the preceding six weeks, always following on after storm weather.

Upon examination, these affected abalone had inflammation throughout, but more severe in the muscle of the foot and head regions. The inflammation in the head probably reflects increased silt in the environment of these animals, including increased silt in the mouth.

Further disturbance of the sea bed in the vicinity of this farm is likely to have a deleterious effect on the abalone and oyster farms in this location.

Dr Hooper and Dr Loh are both experts on the pathology of abalone (Hooper et al. 2007). The evidence presented in the two histopathological reports indicate conclusively sediment is significantly detrimental to abalone.

Page 11 of 17


ADVERSE TEMPERATURE EFFECTS ON ABALONE: LIKELY CONSEQUENCES OF REDUCED LOCAL CURRENTS

Proposed construction of a 250 m causeway will substantially affect nearshore water movement in Smith Bay. The draft EIS indicates that reduction in current speed at Yumbah’s westerly seawater intake will be about 30-40% (Appendix H, page 65): this will coincide with an increase in ambient seawater temperature (Appendix G, page 23).

The adverse consequences of increased water temperature on abalone are acknowledged by Cheshire (2018): Likely increases in water temperature accentuated by recirculation of Yumbah effluent water will also have a harmful effect on abalone. Data collected for the EIS throughout 2017, using moored data buoys that were equipped with a suite of water quality and hydrodynamic sensors (detailed in Chapter 10), show that mean seawater temperature during the monitoring period at Smith Bay within 300 m of shore during summer was around 21-22o C but there were spikes up to 25 o C recorded during heatwaves (see Chapter 9) (Appendix H, Page 27). As Cheshire (2018) further notes: many farms across South Australia have reported substantial mortality events at much lower temperatures (22-23o C; Vandepeer 2006).

SEDIMENT IMPACTS ON DIATOMS AND RISK OF HARMFUL ALGAL BLOOMS

Diatoms are unicellular non-motile phytoplankton important in the diet of abalone farmed at Yumbah (McShane 2017). Dredge spoil presents a risk to the viability of diatoms in the subtidal environment of Smith Bay by decreasing available light and affecting light quality. Several unsubstantiated claims are made in Appendix H in relation to diatoms and dredge effects (Pages 18, 54, and 67):

• Diatoms are only important in diet of early stages of abalone; • Algae exhibit a high level of plasticity in their adaptation to ambient light environments allowing

adjustments to adverse light climate; • Changes in turbidity at shallow depths are small and will not have an adverse effect on diatom

production; • Conditions that would promote harmful algal blooms (red tides) are not likely to occur in Smith Bay.

In fact, advice from Yumbah KI’s hatchery manager reveals that diatoms are important dietary supplements across all life-history stages of the farm operation. My previous report (McShane 2017) drew attention to likely negative impacts of fine sediment dispersal on diatom growth. Fine sediments, particularly clay particles, selectively absorb blue light negatively impacting on diatom growth (Prieur and Sathyendranath 1981). Although diatoms have accessory pigments that can harvest other spectral components e.g. green light (Vesk and Jeffrey 1977, Humphrey 1983), carbon metabolism and growth of diatoms is favoured under conditions of blue light (Mercado et al. 2004, Cao et al. 2013, Lockhart 2013, Lawrenz and Richardson 2017, Baldisserotto et al. 2019).

The benthic diatoms preferred as food for farmed abalone lack the motility to migrate to surface waters where the full spectrum of photosynthetically active radiation (PAR) is available (Ault 2000). Thus, motile organisms such as dinoflagellates including red tide species, may be favoured over diatoms in suboptimal light regimes (low- or poor-quality light) (Ault 2000; Park et al. 2001; Smayda and Reynolds 2001; Peperzak 2003, Shikata et al. 2013, 2015, 2017; Zhou et al. 2017) or low nutrient conditions (Charles et al. 2005). Thus, attenuation of light through suspension of fine sediments during construction of the proposed seaport and during maintenance dredging activities will have a deleterious effect on those benthic diatoms favoured in the diet of abalone farmed at Yumbah. Further to this, changes to light climate in Smith Bay coupled with the potential introduction of exotic dinoflagellates (via ballast water) increases the risk harmful algal blooms (e.g. Park et al. 2001, see also Dowsett et al. 2011 for H. laevigata).

Page 10 of 17


e.g. scallops (Stevens 1987). Pumping rates of the gills of bivalves is reduced by more than 90% in the presence of fine sediment (80 mg/l). Lateral cilia in bivalves lack the capacity to clear particles which accumulate at the leading edge of the gills causing frictional drag (Stevens 1987, Yang et al. 2017). Fine suspended silt (< 5 µm) was found to be more deleterious to bivalves than coarser (5-25 µm particles) (Stevens 1987). Unsurprisingly, when present in aquaria, abalone avoid fine sediment: fine sediment adversely affects the righting response (Chew et al. 2013).

Such findings are consistent with observed mortalities of H. laevigata at Yumbah KI (McShane 2017). Following severe storms at Smith Bay during September 2016, mortalities of farmed abalone were observed. Similar impacts were observed following a less intense storm during October of the same year (David Connell Yumbah, personal communication). Abalone appeared moribund 2 days after the storm and mortality occurred over 6 weeks following initial impact (storm suspension of fine sediment). Histopathological analysis by Dr Richmond Loh, an aquatic animal health specialist, revealed the following (Letter to David Connell 28th March 2017): Mortalities were worst in 3 to 4-year old group (harvest class), though 1-year olds were also affected. Clinical signs reported in abalone include swollen head, swollen foot, and difficulty holding onto substrate, and death within 2 days of showing clinical signs. Storms and abalone deaths coincided with higher frequency of clogging of their 1 µm water filters (in their hatchery).

Microscopic examination of 20 abalone showed consistent lesions, the most significant being gill damage.

Changes in the surface mucus layer observed in H. laevigata may be caused by changes in:

• Viscosity of the mucus (dilution) • Reduced production of mucus • Degradation by enzymes, or • Increased loss of mucus.

We suspect that the breakdown of their mucus barrier and damage to the epithelium of the gills and skin, may lead to electrolyte disturbances and dehydration – and death ensues.

The sick abalone all had inflammation and oedema, varying from moderate to marked, varying between organs in its severity. I did not see any clear evidence of bacteria such as vibrio or flavobacteria.

Similar observations were recorded by Dr Celia Hooper (letter to David Connell 17th November 2016):

Normal gills were apparent from specimens sampled for histopathological examination 5 months after the storm event (February 2017): I examined abalone from KIAB sent to Gribbles Veterinary Pathology on 6th September, following severe storm weather.

Following the poor weather, abalone from this property became ill with puffy heads, swollen feet, difficulty holding onto the autosubstrate and death. Signs were seen two days before death. Losses had occurred over the preceding six weeks, always following on after storm weather.

Upon examination, these affected abalone had inflammation throughout, but more severe in the muscle of the foot and head regions. The inflammation in the head probably reflects increased silt in the environment of these animals, including increased silt in the mouth.

Further disturbance of the sea bed in the vicinity of this farm is likely to have a deleterious effect on the abalone and oyster farms in this location.

Dr Hooper and Dr Loh are both experts on the pathology of abalone (Hooper et al. 2007). The evidence presented in the two histopathological reports indicate conclusively sediment is significantly detrimental to abalone.

Page 13 of 17


There is also potential for ongoing loss of seagrass through erosion of the seafloor adjacent to the dredged basin (Appendix I1, page 23).

These mitigation of these risks to the subtidal flora and fauna of Smith Bay have not been adequately described in the draft EIS. On the contrary as noted by Wiltshire and Brook (2018): the ecological significance of the loss of this habitat, and in particular the seagrass communities, would be minor as there is vast amount of similar habitat within Smith Bay, at Emu Bay and elsewhere along the north coast (Appendix I1, page 27).

There is also an acknowledged risk to marine species listed under the EPBC Act, particularly syngnathids: A study of the mobile epi-fauna inhabiting seagrass meadows on the north coast using beam trawls recorded 119 pipefish comprising 10 species (Kinloch et al. 2007). Although the ring-baked pipefish was not recorded during this study, the overall density of pipefish within the seagrass meadows was found to be approximately one per 20 square metres (Page 25 of Appendix K).

Thus, applying this information from the draft EIS, removing 10 ha of seagrass during construction of the seaport will potentially destroy more than 5,000 listed syngnathids. Yet this is considerably understated (without supporting evidence) in the draft EIS: the loss of a very small amount of pipefish habitat and potentially some pipefish during construction would have a negligible effect on their overall population in the Smith Bay area (Appendix I1, page 28).

REFERENCES

Allen, V.J., Marsden, I.D., Ragg, N.L.C., and Gieseg, S. (2006). The effects of tactile stimulants on feeding, growth, behaviour, and meat quality of cultured Blackfoot abalone, Haliotis iris. Aquaculture. 257, 294-308.

ANZECC (2000). Australian and New Zealand Guidelines for Fresh and Marine Water Quality. Volume 1 (the Guidelines). National Water Quality Management Strategy Paper No. 4. Australian and New Zealand Environment and Conservation Council, Agriculture and Resource Management Council of Australia and New Zealand.

Ault, T. R. (2000). Vertical migration by the marine dinoflagellate Prorocentrum triestinum maximises photosynthetic yield. Oecologica 125, 466-457.

Baldisserotto, C., Sabia, A., Ferroni, L., and Pancaldi, S. (2019). Biological aspects and biotechnological potential of marine diatoms in relation to different light regimes. World Journal of Microbiology and Biotechnology 35, 1-9.

Blott, S. J. and Pye K. (2012). Particle size scales and classification of sediment types based on particle size distributions: review and recommended procedures. Sedimentology 59, 2071-2096.

Bolam, S. G. and Rees, H. L. (2003). Minimising impacts of maintenance dredged material disposal in the coastal environment: a habitat approach. Environmental Management 32, 171-188.

Bray, R. N. (2008). Environmental aspects of dredging. Taylor and Francis, London.

Cao, S., Wang, J., and Chen, D. (2013). Settlement and cell division of diatom Navicula can be influenced by light of various qualities and intensities. Journal of Basic Microbiology 53, 884-894.

Charles, F., Lantoine, F., Brugel, S., Chretiennot-Dinet, M., Quiroga, I., and Riviere, B. (2005). Seasonal survey of the phytoplankton biomass, composition and production in a littoral NW Mediterranean site, with special emphasis on the picoplanktonic contribution. Estuarine, Coastal and Shelf Science 65, 199-212.

Page 12 of 17


There is a significant risk of introduction of harmful marine dinoflagellates from ballast water of vessels using the proposed seaport (Hewitt and Campbell 2019). Although high seas ballast water exchange (as required under existing biosecurity protocols) can reduce numbers of toxic dinoflagellates, it is generally ineffective at reducing ballast sediment which can house cysts of harmful algal species (Ruiz and Reid 2017). The risk of harmful algal blooms will also be enhanced by reduction of nearshore currents following construction of a 250 m causeway in Smith Bay. The draft EIS indicates that reduction in current speed at Yumbah’s westerly seawater intake will be about 30-40% (Appendix H, page 65). This will lead to recirculation of Yumbah effluent and an increase in ambient water temperature: conditions favourable for dinoflagellate blooms (Ault 2000).

EXTRANEOUS LIGHT IMPACTS ON ABALONE

Potential impacts of extraneous light from the seaport operation on Yumbah abalone farm production are dismissed in the Draft EIS. Light has a demonstrable and adverse effect on feeding and growth of abalone.

Abalone are nocturnal feeders and feeding rates decrease in the presence of white (full spectrum) light (Garcia-Esquivel et al. 2007, Gao et al. 2016, Xiaolong et al. 2016). These published findings are consistent with the observations of Yumbah’s hatchery manager and the practice of reducing light to optimise feeding and growth in the farming of abalone. Thus, extraneous light from the proposed seaport will have a negative effect on feeding and growth of abalone farmed at Yumbah.

MARINE ECOLOGICAL IMPACTS: SEAGRASSES AND LISTED MARINE SPECIES

The proposed seaport construction will have a substantial impact on the ecology of the nearshore sublittoral environment of Smith Bay. In particular, the removal of more than 10 ha of seagrass habitat (see Wiltshire and Brooks (2018), Appendix I1 page 22) during construction of the causeway and berthing basin (dredging) will be the most obvious impact. Similarly, construction and operation of the proposed seaport will increase turbidity and sedimentation in Smith Bay and this will have a detrimental effect on adjacent seagrass communities (Westphalen et al. 2004).

From the Summary of Appendix I1 (Wiltshire and Brooks 2018): The marine listed Stipecampus cristatus (ring-backed pipefish) was found in Posidonia habitat in the area that would be dredged and is therefore at credible risk of being affected. It is considered, however, that the loss of a small amount of pipefish habitat and potentially some pipefish during dredging would have a negligible effect on their overall population and viability in the area. The ring-backed pipefish was the only syngnathid observed in visual surveys of Smith Bay but the draft EIS lists another 15 species that may be found in Smith Bay (Appendix I1 pp 21,22).

Dredging of the wharf pocket and approaches would result in the loss of some seagrass habitat and the potential loss of some pipefish. Although pipefish have limited mobility, some are likely to be able to move a short distance away from the area of direct impact during construction. Furthermore, there is an abundance of similar habitat in Smith Bay, Emu Bay and other bays along the north coast which would be expected to support a similar density of pipefish (Appendix I1 page 26).

In fact, the Draft EIS states that about 10 ha of seagrass habitat would be lost during construction (Appendix I1, page 22). The Draft EIS also notes: Dredging can affect seagrass and other marine communities not only through direct physical disturbance of biota inhabiting the sea floor, but also through the effects of the dispersed sediment plume generated during dredging. These effects can include smothering of surrounding biota, light attenuation in the water column reducing the productivity of plants and algae and the clogging of feeding structures of filter-feeding organisms (Cheshire and Miller 1999).

Similar secondary impacts on marine communities may occur during construction of the causeway, from re-suspension of exposed sediments during storms, from winnowing of sediments during shipping operations and from sediment run-off from the on-shore construction site.

Page 13 of 17


There is also potential for ongoing loss of seagrass through erosion of the seafloor adjacent to the dredged basin (Appendix I1, page 23).

These mitigation of these risks to the subtidal flora and fauna of Smith Bay have not been adequately described in the draft EIS. On the contrary as noted by Wiltshire and Brook (2018): the ecological significance of the loss of this habitat, and in particular the seagrass communities, would be minor as there is vast amount of similar habitat within Smith Bay, at Emu Bay and elsewhere along the north coast (Appendix I1, page 27).

There is also an acknowledged risk to marine species listed under the EPBC Act, particularly syngnathids: A study of the mobile epi-fauna inhabiting seagrass meadows on the north coast using beam trawls recorded 119 pipefish comprising 10 species (Kinloch et al. 2007). Although the ring-baked pipefish was not recorded during this study, the overall density of pipefish within the seagrass meadows was found to be approximately one per 20 square metres (Page 25 of Appendix K).

Thus, applying this information from the draft EIS, removing 10 ha of seagrass during construction of the seaport will potentially destroy more than 5,000 listed syngnathids. Yet this is considerably understated (without supporting evidence) in the draft EIS: the loss of a very small amount of pipefish habitat and potentially some pipefish during construction would have a negligible effect on their overall population in the Smith Bay area (Appendix I1, page 28).

REFERENCES

Allen, V.J., Marsden, I.D., Ragg, N.L.C., and Gieseg, S. (2006). The effects of tactile stimulants on feeding, growth, behaviour, and meat quality of cultured Blackfoot abalone, Haliotis iris. Aquaculture. 257, 294-308.

ANZECC (2000). Australian and New Zealand Guidelines for Fresh and Marine Water Quality. Volume 1 (the Guidelines). National Water Quality Management Strategy Paper No. 4. Australian and New Zealand Environment and Conservation Council, Agriculture and Resource Management Council of Australia and New Zealand.

Ault, T. R. (2000). Vertical migration by the marine dinoflagellate Prorocentrum triestinum maximises photosynthetic yield. Oecologica 125, 466-457.

Baldisserotto, C., Sabia, A., Ferroni, L., and Pancaldi, S. (2019). Biological aspects and biotechnological potential of marine diatoms in relation to different light regimes. World Journal of Microbiology and Biotechnology 35, 1-9.

Blott, S. J. and Pye K. (2012). Particle size scales and classification of sediment types based on particle size distributions: review and recommended procedures. Sedimentology 59, 2071-2096.

Bolam, S. G. and Rees, H. L. (2003). Minimising impacts of maintenance dredged material disposal in the coastal environment: a habitat approach. Environmental Management 32, 171-188.

Bray, R. N. (2008). Environmental aspects of dredging. Taylor and Francis, London.

Cao, S., Wang, J., and Chen, D. (2013). Settlement and cell division of diatom Navicula can be influenced by light of various qualities and intensities. Journal of Basic Microbiology 53, 884-894.

Charles, F., Lantoine, F., Brugel, S., Chretiennot-Dinet, M., Quiroga, I., and Riviere, B. (2005). Seasonal survey of the phytoplankton biomass, composition and production in a littoral NW Mediterranean site, with special emphasis on the picoplanktonic contribution. Estuarine, Coastal and Shelf Science 65, 199-212.

Page 12 of 17


There is a significant risk of introduction of harmful marine dinoflagellates from ballast water of vessels using the proposed seaport (Hewitt and Campbell 2019). Although high seas ballast water exchange (as required under existing biosecurity protocols) can reduce numbers of toxic dinoflagellates, it is generally ineffective at reducing ballast sediment which can house cysts of harmful algal species (Ruiz and Reid 2017). The risk of harmful algal blooms will also be enhanced by reduction of nearshore currents following construction of a 250 m causeway in Smith Bay. The draft EIS indicates that reduction in current speed at Yumbah’s westerly seawater intake will be about 30-40% (Appendix H, page 65). This will lead to recirculation of Yumbah effluent and an increase in ambient water temperature: conditions favourable for dinoflagellate blooms (Ault 2000).

EXTRANEOUS LIGHT IMPACTS ON ABALONE

Potential impacts of extraneous light from the seaport operation on Yumbah abalone farm production are dismissed in the Draft EIS. Light has a demonstrable and adverse effect on feeding and growth of abalone.

Abalone are nocturnal feeders and feeding rates decrease in the presence of white (full spectrum) light (Garcia-Esquivel et al. 2007, Gao et al. 2016, Xiaolong et al. 2016). These published findings are consistent with the observations of Yumbah’s hatchery manager and the practice of reducing light to optimise feeding and growth in the farming of abalone. Thus, extraneous light from the proposed seaport will have a negative effect on feeding and growth of abalone farmed at Yumbah.

MARINE ECOLOGICAL IMPACTS: SEAGRASSES AND LISTED MARINE SPECIES

The proposed seaport construction will have a substantial impact on the ecology of the nearshore sublittoral environment of Smith Bay. In particular, the removal of more than 10 ha of seagrass habitat (see Wiltshire and Brooks (2018), Appendix I1 page 22) during construction of the causeway and berthing basin (dredging) will be the most obvious impact. Similarly, construction and operation of the proposed seaport will increase turbidity and sedimentation in Smith Bay and this will have a detrimental effect on adjacent seagrass communities (Westphalen et al. 2004).

From the Summary of Appendix I1 (Wiltshire and Brooks 2018): The marine listed Stipecampus cristatus (ring-backed pipefish) was found in Posidonia habitat in the area that would be dredged and is therefore at credible risk of being affected. It is considered, however, that the loss of a small amount of pipefish habitat and potentially some pipefish during dredging would have a negligible effect on their overall population and viability in the area. The ring-backed pipefish was the only syngnathid observed in visual surveys of Smith Bay but the draft EIS lists another 15 species that may be found in Smith Bay (Appendix I1 pp 21,22).

Dredging of the wharf pocket and approaches would result in the loss of some seagrass habitat and the potential loss of some pipefish. Although pipefish have limited mobility, some are likely to be able to move a short distance away from the area of direct impact during construction. Furthermore, there is an abundance of similar habitat in Smith Bay, Emu Bay and other bays along the north coast which would be expected to support a similar density of pipefish (Appendix I1 page 26).

In fact, the Draft EIS states that about 10 ha of seagrass habitat would be lost during construction (Appendix I1, page 22). The Draft EIS also notes: Dredging can affect seagrass and other marine communities not only through direct physical disturbance of biota inhabiting the sea floor, but also through the effects of the dispersed sediment plume generated during dredging. These effects can include smothering of surrounding biota, light attenuation in the water column reducing the productivity of plants and algae and the clogging of feeding structures of filter-feeding organisms (Cheshire and Miller 1999).

Similar secondary impacts on marine communities may occur during construction of the causeway, from re-suspension of exposed sediments during storms, from winnowing of sediments during shipping operations and from sediment run-off from the on-shore construction site.

Page 15 of 17


KIPT (2019). Smith Bay Wharf Draft Environmental Impact Statements. Prepared for Kangaroo Island Plantation Timbers by Environmental Projects January 2019.

Lawrenz, E., and Richardson, T.L. (2017). Differential effects of changes in spectral irradiance on photoacclimation, primary productivity and growth in Rhodomonas salina (Cryptophyceae) and Skeletonema costatum (Bacillariophyceae) in simulated blackwater environments. Journal of Phycology 53, 1241-1254.

Lee, K.S. (2008). The effects of suspended solids on the mortality and the glycogen content of abalone Haliotis discus hannai. Journal of the Korean Society of Marine Environment and Safety 14, 183-187. English abstract and data tables only.

Lockhart, J. (2013). Blue light checkpoint: how blue light controls the onset of cell division in diatoms. The Plant Cell 25, 1.

McShane P.E. (2017). Impacts of a proposed wharf development on the marine environment and an existing abalone aquaculture facility, Smith Bay, Kangaroo Island, South Australia. Global Marine Resource Management Pty Ltd. 19 pp.

McShane, P.E., Gorfine, H., and Knuckey, I.A. (1994). Factors influencing food selection in the abalone Haliotis rubra (Mollusca: Gastropoda). Journal of Experimental Marine Biology and Ecology 176, 27-37.

Melville-Smith, R., Fotedar, R., Pattiaratchi, C., Adams, B., and Hart, A. (2017). Investigating critical biological issues for commercial greenlip abalone sea ranching in Flinders Bay, Western Australia, Perth. September 2017.

Mercado, J.M., Sanchez-Saavedra, M.P., Correa-Reyes, G., Lubian, L., Montero, O., Figueroa, F.L. (2004). Blue light effect on growth, light absorption characteristics and photosynthesis of five benthic diatom strains. Aquatic Botany 78, 265-277.

Morash, A.J., and Alter, K. (2016). Effects of environmental and farm stress on abalone physiology: perspectives for abalone aquaculture in the face of global climate change. Reviews in Aquaculture 8,342-368.

Moore, P.G. (1977). Inorganic particulate suspensions in the sea and their effects on marine animals. Oceanography Marine Biology Annual Review 15, 225-363.

Mutshinda, C.M., Finkel, Z.V., and Irwin, A.J. (2013). Which environmental factors control phytoplankton populations? A Bayesian variable selection approach. Ecological Modelling 269, 1-8.

Naylor, J.R. and McShane, P.E. (1997). Post settlement survival of abalone (Haliotis iris, H. australis) in turbulent flows. Molluscan Research 18, 227-232.

Park, J.G., Jeong, M.K., Lee, J.A., Cho, K-J, Kwon, O-S. (2001). Diurnal vertical migration of a harmful dinoflagellate, Cochlodinium polykrikoides (Dinophyceae) during a red tide in coastal waters of Namhae Island, Korea. Phycologia 40, 292-297.

Peperzak, L., (2003). Climate change and harmful algal blooms in the North Sea. Acta Oecologica 24, S139-S144.

Phillips, N. E. and Shima, J. S. (2006). Differential effects of suspended sediments on larval survival and settlement of New Zealand urchins Evechinus chloroticus and abalone Haliotis iris. Marine Ecology Progress Series 314, 149-158.

Prieur, L., and Sathyendranath, S. (1981). An optical classification of coastal and oceanic waters based on the specific spectral absorption curves of phytoplankton pigments, dissolved organic matter and other particulate materials. Limnology and Oceanography 26, 671-689.

Page 14 of 17


Cheshire, A. (2018). Assessment of risks and mitigation strategies to the Yumbah Aquaculture Facility from the Construction and Operation of the proposed KI Seaport. Prepared for Kangaroo Island Plantation Timber Pty Ltd. 24 September 2018.

Cheshire, A.C. and Miller, D.J. (1999). The impact of sand dredging on Benthic Community Structure at Port Stanvac Dredge Site: Final report on the results of surveys 1992 to 1999. Report to the Coast Protection Board, South Australian Department of Environment and Natural Resources (as cited in Appendix I1 of KIPT (2019)).

Chew, C.A., Hepburn, C.D., and Stephenson, W. (2013). Low-level sedimentation modifies behaviour in juvenile Haliotis iris and may affect their vulnerability to predation. Marine Biology 160, 1213-1221.

Chung, E.Y., Shin, Y.K., and Lee J.H. (1993). Effects of silt and clay on respiration and mortality of the abalone, Nordotis discus. Korean Journal of Malacology 9, 23-29.

DAC (2017). Guidelines for the preparation of an Environmental Impact Statement: Deep water port facility at Smith Bay, Kangaroo Island. Proposal by Kangaroo Island Plantation Timbers Ltd. Published by the South Australian Development Assessment Commission (DAC) June 2017. 36pp.

Department of Planning, Transport and Infrastructure (2015). Development Plan Kangaroo Island Council. Government of South Australia http://www.dpti.sa.gov.au/__data/assets/pdf_file/0009/249975/Kangaroo_Island_Council_Development_Plan.pdf

Dowsett, N., Hallegraeff, G., van Ruth, P., van Gingkel, R., McNabb, P., Hay, B., O’Connor, W., Kiermeier, A., Deveney, M. and McLeod, C. (2011). Uptake, distribution and depuration of paralytic shellfish toxins from Alexandrium minutum in Australian greenlip abalone, Haliotis laevigata. Toxicon 58, 101-111,

Essink, K. (1999). Ecological effects of dumping of dredged sediments: options for management. Journal of Coastal Conservation 5, 69-80.

Gao, X.L, Zhang, M., Zheng, J.M., Li, X., Chi, L., Song, C.B., and Liu, Y. (2016). Effect of LED light quality on the phototaxis and locomotion behaviour of Haliotis discus hannai. Aquaculture Research 47, 3376-3389.

Garcia-Esquivel, Z., Montes-Magallon, S., Gonzalez-Gomez, M.A. (2007). Effect of temperature and photoperiod on the growth, feed consumption, and biochemical content of juvenile green abalone, Haliotis fulgens, fed on a balanced diet. Aquaculture 262, 129-141.

Gibbs, R. J. (1977). Clay mineral segregation in the marine environment. Journal of Sedimentary Petrology 47, 237-243.

Hewitt, C.L. and Campbell, M.L. (2019). Smith Bay Wharf Draft Environmental Impact Statement. Marine Biosecurity Review. Report for Yumbah Aquaculture. Harry Butler Institute, Murdoch University

Hooper, C., Day, R., Slocombe, R., Handlinger, J., and Benkendorff, K. (2007). Stress and immune responses in abalone: limitations in current knowledge and investigative methods based on other models. Fish and Shellfish Immunology 22, 363-379.

Humphrey, G. F. (1977). The effect of the spectral composition of light on the growth, pigments, and photosynthetic rate of unicellular marine algae. Journal of Experimental Marine Biology and Ecology. 66, 69-67.

Kinloch, M.A., Brock, D.J., Kirkman, H., and Laperousaz, T. (2007). Seagrass Biodiversity on Kangaroo Island. KI NRM Board Coast and Marine Program Report No. CMP07/004.

Page 15 of 17


KIPT (2019). Smith Bay Wharf Draft Environmental Impact Statements. Prepared for Kangaroo Island Plantation Timbers by Environmental Projects January 2019.

Lawrenz, E., and Richardson, T.L. (2017). Differential effects of changes in spectral irradiance on photoacclimation, primary productivity and growth in Rhodomonas salina (Cryptophyceae) and Skeletonema costatum (Bacillariophyceae) in simulated blackwater environments. Journal of Phycology 53, 1241-1254.

Lee, K.S. (2008). The effects of suspended solids on the mortality and the glycogen content of abalone Haliotis discus hannai. Journal of the Korean Society of Marine Environment and Safety 14, 183-187. English abstract and data tables only.

Lockhart, J. (2013). Blue light checkpoint: how blue light controls the onset of cell division in diatoms. The Plant Cell 25, 1.

McShane P.E. (2017). Impacts of a proposed wharf development on the marine environment and an existing abalone aquaculture facility, Smith Bay, Kangaroo Island, South Australia. Global Marine Resource Management Pty Ltd. 19 pp.

McShane, P.E., Gorfine, H., and Knuckey, I.A. (1994). Factors influencing food selection in the abalone Haliotis rubra (Mollusca: Gastropoda). Journal of Experimental Marine Biology and Ecology 176, 27-37.

Melville-Smith, R., Fotedar, R., Pattiaratchi, C., Adams, B., and Hart, A. (2017). Investigating critical biological issues for commercial greenlip abalone sea ranching in Flinders Bay, Western Australia, Perth. September 2017.

Mercado, J.M., Sanchez-Saavedra, M.P., Correa-Reyes, G., Lubian, L., Montero, O., Figueroa, F.L. (2004). Blue light effect on growth, light absorption characteristics and photosynthesis of five benthic diatom strains. Aquatic Botany 78, 265-277.

Morash, A.J., and Alter, K. (2016). Effects of environmental and farm stress on abalone physiology: perspectives for abalone aquaculture in the face of global climate change. Reviews in Aquaculture 8,342-368.

Moore, P.G. (1977). Inorganic particulate suspensions in the sea and their effects on marine animals. Oceanography Marine Biology Annual Review 15, 225-363.

Mutshinda, C.M., Finkel, Z.V., and Irwin, A.J. (2013). Which environmental factors control phytoplankton populations? A Bayesian variable selection approach. Ecological Modelling 269, 1-8.

Naylor, J.R. and McShane, P.E. (1997). Post settlement survival of abalone (Haliotis iris, H. australis) in turbulent flows. Molluscan Research 18, 227-232.

Park, J.G., Jeong, M.K., Lee, J.A., Cho, K-J, Kwon, O-S. (2001). Diurnal vertical migration of a harmful dinoflagellate, Cochlodinium polykrikoides (Dinophyceae) during a red tide in coastal waters of Namhae Island, Korea. Phycologia 40, 292-297.

Peperzak, L., (2003). Climate change and harmful algal blooms in the North Sea. Acta Oecologica 24, S139-S144.

Phillips, N. E. and Shima, J. S. (2006). Differential effects of suspended sediments on larval survival and settlement of New Zealand urchins Evechinus chloroticus and abalone Haliotis iris. Marine Ecology Progress Series 314, 149-158.

Prieur, L., and Sathyendranath, S. (1981). An optical classification of coastal and oceanic waters based on the specific spectral absorption curves of phytoplankton pigments, dissolved organic matter and other particulate materials. Limnology and Oceanography 26, 671-689.

Page 14 of 17


Cheshire, A. (2018). Assessment of risks and mitigation strategies to the Yumbah Aquaculture Facility from the Construction and Operation of the proposed KI Seaport. Prepared for Kangaroo Island Plantation Timber Pty Ltd. 24 September 2018.

Cheshire, A.C. and Miller, D.J. (1999). The impact of sand dredging on Benthic Community Structure at Port Stanvac Dredge Site: Final report on the results of surveys 1992 to 1999. Report to the Coast Protection Board, South Australian Department of Environment and Natural Resources (as cited in Appendix I1 of KIPT (2019)).

Chew, C.A., Hepburn, C.D., and Stephenson, W. (2013). Low-level sedimentation modifies behaviour in juvenile Haliotis iris and may affect their vulnerability to predation. Marine Biology 160, 1213-1221.

Chung, E.Y., Shin, Y.K., and Lee J.H. (1993). Effects of silt and clay on respiration and mortality of the abalone, Nordotis discus. Korean Journal of Malacology 9, 23-29.

DAC (2017). Guidelines for the preparation of an Environmental Impact Statement: Deep water port facility at Smith Bay, Kangaroo Island. Proposal by Kangaroo Island Plantation Timbers Ltd. Published by the South Australian Development Assessment Commission (DAC) June 2017. 36pp.

Department of Planning, Transport and Infrastructure (2015). Development Plan Kangaroo Island Council. Government of South Australia http://www.dpti.sa.gov.au/__data/assets/pdf_file/0009/249975/Kangaroo_Island_Council_Development_Plan.pdf

Dowsett, N., Hallegraeff, G., van Ruth, P., van Gingkel, R., McNabb, P., Hay, B., O’Connor, W., Kiermeier, A., Deveney, M. and McLeod, C. (2011). Uptake, distribution and depuration of paralytic shellfish toxins from Alexandrium minutum in Australian greenlip abalone, Haliotis laevigata. Toxicon 58, 101-111,

Essink, K. (1999). Ecological effects of dumping of dredged sediments: options for management. Journal of Coastal Conservation 5, 69-80.

Gao, X.L, Zhang, M., Zheng, J.M., Li, X., Chi, L., Song, C.B., and Liu, Y. (2016). Effect of LED light quality on the phototaxis and locomotion behaviour of Haliotis discus hannai. Aquaculture Research 47, 3376-3389.

Garcia-Esquivel, Z., Montes-Magallon, S., Gonzalez-Gomez, M.A. (2007). Effect of temperature and photoperiod on the growth, feed consumption, and biochemical content of juvenile green abalone, Haliotis fulgens, fed on a balanced diet. Aquaculture 262, 129-141.

Gibbs, R. J. (1977). Clay mineral segregation in the marine environment. Journal of Sedimentary Petrology 47, 237-243.

Hewitt, C.L. and Campbell, M.L. (2019). Smith Bay Wharf Draft Environmental Impact Statement. Marine Biosecurity Review. Report for Yumbah Aquaculture. Harry Butler Institute, Murdoch University

Hooper, C., Day, R., Slocombe, R., Handlinger, J., and Benkendorff, K. (2007). Stress and immune responses in abalone: limitations in current knowledge and investigative methods based on other models. Fish and Shellfish Immunology 22, 363-379.

Humphrey, G. F. (1977). The effect of the spectral composition of light on the growth, pigments, and photosynthetic rate of unicellular marine algae. Journal of Experimental Marine Biology and Ecology. 66, 69-67.

Kinloch, M.A., Brock, D.J., Kirkman, H., and Laperousaz, T. (2007). Seagrass Biodiversity on Kangaroo Island. KI NRM Board Coast and Marine Program Report No. CMP07/004.

Page 17 of 17


Wanichanon, C., Laimek, P., Linthong, V., Sretarugsa, P., Kruatrachue, M., Upatham, E.S., Poomtong, T., and Sobhon, P. (2004). Histology of hypobrachial gland and gill of Haliotis asinina Linnaeus. Journal of Shellfish Research 23, 1107-1112.

Wang, G.J, Xie, J., De-guang, Y.U., Lan, W.U., and Zhao-ying, H.U. (2007). Physiological responses of abalone Haliotis diversicolor to suspended sediment stress. Journal of Dalian Ocean University 22, 352-356.

Westphalen, G., Collings, G., Wear, R., Fernandes, M., Bryars, S., and Cheshire, A. (2004). A review of seagrass loss on the Adelaide metropolitan coastline. ACWS Technical Report No. 2. Prepared for the Adelaide Coastal Waters Study Steering Committee. South Australian Research and Development Institute (Aquatic Sciences) Publication No. RD04/0073.

Wilber, D.H. and Clarke, D.G. (2001). Biological effects of suspended sediments: A review of suspended sediment impacts on fish and shellfish with relation to dredging activities in estuaries. North American Journal of Fisheries Management 21, 855-875.

Wiltshire, D. and Brook, J. (2018). Smith Bay Marine Ecological Assessment. Report to Kangaroo Island Plantation Timbers Pty Ltd., SEA Pty Ltd. 6th September 2018.

Xiaolong, G., Mo, Z., Xian, L. Ce, S., Changbin, S. and Ying, L. (2016). Effects of LED light quality on the growth, metabolism, and energy budgets of Haliotis discus discus. Aquaculture, 453, 31-39.

Yang, G., Song, L., Lu, X., Wang, N., and Li,Y. (2017). Effect of the exposure to suspended solids on the enzymatic activity in the bivalve Sinonovacula constricta. Aquaculture and Fisheries 2, 10-17.

Yoon, S.J., and Park, G.S. (2011). Ecotoxicological effects of the increased suspended solids on marine benthic organisms. Journal of the Environmental Sciences 1383-1394.

Zhou, Z., Yu, R., Zhou, M. (2017). Seasonal succession of microalgal blooms from diatoms to dinoflagellates in the East China Sea: A numerical simulation study. Ecological Modelling 360, 150- 162.

Page 16 of 17


Ragg, N.L.C., and H.H. Taylor (2006). Oxygen uptake, diffusion limitation, and diffusing capacity of the bipectinate gills of the abalone, Haliotis iris (Mollusca: prosobranchia). Comparative Biochemistry and Physiology Part A. 143, 299-306.

Ragg, N.L.C. (2014). Fighting for breath: how does oxygen exchange limit abalone performance in a changing coastal environment? In Proceedings of the 6th National Trans Tasman Abalone Convention. Queenstown, New Zealand 6th-8th August 2014.

Ruiz, G.M. and Reid, D.F. (2007). Current state of understanding about the effectiveness of ballast water exchange (BWE) in reducing aquatic nonindigenous species (ANS) introductions t the Great Lakes basin and Chesapeake Bay, USA: Synthesis and analysis of existing information. NOAA Technical Memorandum GLERL0142. GL:ERL, Ann Arbor, USA. 127 pp.

Schellenberger Costa, B., Jungandreas, A., Jakob, T., Weisheit, W., Mittag, M. and Wilhelm, C. (2013). Blue light is essential for high light acclimation and photoprotection in the diatom Phaeodactylum tricornutum. Journal of Experimental Botany 64, 483-493.

Shepherd, S. A. (1973). Studies on southern Australian abalone (genus Haliotis). I. The ecology of five sympatric species. Australian Journal of Marine and Freshwater Research 24, 217-257.

Shikata, T., Matsunaga, S., Iseki, M., Nishide, H. Higashi, S., Kamei, Y., Yamaguchi, M., Jenkinson, I.R., and Watanabe, M. (2013). Blue light regulates the rhythm of diurnal vertical migration in the raphidophyte red-tide alga Chattonella antiqua. Journal of Plankton Research 35, 542-552.

Shikata, T., Matsunaga, S., Nishide, H., Sakamoto, S., Onistuka, G., and Yamaguchi, M. (2015). Diurnal vertical migration rhythms and their photoresponse in four phytoflagellates causing harmful algal blooms. Limnology and Oceanography 60, 1251-1264.

Shikata, T., Onitsuka, G., Abe, K., Kitatsuji, S., Yufu, K., Yoshikawa, Y., Honjo, T., and Miyamura, K. 2017). Relationships between light environment and subsurface accumulation during the daytime in the red-tide dinoflagellate Karenia mikimotoi. Marine Biology 164: 18

Smayda, T.J. and Reynolds, C.S. (2001). Community assembly in marine phytoplankton: application of recent models to harmful dinoflagellate blooms. Journal of Plankton Research 23, 447-461.

Stevens, P. M. (1987). Response of excised gill tissue from the New Zealand scallop Pecten novaezelandiae to suspended silt. New Zealand Journal of Marine and Freshwater Research 21, 605-614.

Stringer, T. (2018a). Appendix H2 – Part A. Total Suspended Solids Guideline value for the Pacific Abalone – Professional Opinion. Report No. ECX18-1004. Intertek Welshpool. October 2018.

Stringer, T. (2018b). Appendix H2 – Part B. Effects of total suspended solids on juvenile greenlip abalone – Ecotoxicology Laboratory Test. Report No. ECX18-1116-1. Intertek Welshpool. December 2018.

Thomas, S. and Ridd, P. (2004). Review of methods to measure short time scale sediment accumulation. Marine Geology 207, 95-114.

Vandepeer, M., (2006). Preventing summer mortality of abalone in aquaculture systems by understanding interactions between nutrition and water temperature. Abalone Aquaculture Subprogram, South Australian Research and Development Institute (Aquatic Sciences), Adelaide. SARDI Publication Number RD02/0035-2.

Vesk, M., and Jeffrey, S. W. (1977). Effect of blue-green light on photosynthetic pigments and chloroplast structure in unicellular marine algae from six classes. Journal of Phycology 13, 280-288.

Page 17 of 17


Wanichanon, C., Laimek, P., Linthong, V., Sretarugsa, P., Kruatrachue, M., Upatham, E.S., Poomtong, T., and Sobhon, P. (2004). Histology of hypobrachial gland and gill of Haliotis asinina Linnaeus. Journal of Shellfish Research 23, 1107-1112.

Wang, G.J, Xie, J., De-guang, Y.U., Lan, W.U., and Zhao-ying, H.U. (2007). Physiological responses of abalone Haliotis diversicolor to suspended sediment stress. Journal of Dalian Ocean University 22, 352-356.

Westphalen, G., Collings, G., Wear, R., Fernandes, M., Bryars, S., and Cheshire, A. (2004). A review of seagrass loss on the Adelaide metropolitan coastline. ACWS Technical Report No. 2. Prepared for the Adelaide Coastal Waters Study Steering Committee. South Australian Research and Development Institute (Aquatic Sciences) Publication No. RD04/0073.

Wilber, D.H. and Clarke, D.G. (2001). Biological effects of suspended sediments: A review of suspended sediment impacts on fish and shellfish with relation to dredging activities in estuaries. North American Journal of Fisheries Management 21, 855-875.

Wiltshire, D. and Brook, J. (2018). Smith Bay Marine Ecological Assessment. Report to Kangaroo Island Plantation Timbers Pty Ltd., SEA Pty Ltd. 6th September 2018.

Xiaolong, G., Mo, Z., Xian, L. Ce, S., Changbin, S. and Ying, L. (2016). Effects of LED light quality on the growth, metabolism, and energy budgets of Haliotis discus discus. Aquaculture, 453, 31-39.

Yang, G., Song, L., Lu, X., Wang, N., and Li,Y. (2017). Effect of the exposure to suspended solids on the enzymatic activity in the bivalve Sinonovacula constricta. Aquaculture and Fisheries 2, 10-17.

Yoon, S.J., and Park, G.S. (2011). Ecotoxicological effects of the increased suspended solids on marine benthic organisms. Journal of the Environmental Sciences 1383-1394.

Zhou, Z., Yu, R., Zhou, M. (2017). Seasonal succession of microalgal blooms from diatoms to dinoflagellates in the East China Sea: A numerical simulation study. Ecological Modelling 360, 150- 162.

Page 16 of 17


Ragg, N.L.C., and H.H. Taylor (2006). Oxygen uptake, diffusion limitation, and diffusing capacity of the bipectinate gills of the abalone, Haliotis iris (Mollusca: prosobranchia). Comparative Biochemistry and Physiology Part A. 143, 299-306.

Ragg, N.L.C. (2014). Fighting for breath: how does oxygen exchange limit abalone performance in a changing coastal environment? In Proceedings of the 6th National Trans Tasman Abalone Convention. Queenstown, New Zealand 6th-8th August 2014.

Ruiz, G.M. and Reid, D.F. (2007). Current state of understanding about the effectiveness of ballast water exchange (BWE) in reducing aquatic nonindigenous species (ANS) introductions t the Great Lakes basin and Chesapeake Bay, USA: Synthesis and analysis of existing information. NOAA Technical Memorandum GLERL0142. GL:ERL, Ann Arbor, USA. 127 pp.

Schellenberger Costa, B., Jungandreas, A., Jakob, T., Weisheit, W., Mittag, M. and Wilhelm, C. (2013). Blue light is essential for high light acclimation and photoprotection in the diatom Phaeodactylum tricornutum. Journal of Experimental Botany 64, 483-493.

Shepherd, S. A. (1973). Studies on southern Australian abalone (genus Haliotis). I. The ecology of five sympatric species. Australian Journal of Marine and Freshwater Research 24, 217-257.

Shikata, T., Matsunaga, S., Iseki, M., Nishide, H. Higashi, S., Kamei, Y., Yamaguchi, M., Jenkinson, I.R., and Watanabe, M. (2013). Blue light regulates the rhythm of diurnal vertical migration in the raphidophyte red-tide alga Chattonella antiqua. Journal of Plankton Research 35, 542-552.

Shikata, T., Matsunaga, S., Nishide, H., Sakamoto, S., Onistuka, G., and Yamaguchi, M. (2015). Diurnal vertical migration rhythms and their photoresponse in four phytoflagellates causing harmful algal blooms. Limnology and Oceanography 60, 1251-1264.

Shikata, T., Onitsuka, G., Abe, K., Kitatsuji, S., Yufu, K., Yoshikawa, Y., Honjo, T., and Miyamura, K. 2017). Relationships between light environment and subsurface accumulation during the daytime in the red-tide dinoflagellate Karenia mikimotoi. Marine Biology 164: 18

Smayda, T.J. and Reynolds, C.S. (2001). Community assembly in marine phytoplankton: application of recent models to harmful dinoflagellate blooms. Journal of Plankton Research 23, 447-461.

Stevens, P. M. (1987). Response of excised gill tissue from the New Zealand scallop Pecten novaezelandiae to suspended silt. New Zealand Journal of Marine and Freshwater Research 21, 605-614.

Stringer, T. (2018a). Appendix H2 – Part A. Total Suspended Solids Guideline value for the Pacific Abalone – Professional Opinion. Report No. ECX18-1004. Intertek Welshpool. October 2018.

Stringer, T. (2018b). Appendix H2 – Part B. Effects of total suspended solids on juvenile greenlip abalone – Ecotoxicology Laboratory Test. Report No. ECX18-1116-1. Intertek Welshpool. December 2018.

Thomas, S. and Ridd, P. (2004). Review of methods to measure short time scale sediment accumulation. Marine Geology 207, 95-114.

Vandepeer, M., (2006). Preventing summer mortality of abalone in aquaculture systems by understanding interactions between nutrition and water temperature. Abalone Aquaculture Subprogram, South Australian Research and Development Institute (Aquatic Sciences), Adelaide. SARDI Publication Number RD02/0035-2.

Vesk, M., and Jeffrey, S. W. (1977). Effect of blue-green light on photosynthetic pigments and chloroplast structure in unicellular marine algae from six classes. Journal of Phycology 13, 280-288.

APPENDIX 3 –

AUSTRALIAN ABALONE GROWERS ASSOCIATION (AAGA) SUBMISSION2019


| Page 1 of 4

Minister for Planning C/- Robert Kleeman Unit Manager Policy and Strategic Assessment Department of Planning, Transport and Infrastructure GPO Box 1815 ADELAIDE SA 5000

[email protected]

21/5/2019 Re: AAGA response to draft Environmental Impact Statement (EIS) Smith Bay Sea Port, Kangaroo Island Plantation Timbers (KPT). Dear Minister Australian Abalone Growers Association is the peak body for all Australian pump ashore abalone farms and presents a united and expert voice for the Australian industry. This letter addresses Cheshire, A. (2018) Assessment of risks and mitigation strategies to the Yumbah Aquaculture Facility from the Construction and Operation of the proposed KI Seaport and especially Appendix H and I – Marine Ecological Assessment by David Wiltshire and James Brook The Australian Abalone Aquaculture industry includes 15 pump ashore abalone farms located on the Southern coastline of Australia from the southwest of Western Australia to Tasmania. Abalone aquaculture is one the fastest growing seafood industries in the country, and it is primarily undertaken in areas that are protected from the negative impacts associated with heavy industry, such as Smith Bay, Kangaroo Island. Abalone farms produced over 1000T abalone worth $50m in the FY ending 2018. The increasing production and profitability of Australian abalone farms in recent years is underpinned by substantial and ongoing research and development investment in biosecurity, disease surveillance, health, nutrition, genetics, breeding and marketing. Much of our investment is directed through an Industry Partnership with the FRDC. Cheshire (2018) presents information regarding abalone farming, which is incorrect or outdated demonstrating little understanding of current farming practices. It then uses this false interpretation

AUSTRALIAN ABALONE GROWERS ASSOCIATION INC. PO Box 216, BEACONSFIELD Tasmania 7270, Australia Phone +61 3 6383 4115 Fax +61 3 6383 4117 Email [email protected] APPENDIX 3 –

AUSTRALIAN ABALONE GROWERS ASSOCIATION (AAGA) SUBMISSION2019

| Page 3 of 4

Abalone farms use micro filtration systems for water supplied to the hatchery and nursery to remove fine silt as this inhibits larval survival and settlement. These filtration systems will be at risk of being overwhelmed. Growout systems rely on pumping large volumes of clean water and are not suited to filtration as this would dramatically increase both the pumping costs, (energy consumption) and infrastructure costs. The tank systems are also not designed to cope with heavy silt loads. Likewise, the gill configuration of abalone is adapted to a high energy environment. Abalone can cope with being covered by sand following storm events; but they are susceptible to smothering and asphyxiation by silt. Bacteria are generally not carried directly in the water column but are borne on particles; the finer the particles (silt) the greater the surface area available for bacteria to inhabit. The threat of elevated bacterial loads (Vibrio spp. in particular) associated with silt loadings and elevated temperatures was ignored in the EIS. Ecotoxicological Studies Cheshire (2018) refers to an ecotoxicology study conducted over 24 hours at 18 °c. Cheshire (2018) states “On the basis of these findings it is concluded that the construction and operation of the Kangaroo Island Seaport will not have any measurable impact on water quality that would impact on the performance of the Yumbah Smith Bay abalone farm.” However:

• This was very short acute study conducted at the ideal temperature for survival. • It is impossible to determine chronic effects from such a study. • It ignores the compounding effects of elevated bacteria levels associated with increased silt

loading. • It ignores compounding effects of the above at higher summer water temperatures.

Yet Cheshire (2018) concludes that there would be no impact on the Yumbah Smith Bay Abalone Farm, (regardless of chronic effects and at higher summer temperatures). Furthermore, the report goes on to suggest, based on this simplistic study that ANZECC guidelines for TSS be relaxed. (Re. Dredge Spoil Management). Such nonsensible claims are alarming and indefensible. Dust Noise and Light. AAGA shares YKI’s further concerns regarding dust, noise and light.

• Dust from the woodchip piles and heavy traffic is likely to accumulate on the shade cloth of the abalone farm and enter the tanks in concentrated form following rain events.

• Noise from woodchipping and other activities is likely to disturb abalone. • Light: Abalone farms are deliberately not lit at night, so as not to disturb the nocturnal habits

of abalone. The EIS fails to address remediation of the above factors.

Conclusion. The Seaport proposal is an unprecedented encroachment on a successful, established business that provides permanent employment for some 30 people, within a company that employs 125 people within an industry that employs more than 400 people. This is an expanding industry with Yumbah alone proposing a $73 million expansion of its Portland (Vic.) abalone operations and all other farms

| Page 2 of 4

to denigrate our industry. The report fails to recognize that seaports of this scale and aquaculture in such immediate proximity cannot successfully co-exist. For example, Southwood Fibre recently abandoned its proposed woodchip export facility near Dover in Tasmania due to an impasse with salmon grower Tassal. Should the Sea Port proposal be approved it will set a precedent for similar emerging incompatible encroachments to aquaculture around the country. AAGA’s opposition to the proposal is entirely based on proximity, it is simply too close. Australian abalone is highly regarded in both our domestic and export markets as a clean, green and healthy product. Our production relies on pumping clean seawater of oceanic quality. This is a hard-fought reputation and one that could be easily lost. Yumbah Kangaroo Island farm (YKI) relies on the South Australia Environment Protection (Water Quality) Policy 2015 (SAEP) guidelines as set out in Australian and New Zealand Environment and Conservation Council (ANZECC) & Agriculture and Resource Management Council of Australia and New Zealand (ARMCANZ), 2000 to protect the precious marine resource that abalone farms depend on. The proposed seaport poses an extreme risk to Yumbah Kangaroo Island farm (YKI) due to its immediate proximity, raising threats to biosecurity, pollution, elevation of fine settlement loading beyond the SAEP and ANZECC standards, air-borne pollution, sawdust and dust, artificial lighting and interruptions to the existing coastal processes within Smiths Bay. Vessel born Biohazards and Pollution. The potential biosecurity threats to the marine environment and aquaculture from cargo hold ballast water, hull-clinging (or hull-fouling) and ships’ bilge water is understated in the EIS. Ballast water may contain oil, bacteria, viruses, algae and other marine organisms including the often-microscopic egg, embryo or immature larval stage of marine invertebrates. Ballast water taken from one ecological zone then discharged it into another can introduce invasive species and exotic diseases. Hull-clinging can also transport marine organisms and pathogens between locations. Bio-invasion is one of greatest threats facing the world’s oceans today, once established these pests are almost impossible to eradicate in the marine environment with catastrophic consequences. The Smiths Bay Seaport would place the Yumbah KI farm directly in the firing line of these threats greatly increasing the biosecurity risk to the farm. Ship’s bilge water can contain oil, detergents, chemicals and more. The EIS does not refer to any risks from bilge water and is void of any reference to its management. It should be noted also that YKI like most abalone farm has approval and intentions of culturing other species under a multitrophic aquaculture model. No consideration has been applied to risk the report poses to any other species the farm may grow in the future. Total Suspended Solids (TSS). The KPT EIS report neglects to properly describe the impacts of elevated TSS and sediment resuspension that would be created during construction, maintenance dredging and operation of the seaport. The report attempts equate sand particles with silt. Whereas abalone are well adapted to the rigors of high energy marine environments and the sand present there they are much less tolerant of fine silts and clays and the high bacteria loads typically associated with such sediments. (McShane 2019)

| Page 3 of 4

Abalone farms use micro filtration systems for water supplied to the hatchery and nursery to remove fine silt as this inhibits larval survival and settlement. These filtration systems will be at risk of being overwhelmed. Growout systems rely on pumping large volumes of clean water and are not suited to filtration as this would dramatically increase both the pumping costs, (energy consumption) and infrastructure costs. The tank systems are also not designed to cope with heavy silt loads. Likewise, the gill configuration of abalone is adapted to a high energy environment. Abalone can cope with being covered by sand following storm events; but they are susceptible to smothering and asphyxiation by silt. Bacteria are generally not carried directly in the water column but are borne on particles; the finer the particles (silt) the greater the surface area available for bacteria to inhabit. The threat of elevated bacterial loads (Vibrio spp. in particular) associated with silt loadings and elevated temperatures was ignored in the EIS. Ecotoxicological Studies Cheshire (2018) refers to an ecotoxicology study conducted over 24 hours at 18 °c. Cheshire (2018) states “On the basis of these findings it is concluded that the construction and operation of the Kangaroo Island Seaport will not have any measurable impact on water quality that would impact on the performance of the Yumbah Smith Bay abalone farm.” However:

• This was very short acute study conducted at the ideal temperature for survival. • It is impossible to determine chronic effects from such a study. • It ignores the compounding effects of elevated bacteria levels associated with increased silt

loading. • It ignores compounding effects of the above at higher summer water temperatures.

Yet Cheshire (2018) concludes that there would be no impact on the Yumbah Smith Bay Abalone Farm, (regardless of chronic effects and at higher summer temperatures). Furthermore, the report goes on to suggest, based on this simplistic study that ANZECC guidelines for TSS be relaxed. (Re. Dredge Spoil Management). Such nonsensible claims are alarming and indefensible. Dust Noise and Light. AAGA shares YKI’s further concerns regarding dust, noise and light.

• Dust from the woodchip piles and heavy traffic is likely to accumulate on the shade cloth of the abalone farm and enter the tanks in concentrated form following rain events.

• Noise from woodchipping and other activities is likely to disturb abalone. • Light: Abalone farms are deliberately not lit at night, so as not to disturb the nocturnal habits

of abalone. The EIS fails to address remediation of the above factors.

Conclusion. The Seaport proposal is an unprecedented encroachment on a successful, established business that provides permanent employment for some 30 people, within a company that employs 125 people within an industry that employs more than 400 people. This is an expanding industry with Yumbah alone proposing a $73 million expansion of its Portland (Vic.) abalone operations and all other farms

| Page 2 of 4

to denigrate our industry. The report fails to recognize that seaports of this scale and aquaculture in such immediate proximity cannot successfully co-exist. For example, Southwood Fibre recently abandoned its proposed woodchip export facility near Dover in Tasmania due to an impasse with salmon grower Tassal. Should the Sea Port proposal be approved it will set a precedent for similar emerging incompatible encroachments to aquaculture around the country. AAGA’s opposition to the proposal is entirely based on proximity, it is simply too close. Australian abalone is highly regarded in both our domestic and export markets as a clean, green and healthy product. Our production relies on pumping clean seawater of oceanic quality. This is a hard-fought reputation and one that could be easily lost. Yumbah Kangaroo Island farm (YKI) relies on the South Australia Environment Protection (Water Quality) Policy 2015 (SAEP) guidelines as set out in Australian and New Zealand Environment and Conservation Council (ANZECC) & Agriculture and Resource Management Council of Australia and New Zealand (ARMCANZ), 2000 to protect the precious marine resource that abalone farms depend on. The proposed seaport poses an extreme risk to Yumbah Kangaroo Island farm (YKI) due to its immediate proximity, raising threats to biosecurity, pollution, elevation of fine settlement loading beyond the SAEP and ANZECC standards, air-borne pollution, sawdust and dust, artificial lighting and interruptions to the existing coastal processes within Smiths Bay. Vessel born Biohazards and Pollution. The potential biosecurity threats to the marine environment and aquaculture from cargo hold ballast water, hull-clinging (or hull-fouling) and ships’ bilge water is understated in the EIS. Ballast water may contain oil, bacteria, viruses, algae and other marine organisms including the often-microscopic egg, embryo or immature larval stage of marine invertebrates. Ballast water taken from one ecological zone then discharged it into another can introduce invasive species and exotic diseases. Hull-clinging can also transport marine organisms and pathogens between locations. Bio-invasion is one of greatest threats facing the world’s oceans today, once established these pests are almost impossible to eradicate in the marine environment with catastrophic consequences. The Smiths Bay Seaport would place the Yumbah KI farm directly in the firing line of these threats greatly increasing the biosecurity risk to the farm. Ship’s bilge water can contain oil, detergents, chemicals and more. The EIS does not refer to any risks from bilge water and is void of any reference to its management. It should be noted also that YKI like most abalone farm has approval and intentions of culturing other species under a multitrophic aquaculture model. No consideration has been applied to risk the report poses to any other species the farm may grow in the future. Total Suspended Solids (TSS). The KPT EIS report neglects to properly describe the impacts of elevated TSS and sediment resuspension that would be created during construction, maintenance dredging and operation of the seaport. The report attempts equate sand particles with silt. Whereas abalone are well adapted to the rigors of high energy marine environments and the sand present there they are much less tolerant of fine silts and clays and the high bacteria loads typically associated with such sediments. (McShane 2019)

APPENDIX 4 –

MARINE BIOSECURITY REVIEWHewitt & Campbell

2019

| Page 4 of 4

expanding or actively seeking expansion opportunities. The YKI site has available land and licenses to expand to more than double its current capacity, creating significantly more jobs and investment to Kangaroo Island. I am advised that this expansion would be already underway if there wasn’t a proposed seaport threatening its ongoing existence. AAGA appreciates the effort KPT have undertaken to gain approvals for their project. It is most unfortunate that they chose such an inappropriate site and failed to consult properly with their immediate neighbor. YKI should not be forced to bear the cost of KPT’s poor decision making.

Yours sincerely

Nicholas Savva

Executive Officer References Cheshire, A. (2018). Assessment of risks and mitigation strategies to the Yumbah Aquaculture Facility from the Construction and Operation of the proposed KI Seaport. Prepared for Kangaroo Island Plantation Timber Pty Ltd. 24 September 2018. McShane, P. (2019). Smith Bay Wharf. Response to Draft Environmental Impact Statement. Kangaroo Island Plantation Timbers.

APPENDIX 4 –

MARINE BIOSECURITY REVIEWHewitt & Campbell

2019


Smith Bay Wharf Draft Environmental Impact Statement


Prepared by:

Professor Chad L Hewitt and Professor Marnie L Campbell

Harry Butler Institute, Murdoch University, Murdoch, Western Australia

P a g e | 1

REVIEW OF MARINE BIOSECURITY ASPECTS OF SMITH BAY WHARF DRAFT ENVIRONMENTAL IMPACT ASSESSMENT

As requested by Yumbah Kangaroo Island (Yumbah KI), we have undertaken an analysis of the Smith Bay Wharf Draft Environmental Impact Statement (SBW Draft EIS 2019). Specifically we have focused on aspects that will influence marine biosecurity hazards, specifically the Marine Biosecurity chapter in Appendix A and the information provided in Appendix I, but also including information provided in other locations in the SBW Draft EIS (2019). There is limited description of the methods used to identify risk species other than reference to the previously developed Commonwealth and South Australian pest identification. While these represent legislated activity, they do not specifically examine the likely species that would be transported from the Northwest Pacific (ie China, Japan, Korea). These findings are discussed further below, and additional risk species are highlighted. PRIORITY PEST SPECIES The proponents highlight that they have focused attention on a priority list developed by CSIRO (Hayes et al. 2005) and note that further work by the Australian Government is being undertaken to determine a priority list of invasive marine species (DAWR 2015). Additionally they note that “[a]ll exotic species are of concern to the South Australian Government”, but note a list of species of most concern (PIRSA 2015).

Given the statement that “all exotic species are of concern to the South Australian Government” I would have anticipated a much more comprehensive assessment than seems to have occurred, with specific focus on both the port construction phase (with assessment of likely species transfer from domestic and international ports associated with the construction) and the operational phase.

Port construction phase There is no explicit assessment of species’ transfer risk associated with the construction phase, despite this representing a very high potential due to the movement and arrival of slow-moving vessels with long port residence times, including the potential for sediment transport (dredges and barges) which may lead to the transfer of harmful algal blooms in cyst stage. I would expect to see an identification of source ports for vessel transfer during this phase, and some explicit statements surrounding species known from those ports/regions that might pose a risk of transfer.

The mitigation measures as stated are unlikely to be adequate to mitigate risk during the construction phase.

• Dredges and associated supporting barges should have an explicit cleaning protocol prior to departing the last port of call. Dredges and supporting vessels have been explicitly linked to the transfer and spread of non-native marine species, particularly biofouling species such as Sabella spallanzanii, and dinoflagellate cysts in retained sediments from the last port of operations.

• During the construction phase it is unlikely that vessels will be “in ballast” due to transfer of goods and materials for construction, however once construction is complete, material and equipment will need to be removed/relocated and it is likely that vessels will arrive in ballast. The mitigation measures for discharges and ballast water management state that they will adhere to international and Commonwealth law protocols for “complete ballast exchange enroute.” High seas ballast exchange is moderately successful at reducing the planktonic component of the assemblage, however is poor at reducing the ballast sediment


Smith Bay Wharf Draft Environmental Impact Statement


Prepared by:

Professor Chad L Hewitt and Professor Marnie L Campbell

Harry Butler Institute, Murdoch University, Murdoch, Western Australia

P a g e | 1

REVIEW OF MARINE BIOSECURITY ASPECTS OF SMITH BAY WHARF DRAFT ENVIRONMENTAL IMPACT ASSESSMENT

As requested by Yumbah Kangaroo Island (Yumbah KI), we have undertaken an analysis of the Smith Bay Wharf Draft Environmental Impact Statement (SBW Draft EIS 2019). Specifically we have focused on aspects that will influence marine biosecurity hazards, specifically the Marine Biosecurity chapter in Appendix A and the information provided in Appendix I, but also including information provided in other locations in the SBW Draft EIS (2019). There is limited description of the methods used to identify risk species other than reference to the previously developed Commonwealth and South Australian pest identification. While these represent legislated activity, they do not specifically examine the likely species that would be transported from the Northwest Pacific (ie China, Japan, Korea). These findings are discussed further below, and additional risk species are highlighted. PRIORITY PEST SPECIES The proponents highlight that they have focused attention on a priority list developed by CSIRO (Hayes et al. 2005) and note that further work by the Australian Government is being undertaken to determine a priority list of invasive marine species (DAWR 2015). Additionally they note that “[a]ll exotic species are of concern to the South Australian Government”, but note a list of species of most concern (PIRSA 2015).

Given the statement that “all exotic species are of concern to the South Australian Government” I would have anticipated a much more comprehensive assessment than seems to have occurred, with specific focus on both the port construction phase (with assessment of likely species transfer from domestic and international ports associated with the construction) and the operational phase.

Port construction phase There is no explicit assessment of species’ transfer risk associated with the construction phase, despite this representing a very high potential due to the movement and arrival of slow-moving vessels with long port residence times, including the potential for sediment transport (dredges and barges) which may lead to the transfer of harmful algal blooms in cyst stage. I would expect to see an identification of source ports for vessel transfer during this phase, and some explicit statements surrounding species known from those ports/regions that might pose a risk of transfer.

The mitigation measures as stated are unlikely to be adequate to mitigate risk during the construction phase.

• Dredges and associated supporting barges should have an explicit cleaning protocol prior to departing the last port of call. Dredges and supporting vessels have been explicitly linked to the transfer and spread of non-native marine species, particularly biofouling species such as Sabella spallanzanii, and dinoflagellate cysts in retained sediments from the last port of operations.

• During the construction phase it is unlikely that vessels will be “in ballast” due to transfer of goods and materials for construction, however once construction is complete, material and equipment will need to be removed/relocated and it is likely that vessels will arrive in ballast. The mitigation measures for discharges and ballast water management state that they will adhere to international and Commonwealth law protocols for “complete ballast exchange enroute.” High seas ballast exchange is moderately successful at reducing the planktonic component of the assemblage, however is poor at reducing the ballast sediment


P a g e | 2

load (eg Ruiz and Reid 2007). Additionally it is unlikely that domestic movements will be able to undertake ballast exchange in the “high seas” and indeed are not required to under international or Commonwealth legislation. Therefore this mitigation is unlikely to be applied unless explicit agreements and requirements are made.

• Biofouling on domestic vessels, particularly in niche areas or on slow moving vessels (such as dumb barges and dredges) can transfer mature communities resulting in the spawning or accidental dislodgment of material. While the mitigation requiring “no in-water or dry dock cleaning would be permitted at Smith Bay” will limit intentional discharge of material, a more thorough method would require all vessels used during the construction phase to be “cleaned prior to entry”. This would significantly minimize the likelihood of transferring biofouling species from domestic ports into Smith Bay during the construction phase.

Port operation phase The primary assessment appears to be restricted to the operation phase with a primary focus on ballast water and biofouling. Hewitt and Campbell (2010) highlighted that a large majority of recognised global marine invaders are capable of being transported by multiple vectors, with ballast water (of commercial vessels) and biofouling (of commercial and recreational vessels) having the greatest contribution.

The assessment has been restricted to previously highlighted lists of species as mentioned above. It should also be noted that many of the species identified in Table 1 (Appendix I5) are not native to, nor currently introduced to, the Northwest Pacific (see the emended Table 1 below). This information may aid in targeting marine biosecurity surveillance, however it should also be noted that numerous other species with known invasion histories are found in the Northwest Pacific that should be considered further.

Hewitt et al (2009) identified 324 marine species introduced to the Northwest Pacific bioregion (107 of which are not present in Australia), and 645 native species that have been introduced to other parts of the world (266 of which are not present in Australia). The 373 species with an invasion history and known to be present in the Northwest Pacific but not present in Australasia represent a significant risk.

Additionally, we note that there is mention that trading vessels from other regions are likely to use the port facilities. This will create additional unassessed exposure to biosecurity risks as new connections with other trade regions occur.

The mitigation measures as stated are unlikely to be adequate to mitigate risk during the operation phase.

• The proposed mitigation measures focus on “Discharges and Ballast Water Management”, stating that “all vessels would adhere to international and Commonwealth law protocols for complete ballast water exchange enroute. Ballast water exchange, if conducted properly, can be highly efficient (~99% volumetric exchange of coastal waters for open ocean water) and significantly reduce the density of many planktonic organisms, however many studies have also demonstrated that ballast water exchange has severe limitations depending on the type and location of exchange resulting in variable outcomes for many taxa ranging from 95% reduction to <50% reduction in population size.

P a g e | 3

Ballast water exchange is a risk minimisation strategy, and does not provide a zero risk scenario. For this reason International Convention for the Control and Management of Ships' Ballast Water and Sediments (aka BWM; IMO 2004) explicitly highlighted that ballast exchange was an interim measure, with a focus on developing ballast water treatment technologies that would achieve much more rigorous standards as highlighted in the Convention, and now in the Biosecurity Act.

P a g e | 2

load (eg Ruiz and Reid 2007). Additionally it is unlikely that domestic movements will be able to undertake ballast exchange in the “high seas” and indeed are not required to under international or Commonwealth legislation. Therefore this mitigation is unlikely to be applied unless explicit agreements and requirements are made.

• Biofouling on domestic vessels, particularly in niche areas or on slow moving vessels (such as dumb barges and dredges) can transfer mature communities resulting in the spawning or accidental dislodgment of material. While the mitigation requiring “no in-water or dry dock cleaning would be permitted at Smith Bay” will limit intentional discharge of material, a more thorough method would require all vessels used during the construction phase to be “cleaned prior to entry”. This would significantly minimize the likelihood of transferring biofouling species from domestic ports into Smith Bay during the construction phase.

Port operation phase The primary assessment appears to be restricted to the operation phase with a primary focus on ballast water and biofouling. Hewitt and Campbell (2010) highlighted that a large majority of recognised global marine invaders are capable of being transported by multiple vectors, with ballast water (of commercial vessels) and biofouling (of commercial and recreational vessels) having the greatest contribution.

The assessment has been restricted to previously highlighted lists of species as mentioned above. It should also be noted that many of the species identified in Table 1 (Appendix I5) are not native to, nor currently introduced to, the Northwest Pacific (see the emended Table 1 below). This information may aid in targeting marine biosecurity surveillance, however it should also be noted that numerous other species with known invasion histories are found in the Northwest Pacific that should be considered further.

Hewitt et al (2009) identified 324 marine species introduced to the Northwest Pacific bioregion (107 of which are not present in Australia), and 645 native species that have been introduced to other parts of the world (266 of which are not present in Australia). The 373 species with an invasion history and known to be present in the Northwest Pacific but not present in Australasia represent a significant risk.

Additionally, we note that there is mention that trading vessels from other regions are likely to use the port facilities. This will create additional unassessed exposure to biosecurity risks as new connections with other trade regions occur.

The mitigation measures as stated are unlikely to be adequate to mitigate risk during the operation phase.

• The proposed mitigation measures focus on “Discharges and Ballast Water Management”, stating that “all vessels would adhere to international and Commonwealth law protocols for complete ballast water exchange enroute. Ballast water exchange, if conducted properly, can be highly efficient (~99% volumetric exchange of coastal waters for open ocean water) and significantly reduce the density of many planktonic organisms, however many studies have also demonstrated that ballast water exchange has severe limitations depending on the type and location of exchange resulting in variable outcomes for many taxa ranging from 95% reduction to <50% reduction in population size.

P a g e | 3

Ballast water exchange is a risk minimisation strategy, and does not provide a zero risk scenario. For this reason International Convention for the Control and Management of Ships' Ballast Water and Sediments (aka BWM; IMO 2004) explicitly highlighted that ballast exchange was an interim measure, with a focus on developing ballast water treatment technologies that would achieve much more rigorous standards as highlighted in the Convention, and now in the Biosecurity Act.

Pa

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sh

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us m

elan

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mus

ro

und

goby

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Fish

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ganu

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ulat

us

rabb

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h

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Tr

iden

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bifa

scia

tus

shim

ofur

i gob

y M

Y M

acro

alga

e Ca

uler

pa c

ylin

drac

ea

(gre

en m

acro

alga

)

Y

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roal

gae

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erpa

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(g

reen

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Y

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acro

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adop

hora

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roal

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Y

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frag

ile ss

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men

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ides

(g

reen

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roal

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Y

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alga

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atel

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ru

(red

mac

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(bro

wn

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ento

us m

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)

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Mac

roal

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nia

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iei

(red

mac

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roal

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assu

m m

utic

um

Asia

n se

awee

d

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roal

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a

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e U

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taen

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Y M

acro

alga

e U

ndar

ia p

inna

tifid

a Ja

pane

se se

awee

d M

Y

Y

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icro

alga

e Al

exan

driu

m c

aten

ella

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Y M

icro

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e Al

exan

driu

m m

inut

um

H

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andr

ium

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ma

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o

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scs

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ula

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ensis

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ian

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Y

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scs

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sost

rea

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cific

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ter

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lusc

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epid

ula

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icat

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pet

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sis d

irect

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jack

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fe c

lam

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lusc

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mno

pern

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ei

gold

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lam

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Y M

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scs

Mao

ricol

pus r

oseu

s N

ew Z

eala

nd sc

rew

shel

l M

Y

Y

Mol

lusc

s M

uscu

lista

senh

ousia

As

ian

date

mus

sel

M

Y

Y

Mol

lusc

s M

ya a

rena

ria

soft

shel

l cla

m

Y

Mol

lusc

s M

ytilo

psis

salle

i bl

ack-

strip

ed m

usse

l M

Y

Y M

ollu

scs

Pern

a pe

rna

brow

n m

usse

l

Y

Mol

lusc

s Pe

rna

virid

is As

ian

gree

n m

usse

l H

Y Y

Y

Mol

lusc

s Pi

ncta

da a

lbin

a su

gilla

ta

pear

l oys

ter

Y

Pa

ge

| 4

Ta

ble

1: In

trod

uced

mar

ine

spec

ies r

elev

ant t

o Sm

ith B

ay fr

om S

mith

Bay

Wha

rf D

raft

EIS

(201

9), e

men

ded

to in

clud

e th

ose

spec

ies k

now

n fr

om th

e N

orth

wes

t Pac

ific

bior

egio

n. N

ote

high

light

ed se

ctio

ns in

yel

low

repr

esen

t mis-

alig

nmen

t to

phyl

a in

the

orig

inal

tabl

e.

Grou

p Sp

ecie

s Co

mm

on n

ame

Nat

iona

l pr

iorit

y PI

RSA

conc

ern

Decl

ared

no

xiou

s Re

cord

ed

on

Kang

aroo

Is

land

Know

n fr

om N

W

Paci

fic

Bior

egio

n As

cidi

ans

Asci

diel

la a

sper

sa

Euro

pean

sea

squi

rt

Y

Asci

dian

s Bo

tryl

loid

es le

achi

Y

Y As

cidi

ans

Botr

yllu

s sch

loss

eri

Y Y

Asci

dian

s Ci

ona

inte

stin

alis

Vase

tuni

cate

M

Y

Y As

cidi

ans

Dide

mnu

m sp

p (e

xotic

stra

ins o

nly)

Y As

cidi

ans

Stye

la c

lava

M

Y

Asci

dian

s St

yela

plic

ata

Y Y

Mac

roal

gae

Bryo

psis

plum

osa

Y Y

Bryo

zoan

s Bu

gulla

flab

ella

ta

M

Y Br

yozo

ans

Bugu

la n

eriti

na

M

Y

Y Br

yozo

ans

Schi

zopo

rella

err

ata

M

Bryo

zoan

s Tr

icel

laria

occ

iden

talis

M

Y

Bryo

zoan

s W

ater

sipor

a ar

cuat

a

M

Y

Bryo

zoan

s W

ater

sipor

a su

btor

quat

a

M

Y

Crus

tace

ans

Bala

nus e

burn

eus

M

Y Cr

usta

cean

s Ba

lanu

s ret

icul

atus

M

Y

Crus

tace

ans

Bala

nus i

mpr

ovisu

s

M

Y

Y

Crus

tace

ans

Meg

abal

anus

rosa

M

Y

Crus

tace

ans

Meg

abal

anus

tint

inna

bulu

m

M

Y

Cten

opho

re

Mne

mio

psis

leid

yi

com

b je

lly

Y

Poly

chae

tes

Sabe

lla sp

alla

nzan

ii Eu

rope

an fa

n w

orm

M

Y

Y Y

Crus

tace

ans

Carc

inus

mae

nas

Euro

pean

shor

e cr

ab

M

Y Y

Y

Crus

tace

ans

Char

ybdi

s jap

onic

a la

dy c

rab

M

Y

Y

Crus

tace

ans

Erio

chei

r sin

ensis

Ch

ines

e m

itten

cra

b M

Y

Y

Y Cr

usta

cean

s He

mig

raps

us sa

ngui

neus

Ja

pane

se sh

ore

crab

M

Y

Y Cr

usta

cean

s He

mig

raps

us ta

kano

i/pen

icill

atus

Pa

cific

cra

b

Y

Y P

ag

e |

5

Crus

tace

ans

Pseu

dodi

apto

mus

mar

inus

(a

cop

epod

) M

Y Ec

hino

derm

s As

teria

s am

uren

sis

Nor

ther

n Pa

cific

sea

star

M

Y

Y

Y Fi

sh

Neo

gobi

us m

elan

osto

mus

ro

und

goby

M

Fish

Si

ganu

s riv

ulat

us

rabb

it fis

h

Y

Fish

Tr

iden

tiger

bifa

scia

tus

shim

ofur

i gob

y M

Y M

acro

alga

e Ca

uler

pa c

ylin

drac

ea

(gre

en m

acro

alga

)

Y

Mac

roal

gae

Caul

erpa

taxi

folia

(g

reen

mac

roal

ga)

Y

Y

Y M

acro

alga

e Cl

adop

hora

pro

lifer

a (g

reen

mac

roal

ga)

Y

Y M

acro

alga

e Co

dium

frag

ile ss

p to

men

toso

ides

(g

reen

mac

roal

ga)

Y

Y M

acro

alga

e Gr

atel

oupi

a tu

rutu

ru

(red

mac

roal

ga)

Y

Y M

acro

alga

e Hi

ncks

ia sa

ndria

na

(bro

wn

filam

ento

us m

acro

alga

)

Y Y

Mac

roal

gae

Poly

sipho

nia

brod

iei

(red

mac

roal

ga)

M

Y Y

Mac

roal

gae

Sarg

assu

m m

utic

um

Asia

n se

awee

d

Y

Y

Mac

roal

gae

Ulv

a la

ctuc

a

Y

Y M

acro

alga

e U

lva

taen

iata

Y

Y M

acro

alga

e U

ndar

ia p

inna

tifid

a Ja

pane

se se

awee

d M

Y

Y

Y M

icro

alga

e Al

exan

driu

m c

aten

ella

Y

Y M

icro

alga

e Al

exan

driu

m m

inut

um

H

Y Y

Mic

roal

gae

Alex

andr

ium

tam

aren

se

Y Y

Mic

roal

gae

Gym

nodi

nium

cat

enat

um

H

Y Y

Mic

roal

gae

Hete

rosig

ma

akas

hiw

o

Y

Y M

ollu

scs

Corb

ula

amur

ensis

As

ian

clam

M

Y

Y M

ollu

scs

Cras

sost

rea

giga

s Pa

cific

oys

ter

M

Y

Y Y

Mol

lusc

s Cr

epid

ula

forn

icat

a Am

eric

an sl

ippe

r lim

pet

Y

Mol

lusc

s En

sis d

irect

us

jack

-kni

fe c

lam

Y

Mol

lusc

s Li

mno

pern

a fo

rtun

ei

gold

en c

lam

M

Y M

ollu

scs

Mao

ricol

pus r

oseu

s N

ew Z

eala

nd sc

rew

shel

l M

Y

Y

Mol

lusc

s M

uscu

lista

senh

ousia

As

ian

date

mus

sel

M

Y

Y

Mol

lusc

s M

ya a

rena

ria

soft

shel

l cla

m

Y

Mol

lusc

s M

ytilo

psis

salle

i bl

ack-

strip

ed m

usse

l M

Y

Y M

ollu

scs

Pern

a pe

rna

brow

n m

usse

l

Y

Mol

lusc

s Pe

rna

virid

is As

ian

gree

n m

usse

l H

Y Y

Y

Mol

lusc

s Pi

ncta

da a

lbin

a su

gilla

ta

pear

l oys

ter

Y

Pa

ge

| 6

M

ollu

scs

Rapa

na v

enos

a ra

pa w

helk

Y

Y

Mol

lusc

s Va

ricor

bula

gib

ba

Euro

pean

cla

m

Y

Poly

chae

tes

Hydr

oide

s ezo

ensis

M

Y

Poly

chae

tes

Hydr

oide

s san

ctae

cruc

is

M

Y

Poly

chae

tes

Mar

ense

lleria

spp.

re

d-gi

lled

mud

wor

m

Y

P a g e | 7

• As noted in the Operational phase, ballast water exchange is poor at reducing the risks associated with ballast sediments, particularly for the cysts of toxic dinoflagellates.

• Biofouling of commercial vessels, particularly in niche areas and dry docking support strips (areas that were not repainted during the previous dry docking), can transfer mature communities resulting in the spawning or accidental dislodgment of material. At present there are only international guidelines to mitigate biofouling risks, and several States and Territories have undertaken independent measures, primarily focused on recreational vessels and High Value Areas.

Additional risks associated with mature biofouling communities include the transfer of disease agents and parasites in species present on the hulls of vessels.

There is some concern with the exclusion of species considered “[e]xceptions that meet [those] criteria but are considered unlikely to establish in the oceanographic environment at Smith Bay”

• Toxic dinoflagellates in the genus Alexandrium are stated to be “restricted to coastal, nutrient-enriched sites, particularly harbours, estuaries and lagoons (GISD 2017)” and therefore not represent a threat of establishment in the Smith Bay environment. Alexandrium spp are widely distributed and continue to represent threats to coastal waters, particularly but not restricted to harbours, estuaries and lagoons.

• The Pacific oyster, Crassostrea gigas, is a well-known biofouling species particularly in niche areas of the hull including the propeller, propeller shaft, and thrusters. While its primary mechanism of global transfer has been through intentional movements for aquaculture, the transport by commercial and recreational vessels is well documented and has contributed to the ‘feral’ oyster problem in Australia and overseas.

While it is noted that several species of concern (ie either by the Commonwealth or by PIRSA) have already been detected on Kangaroo Island, the influx of additional and potentially novel genetic material may enhance the invasibility of the already established pests. Of particular concern to abalone farming would be:

• The toxic, bloom forming microalga, Gymnodinium catenatum, which is already known to occur from Eastern Cove, Western Cove and American River. The addition of new material, combined with the changing environmental conditions associated with port development, may enhance the likelihood of establishment and bloom formation in Smith Bay. The EIS reports that currents may reduce by 30-40% and drift algae will be become concentrated as a consequence of the causeway. The reduced turnover and mixing of the water, coupled with increasing water temperature will create optimal conditions for bloom forming toxic microalgae.

• The European fan worm, Sabella spallanzanii, can have direct impacts to seawater intakes and to aquaculture facilities. Increased activity linked with Port Adelaide may enhance the population and distribution at Kangaroo Island.

• Codium fragile ssp tomentosoides is known to interfere with shellfish aquaculture through attachment onto the shells leading to enhanced drag and hindering the movement and feeding of the shellfish.

• Asterias amurensis, the Northern Pacific Seastar, which could cause direct predatory mortality • Undaria pinnatifida, the Japanese kelp, which could settle on shells and enhance drag, as well as compete

for aspect dominance with abalone’s native algal food sources. Direct effects to Yumbah KI could also include fouling intake screens and pipes and growing in tanks.

It should also be noted that numerous species native to the Northwest Pacific (China, Japan, Korea) have been introduced globally. These species would now have a higher likelihood of arriving in Australia (specifically to Kangaroo Island) via residual ballast water and sediments, and biofouling.

We find that the EIS fails to sufficiently consider the domestic and international introduction risks to the environment and to Yumbah KI’s interests.

Pa

ge

| 6

M

ollu

scs

Rapa

na v

enos

a ra

pa w

helk

Y

Y

Mol

lusc

s Va

ricor

bula

gib

ba

Euro

pean

cla

m

Y

Poly

chae

tes

Hydr

oide

s ezo

ensis

M

Y

Poly

chae

tes

Hydr

oide

s san

ctae

cruc

is

M

Y

Poly

chae

tes

Mar

ense

lleria

spp.

re

d-gi

lled

mud

wor

m

Y

P a g e | 7

• As noted in the Operational phase, ballast water exchange is poor at reducing the risks associated with ballast sediments, particularly for the cysts of toxic dinoflagellates.

• Biofouling of commercial vessels, particularly in niche areas and dry docking support strips (areas that were not repainted during the previous dry docking), can transfer mature communities resulting in the spawning or accidental dislodgment of material. At present there are only international guidelines to mitigate biofouling risks, and several States and Territories have undertaken independent measures, primarily focused on recreational vessels and High Value Areas.

Additional risks associated with mature biofouling communities include the transfer of disease agents and parasites in species present on the hulls of vessels.

There is some concern with the exclusion of species considered “[e]xceptions that meet [those] criteria but are considered unlikely to establish in the oceanographic environment at Smith Bay”

• Toxic dinoflagellates in the genus Alexandrium are stated to be “restricted to coastal, nutrient-enriched sites, particularly harbours, estuaries and lagoons (GISD 2017)” and therefore not represent a threat of establishment in the Smith Bay environment. Alexandrium spp are widely distributed and continue to represent threats to coastal waters, particularly but not restricted to harbours, estuaries and lagoons.

• The Pacific oyster, Crassostrea gigas, is a well-known biofouling species particularly in niche areas of the hull including the propeller, propeller shaft, and thrusters. While its primary mechanism of global transfer has been through intentional movements for aquaculture, the transport by commercial and recreational vessels is well documented and has contributed to the ‘feral’ oyster problem in Australia and overseas.

While it is noted that several species of concern (ie either by the Commonwealth or by PIRSA) have already been detected on Kangaroo Island, the influx of additional and potentially novel genetic material may enhance the invasibility of the already established pests. Of particular concern to abalone farming would be:

• The toxic, bloom forming microalga, Gymnodinium catenatum, which is already known to occur from Eastern Cove, Western Cove and American River. The addition of new material, combined with the changing environmental conditions associated with port development, may enhance the likelihood of establishment and bloom formation in Smith Bay. The EIS reports that currents may reduce by 30-40% and drift algae will be become concentrated as a consequence of the causeway. The reduced turnover and mixing of the water, coupled with increasing water temperature will create optimal conditions for bloom forming toxic microalgae.

• The European fan worm, Sabella spallanzanii, can have direct impacts to seawater intakes and to aquaculture facilities. Increased activity linked with Port Adelaide may enhance the population and distribution at Kangaroo Island.

• Codium fragile ssp tomentosoides is known to interfere with shellfish aquaculture through attachment onto the shells leading to enhanced drag and hindering the movement and feeding of the shellfish.

• Asterias amurensis, the Northern Pacific Seastar, which could cause direct predatory mortality • Undaria pinnatifida, the Japanese kelp, which could settle on shells and enhance drag, as well as compete

for aspect dominance with abalone’s native algal food sources. Direct effects to Yumbah KI could also include fouling intake screens and pipes and growing in tanks.

It should also be noted that numerous species native to the Northwest Pacific (China, Japan, Korea) have been introduced globally. These species would now have a higher likelihood of arriving in Australia (specifically to Kangaroo Island) via residual ballast water and sediments, and biofouling.

We find that the EIS fails to sufficiently consider the domestic and international introduction risks to the environment and to Yumbah KI’s interests.

P a g e | 8

DISEASES The proponents have identified two “most significant diseases” of concern, however no methodology is presented that suggests a rigorous process was employed to determine either the significance or the likelihood of these two species. It should also be noted that the proponent’s analysis is solely focused on the current species (Haliotis laevigata) at Yumbah KI and not on the complete list of permitted species that Yumbah KI is licensed to cultivate at the Smith Bay site (Table 2).

Table 2: Permitted culture species for Yumbah KI at the Smith Bay lease

Phylum Common name Genus Species Channels Tanks

Crustaceans Lobster, Southern Rock Jasus Edwardsii x

Echinoderms Sea Urchin Heliocidaris erythrogramma x Fish Bream, Black Acanthopagrus butcheri x Fish Mullaway Argyrosomus Japonicas x Fish Seahorse, Potbellied Hippocampus abdominalis x Fish Trout, Rainbow Oncorhynchus Mykiss x Fish Snapper Pagrus auratus x Fish Flounder, Greenback Rhombosolea Taparina x x Fish Trout, Brown Salmo Trutta x Fish Kingfish, Yellowtail Seriola lalandi x x Fish Whiting, King George Sillaginodes Punctate x Molluscs Oyster, Pacific Crassostrea Gigas x Molluscs Scallops, Queen Equichlamys Bifrons x Molluscs Abalone Haliotis conicopora x x Molluscs Abalone Haliotis Laevigata x x Molluscs Abalone Haliotis Roei x x Molluscs Abalone Haliotis Rubra x x Molluscs Abalone Haliotis rubra x laevigata x x Molluscs Abalone Haliotis Scalaris x x Molluscs Scallops, Doughboy Mimachlamys asperrimus x Molluscs Oyster, Native Ostrea angasii x

The selection of disease species for consideration should have examined diseases or etiological agents that affect the target aquaculture species listed in Table 2 (or congeners), and the likelihood of introduction from the prospective trading locations, specifically in the Northwest Pacific (China, Japan), and the anticipated domestic movements of vessels during construction and operation. We note that vessels may also arrive from other regions, exposing the Smith Bay ecosystem to a much wider range of unassessed biosecurity risks.

Domestic movements The variety of hazards examined for domestic movements of diseases (pathogens and parasites), are insufficiently identified, particularly during the construction phase and should examine a wider variety of hazards than just the two identified: Abalone Herpes Virus (causing Abalone Viral Ganglioneuritis - AVG) and Perkensis. The EIS makes no comment on the extent to which movements from these locations is anticipated to occur, nor is there any specific surety provided, other than compliance with legal obligations, to prevent the exposure to AbHV.

The unexamined domestic risks to Yumbah KI’s licensed species (Table 2) is considerable.

• The Ostreid Herpesvirus 1 microvariant (OsHV-1) which causes Pacific Oyster Mortality Syndrome (POMS) is now present in Port Adelaide. During the construction phase the risk of transfer will be significant,

P a g e | 9

particularly for vessels that have not been recently cleaned. While Yumbah KI may not currently be culturing the Pacific Oyster, Crassostrea gigas, in Smith Bay, the transfer and infection of wild oysters will establish a source for future infection.

• The risk of transfer of salmonid diseases, including Anaphomyces invadans, from other locations within Australia has not been assessed.

We find that the EIS fails to sufficiently consider the domestic disease and pathogen risks to Yumbah Aquaculture’s current and licensed interests.

International movements An examination of listed Office International des Epizootics (OIE) species identifies nine notifiable diseases of marine species that are known to be present in Japan or China that affect species, or congeners of species, on the Yumbah KI permitted species list. These include two abalone diseases; and one oyster disease; and six fish diseases (Table 3). Additionally, a cursory examination of the literature for disease agents and mortality events in aquaculture facilities, including abalone hatcheries or farms, in China and Japan provides an additional nine non-OIE species of concern (Table 3).

The full extent to which these disease agents pose a risk to Australian native species has not been investigated, however consideration of transfer through ballast water (including retention after ballast water exchange), or via infected biofouling is warranted as these represent an ignored yet significant suite of biosecurity hazards to Yumbah KI. Note that many are water-borne, or have unknown (eg un-researched) horizontal transfer mechanisms (not inherited disease spread between individuals).

We find that the EIS fails to sufficiently consider the international disease and pathogen risks to Yumbah KI’s current and licensed interests.

P a g e | 8

DISEASES The proponents have identified two “most significant diseases” of concern, however no methodology is presented that suggests a rigorous process was employed to determine either the significance or the likelihood of these two species. It should also be noted that the proponent’s analysis is solely focused on the current species (Haliotis laevigata) at Yumbah KI and not on the complete list of permitted species that Yumbah KI is licensed to cultivate at the Smith Bay site (Table 2).

Table 2: Permitted culture species for Yumbah KI at the Smith Bay lease

Phylum Common name Genus Species Channels Tanks

Crustaceans Lobster, Southern Rock Jasus Edwardsii x

Echinoderms Sea Urchin Heliocidaris erythrogramma x Fish Bream, Black Acanthopagrus butcheri x Fish Mullaway Argyrosomus Japonicas x Fish Seahorse, Potbellied Hippocampus abdominalis x Fish Trout, Rainbow Oncorhynchus Mykiss x Fish Snapper Pagrus auratus x Fish Flounder, Greenback Rhombosolea Taparina x x Fish Trout, Brown Salmo Trutta x Fish Kingfish, Yellowtail Seriola lalandi x x Fish Whiting, King George Sillaginodes Punctate x Molluscs Oyster, Pacific Crassostrea Gigas x Molluscs Scallops, Queen Equichlamys Bifrons x Molluscs Abalone Haliotis conicopora x x Molluscs Abalone Haliotis Laevigata x x Molluscs Abalone Haliotis Roei x x Molluscs Abalone Haliotis Rubra x x Molluscs Abalone Haliotis rubra x laevigata x x Molluscs Abalone Haliotis Scalaris x x Molluscs Scallops, Doughboy Mimachlamys asperrimus x Molluscs Oyster, Native Ostrea angasii x

The selection of disease species for consideration should have examined diseases or etiological agents that affect the target aquaculture species listed in Table 2 (or congeners), and the likelihood of introduction from the prospective trading locations, specifically in the Northwest Pacific (China, Japan), and the anticipated domestic movements of vessels during construction and operation. We note that vessels may also arrive from other regions, exposing the Smith Bay ecosystem to a much wider range of unassessed biosecurity risks.

Domestic movements The variety of hazards examined for domestic movements of diseases (pathogens and parasites), are insufficiently identified, particularly during the construction phase and should examine a wider variety of hazards than just the two identified: Abalone Herpes Virus (causing Abalone Viral Ganglioneuritis - AVG) and Perkensis. The EIS makes no comment on the extent to which movements from these locations is anticipated to occur, nor is there any specific surety provided, other than compliance with legal obligations, to prevent the exposure to AbHV.

The unexamined domestic risks to Yumbah KI’s licensed species (Table 2) is considerable.

• The Ostreid Herpesvirus 1 microvariant (OsHV-1) which causes Pacific Oyster Mortality Syndrome (POMS) is now present in Port Adelaide. During the construction phase the risk of transfer will be significant,

P a g e | 9

particularly for vessels that have not been recently cleaned. While Yumbah KI may not currently be culturing the Pacific Oyster, Crassostrea gigas, in Smith Bay, the transfer and infection of wild oysters will establish a source for future infection.

• The risk of transfer of salmonid diseases, including Anaphomyces invadans, from other locations within Australia has not been assessed.

We find that the EIS fails to sufficiently consider the domestic disease and pathogen risks to Yumbah Aquaculture’s current and licensed interests.

International movements An examination of listed Office International des Epizootics (OIE) species identifies nine notifiable diseases of marine species that are known to be present in Japan or China that affect species, or congeners of species, on the Yumbah KI permitted species list. These include two abalone diseases; and one oyster disease; and six fish diseases (Table 3). Additionally, a cursory examination of the literature for disease agents and mortality events in aquaculture facilities, including abalone hatcheries or farms, in China and Japan provides an additional nine non-OIE species of concern (Table 3).

The full extent to which these disease agents pose a risk to Australian native species has not been investigated, however consideration of transfer through ballast water (including retention after ballast water exchange), or via infected biofouling is warranted as these represent an ignored yet significant suite of biosecurity hazards to Yumbah KI. Note that many are water-borne, or have unknown (eg un-researched) horizontal transfer mechanisms (not inherited disease spread between individuals).

We find that the EIS fails to sufficiently consider the international disease and pathogen risks to Yumbah KI’s current and licensed interests.

Pa

ge

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spec

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nder

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ase

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ents

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mith

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. NO

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olde

d di

seas

e ag

ents

are

re

port

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list

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cted

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P a g e | 12

MANAGEMENT AND MITIGATION MEASURES It should be noted that preventative management of potential invasion transport vectors does not, and cannot, result in zero risk, but is intended to provide risk minimisation.

It should also be acknowledged that risk species can potentially be transported to a new location by a number of means (Hewitt and Campbell 2010). For example, many species can be transported during a planktonic phase in ballast water, and as benthic adults in biofouling (Hewitt and Campbell 2010; Davidson et al. 2016).

As a consequence, it is difficult to determine if a species’ arrival following ballast exchange was due a “failure” of ballast water exchange or if the species arrived by other means. There is, however, evidence that species are retained in ballast tanks following open ocean exchange (eg Murphy et al 2002; Ruiz and Reid 2007; Bailey et al. 2011).

The proposed marine biosecurity management and mitigation measures provided in the SBW Draft EIS (2019) are insufficiently defined to determine the level of biosecurity protection. Management and mitigation measures have been provided for two elements: Discharges and Ballast Water Management, and for Biofouling. Each are further addressed below with consideration of how these might be improved:

Discharges and Ballast Water Management The proponents state that the primary risk mitigation and management strategy will be to comply with international and Commonwealth law. This is a mandated (and expected) mitigation and does not adequately and explicitly address the additional risks created by this activity.

As indicated above, there are additional risks associated with the construction and operational phases that would not be adequately addressed through simple compliance with international and Commonwealth law.

• Dredges and associated supporting barges are exposed to sediments in previous ports of operation and have been explicitly linked to the transfer and spread of non-native marine species, particularly biofouling species such as Sabella spallanzanii, and dinoflagellate cysts in retained sediments from the last port of operations.

• Ballast water exchange on the “high seas” is only moderately successful at reducing the planktonic component of the assemblage, although this varies significantly by taxa, and by the method and location of ballast exchange (Molina and Drake 2016; Bailey et al. 2011).

• Ballast water exchange on the “high seas” is very poor at reducing the ballast sediment load and will not adequately mitigate the risk of toxic dinoflagellate cyst introductions (Molina and Drake 2016).

• Vessel trading routes between the Northwest Pacific bioregion and Australia are largely in nearshore and shallow waters which may restrict the opportunities for these vessels to undertake ballast water exchange in water of sufficient depth and distance offshore. How these situations will be managed by the Commonwealth remains unclear (ie will the vessel still be allowed to enter and discharge).

• Under international and Commonwealth law there are clear protections to vessels to not undertake ballast exchange if they consider it to be a risk to the vessel (Endresen et al. 2004). How these situations will be managed by the Commonwealth remains unclear (ie will the vessel still be allowed to enter and discharge).

• Domestic vessel movements are not managed under international or Commonwealth law, and are unlikely to be able to undertake ballast exchange on the “high seas”. Therefore this mitigation is unlikely to be applied unless explicit agreements and requirements are made.

Biofouling • Biofouling is currently unregulated. International guidelines have been developed and adopted by the

International Maritime Organization (IMO) Marine Environmental Protection Committee (MEPC) in Resolution MEPC.207. The Commonwealth further developed biofouling guidelines in 2015 (DAWR 2015).

P a g e | 13

• Biofouling is currently managed by vessel owners and operators with a key focus on reducing vessel drag and fuel efficiency rather than on biosecurity needs. As a consequence the incentives to manage “niche fouling” in protected areas of a vessel (ie areas not exposed to moving water) are likely to be insufficient (Davidson et al 2016).

• Biofouling on slow moving vessels (such as dumb barges and dredges) can transfer mature communities resulting in the spawning or accidental dislodgment of material.

• The proposed mitigation to restrict biofouling discharge through “no in-water or dry dock cleaning would be permitted at Smith Bay” will limit the intentional discharge of biofouling species. This will not mitigate the accidental dislodgement of biofouling organisms or spawning of biofouling species on ship’s hulls and protected areas while in port.

• Disease agents and parasites may be transmitted within biofouling species, including primary and secondary hosts.

SUMMARY 1. The methodology for determining marine biosecurity risk activities, vectors and species is unclear and, based on

the material presented, inadequate. a. The species assessments do not appropriately consider either the domestic or international source

locations to determine the species (and disease agents and parasites) likely to be transported into Smith Bay waters.

b. The assessment of disease agents (pathogens and parasites) does not adequately consider the suite of licensed aquaculture species permitted to Yumbah KI.

c. Nine OIE listed diseases or etiological agents present in Japan or China are known to affect Genera licensed to Yumbah KI.

d. An additional nine diseases or etiological agents species from Japan or China are known to affect Genera licensed to Yumbah KI, and known to have caused mass mortalities of aquaculture species in China or Japan.

2. The risk mitigation measures proposed are generic and meet the letter, rather than the intent, of international, Commonwealth and State requirements.

3. The measures for discharges and ballast water management focus explicitly on the operational phase using commercial trading vessels and are insufficiently detailed to address the construction phase, particularly for the risks associated with slow moving vessels including dredges and barges.

4. The lack of mitigation measures that consider sediment transfer risk either in the dredges and barges, or in the commercial trading vessels is insufficient to provide harmful algal bloom protections.

5. Domestic ballast water movement is unlikely to attain distances offshore to meet the definition of “high seas” and therefore will not be able to undertake adequate protections.

6. Biofouling species hazards associated with both construction and operational phases will continue to pose unmitigated risks. The restriction on “in water or dry dock cleaning” at Smith Bay will not prevent mature species from spawning or being dislodged into Smith Bay waters.

7. Additionally, mature biofouling assemblages are likely to pose the additional risk of transferring disease agents and parasites into Smith Bay waters.

REFERENCES Bailey SA, Deneau MG, Jean L, Wiley CJ, Leung B, MacIsaac HJ. 2011. Evaluating efficacy of an environmental policy

to prevent biological invasions. Environ. Sci. Technol 45: 2554–2561

Davidson I, Scianni C, Hewitt CL, Everett R, Holm E, Tamburri M, Ruiz G. 2016. Assessing drivers of ship biofouling management: aligning industry and biosecurity goals. Biofouling 32:411-428.

P a g e | 12

MANAGEMENT AND MITIGATION MEASURES It should be noted that preventative management of potential invasion transport vectors does not, and cannot, result in zero risk, but is intended to provide risk minimisation.

It should also be acknowledged that risk species can potentially be transported to a new location by a number of means (Hewitt and Campbell 2010). For example, many species can be transported during a planktonic phase in ballast water, and as benthic adults in biofouling (Hewitt and Campbell 2010; Davidson et al. 2016).

As a consequence, it is difficult to determine if a species’ arrival following ballast exchange was due a “failure” of ballast water exchange or if the species arrived by other means. There is, however, evidence that species are retained in ballast tanks following open ocean exchange (eg Murphy et al 2002; Ruiz and Reid 2007; Bailey et al. 2011).

The proposed marine biosecurity management and mitigation measures provided in the SBW Draft EIS (2019) are insufficiently defined to determine the level of biosecurity protection. Management and mitigation measures have been provided for two elements: Discharges and Ballast Water Management, and for Biofouling. Each are further addressed below with consideration of how these might be improved:

Discharges and Ballast Water Management The proponents state that the primary risk mitigation and management strategy will be to comply with international and Commonwealth law. This is a mandated (and expected) mitigation and does not adequately and explicitly address the additional risks created by this activity.

As indicated above, there are additional risks associated with the construction and operational phases that would not be adequately addressed through simple compliance with international and Commonwealth law.

• Dredges and associated supporting barges are exposed to sediments in previous ports of operation and have been explicitly linked to the transfer and spread of non-native marine species, particularly biofouling species such as Sabella spallanzanii, and dinoflagellate cysts in retained sediments from the last port of operations.

• Ballast water exchange on the “high seas” is only moderately successful at reducing the planktonic component of the assemblage, although this varies significantly by taxa, and by the method and location of ballast exchange (Molina and Drake 2016; Bailey et al. 2011).

• Ballast water exchange on the “high seas” is very poor at reducing the ballast sediment load and will not adequately mitigate the risk of toxic dinoflagellate cyst introductions (Molina and Drake 2016).

• Vessel trading routes between the Northwest Pacific bioregion and Australia are largely in nearshore and shallow waters which may restrict the opportunities for these vessels to undertake ballast water exchange in water of sufficient depth and distance offshore. How these situations will be managed by the Commonwealth remains unclear (ie will the vessel still be allowed to enter and discharge).

• Under international and Commonwealth law there are clear protections to vessels to not undertake ballast exchange if they consider it to be a risk to the vessel (Endresen et al. 2004). How these situations will be managed by the Commonwealth remains unclear (ie will the vessel still be allowed to enter and discharge).

• Domestic vessel movements are not managed under international or Commonwealth law, and are unlikely to be able to undertake ballast exchange on the “high seas”. Therefore this mitigation is unlikely to be applied unless explicit agreements and requirements are made.

Biofouling • Biofouling is currently unregulated. International guidelines have been developed and adopted by the

International Maritime Organization (IMO) Marine Environmental Protection Committee (MEPC) in Resolution MEPC.207. The Commonwealth further developed biofouling guidelines in 2015 (DAWR 2015).

P a g e | 13

• Biofouling is currently managed by vessel owners and operators with a key focus on reducing vessel drag and fuel efficiency rather than on biosecurity needs. As a consequence the incentives to manage “niche fouling” in protected areas of a vessel (ie areas not exposed to moving water) are likely to be insufficient (Davidson et al 2016).

• Biofouling on slow moving vessels (such as dumb barges and dredges) can transfer mature communities resulting in the spawning or accidental dislodgment of material.

• The proposed mitigation to restrict biofouling discharge through “no in-water or dry dock cleaning would be permitted at Smith Bay” will limit the intentional discharge of biofouling species. This will not mitigate the accidental dislodgement of biofouling organisms or spawning of biofouling species on ship’s hulls and protected areas while in port.

• Disease agents and parasites may be transmitted within biofouling species, including primary and secondary hosts.

SUMMARY 1. The methodology for determining marine biosecurity risk activities, vectors and species is unclear and, based on

the material presented, inadequate. a. The species assessments do not appropriately consider either the domestic or international source

locations to determine the species (and disease agents and parasites) likely to be transported into Smith Bay waters.

b. The assessment of disease agents (pathogens and parasites) does not adequately consider the suite of licensed aquaculture species permitted to Yumbah KI.

c. Nine OIE listed diseases or etiological agents present in Japan or China are known to affect Genera licensed to Yumbah KI.

d. An additional nine diseases or etiological agents species from Japan or China are known to affect Genera licensed to Yumbah KI, and known to have caused mass mortalities of aquaculture species in China or Japan.

2. The risk mitigation measures proposed are generic and meet the letter, rather than the intent, of international, Commonwealth and State requirements.

3. The measures for discharges and ballast water management focus explicitly on the operational phase using commercial trading vessels and are insufficiently detailed to address the construction phase, particularly for the risks associated with slow moving vessels including dredges and barges.

4. The lack of mitigation measures that consider sediment transfer risk either in the dredges and barges, or in the commercial trading vessels is insufficient to provide harmful algal bloom protections.

5. Domestic ballast water movement is unlikely to attain distances offshore to meet the definition of “high seas” and therefore will not be able to undertake adequate protections.

6. Biofouling species hazards associated with both construction and operational phases will continue to pose unmitigated risks. The restriction on “in water or dry dock cleaning” at Smith Bay will not prevent mature species from spawning or being dislodged into Smith Bay waters.

7. Additionally, mature biofouling assemblages are likely to pose the additional risk of transferring disease agents and parasites into Smith Bay waters.

REFERENCES Bailey SA, Deneau MG, Jean L, Wiley CJ, Leung B, MacIsaac HJ. 2011. Evaluating efficacy of an environmental policy

to prevent biological invasions. Environ. Sci. Technol 45: 2554–2561

Davidson I, Scianni C, Hewitt CL, Everett R, Holm E, Tamburri M, Ruiz G. 2016. Assessing drivers of ship biofouling management: aligning industry and biosecurity goals. Biofouling 32:411-428.

P a g e | 14

DAWR 2015, Review of national marine pest biosecurity, Department of Agriculture and Water Resources, Australian Government, Canberra

DAWR. 2015. Anti-fouling and in-water cleaning guidelines. http://www.agriculture.gov.au/biosecurity/avm/vessels/biofouling/anti-fouling-and-inwater-cleaning-guidelines. accessed 2 April 2019

Deagle BE, Bax N, Hewitt CL, Patil JG. 2003. Development and evaluation of a PCR based test for detection of Asterias (Echinodermata: Asteroidea) larvae in plankton samples from ballast water. Marine and Freshwater Research 54: 709-719.

Endresen Ø, Lee Behrens H, Brynestad S, Bjørn Andersen A, Skjong R. 2004. Challenges in global ballast water management. Marine Pollution Bulletin 48: 615–623.

GISD 2017, Global Invasive Species Database, accessed 2 April 2019, <http://www.iucngisd.org/gisd/about.php>.

Hatai K. 2012. Diseases of fish and shellfish caused by marine fungi. Pp 15-52, In: C Raghukumar (ed.), Biology of Marine Fungi, Progress in Molecular and Subcellular Biology 53.

Hayes, K, Sliwa, C, Migus, S, McEnnulty, F, Dunstan, P. 2005. National priority pests: Part II – Ranking of Australian marine pests, Technical Report for Department of Environment and Heritage by CSIRO Marine Research.

Hewitt CL, Campbell ML, Coutts ADM, Dahlstrom A, Valentine J, Shields D. 2009. Species Biofouling Risk Assessment. Commissioned by The Department of Agriculture, Fisheries and Forestry (DAFF), Canberra. 172pp. ISBN: 978-1-921575-18-1. <http://www.marinepests.gov.au/marine_pests/publications>, accessed 8 August 2013

Hewitt, CL, Campbell, ML. 2010. The relative contribution of vectors to the introduction and translocation of marine invasive species. Report for the Department of Agriculture, Fisheries and Forestry, the National Centre for Marine Conservation and Resource Sustainability, Australian Maritime College, University of Tasmania, Launceston.

IMO. 2004. International Convention for the Control and Management of Ships' Ballast Water and Sediments. http://www.imo.org/en/About/Conventions/ListOfConventions/Pages/International-Convention-for-the-Control-and-Management-of-Ships'-Ballast-Water-and-Sediments-(BWM).aspx, accessed 2 April 2019.

Li T, Ding M, Zhang J, Xiang J, Liu R. 1998. Studies on the pustule disease of abalone (Haliotis discus hannai Ino) on the Dalian coast. J Shellfish Res 17:707–711

Kamaishi T, Miwa S, Goto E, Matsuyama T, Oseko N. 2010. Mass mortality of giant abalone Haliotis gigantean caused by a Francisella sp. bacterium. Diseases of Aquatic Organisms 89: 145-154.

Kiryu I, Kurita J, Yuasa K, Nishioka T, Shimahara Y, Kamaishi T, Ototake M, Oseko N, Tange N, Inoue M, Yatabe T, Friedman CS. 2013. First detection of Candidatus Xenohaliotis californiensis, the causative agent of withering syndrome, in Japanese black abalone Haliotis discus discus in Japan. Fish Pathology 48: 35-41.

Molina V, Drake LA. 2016. Efficacy of open-ocean ballast water exchange: a review. Management of Biological Invasions 7: 375-388.

Moss JA, Burreson EM, Cordes JF, Dungan CF, Brown GD, Wang A, Wu X, Reece KS. 2007. Pathogens in Crassostrea ariakensis and other Asian oyster species: implications for non-native oyster introduction to Chesapeake Bay. Diseases of Aquatic Organisms 77:207-223.

Murphy KR, Ritz D, Hewitt CL. 2002. Heterogeneous zooplankton distribution in a ship’s ballast tanks. Journal of Plankton Research 24(7): 729-734.

Nakatsugawa T, Nagai T, Hiya K, Nishizawa T, Muroga K. 1999. A virus isolated from juvenile Nordotis discus discus affected with amyotrophia. Diseases of Aquatic Organisms 36: 159-161.

Nicolas JL, Basuyauz O, Mazurié J, Thébault A. 2002. Vibrio carchariae, a pathogen of the abalone Haliotis tuberculata. Diseases of Aquatic Organisms 50: 35-43.

P a g e | 15

Nishimori E, Hasegawa O, Numata T, Wakabayashi H. 1998. Vibrio carchariae causes mass mortalities in Japanese abalone, Sulculus diversicolor supratexta. Fish Pathology 33: 495–502.

OIE. 2018. Manual of Diagnostic Tests for Aquatic Animals. http://www.oie.int/index.php?id=2439&L=0&htmfile=sommaire.htm, accessed 17 April 2019.

PIRSA. 2015. Noxious fish list, Primary Industries and Regions South Australia, Government of South Australia, Adelaide, viewed 24 July 2017, http://pir.sa.gov.au/biosecurity/aquatics/aquatic_pests/noxious_fish_list>.

Ruiz GM, Reid DF. 2007. Current State of Understanding about the Effectiveness of Ballast Water Exchange (BWE) in Reducing Aquatic Nonindigenous Species (ANS) Introductions to the Great Lakes Basin and Chesapeake Bay, USA: Synthesis and Analysis of Existing Information. NOAA Technical Memorandum GLERL-142. GL:ERL, Ann Arbor, USA. 127 pp.

Sawabe T, Inoue S, Fukui Y, Yoshie K, Nishihara Y, Miura H. 2007. Mass mortality of Japanese abalone Haliiotis discus hannai caused by Vibrio harveyi infection. Microbes and Environment 22: 300-308.

Tun KL, Shimizu Y, Yamanoi H, Yoshinaga T, Ogawa K. 2008. Seasonality in the infection and invasion of Marteilioides chungmuensis in the Pacific oyster Crassostrea gigas. Diseases of Aquatic Organisms 80:157-165

P a g e | 14

DAWR 2015, Review of national marine pest biosecurity, Department of Agriculture and Water Resources, Australian Government, Canberra

DAWR. 2015. Anti-fouling and in-water cleaning guidelines. http://www.agriculture.gov.au/biosecurity/avm/vessels/biofouling/anti-fouling-and-inwater-cleaning-guidelines. accessed 2 April 2019

Deagle BE, Bax N, Hewitt CL, Patil JG. 2003. Development and evaluation of a PCR based test for detection of Asterias (Echinodermata: Asteroidea) larvae in plankton samples from ballast water. Marine and Freshwater Research 54: 709-719.

Endresen Ø, Lee Behrens H, Brynestad S, Bjørn Andersen A, Skjong R. 2004. Challenges in global ballast water management. Marine Pollution Bulletin 48: 615–623.

GISD 2017, Global Invasive Species Database, accessed 2 April 2019, <http://www.iucngisd.org/gisd/about.php>.

Hatai K. 2012. Diseases of fish and shellfish caused by marine fungi. Pp 15-52, In: C Raghukumar (ed.), Biology of Marine Fungi, Progress in Molecular and Subcellular Biology 53.

Hayes, K, Sliwa, C, Migus, S, McEnnulty, F, Dunstan, P. 2005. National priority pests: Part II – Ranking of Australian marine pests, Technical Report for Department of Environment and Heritage by CSIRO Marine Research.

Hewitt CL, Campbell ML, Coutts ADM, Dahlstrom A, Valentine J, Shields D. 2009. Species Biofouling Risk Assessment. Commissioned by The Department of Agriculture, Fisheries and Forestry (DAFF), Canberra. 172pp. ISBN: 978-1-921575-18-1. <http://www.marinepests.gov.au/marine_pests/publications>, accessed 8 August 2013

Hewitt, CL, Campbell, ML. 2010. The relative contribution of vectors to the introduction and translocation of marine invasive species. Report for the Department of Agriculture, Fisheries and Forestry, the National Centre for Marine Conservation and Resource Sustainability, Australian Maritime College, University of Tasmania, Launceston.

IMO. 2004. International Convention for the Control and Management of Ships' Ballast Water and Sediments. http://www.imo.org/en/About/Conventions/ListOfConventions/Pages/International-Convention-for-the-Control-and-Management-of-Ships'-Ballast-Water-and-Sediments-(BWM).aspx, accessed 2 April 2019.

Li T, Ding M, Zhang J, Xiang J, Liu R. 1998. Studies on the pustule disease of abalone (Haliotis discus hannai Ino) on the Dalian coast. J Shellfish Res 17:707–711

Kamaishi T, Miwa S, Goto E, Matsuyama T, Oseko N. 2010. Mass mortality of giant abalone Haliotis gigantean caused by a Francisella sp. bacterium. Diseases of Aquatic Organisms 89: 145-154.

Kiryu I, Kurita J, Yuasa K, Nishioka T, Shimahara Y, Kamaishi T, Ototake M, Oseko N, Tange N, Inoue M, Yatabe T, Friedman CS. 2013. First detection of Candidatus Xenohaliotis californiensis, the causative agent of withering syndrome, in Japanese black abalone Haliotis discus discus in Japan. Fish Pathology 48: 35-41.

Molina V, Drake LA. 2016. Efficacy of open-ocean ballast water exchange: a review. Management of Biological Invasions 7: 375-388.

Moss JA, Burreson EM, Cordes JF, Dungan CF, Brown GD, Wang A, Wu X, Reece KS. 2007. Pathogens in Crassostrea ariakensis and other Asian oyster species: implications for non-native oyster introduction to Chesapeake Bay. Diseases of Aquatic Organisms 77:207-223.

Murphy KR, Ritz D, Hewitt CL. 2002. Heterogeneous zooplankton distribution in a ship’s ballast tanks. Journal of Plankton Research 24(7): 729-734.

Nakatsugawa T, Nagai T, Hiya K, Nishizawa T, Muroga K. 1999. A virus isolated from juvenile Nordotis discus discus affected with amyotrophia. Diseases of Aquatic Organisms 36: 159-161.

Nicolas JL, Basuyauz O, Mazurié J, Thébault A. 2002. Vibrio carchariae, a pathogen of the abalone Haliotis tuberculata. Diseases of Aquatic Organisms 50: 35-43.

P a g e | 15

Nishimori E, Hasegawa O, Numata T, Wakabayashi H. 1998. Vibrio carchariae causes mass mortalities in Japanese abalone, Sulculus diversicolor supratexta. Fish Pathology 33: 495–502.

OIE. 2018. Manual of Diagnostic Tests for Aquatic Animals. http://www.oie.int/index.php?id=2439&L=0&htmfile=sommaire.htm, accessed 17 April 2019.

PIRSA. 2015. Noxious fish list, Primary Industries and Regions South Australia, Government of South Australia, Adelaide, viewed 24 July 2017, http://pir.sa.gov.au/biosecurity/aquatics/aquatic_pests/noxious_fish_list>.

Ruiz GM, Reid DF. 2007. Current State of Understanding about the Effectiveness of Ballast Water Exchange (BWE) in Reducing Aquatic Nonindigenous Species (ANS) Introductions to the Great Lakes Basin and Chesapeake Bay, USA: Synthesis and Analysis of Existing Information. NOAA Technical Memorandum GLERL-142. GL:ERL, Ann Arbor, USA. 127 pp.

Sawabe T, Inoue S, Fukui Y, Yoshie K, Nishihara Y, Miura H. 2007. Mass mortality of Japanese abalone Haliiotis discus hannai caused by Vibrio harveyi infection. Microbes and Environment 22: 300-308.

Tun KL, Shimizu Y, Yamanoi H, Yoshinaga T, Ogawa K. 2008. Seasonality in the infection and invasion of Marteilioides chungmuensis in the Pacific oyster Crassostrea gigas. Diseases of Aquatic Organisms 80:157-165

APPENDIX 5 –

ECONOMIC IMPACT STATEMENTDench McLean Carlson

2019

Current Operation

Yumbah’s current Kangaroo Island operation generates some $6M in sales (or output). This is estimated to:

• Generate 25 FTE jobs directly and 7 FTE jobs indirectly within Kangaroo Island’s local economy

• Generate $1.077 million in wages and salaries, and

• Grow Value added within the local economy by $4.110 million

Stage 1 – Expansion of Yumbah’s Kangaroo Island operation

The Stage 1 expansion of Yumbah’s current Kangaroo Island operation is forecast to generate $20M in sales (or output) This increase in output is estimated to:

• Generate 60 FTE jobs directly and 25 FTE jobs indirectly within Kangaroo Island’s local economy – this represents a growth of 53 jobs from the current operation

• Generate $5.663 million in wages and salaries– both direct and indirectly – this represents a growth of $3.96 million in wages and salaries within the local economy

• Grow Value added – both direct and indirectly, within the local economy by $13.7 million - this represents a growth of $9.59 million in Value Added within the local economy



• Generate 140 FTE jobs directly and 61 FTE jobs indirectly within Kangaroo Island’s local economy – this represents a growth of : • 116 jobs from Stage 1, and • 169 jobs from the current operation

• Generate $14.16 million in wages and salaries– both direct and indirectly – in the local economy this represents a growth of: • $8.5 million in wages and salaries from Stage 1, and • $12.46 million in wages and salaries from the current operation

• Generate $34.25 in Value added within the local economy- both direct and indirectly - this represents a growth of: • $20.55 million from Stage 1, and • $30.14 million from the current operation

Proposed Tourism Operation

Yumbah propose a tourism offer to be part of their Stage 2 operations and its is estimated that this offer will attract some 15,000 visitors per annum – this aspect of the operation is estimated to generate some $2.48 million in sales (or output) and this output is estimated to:


• Generate $0.53 million in wages and salaries– both direct and indirectly

• Grow Value added – both direct and indirectly, within the local economy by $1.15 million

The above economic impact modelling has been undertaken by REMPLAN with all figures, data and commentary presented in this report are based on data sourced from the Australia Bureau of Statistics (ABS), most of which relates to the 2016, 2011, 2006 and 2001 Censuses.

Using ABS datasets and an input / output methodology industrial economic data estimates for defined geographic regions are generated.

This report is provided in good faith with every effort made to provide accurate data and apply comprehensive knowledge. However, REMPLAN does not guarantee the accuracy of data nor the conclusions drawn from this information. A decision to pursue any action in any way related to the figures, data and commentary presented in this report is wholly the responsibility of the party concerned. REMPLAN advises any party to conduct detailed feasibility studies and seek professional advice before proceeding with any such action and accept no responsibility for the consequences of pursuing any such action.


Current Operation

Yumbah’s current Kangaroo Island operation generates some $6M in sales (or output). This is estimated to:


• Generate $1.077 million in wages and salaries, and

• Grow Value added within the local economy by $4.110 million



• Generate 60 FTE jobs directly and 25 FTE jobs indirectly within Kangaroo Island’s local economy – this represents a growth of 53 jobs from the current operation

• Generate $5.663 million in wages and salaries– both direct and indirectly – this represents a growth of $3.96 million in wages and salaries within the local economy

• Grow Value added – both direct and indirectly, within the local economy by $13.7 million - this represents a growth of $9.59 million in Value Added within the local economy



• Generate 140 FTE jobs directly and 61 FTE jobs indirectly within Kangaroo Island’s local economy – this represents a growth of : • 116 jobs from Stage 1, and • 169 jobs from the current operation

• Generate $14.16 million in wages and salaries– both direct and indirectly – in the local economy this represents a growth of: • $8.5 million in wages and salaries from Stage 1, and • $12.46 million in wages and salaries from the current operation

• Generate $34.25 in Value added within the local economy- both direct and indirectly - this represents a growth of: • $20.55 million from Stage 1, and • $30.14 million from the current operation

Proposed Tourism Operation

Yumbah propose a tourism offer to be part of their Stage 2 operations and its is estimated that this offer will attract some 15,000 visitors per annum – this aspect of the operation is estimated to generate some $2.48 million in sales (or output) and this output is estimated to:


• Generate $0.53 million in wages and salaries– both direct and indirectly

• Grow Value added – both direct and indirectly, within the local economy by $1.15 million

The above economic impact modelling has been undertaken by REMPLAN with all figures, data and commentary presented in this report are based on data sourced from the Australia Bureau of Statistics (ABS), most of which relates to the 2016, 2011, 2006 and 2001 Censuses.

Using ABS datasets and an input / output methodology industrial economic data estimates for defined geographic regions are generated.

This report is provided in good faith with every effort made to provide accurate data and apply comprehensive knowledge. However, REMPLAN does not guarantee the accuracy of data nor the conclusions drawn from this information. A decision to pursue any action in any way related to the figures, data and commentary presented in this report is wholly the responsibility of the party concerned. REMPLAN advises any party to conduct detailed feasibility studies and seek professional advice before proceeding with any such action and accept no responsibility for the consequences of pursuing any such action.

Summary of Estimated Economic Impacts of Yumbah’s Kangaroo Island Operation on the Kangaroo Island Local Economy

Impact Summary Direct Effect Supply-Chain Effect

Consumption Effect Total Effect

Current KI Operation

Output ($M) $6.00 $1.60 $1.00 $8.59

Employment (Jobs FTE) 25 4 3 32

Wages and Salaries ($M) $1.08 $0.41 $0.22 $1.70

Value-added ($M) $2.80 $0.71 $0.60 $4.11

Stage 1 – Proposed Growth of KI Operation

Output ($M) $20.00 $5.32 $3.32 $28.64



Value-added ($M) $9.33 $2.37 $2.00 $13.70

Change

Current to Stage 1

Output ($M) $14.00 $3.73 $2.32 $20.05



Value-added ($M) $6.53 $1.66 $1.40 $9.59


Output ($M) $50.00 $13.30 $8.29 $71.59



Value-added ($M) $23.32 $5.92 $5.00 $34.25

Change

Stage 1 to Stage 2

Output ($M) $30.00 $7.98 $4.97 $42.96



Value-added ($M) $13.99 $3.55 $3.00 $20.55

Change

Current to Stage 2

Output ($M) $44.00 $11.71 $7.29 $63.00



Value-added ($M) $20.52 $5.21 $4.40 $30.14

Tourism Impact

Output ($M) $1.77 $0.40 $0.31 $2.48



Value-added ($M) $0.77 $0.19 $0.19 $1.15

Estimated FTE Employment Kangaroo Island

Sectors FTE Jobs % of FTE Jobs

Agriculture, Forestry & Fishing

Sheep, Grains, Beef & Dairy Cattle 366 19.50%

Poultry & Other Livestock 51 2.70%

Other Agriculture 29 1.60%

Fishing, Hunting & Trapping 29 1.60%

Forestry & Logging 6 0.30%

Agriculture, Forestry & Fishing Support Services 29 1.60%

Aquaculture 25 1.30%

Accommodation & Food Services 199 10.60%

Construction 173 9.20%

Education & Training 142 7.50%

Transport, Postal & Warehousing 131 7.00%

Health Care & Social Assistance 125 6.60%

Retail Trade 119 6.30%

Public Administration & Safety 105 5.60%

Administrative & Support Services 64 3.40%

Other Services 61 3.20%

Manufacturing 60 3.20%

Professional, Scientific & Technical Services 47 2.50%

Wholesale Trade 40 2.10%

Arts & Recreation Services 34 1.80%

Rental, Hiring & Real Estate Services 16 0.90%

Electricity, Gas, Water & Waste Services 12 0.60%

Financial & Insurance Services 11 0.60%

Information Media & Telecommunications 5 0.30%

Mining 0 0.00%

Total 1,880 100.00%

The increase in FTE jobs generated by the Yumbah’s Stage 2 Expansion represents an 8.9% increase on all current FTE jobs in the Kangaroo Island local economy

Summary of Estimated Economic Impacts of Yumbah’s Kangaroo Island Operation on the Kangaroo Island Local Economy

Impact Summary Direct Effect Supply-Chain Effect

Consumption Effect Total Effect

Current KI Operation

Output ($M) $6.00 $1.60 $1.00 $8.59



Value-added ($M) $2.80 $0.71 $0.60 $4.11


Output ($M) $20.00 $5.32 $3.32 $28.64



Value-added ($M) $9.33 $2.37 $2.00 $13.70

Change

Current to Stage 1

Output ($M) $14.00 $3.73 $2.32 $20.05



Value-added ($M) $6.53 $1.66 $1.40 $9.59


Output ($M) $50.00 $13.30 $8.29 $71.59



Value-added ($M) $23.32 $5.92 $5.00 $34.25

Change

Stage 1 to Stage 2

Output ($M) $30.00 $7.98 $4.97 $42.96



Value-added ($M) $13.99 $3.55 $3.00 $20.55

Change

Current to Stage 2

Output ($M) $44.00 $11.71 $7.29 $63.00



Value-added ($M) $20.52 $5.21 $4.40 $30.14

Tourism Impact

Output ($M) $1.77 $0.40 $0.31 $2.48



Value-added ($M) $0.77 $0.19 $0.19 $1.15

Estimated FTE Employment Kangaroo Island

Sectors FTE Jobs % of FTE Jobs

Agriculture, Forestry & Fishing

Sheep, Grains, Beef & Dairy Cattle 366 19.50%

Poultry & Other Livestock 51 2.70%

Other Agriculture 29 1.60%

Fishing, Hunting & Trapping 29 1.60%

Forestry & Logging 6 0.30%

Agriculture, Forestry & Fishing Support Services 29 1.60%

Aquaculture 25 1.30%

Accommodation & Food Services 199 10.60%

Construction 173 9.20%

Education & Training 142 7.50%

Transport, Postal & Warehousing 131 7.00%

Health Care & Social Assistance 125 6.60%

Retail Trade 119 6.30%

Public Administration & Safety 105 5.60%

Administrative & Support Services 64 3.40%

Other Services 61 3.20%

Manufacturing 60 3.20%

Professional, Scientific & Technical Services 47 2.50%

Wholesale Trade 40 2.10%

Arts & Recreation Services 34 1.80%

Rental, Hiring & Real Estate Services 16 0.90%

Electricity, Gas, Water & Waste Services 12 0.60%

Financial & Insurance Services 11 0.60%

Information Media & Telecommunications 5 0.30%

Mining 0 0.00%

Total 1,880 100.00%

The increase in FTE jobs generated by the Yumbah’s Stage 2 Expansion represents an 8.9% increase on all current FTE jobs in the Kangaroo Island local economy

APPENDIX 6 –

REVIEW OF AIR QUALITY IMPACTSCook

2019

27 May 2019

David Connell Manager Yumbah Kangaroo Island

Our ref: 6137616-2601 Your ref:

Dear David

Smith Bay Aquaculture AssessmentReview of Air Quality Impacts

Yumbah Kangaroo Island (Yumbah KI) requested a review of the predicted Air Quality impacts, inclusive of dust, of the Smith Bay Wharf Draft Environmental Impact Statement (KIPT 2019, hereafter referred to as EIS). This review has focused primarily on Chapter 12 of the EIS.

1 BackgroundKangaroo Island Plantation Timbers (KIPT) is seeking approval to build a deep-water port and associated infrastructure at Smith Bay, from which it proposes to export logs (softwood) and woodchips (hardwood) from its Kangaroo Island plantation forests to overseas markets. The facility is proposed in Smith Bay approximately 20 km west-northwest of the town of Kingscote and 15 km northwest of the Kingscote airport.

The non-marine components of the Seaport include log and woodchip storage areas, a laydown area, materials handling infrastructure (e.g. conveyor), road transport access with ancillary facilities and infrastructure including administration buildings, car parks and security fencing.

The associated in-water structures would include a causeway, suspended jetty, link span bridge, floating pontoon, tug mooring facilities, berthing pocket, and mooring dolphins.

Ancillary services would include electricity, water storage and supply, wastewater and stormwater management facilities, telecommunications, and security.

The project submission is accompanied by multiple documents that contain information on both an operational and construction air quality assessment.

Air Quality impacts are associated with the construction dust and the operational dust (principally wood chip associated particulate matter). The EIS as part of the project submission provides information on both air quality impact pathways. As no wood chipping is planned to be conducted on-site, it is only the material transfer and storage of wood chips that produces fibrous material. However, some (crustal) dust will be generated associated with vehicle movements during operation while the same (non-fibrous) dust types will dominate during construction.


27 May 2019



Dear David

Smith Bay Aquaculture AssessmentReview of Air Quality Impacts

Yumbah Kangaroo Island (Yumbah KI) requested a review of the predicted Air Quality impacts, inclusive of dust, of the Smith Bay Wharf Draft Environmental Impact Statement (KIPT 2019, hereafter referred to as EIS). This review has focused primarily on Chapter 12 of the EIS.

1 BackgroundKangaroo Island Plantation Timbers (KIPT) is seeking approval to build a deep-water port and associated infrastructure at Smith Bay, from which it proposes to export logs (softwood) and woodchips (hardwood) from its Kangaroo Island plantation forests to overseas markets. The facility is proposed in Smith Bay approximately 20 km west-northwest of the town of Kingscote and 15 km northwest of the Kingscote airport.

The non-marine components of the Seaport include log and woodchip storage areas, a laydown area, materials handling infrastructure (e.g. conveyor), road transport access with ancillary facilities and infrastructure including administration buildings, car parks and security fencing.


Ancillary services would include electricity, water storage and supply, wastewater and stormwater management facilities, telecommunications, and security.

The project submission is accompanied by multiple documents that contain information on both an operational and construction air quality assessment.

Air Quality impacts are associated with the construction dust and the operational dust (principally wood chip associated particulate matter). The EIS as part of the project submission provides information on both air quality impact pathways. As no wood chipping is planned to be conducted on-site, it is only the material transfer and storage of wood chips that produces fibrous material. However, some (crustal) dust will be generated associated with vehicle movements during operation while the same (non-fibrous) dust types will dominate during construction.

3 6137616/6137616-LET-0_Review of KIPT EIS Air Quality Impacts.docx

4.1 EIS purpose

Chapter 17 of the EIS Main report (page 373) identifies the scope for the Air Quality assessment in addressing how the “Draft EIS considers the extent to which the expected impacts of the development are consistent with the provisions of any development plan, the South Australian Planning Strategy and any matter prescribed by regulations under the Development Act)” (EIS, p.9). The published guidelines for the EIS process of 6 July 2017 specifically reference (emphasis added) the impact on Yumbah KI:

Guideline 5.2

“Outline the impacts of dust and/or particle generation on the existing commercial operations and any other identified nearby sensitive receivers in the vicinity of the proposed development, in particular the existing abalone farm” (EIS, p.373).

Guideline 5.1 “includes modelling undertaken in accordance with the Environment Protection (Air Quality) Policy 2016 and the Environment Protection Authority’s Ambient Air Quality Assessment 2016 guideline (ibid.). Guideline 5.3 includes “all potential sources of air pollution (especially dust and particulates from transport, unloading, storage and shiploading) will be controlled and monitored, including measures for their reduction or elimination” (ibid.).

4.2 Modelling to Policy and guideline requirements

The author of the EIS air quality assessment has demonstrated competencies in following the SA Environment Protection Authority’s Ambient Air Quality Assessment (2016) guidelines. The guideline, for example, requires an electronic copy of the output text file(s) to be provided. Appendix M provides these. However, the guideline also says that “the EPA recommends that practitioners produce a ‘capability statement’ based on the guide”. This may have been to assist the proponent in selecting a consultant, but that information was not provided in the reporting (with no branding from the consultant within Chapter 17 – even on the figures). A number of assessment choices have been made that raise concerns about the accuracy of the modelling – these are expanded upon below.

A key issue identified in the Executive Summary (p.38) is an assessment against compliance with air quality standards and guidelines with potential effects of dust emissions on neighbours, including Yumbah’s abalone operation. AQ standards, as assessed by the consultant for ‘dust’, really only apply to human health (toxicity as specified in the Air Policy) and amenity (not a reason for classification in the Air Policy – so NSW criterion adopted). These are not very relevant to the abalone farm although they are the requirement for assessing impact at the residential sensitive receptor locations (as done by the consultant).

The guideline (p.10) identifies “Important stages for assessment using air quality modelling” as:

1. Emissions inventory development

2. Consideration of meteorological and terrain effects

3. Modelling using suitable dispersion models

4. Airshed approach (if considering cumulative impacts)

5. Validation of air pollution modelling output

6. Presenting air pollution modelling results


2 Documents consideredThe following documents have been considered during the peer review of the Air Quality EIS chapters, sections and appendix:

Smith Bay Wharf - Draft Environmental Impact Statement Executive Summary, January 2019

Smith Bay Wharf - Draft Environmental Impact Statement Main Report, January 2019

Smith Bay Wharf - Draft Environmental Impact Statement Appendix M – Air Quality: Air Pollution Modelling Outputs, January 2019

SA Environment Protection (Air Quality) Policy 2016

SA Guideline for Ambient air quality assessment, August 2016

Other documents and results of research pertaining to the assessment of air quality are also taken into account (e.g. National Environment Protection (Ambient Air Quality) Measure).

3 Methodology In undertaking this review, consideration has been given to:

The expected character of the air quality impacts during operational and construction phases of the project

The relevant regulatory and technical/scientific documents referenced in section 2

Australian and South Australian Environment Protection Authority (EPA SA) practices in assessing the predicted air quality from projects

The review has taken a risk-based approach and has sought to identify the more important issues where problems might arise. A summary of the key findings from the peer review is provided in section 4. The technical terminology used in this letter is consistent with the terminology used in the air quality related EIS documents reviewed and relevant standards/guidelines/policies.

4 Key findingsThe key findings of the review address the key concern of ‘dust, expressed as (Pers. Comm, Sustainable Project Management, May 2019):

The dust review should “consider the accumulation of dust on the abalone grow out shade cloth”

“The accumulated dust on the grow out shade cloth may be an issue, particularly if rains washes the accumulated dust into the abalone tanks”


4.1 EIS purpose

Chapter 17 of the EIS Main report (page 373) identifies the scope for the Air Quality assessment in addressing how the “Draft EIS considers the extent to which the expected impacts of the development are consistent with the provisions of any development plan, the South Australian Planning Strategy and any matter prescribed by regulations under the Development Act)” (EIS, p.9). The published guidelines for the EIS process of 6 July 2017 specifically reference (emphasis added) the impact on Yumbah KI:

Guideline 5.2

“Outline the impacts of dust and/or particle generation on the existing commercial operations and any other identified nearby sensitive receivers in the vicinity of the proposed development, in particular the existing abalone farm” (EIS, p.373).

Guideline 5.1 “includes modelling undertaken in accordance with the Environment Protection (Air Quality) Policy 2016 and the Environment Protection Authority’s Ambient Air Quality Assessment 2016 guideline (ibid.). Guideline 5.3 includes “all potential sources of air pollution (especially dust and particulates from transport, unloading, storage and shiploading) will be controlled and monitored, including measures for their reduction or elimination” (ibid.).

4.2 Modelling to Policy and guideline requirements

The author of the EIS air quality assessment has demonstrated competencies in following the SA Environment Protection Authority’s Ambient Air Quality Assessment (2016) guidelines. The guideline, for example, requires an electronic copy of the output text file(s) to be provided. Appendix M provides these. However, the guideline also says that “the EPA recommends that practitioners produce a ‘capability statement’ based on the guide”. This may have been to assist the proponent in selecting a consultant, but that information was not provided in the reporting (with no branding from the consultant within Chapter 17 – even on the figures). A number of assessment choices have been made that raise concerns about the accuracy of the modelling – these are expanded upon below.

A key issue identified in the Executive Summary (p.38) is an assessment against compliance with air quality standards and guidelines with potential effects of dust emissions on neighbours, including Yumbah’s abalone operation. AQ standards, as assessed by the consultant for ‘dust’, really only apply to human health (toxicity as specified in the Air Policy) and amenity (not a reason for classification in the Air Policy – so NSW criterion adopted). These are not very relevant to the abalone farm although they are the requirement for assessing impact at the residential sensitive receptor locations (as done by the consultant).

The guideline (p.10) identifies “Important stages for assessment using air quality modelling” as:

1. Emissions inventory development

2. Consideration of meteorological and terrain effects

3. Modelling using suitable dispersion models

4. Airshed approach (if considering cumulative impacts)

5. Validation of air pollution modelling output

6. Presenting air pollution modelling results


2 Documents consideredThe following documents have been considered during the peer review of the Air Quality EIS chapters, sections and appendix:



Smith Bay Wharf - Draft Environmental Impact Statement Appendix M – Air Quality: Air Pollution Modelling Outputs, January 2019

SA Environment Protection (Air Quality) Policy 2016

SA Guideline for Ambient air quality assessment, August 2016

Other documents and results of research pertaining to the assessment of air quality are also taken into account (e.g. National Environment Protection (Ambient Air Quality) Measure).


The expected character of the air quality impacts during operational and construction phases of the project

The relevant regulatory and technical/scientific documents referenced in section 2

Australian and South Australian Environment Protection Authority (EPA SA) practices in assessing the predicted air quality from projects

The review has taken a risk-based approach and has sought to identify the more important issues where problems might arise. A summary of the key findings from the peer review is provided in section 4. The technical terminology used in this letter is consistent with the terminology used in the air quality related EIS documents reviewed and relevant standards/guidelines/policies.

4 Key findingsThe key findings of the review address the key concern of ‘dust, expressed as (Pers. Comm, Sustainable Project Management, May 2019):

The dust review should “consider the accumulation of dust on the abalone grow out shade cloth”

“The accumulated dust on the grow out shade cloth may be an issue, particularly if rains washes the accumulated dust into the abalone tanks”


4.2.1 Emissions inventory developmentTwo emission inventories are required – for construction and operation. In the absence of site-specific data, it is standard procedure to use default NPI emission factors. Such factors are usually based on emission factor estimates for mining operations, and are acceptable for construction activity and vehicle related fugitive dust sources due to operational traffic. However, NPI emission factors are not available for woodchips, otherwise the assumptions made are all on the conservative side. For example, a reasonable assumption around dredge spoil stockpiling is that drying the material out to below 10% moisture is unlikely to occur. Importantly, there is an improvement available to change the emission inventory for wind erosion to being a function of wind speed (rather than just the threshold, and binary, wind speed cut-off) – further compounded by the meteorological modelling by the TAPM model under predicting the wind speed (see also section 4.2.2).

Wind erosion emissions only occur when the winds are high enough and then at the NPI default emission factors. Since the TAPM model has under predicted winds, which is considered overly conservative. The default emission factors (EF's) are wind speed independent. If winds are light, then the particles will not disperse as far. The model is better to be used to have the emission inventory at the default EF's all the time (and allowing the model to disperse accordingly) or adjusting the hour-by-hour EF's according to the emission rate varying as a function of the wind speed.

Dust-generating activities and assumptions for both construction and operations used NPI default emission factors of 4.23 kg of TSP emission per VKT, and 1.25 kg of PM10 particulate per VKT. These are conservative assumptions as the default values assume a vehicle mass of 48 t which is greater than the expected tonnage of loaded and unloaded log/woodchip trucks.

A 75% emission reduction is assumed for vehicle dust emissions on unsealed haul roads. This is due to (mine site) standard level 2 watering of >2 L/m2/hr. This is not stated in the main text but is contained in a table. Such a mitigation measure assumes that this is applied during all hours of operation where vehicles are on unsealed roads. Such a water cart, or even a source of water, may not be available at all times.

A very brave assumption has been made that the handling of woodchips produces the same emissions as 'Log debarking' (USEPA emission factor from the late 1970s). It is further assumed that the PM10 to TSP ratio is the same as for soil/overburden at 50% (and PM2.5 is 10% of TSP). Both of these assumptions have the potential to cause a large error in the accuracy of the predictions.

As woodchip material handling is assumed to occur four times (Table 17-6), the accuracy of this assumption is very important. The total of the assumed emissions of woodchip handling (0.32 g/s of TSP) is of the same order as crustal material emissions of vehicles on unpaved roads (0.8 g/s - controlled by water cart use) and almost as much as wind erosion of the stockpile (0.62 g/s - assumed to be woodchips).


Some rigor has been applied to partition the data into size fractions - but these assume soil characteristics and not fibrous/cellulous material. Wind erosion from the woodchip stockpile has assumed the same default NPI emission factor as that used for mine-site overburden. Further, the deposition modelling assumes a particle density that needs to be different from the other sources - this is not discussed and may have to be re-modelled correctly. Both of these assumptions have the potential to cause an error in the accuracy of the predictions.

4.2.2 Consideration of meteorological and terrain effectsIt is stated that for Kingscote PO and Kingscote Airport the meteorological "data are generally consistent" (EIS, p.378). However, there are differences between the sites, somewhat related to the measurement method (wind) and exposure (temperature and rain).

Because of the distance the airport is inland the "Kingscote Aero is generally warmer during the day and colder at night than the Kingscote" Post Office (EIS, p.378). This questions the assumption that wind data at the Airport are representative of the coastal location. However, differences between the sites are critical as the comparison is done to justify using a slightly inland site at the airport as being representative of a site with a beachhead. It can be assumed that the coastal sites of Smith Bay are more exposed than the Post Office so that the Airport data are the best that can be used to be site-representative. Therefore, measured data from the airport can be used to improve the accuracy of the representativeness of the modelled winds.

A standard procedure, when site-specific data are not available, is to initialise the CALMET (wind) model with a prognostic meteorological model (such as the CSIRO TAPM model). However, it appears that observations from the Airport are not used in either nudging of TAPM or diagnostic correction of CALMET fields. This diminishes the accuracy of the modelling as the comparison done shows that TAPM under predicts the winds (at the reference site of the Airport and by analogy at the subject site), a known artefact of the model. No model settings for the TAPM or CALMET models are provided. It would also have been useful to compare the TAPM predicted winds to the Airport annual wind climate. The methodology of including measured winds, and varying the wind erosion with wind speed, will lead to higher predicted dust impacts.

4.2.3 Modelling using suitable dispersion models“Dispersion modelling was undertaken using the CALMET (meteorology) and CALPUFF (emissions) system of dispersion models” (EIS, p.382). This is consistent with the SA EPA guidelines. Although, CALPUFF is preferred when "for conditions such as coastal fumigation, cold-air drainage or a location with complex terrain" (SA EPA, 2016, p.12). None of these apply here.

"It is important that the complex mechanisms that affect air movements are incorporated into dispersion modelling studies for accurate predictions of dust concentrations" (EIS, p.382). While this is a true statement, it is unlikely to be significant here as the dust sources are close to the critical receptors.


4.2.1 Emissions inventory developmentTwo emission inventories are required – for construction and operation. In the absence of site-specific data, it is standard procedure to use default NPI emission factors. Such factors are usually based on emission factor estimates for mining operations, and are acceptable for construction activity and vehicle related fugitive dust sources due to operational traffic. However, NPI emission factors are not available for woodchips, otherwise the assumptions made are all on the conservative side. For example, a reasonable assumption around dredge spoil stockpiling is that drying the material out to below 10% moisture is unlikely to occur. Importantly, there is an improvement available to change the emission inventory for wind erosion to being a function of wind speed (rather than just the threshold, and binary, wind speed cut-off) – further compounded by the meteorological modelling by the TAPM model under predicting the wind speed (see also section 4.2.2).

Wind erosion emissions only occur when the winds are high enough and then at the NPI default emission factors. Since the TAPM model has under predicted winds, which is considered overly conservative. The default emission factors (EF's) are wind speed independent. If winds are light, then the particles will not disperse as far. The model is better to be used to have the emission inventory at the default EF's all the time (and allowing the model to disperse accordingly) or adjusting the hour-by-hour EF's according to the emission rate varying as a function of the wind speed.

Dust-generating activities and assumptions for both construction and operations used NPI default emission factors of 4.23 kg of TSP emission per VKT, and 1.25 kg of PM10 particulate per VKT. These are conservative assumptions as the default values assume a vehicle mass of 48 t which is greater than the expected tonnage of loaded and unloaded log/woodchip trucks.

A 75% emission reduction is assumed for vehicle dust emissions on unsealed haul roads. This is due to (mine site) standard level 2 watering of >2 L/m2/hr. This is not stated in the main text but is contained in a table. Such a mitigation measure assumes that this is applied during all hours of operation where vehicles are on unsealed roads. Such a water cart, or even a source of water, may not be available at all times.

A very brave assumption has been made that the handling of woodchips produces the same emissions as 'Log debarking' (USEPA emission factor from the late 1970s). It is further assumed that the PM10 to TSP ratio is the same as for soil/overburden at 50% (and PM2.5 is 10% of TSP). Both of these assumptions have the potential to cause a large error in the accuracy of the predictions.

As woodchip material handling is assumed to occur four times (Table 17-6), the accuracy of this assumption is very important. The total of the assumed emissions of woodchip handling (0.32 g/s of TSP) is of the same order as crustal material emissions of vehicles on unpaved roads (0.8 g/s - controlled by water cart use) and almost as much as wind erosion of the stockpile (0.62 g/s - assumed to be woodchips).


Some rigor has been applied to partition the data into size fractions - but these assume soil characteristics and not fibrous/cellulous material. Wind erosion from the woodchip stockpile has assumed the same default NPI emission factor as that used for mine-site overburden. Further, the deposition modelling assumes a particle density that needs to be different from the other sources - this is not discussed and may have to be re-modelled correctly. Both of these assumptions have the potential to cause an error in the accuracy of the predictions.

4.2.2 Consideration of meteorological and terrain effectsIt is stated that for Kingscote PO and Kingscote Airport the meteorological "data are generally consistent" (EIS, p.378). However, there are differences between the sites, somewhat related to the measurement method (wind) and exposure (temperature and rain).

Because of the distance the airport is inland the "Kingscote Aero is generally warmer during the day and colder at night than the Kingscote" Post Office (EIS, p.378). This questions the assumption that wind data at the Airport are representative of the coastal location. However, differences between the sites are critical as the comparison is done to justify using a slightly inland site at the airport as being representative of a site with a beachhead. It can be assumed that the coastal sites of Smith Bay are more exposed than the Post Office so that the Airport data are the best that can be used to be site-representative. Therefore, measured data from the airport can be used to improve the accuracy of the representativeness of the modelled winds.

A standard procedure, when site-specific data are not available, is to initialise the CALMET (wind) model with a prognostic meteorological model (such as the CSIRO TAPM model). However, it appears that observations from the Airport are not used in either nudging of TAPM or diagnostic correction of CALMET fields. This diminishes the accuracy of the modelling as the comparison done shows that TAPM under predicts the winds (at the reference site of the Airport and by analogy at the subject site), a known artefact of the model. No model settings for the TAPM or CALMET models are provided. It would also have been useful to compare the TAPM predicted winds to the Airport annual wind climate. The methodology of including measured winds, and varying the wind erosion with wind speed, will lead to higher predicted dust impacts.

4.2.3 Modelling using suitable dispersion models“Dispersion modelling was undertaken using the CALMET (meteorology) and CALPUFF (emissions) system of dispersion models” (EIS, p.382). This is consistent with the SA EPA guidelines. Although, CALPUFF is preferred when "for conditions such as coastal fumigation, cold-air drainage or a location with complex terrain" (SA EPA, 2016, p.12). None of these apply here.

"It is important that the complex mechanisms that affect air movements are incorporated into dispersion modelling studies for accurate predictions of dust concentrations" (EIS, p.382). While this is a true statement, it is unlikely to be significant here as the dust sources are close to the critical receptors.


4.2.4 Airshed approach (if considering cumulative impacts)“Kangaroo Island has no air quality monitoring stations” (EIS, p.381). It is the incremental change that is critical to the assessment of impacts so it is best to treat the estimated baseline values as indicative only. PM10 and PM2.5 can be used to assess human health exposure. However, as we are concerned with 'ecological-like' impacts of dust deposition into water bodies or the shade-cloth areas of the abalone tanks, the use of these indicators can be ignored.

For the important dust deposition criterion, a background of 2 g/m2/month is assumed as a baseline (not seasonally varying). While this is based on Eyre Peninsula benchmarking, it is consistent with the assumed background/natural deposition rate in the NSW Approved Methods (albeit an overestimation for a coastal site on an island off the mainland).

4.2.5 Validation of air pollution modelling outputThis is not possible for a proposed facility but could have been included as a literature survey of existing woodchip exporting port facilities (e.g. Portland, Geelong, Burnie, Bell Bay). Due the wide range of assumptions around woodchip emission factors (including the particle size distribution being the same between crustal soil and fibrous material), an investigation of particulate matter fallout across port boundaries to residential areas is likely to be more accurate than a modelling approach. For example, the residential areas of Portland are just 150 m from the site boundary and within a 1,500 m threshold distance of the woodchip stockpiling and material handling.

4.2.6 Presenting air pollution modelling results.It is noted that the construction impact is almost the same (slightly lower, 0.3 to 0.4 g/m2/month added to background) as for the operational phase. The increment will be about an order of magnitude lower than background. This is an important finding for construction impacts where it will be all crustal dust, but operationally it will be a mixture of dust and wood fibre.

Assuming that the modelling is accurate enough, the impact of material falling out of the sky onto Yumbah is unlikely to be significantly higher than the assumed background. Despite this estimated result, overestimation of the background particulate matter deposition at a coastal environment is unlikely and would be expected to have less than a default fallout rate of 2 g/m2/month. The latter is adopted from mainland reference projects (and the default value for the NSW Approved Methods criterion) as sea spray salt will be in the soluble portion and the majority of wind directions at the site involve over water fetch.

4.3 Measures to control and monitor

A range of mitigation and management measures are detailed for both construction and operation phases (EIS, p.396). While these are yet to be confirmed by detailed design - all are sensible (except for watering land to be cleared during construction) and would lower the off-site impacts.


The only monitoring proposed is “A series of gauges would be established on the site boundaries to monitor dust deposition rates before and during construction and during operation” (EIS, p.396). It is standard procedure to undertake audit monitoring of impacts (just deposition as PM monitoring not a health issue at Yumbah) along the common boundary so as to enable adjustments to the dust management plan if levels are experienced to be too high. However, this will be too late (as it takes a month to gather a sample and then send to a laboratory for analysis) during construction. Reactive, real-time continuous monitoring between the two sites is a better approach. If elevated levels of dust are detected to cross the boundary, either visually or measured, construction activity should cease. Downtime is only required due to drying conditions involving stronger winds and are likely to be rare enough that activity curtailment does not delay the construction program significantly.

Yours sincerely

Barry CookTechnical Director - Air Quality and Meteorology +61 3 8687 8649


4.2.4 Airshed approach (if considering cumulative impacts)“Kangaroo Island has no air quality monitoring stations” (EIS, p.381). It is the incremental change that is critical to the assessment of impacts so it is best to treat the estimated baseline values as indicative only. PM10 and PM2.5 can be used to assess human health exposure. However, as we are concerned with 'ecological-like' impacts of dust deposition into water bodies or the shade-cloth areas of the abalone tanks, the use of these indicators can be ignored.

For the important dust deposition criterion, a background of 2 g/m2/month is assumed as a baseline (not seasonally varying). While this is based on Eyre Peninsula benchmarking, it is consistent with the assumed background/natural deposition rate in the NSW Approved Methods (albeit an overestimation for a coastal site on an island off the mainland).

4.2.5 Validation of air pollution modelling outputThis is not possible for a proposed facility but could have been included as a literature survey of existing woodchip exporting port facilities (e.g. Portland, Geelong, Burnie, Bell Bay). Due the wide range of assumptions around woodchip emission factors (including the particle size distribution being the same between crustal soil and fibrous material), an investigation of particulate matter fallout across port boundaries to residential areas is likely to be more accurate than a modelling approach. For example, the residential areas of Portland are just 150 m from the site boundary and within a 1,500 m threshold distance of the woodchip stockpiling and material handling.

4.2.6 Presenting air pollution modelling results.It is noted that the construction impact is almost the same (slightly lower, 0.3 to 0.4 g/m2/month added to background) as for the operational phase. The increment will be about an order of magnitude lower than background. This is an important finding for construction impacts where it will be all crustal dust, but operationally it will be a mixture of dust and wood fibre.

Assuming that the modelling is accurate enough, the impact of material falling out of the sky onto Yumbah is unlikely to be significantly higher than the assumed background. Despite this estimated result, overestimation of the background particulate matter deposition at a coastal environment is unlikely and would be expected to have less than a default fallout rate of 2 g/m2/month. The latter is adopted from mainland reference projects (and the default value for the NSW Approved Methods criterion) as sea spray salt will be in the soluble portion and the majority of wind directions at the site involve over water fetch.

4.3 Measures to control and monitor

A range of mitigation and management measures are detailed for both construction and operation phases (EIS, p.396). While these are yet to be confirmed by detailed design - all are sensible (except for watering land to be cleared during construction) and would lower the off-site impacts.


The only monitoring proposed is “A series of gauges would be established on the site boundaries to monitor dust deposition rates before and during construction and during operation” (EIS, p.396). It is standard procedure to undertake audit monitoring of impacts (just deposition as PM monitoring not a health issue at Yumbah) along the common boundary so as to enable adjustments to the dust management plan if levels are experienced to be too high. However, this will be too late (as it takes a month to gather a sample and then send to a laboratory for analysis) during construction. Reactive, real-time continuous monitoring between the two sites is a better approach. If elevated levels of dust are detected to cross the boundary, either visually or measured, construction activity should cease. Downtime is only required due to drying conditions involving stronger winds and are likely to be rare enough that activity curtailment does not delay the construction program significantly.

Yours sincerely

Barry CookTechnical Director - Air Quality and Meteorology +61 3 8687 8649

APPENDIX 7 –

EASEMENTS - CERTIFICATES OF TITLE


The Registrar-General certifies that this Title Register Search displays the recordsmaintained in the Register Book and other notations at the time of searching.

Certificate of Title - Volume 6127 Folio 273Parent Title(s) CT 5870/746

Creating Dealing(s) RTC 12040789

Title Issued 17/12/2013 Edition 2 Edition Issued 24/04/2014

Estate TypeFEE SIMPLE

Registered ProprietorCINEREA PTY. LTD. (ACN: 167 774 058)

OF SE 816 AURORA HOUSE 147 PIRIE STREET ADELAIDE SA 5000

Description of LandALLOTMENT COMPRISING PIECES 51 AND 52 DEPOSITED PLAN 92343IN THE AREA NAMED WISANGERHUNDRED OF MENZIES

EasementsSUBJECT TO EASEMENT(S) OVER THE LAND MARKED A ON DP 92343 TO DISTRIBUTION LESSORCORPORATION (SUBJECT TO LEASE 8890000) (TG 8363477)

SUBJECT TO EASEMENT(S) OVER THE LAND MARKED B ON DP 92343 (RTC 12040789)

TOGETHER WITH EASEMENT(S) OVER THE LAND MARKED J ON DP 92343 (RTC 9234708)

TOGETHER WITH EASEMENT(S) OVER THE LAND MARKED C ON DP 92343 FOR THE TRANSMISSION OFELECTRICITY BY UNDERGROUND CABLE (RTC 12040789)

Schedule of DealingsDealing Number Description

12719258 MORTGAGE TO COMMONWEALTH BANK OF AUSTRALIA (ACN: 123 123 124)

NotationsDealings Affecting Title NIL

Priority Notices NIL

Notations on Plan NIL

Registrar-General's Notes NIL

Administrative Interests NIL

Product Register Search (CT 6127/273)Date/Time 07/02/2018 03:40PMCustomer Reference pmedOrder ID 20180207010162Cost $28.25

Land Services Page 1 of 1Copyright Privacy Disclaimer: www.sailis.sa.gov.au/home/showCopyright www.sailis.sa.gov.au/home/showPrivacyStatement www.sailis.sa.gov.au/home/showDisclaimer

APPENDIX 8 –

REVIEW OF NOISE AND VIBRATIONLenchine

2019

20 May 2019



Dear David

Smith Bay Aquaculture AssessmentNoise & Vibration Review

Yumbah Kangaroo Island (Yumbah KI) requested a review of the predicted noise and vibration impacts of the Smith Bay Wharf Draft Environmental Impact Statement (KIPT 2019, hereafter referred to as EIS). This review has focused primarily on Appendix N of the EIS (KIPT-EIS_Appendix_N_Noise-and-Vibration.pdf).

1 BackgroundKangaroo Island Plantation Timbers (KIPT) is seeking approval to build a deep-water port and associated infrastructure at Smith Bay, from which it proposes to export logs (softwood) and woodchips (hardwood) from its Kangaroo Island plantation forests to overseas markets. The facility is proposed in Smith Bay approximately 20 km west of Kingscote.

The on-land components of the Seaport would include log and woodchip storage areas, a laydown area, materials handling infrastructure (e.g. conveyor), road transport access, and ancillary facilities and infrastructure including administration buildings, car parks, and security fencing.


Ancillary services would include electricity, water storage and supply, wastewater and stormwater management facilities, telecommunications and security.

The project submission is accompanied by multiple documents that contain information on both operational and construction noise and vibration assessments.

2 Documents consideredThe following documents have been considered during the peer review of the Background Noise Monitoring Report:



Smith Bay Wharf - Draft Environmental Impact Statement Appendix N- Noise and Vibration: Environmental Noise Impact Assessment, Resonate 17 Dec. 2018


20 May 2019



Dear David

Smith Bay Aquaculture AssessmentNoise & Vibration Review

Yumbah Kangaroo Island (Yumbah KI) requested a review of the predicted noise and vibration impacts of the Smith Bay Wharf Draft Environmental Impact Statement (KIPT 2019, hereafter referred to as EIS). This review has focused primarily on Appendix N of the EIS (KIPT-EIS_Appendix_N_Noise-and-Vibration.pdf).

1 BackgroundKangaroo Island Plantation Timbers (KIPT) is seeking approval to build a deep-water port and associated infrastructure at Smith Bay, from which it proposes to export logs (softwood) and woodchips (hardwood) from its Kangaroo Island plantation forests to overseas markets. The facility is proposed in Smith Bay approximately 20 km west of Kingscote.

The on-land components of the Seaport would include log and woodchip storage areas, a laydown area, materials handling infrastructure (e.g. conveyor), road transport access, and ancillary facilities and infrastructure including administration buildings, car parks, and security fencing.


Ancillary services would include electricity, water storage and supply, wastewater and stormwater management facilities, telecommunications and security.

The project submission is accompanied by multiple documents that contain information on both operational and construction noise and vibration assessments.

2 Documents consideredThe following documents have been considered during the peer review of the Background Noise Monitoring Report:



Smith Bay Wharf - Draft Environmental Impact Statement Appendix N- Noise and Vibration: Environmental Noise Impact Assessment, Resonate 17 Dec. 2018

2 6137616/6137616 LET-Smith Bay Noise Vibration Review May 2019.docx

SA Environment Protection (Noise) Policy 2007

SA Guidelines for the Use of the Environment Protection (Noise) Policy 2007

SA DPTI Underwater Piling Noise Guidelines 2012

SA DPTI Road Traffic Noise Guidelines 2016

Other documents and results of research pertaining to the assessment of airborne underwater noise and vibration are also taken into account.


The expected character of the noise and vibration impacts during operational and construction phases of the project.

The relevant regulatory and technical/scientific documents referenced in the previous section.

Australian and international practices in assessing onshore and offshore noise and vibration.

The review has taken a risk-based approach and has sought to identify the more important issues where problems might arise. A summary of the key findings from the peer review is provided in section 4. The acoustic terminology used in this letter is consistent with the terminology used in the acoustic report reviewed and relevant standards.

4 Key findingsThe key findings of the review are:

The SA Environment Protection (Noise) Policy 2007 (SA Noise EPP) contains procedures to derive permissible noise levels for operational noise from developments and during construction. Applicable noise limits for the development have been derived correctly and the approach used in the main report and other documents is in line with the SA Noise EPP and other relevant regulatory documents.

Formally there are no noise limits for construction activities during the day time period. The report appears to have based its conclusion on meeting construction noise limits on the assumption that there will only be day time construction activities carried out. There has been no actual assessment of construction noise undertaken. If the proponent intends to carry out construction during the night period, a more in-depth assessment should be performed and included into the submitted documents.

The main report contains a shorter version of the findings of the noise assessment report (Appendix N) and does not contain an assessment of the efficiency of noise mitigation measures. Information in the main report does not align with the acoustic report and the information in the main report does not reflect the recommendations found in the acoustic report around what noise mitigation measures should be implemented to meet the relevant noise criteria at the nearest residential receivers.


Operational noise from the development is not expected to meet the applicable criteria at the abalone farm. The SA Noise EPP contains provisions for situations where a development is not expected to comply with limits in the policy, as is the case with the proposed development. Therefore, it is desirable to expand the acoustic report to show that meeting applicable noise limits at the receivers R1 and R3 is not reasonable and practicable providing a better explanation as to why a reduction of the noise levels down to the applicable limits is not reasonable and practicable. Such analysis does not form a part of the current report.

SA Noise EPP and Guidelines contain procedures for noise acquisition that require removal of erroneous data from noise estimates acquired during adverse environmental conditions. There is no clarity on how it was done and whether local wind speed was monitored during the background. A separate section on the weather data used in the assessment should be included in the report and further clarification on the data filtering that has been undertaken should be included. It should be noted that under SA Noise EPP the criteria does not depend on the pre-existing background level but rather on the zoning of the noise source and the relevant receivers.

Consideration should be given to the adverse environmental conditions that were present during the noise monitoring period. The reported data should be corrected to take into account periods of rain and high wind speeds. The acoustic report should have a weather analysis section for this.

A traffic noise assessment is a relatively complex task. Summaries of the study are included in the main report and the executive summary. However there are no details of the assessment in the acoustic report or any of the other available documents. Findings of the assessment in the main report and executive summary consider traffic noise associated with the development. They state that it complies with requirements in the DPTI Road Traffic Noise Guidelines. Details of the traffic inputs relevant to predicting noise impact are not provided in the considered documents. Method of the traffic noise predictions, locations of affected receivers, predicted traffic noise levels and other relevant information should be included as a part of the acoustic report or in other submission documents.

Yours sincerely

Val LenchineTechnical Director- Noise & Vibration +61 3 8687 8710

Attachment: Tabulated comments – EIS Tracker Acoutics.xlsx


SA Environment Protection (Noise) Policy 2007

SA Guidelines for the Use of the Environment Protection (Noise) Policy 2007

SA DPTI Underwater Piling Noise Guidelines 2012

SA DPTI Road Traffic Noise Guidelines 2016

Other documents and results of research pertaining to the assessment of airborne underwater noise and vibration are also taken into account.


The expected character of the noise and vibration impacts during operational and construction phases of the project.

The relevant regulatory and technical/scientific documents referenced in the previous section.

Australian and international practices in assessing onshore and offshore noise and vibration.

The review has taken a risk-based approach and has sought to identify the more important issues where problems might arise. A summary of the key findings from the peer review is provided in section 4. The acoustic terminology used in this letter is consistent with the terminology used in the acoustic report reviewed and relevant standards.

4 Key findingsThe key findings of the review are:

The SA Environment Protection (Noise) Policy 2007 (SA Noise EPP) contains procedures to derive permissible noise levels for operational noise from developments and during construction. Applicable noise limits for the development have been derived correctly and the approach used in the main report and other documents is in line with the SA Noise EPP and other relevant regulatory documents.

Formally there are no noise limits for construction activities during the day time period. The report appears to have based its conclusion on meeting construction noise limits on the assumption that there will only be day time construction activities carried out. There has been no actual assessment of construction noise undertaken. If the proponent intends to carry out construction during the night period, a more in-depth assessment should be performed and included into the submitted documents.

The main report contains a shorter version of the findings of the noise assessment report (Appendix N) and does not contain an assessment of the efficiency of noise mitigation measures. Information in the main report does not align with the acoustic report and the information in the main report does not reflect the recommendations found in the acoustic report around what noise mitigation measures should be implemented to meet the relevant noise criteria at the nearest residential receivers.


Operational noise from the development is not expected to meet the applicable criteria at the abalone farm. The SA Noise EPP contains provisions for situations where a development is not expected to comply with limits in the policy, as is the case with the proposed development. Therefore, it is desirable to expand the acoustic report to show that meeting applicable noise limits at the receivers R1 and R3 is not reasonable and practicable providing a better explanation as to why a reduction of the noise levels down to the applicable limits is not reasonable and practicable. Such analysis does not form a part of the current report.

SA Noise EPP and Guidelines contain procedures for noise acquisition that require removal of erroneous data from noise estimates acquired during adverse environmental conditions. There is no clarity on how it was done and whether local wind speed was monitored during the background. A separate section on the weather data used in the assessment should be included in the report and further clarification on the data filtering that has been undertaken should be included. It should be noted that under SA Noise EPP the criteria does not depend on the pre-existing background level but rather on the zoning of the noise source and the relevant receivers.

Consideration should be given to the adverse environmental conditions that were present during the noise monitoring period. The reported data should be corrected to take into account periods of rain and high wind speeds. The acoustic report should have a weather analysis section for this.

A traffic noise assessment is a relatively complex task. Summaries of the study are included in the main report and the executive summary. However there are no details of the assessment in the acoustic report or any of the other available documents. Findings of the assessment in the main report and executive summary consider traffic noise associated with the development. They state that it complies with requirements in the DPTI Road Traffic Noise Guidelines. Details of the traffic inputs relevant to predicting noise impact are not provided in the considered documents. Method of the traffic noise predictions, locations of affected receivers, predicted traffic noise levels and other relevant information should be included as a part of the acoustic report or in other submission documents.

Yours sincerely

Val LenchineTechnical Director- Noise & Vibration +61 3 8687 8710

Attachment: Tabulated comments – EIS Tracker Acoutics.xlsx

APPENDIX 9 –

AUSOCEAN MARINE ECOLOGY REPORT2019

Australian Ocean Lab

SMITH BAY MARINE ECOLOGY REPORT

(AusOcean)


Australian Ocean Lab


(AusOcean)


A report prepared for AusOcean

by Ms Catherine Larkin

Marine Biologist

Smith Bay Marine Ecology Report 3

Copyright

Copyright © The Australian Ocean Laboratory Limited (AusOcean) 2019.

The information contained herein is licensed under a Creative Commons Attribution 3.0 Australia License (http://creativecommons.org/licences/by/3.0/au).


A report prepared for AusOcean

by Ms Catherine Larkin

Marine Biologist


Copyright

Copyright © The Australian Ocean Laboratory Limited (AusOcean) 2019.

The information contained herein is licensed under a Creative Commons Attribution 3.0 Australia License (http://creativecommons.org/licences/by/3.0/au).


Acknowledgements A big thanks to the AusOcean expedition crew for both enjoyable and productive expeditions.

It was valuable to have a multidisiplinary team of engineers and scientists that worked so well

together. Thanks also to Dave Muirhead from the Marine Life Society of South Australia for

joining two expeditions. Your marine expertise, your insight and knowledge of marine species

and marine ecology helped immensely.

We would also like to thank molecular biologist and on-board syngnathid expert Graham

Short from the California Academy of Sciences for joining our third expedition. Your

knowledge and expertise all things syngnathid was invaluable. Finally, thanks also to

AusOcean intern Trek Hopton for his wonderful underwater photos.


Contents

Copyright .................................................................................................................................... 3

Acknowledgements .................................................................................................................... 4

Tables and Figures ..................................................................................................................... 6

Foreword .................................................................................................................................... 7

Introduction ............................................................................................................................... 9

Methods ................................................................................................................................... 11

Results ...................................................................................................................................... 14

Species of Conservation Significance ....................................................................................... 19

Discussion................................................................................................................................. 23

Limitations................................................................................................................................ 26

Conclusions and Future Research ............................................................................................ 27

References ............................................................................................................................... 28

Appendices ............................................................................................................................... 32


Acknowledgements A big thanks to the AusOcean expedition crew for both enjoyable and productive expeditions.

It was valuable to have a multidisiplinary team of engineers and scientists that worked so well

together. Thanks also to Dave Muirhead from the Marine Life Society of South Australia for

joining two expeditions. Your marine expertise, your insight and knowledge of marine species

and marine ecology helped immensely.

We would also like to thank molecular biologist and on-board syngnathid expert Graham

Short from the California Academy of Sciences for joining our third expedition. Your

knowledge and expertise all things syngnathid was invaluable. Finally, thanks also to

AusOcean intern Trek Hopton for his wonderful underwater photos.


Contents

Copyright .................................................................................................................................... 3

Acknowledgements .................................................................................................................... 4

Tables and Figures ..................................................................................................................... 6

Foreword .................................................................................................................................... 7

Introduction ............................................................................................................................... 9

Methods ................................................................................................................................... 11

Results ...................................................................................................................................... 14

Species of Conservation Significance ....................................................................................... 19

Discussion................................................................................................................................. 23

Limitations................................................................................................................................ 26

Conclusions and Future Research ............................................................................................ 27

References ............................................................................................................................... 28

Appendices ............................................................................................................................... 32


Foreword

I learned to dive in the cold, clear waters of the Monterey Bay, California, and for that I am

very grateful. Had I learned in warmer waters, I might never have donned a 7mm-thick

wetsuit. Many divers never experience the wonders of temperate waters, eschewing them

for the tropical coral reefs that attract so much media and research attention. Yet temperate

waters hold a great diversity of marine life and few more so than the waters of southern

Australia, increasingly referred to as the Great Southern Reef (GSR). Unlike tropical reefs in

which species are distributed globally, 90% of species found in the Great Southern Reef are

endemic to southern Australia, and what marvellous creatures they are; from the colony-

forming bryozoans that rival corals in their fantastic shapes and colours, to those masters of

camouflage, the stunning seadragons. These are not cosmopolitan species that might just as

easily pop up on the Great Barrier Reef (GBR) as a reef in Belize, The Maldives or The

Philippines. These are marine species that are native to Australia and geographical isolation

has confined them to our waters. They are as much a part of the Australia’s wonderful natural

heritage as our unique terrestrial wildlife.

Kangaroo Island's marine environment is particularly significant as it encompasses semi-

protected Gulf waters, unprotected Southern Ocean waters and areas of confluence between

the two. While several marine studies have been conducted over the years, generally these

have been quite sparse in their geographical coverage. During the summer of 2018-2019

AusOcean therefore embarked upon a series of expeditions to intensively study Smith Bay on

the North Coast of Kangaroo Island. This bay was chosen for two reasons. Firstly, it is the

location of a proposed port, and it therefore seemed prudent to study a place that might be

impacted by development. Secondly, preliminary work suggested that Smith Bay would

present a great range of benthic environments, namely sandy seafloor, rocky reef, dense

seagrass, kelp and combinations of all of the above.


Tables and Figures

Table 1: Focal species of Kangaroo Island. .............................................................................. 10

Table 2: Number of transects at sites ...................................................................................... 11

Table 3: Area ecology of each site ........................................................................................... 14

Table 4: Frequency of Occurrence (FOO) of the most commonly sighted species. ................ 15

Table 5: Most abundant fish and invertebrate species. .......................................................... 18

Figure 1: Map of survey locations and image of Smith Bay facing east. ................................. 12

Figure 2: Frequency of Occurrence of fish and invertebrate species ...................................... 16

Figure 3: Total species at each site .......................................................................................... 17

Figure 4: Fish and invertebrate species occurring in each site ................................................ 17

Figure 5: Total number of fish and invertebrates recorded at each site ................................ 18

Plate 1: Divers preparing to survey.......................................................................................... 13

Plate 2: Divers conducting reef life surveys ............................................................................. 13

Plate 3: Senator wrasse - Pictilabrus laticlavius ...................................................................... 16

Plate 4: Western slatepencil urchin - Phyllacanthus irregularis .............................................. 16

Plate 5: Weedy seadragon - Phyllopteryx taeniolatus ............................................................. 20

Plate 6: Mother of pearl pipefish – Vanacampus margaritifer ............................................... 20

Plate 7: Western Blue groper - Achoerodus gouldii ................................................................ 21

Plate 8: Longsnout boarfish – Pentaceropsis recurvirostris ..................................................... 21

Plate 9: Southern blue devil – Paraplesiops meleagris............................................................ 21

Plate 10: Coral - Plesiastrea versipora ..................................................................................... 22

Plate 11: Diver surveying coral ................................................................................................ 22


Foreword

I learned to dive in the cold, clear waters of the Monterey Bay, California, and for that I am

very grateful. Had I learned in warmer waters, I might never have donned a 7mm-thick

wetsuit. Many divers never experience the wonders of temperate waters, eschewing them

for the tropical coral reefs that attract so much media and research attention. Yet temperate

waters hold a great diversity of marine life and few more so than the waters of southern

Australia, increasingly referred to as the Great Southern Reef (GSR). Unlike tropical reefs in

which species are distributed globally, 90% of species found in the Great Southern Reef are

endemic to southern Australia, and what marvellous creatures they are; from the colony-

forming bryozoans that rival corals in their fantastic shapes and colours, to those masters of

camouflage, the stunning seadragons. These are not cosmopolitan species that might just as

easily pop up on the Great Barrier Reef (GBR) as a reef in Belize, The Maldives or The

Philippines. These are marine species that are native to Australia and geographical isolation

has confined them to our waters. They are as much a part of the Australia’s wonderful natural

heritage as our unique terrestrial wildlife.

Kangaroo Island's marine environment is particularly significant as it encompasses semi-

protected Gulf waters, unprotected Southern Ocean waters and areas of confluence between

the two. While several marine studies have been conducted over the years, generally these

have been quite sparse in their geographical coverage. During the summer of 2018-2019

AusOcean therefore embarked upon a series of expeditions to intensively study Smith Bay on

the North Coast of Kangaroo Island. This bay was chosen for two reasons. Firstly, it is the

location of a proposed port, and it therefore seemed prudent to study a place that might be

impacted by development. Secondly, preliminary work suggested that Smith Bay would

present a great range of benthic environments, namely sandy seafloor, rocky reef, dense

seagrass, kelp and combinations of all of the above.


Tables and Figures

Table 1: Focal species of Kangaroo Island. .............................................................................. 10

Table 2: Number of transects at sites ...................................................................................... 11

Table 3: Area ecology of each site ........................................................................................... 14

Table 4: Frequency of Occurrence (FOO) of the most commonly sighted species. ................ 15

Table 5: Most abundant fish and invertebrate species. .......................................................... 18

Figure 1: Map of survey locations and image of Smith Bay facing east. ................................. 12

Figure 2: Frequency of Occurrence of fish and invertebrate species ...................................... 16

Figure 3: Total species at each site .......................................................................................... 17

Figure 4: Fish and invertebrate species occurring in each site ................................................ 17

Figure 5: Total number of fish and invertebrates recorded at each site ................................ 18

Plate 1: Divers preparing to survey.......................................................................................... 13

Plate 2: Divers conducting reef life surveys ............................................................................. 13

Plate 3: Senator wrasse - Pictilabrus laticlavius ...................................................................... 16

Plate 4: Western slatepencil urchin - Phyllacanthus irregularis .............................................. 16

Plate 5: Weedy seadragon - Phyllopteryx taeniolatus ............................................................. 20

Plate 6: Mother of pearl pipefish – Vanacampus margaritifer ............................................... 20

Plate 7: Western Blue groper - Achoerodus gouldii ................................................................ 21

Plate 8: Longsnout boarfish – Pentaceropsis recurvirostris ..................................................... 21

Plate 9: Southern blue devil – Paraplesiops meleagris............................................................ 21

Plate 10: Coral - Plesiastrea versipora ..................................................................................... 22

Plate 11: Diver surveying coral ................................................................................................ 22


As such, it would represent a microcosm of the marine environment of Kangaroo Island’s

North Coast. We anticipated that such a range of habitats would foster good species diversity.

We were not disappointed.

Prof. Alan Noble

Founder, AusOcean

B.Eng. (Hons) (Adelaide), M.S. (A.I.) (Stanford), Fellow, Engineers Australia


Introduction

Kangaroo Island (KI) is uniquely situated at the confluence of several oceanographic systems

(Kinloch, 2005). This unique positioning and, the effects of the warm waters of the Leeuwin

current have a profound influence on marine assemblages (Middleton & Bye 2007). The

northern coastline comprises a mixture of macroalgal (“seaweeds” such as kelp) dominated

rocky reef systems and dense seagrass communities. These systems form part of the wider

Great Southern Reef (GSR) spanning the entire southern coastline of the Australian continent

(Bennett et al. 2015). In addition to the many significant economic and social benefits, these

systems provide key ecological services such as nutrient cycling, sediment stabilisation,

enhanced biodiversity, trophic transfers and carbon sequestration (Orth et al. 2006; Smale et

al. 2013).

KI’s marine environment exhibits high species richness and endemism supporting an

abundance of emblematic and threatened species with high conservation value such as the

Leafy sea dragon (Phycodurus eques), the Western blue groper (Achoerodus gouldii), Blue

devil (Paraplesiops meleagris) and Harlequin fish (Othos dentex) (McArdle et al. 2015,

Reinhold et al. 2013). KI’s coastline provides unique habitat that is paramount for the

existence and longevity of these species, whose numbers have declined significantly

elsewhere. Additionally, valuable commercial fisheries such as Yumbah aquaculture- the

world’s largest exporter of Greenlip abalone and the Rock lobster industry rely heavily on the

local environment for quality production.

Eleven species of fish and one invertebrate are listed as ‘in peril’ by the SA conservation

Council (Reef Watch, 2018). These species are known to frequent South Australian waters and

have been previously noted on KI (McArdle et al. 2015, Reinhold et al. 2013, Shepherd et al.

2009). The Western blue groper is listed as Vulnerable on the IUCN red list of threatened

species (Choat et al., 2010) and the giant cuttlefish is listed as Near threatened with

populations declining drastically since the turn of the century (Prowse et al. 2015) (table 1).

All members of the Syngnathidae family (seahorses, sea-dragons and pipefish) are listed as

protected species under the Australian Commonwealth’s Environmental Protection and

Biodiversity Conservation (EPBC) Act (1999).


As such, it would represent a microcosm of the marine environment of Kangaroo Island’s

North Coast. We anticipated that such a range of habitats would foster good species diversity.

We were not disappointed.

Prof. Alan Noble

Founder, AusOcean

B.Eng. (Hons) (Adelaide), M.S. (A.I.) (Stanford), Fellow, Engineers Australia


Introduction

Kangaroo Island (KI) is uniquely situated at the confluence of several oceanographic systems

(Kinloch, 2005). This unique positioning and, the effects of the warm waters of the Leeuwin

current have a profound influence on marine assemblages (Middleton & Bye 2007). The

northern coastline comprises a mixture of macroalgal (“seaweeds” such as kelp) dominated

rocky reef systems and dense seagrass communities. These systems form part of the wider

Great Southern Reef (GSR) spanning the entire southern coastline of the Australian continent

(Bennett et al. 2015). In addition to the many significant economic and social benefits, these

systems provide key ecological services such as nutrient cycling, sediment stabilisation,

enhanced biodiversity, trophic transfers and carbon sequestration (Orth et al. 2006; Smale et

al. 2013).

KI’s marine environment exhibits high species richness and endemism supporting an

abundance of emblematic and threatened species with high conservation value such as the

Leafy sea dragon (Phycodurus eques), the Western blue groper (Achoerodus gouldii), Blue

devil (Paraplesiops meleagris) and Harlequin fish (Othos dentex) (McArdle et al. 2015,

Reinhold et al. 2013). KI’s coastline provides unique habitat that is paramount for the

existence and longevity of these species, whose numbers have declined significantly

elsewhere. Additionally, valuable commercial fisheries such as Yumbah aquaculture- the

world’s largest exporter of Greenlip abalone and the Rock lobster industry rely heavily on the

local environment for quality production.

Eleven species of fish and one invertebrate are listed as ‘in peril’ by the SA conservation

Council (Reef Watch, 2018). These species are known to frequent South Australian waters and

have been previously noted on KI (McArdle et al. 2015, Reinhold et al. 2013, Shepherd et al.

2009). The Western blue groper is listed as Vulnerable on the IUCN red list of threatened

species (Choat et al., 2010) and the giant cuttlefish is listed as Near threatened with

populations declining drastically since the turn of the century (Prowse et al. 2015) (table 1).

All members of the Syngnathidae family (seahorses, sea-dragons and pipefish) are listed as

protected species under the Australian Commonwealth’s Environmental Protection and

Biodiversity Conservation (EPBC) Act (1999).


Table 1: Focal species of Kangaroo Island.

Southern Australia’s marine macroalgal flora has the highest levels of species richness and

endemism of any regional macroalgal flora in the world (Phillips 2001). However, despite their

intrinsic and economic value, temperate reef systems are often overlooked by their tropical

reef counterparts. A defining feature of these reef systems is the kelp (Ecklonia Radiata),

which is largely supported by neighbouring seagrass systems that facilitate both reef

interconnectivity (Heck et al. 2008; Ricart et al. 2015) and provide important ‘nursery’ areas

for fishes (Jenkins and Wheatley 1998; McDevitt-Irwin et al. 2016). In South Australia,

seagrass habitats are protected under the Native Vegetation Act (1991).

Current levels of both scientific and public engagement threaten the health and longevity of

these significant systems (Bennett et al. 2015). As part of AusOcean’s first expedition to KI’s

north coast, Smith Bay was selected as an appropriate site for a comprehensive marine life

survey due to both its high diversity of flora and fauna and unique variety of habitats.

Although a number of both scientific and community-based programs have conducted

surveys along the north coast of KI collecting baseline data on fish, invertebrate and algae

communities for long term reef health monitoring (McArdle et al. 2015, Reinhold et al. 2013,

Scorseby & Baker 2008), Smith Bay remains relatively lightly studied.

Conservation Value Commercial Value

Western blue groper Southern rock lobster

Southern blue devil Greenlip abalone

Harlequin fish Blacklip abalone

Queen snapper

Long-snout boarfish

Leafy sea dragon

Weedy sea dragon

Spotted wobbegong

Gulf wobbegong

Cobbler wobbegong

Black cowrie

Giant cuttlefish


Methods Ten survey locations within Smith Bay on the northern coast of Kangaroo Island were selected

for marine life surveys (figure 1). Sites were strategically selected to encompass both the

eastern and western sides of the bay and deeper waters located more centrally (table 2).

Survey data was collected on two dive trips in December of 2018 and one in February of 2019.

All dives were off a boat and undertaken during daylight hours.

Standardised Reef Life Survey (RLS) methods were adapted to gather substrate, fish and

invertebrate species composition and abundance data at each site (Reef Life Survey

Foundation 2013). The standard RLS method involves laying out 50m long transects along

continuous depth contours to assess reef biodiversity. A complete survey consists of the

following components:

Photo quadrats taken at 2.5m intervals along the transect line (20 per 50m transect). Fish surveyed in two 5m wide by 5m high bands parallel with the transect line. Cryptic fish and large (>2.5cm) macroinvertebrate (mollusc, echinoderm and

crustacean) searches in 1m wide by 2m high bands either side of the transect line.

Each survey location was located >200m apart. Multiple transects within a survey location

were located within 50m of each other. The only sites in which transects were not undertaken

was Smith Bay North (N) and North Central (NC) as they did not adhere to the requirements

of the RLS methods. However, location species was noted via an area ‘swim around’.

Therefore, these sites have been excluded from the main data analysis but are included in

Appendix 1. Species identifications were supported by - Fishes of Australia’s Southern Coast

(Gomon et al., 2008).

Table 2: Number of transects at sites.

Smith Bay No of transects East Rocks (ER) 1 East (E) 2 East Shore (ES) 2 North Central (NC) N/A North (N) N/A Creek Channel (C) 1 West Central (WC) 2 West Shore (WS) 2 West (W) 2 West Rocks (WR) 2


Table 1: Focal species of Kangaroo Island.

Southern Australia’s marine macroalgal flora has the highest levels of species richness and

endemism of any regional macroalgal flora in the world (Phillips 2001). However, despite their

intrinsic and economic value, temperate reef systems are often overlooked by their tropical

reef counterparts. A defining feature of these reef systems is the kelp (Ecklonia Radiata),

which is largely supported by neighbouring seagrass systems that facilitate both reef

interconnectivity (Heck et al. 2008; Ricart et al. 2015) and provide important ‘nursery’ areas

for fishes (Jenkins and Wheatley 1998; McDevitt-Irwin et al. 2016). In South Australia,

seagrass habitats are protected under the Native Vegetation Act (1991).

Current levels of both scientific and public engagement threaten the health and longevity of

these significant systems (Bennett et al. 2015). As part of AusOcean’s first expedition to KI’s

north coast, Smith Bay was selected as an appropriate site for a comprehensive marine life

survey due to both its high diversity of flora and fauna and unique variety of habitats.

Although a number of both scientific and community-based programs have conducted

surveys along the north coast of KI collecting baseline data on fish, invertebrate and algae

communities for long term reef health monitoring (McArdle et al. 2015, Reinhold et al. 2013,

Scorseby & Baker 2008), Smith Bay remains relatively lightly studied.

Conservation Value Commercial Value

Western blue groper Southern rock lobster

Southern blue devil Greenlip abalone

Harlequin fish Blacklip abalone

Queen snapper

Long-snout boarfish

Leafy sea dragon

Weedy sea dragon

Spotted wobbegong

Gulf wobbegong

Cobbler wobbegong

Black cowrie

Giant cuttlefish


Methods Ten survey locations within Smith Bay on the northern coast of Kangaroo Island were selected

for marine life surveys (figure 1). Sites were strategically selected to encompass both the

eastern and western sides of the bay and deeper waters located more centrally (table 2).

Survey data was collected on two dive trips in December of 2018 and one in February of 2019.

All dives were off a boat and undertaken during daylight hours.

Standardised Reef Life Survey (RLS) methods were adapted to gather substrate, fish and

invertebrate species composition and abundance data at each site (Reef Life Survey

Foundation 2013). The standard RLS method involves laying out 50m long transects along

continuous depth contours to assess reef biodiversity. A complete survey consists of the

following components:

Photo quadrats taken at 2.5m intervals along the transect line (20 per 50m transect). Fish surveyed in two 5m wide by 5m high bands parallel with the transect line. Cryptic fish and large (>2.5cm) macroinvertebrate (mollusc, echinoderm and

crustacean) searches in 1m wide by 2m high bands either side of the transect line.

Each survey location was located >200m apart. Multiple transects within a survey location

were located within 50m of each other. The only sites in which transects were not undertaken

was Smith Bay North (N) and North Central (NC) as they did not adhere to the requirements

of the RLS methods. However, location species was noted via an area ‘swim around’.

Therefore, these sites have been excluded from the main data analysis but are included in

Appendix 1. Species identifications were supported by - Fishes of Australia’s Southern Coast

(Gomon et al., 2008).

Table 2: Number of transects at sites.

Smith Bay No of transects East Rocks (ER) 1 East (E) 2 East Shore (ES) 2 North Central (NC) N/A North (N) N/A Creek Channel (C) 1 West Central (WC) 2 West Shore (WS) 2 West (W) 2 West Rocks (WR) 2


Figure 1: Map of survey locations and image of Smith Bay facing east.

ER

N

E

WR

C

W E

E

WC WS

Smith Bay

ES

E

NC

E


Plate 1: Divers preparing to survey.

Plate 2: Divers conducting reef life surveys.


Figure 1: Map of survey locations and image of Smith Bay facing east.

ER

N

E

WR

C

W E

E

WC WS

Smith Bay

ES

E

NC

E


Plate 1: Divers preparing to survey.

Plate 2: Divers conducting reef life surveys.


Results

Smith Bay is comprised of mixed rocky reef, dense seagrass and sponge habitat. Rocky reefs

were dominated by macroalgal assemblages comprising Cystophora spp., Sargassum spp.,

and Ecklonia radiata with interstitial patches of Posidonia spp., Amphibolis spp. and Zostera

nigricaulis seagrasses. Rocky reef habitat sites were often covered in the brown alga

Lobophora variegate. Survey locations have been grouped together in relation to their area

ecology (table 3). East Rocks, East shore and West Shore had much higher macroalgal cover

in comparison to other sites which consisted of mixed seagrass, rocky reef and sponge with

areas of bare sand. The northern sites substrate comprised of bare sand, shell fragments and

rhodoliths (Sporolithon durum) with interspersed patches of seagrass, rocky reef and sponge.

It is worth noting that although the habitat at these deeper-water sites was somewhat

fragmented, supporting less dense canopies, a number of macroalgae species including

Scaberia aghardii and several species of Cystophora and Sargassum were noted (table 3).

Table 3: Area ecology of each site. Site Area Ecology Image East Rocks East Shore West Shore

Dense macroalgae covered rocky reef.

East West Rocks

Mixed macroalgae covered rocky reef and seagrass.


West Creek Channel West Central

Mixed sponge/seagrass and patches of macroalgae covered rocky reef.

North North Central

Rubble and shell fragments with mixed seagrass/sponge and patches of rocky reef.

Across all surveyed sites within Smith Bay, 55 species of fish and 35 species of invertebrates

were noted, comprising 1124 individuals (902 fish and 222 invertebrates). Of these, 539 fish

and 162 invertebrates were noted within transects. Where multiple transects were

undertaken, data has been collated to assess each site. It should be noted that the scallop

count from the both North and North Central has been excluded due to their occurrence in

large abundances and lack of formal transects.

The Senator wrasse was the most commonly occurring species appearing at all sites followed

by the Blue throat wrasse at 7 sites and the Blackspotted wrasse at 6 sites (table 4). The most

frequently occurring invertebrates were the Western slatepencil urchin at 6 sites and both

the Painted lady mollusc and the Biscuit star noted at 5 sites (table 4).

Table 4: Frequency of Occurrence (FOO) of the most commonly sighted species.

Fish Species (FOO) Invertebrate Species (FOO) Senator Wrasse (8) Western slate pencil urchin (6) Blue throat Wrasse (7) Painted lady (5) Black-spotted Wrasse (6) Biscuit Star (5) Castelnau’s wrasse (5) Dusky Morwong, Pencil weed whiting, Magpie perch, Yellow-headed hula fish, Toadfish (4)


Results

Smith Bay is comprised of mixed rocky reef, dense seagrass and sponge habitat. Rocky reefs

were dominated by macroalgal assemblages comprising Cystophora spp., Sargassum spp.,

and Ecklonia radiata with interstitial patches of Posidonia spp., Amphibolis spp. and Zostera

nigricaulis seagrasses. Rocky reef habitat sites were often covered in the brown alga

Lobophora variegate. Survey locations have been grouped together in relation to their area

ecology (table 3). East Rocks, East shore and West Shore had much higher macroalgal cover

in comparison to other sites which consisted of mixed seagrass, rocky reef and sponge with

areas of bare sand. The northern sites substrate comprised of bare sand, shell fragments and

rhodoliths (Sporolithon durum) with interspersed patches of seagrass, rocky reef and sponge.

It is worth noting that although the habitat at these deeper-water sites was somewhat

fragmented, supporting less dense canopies, a number of macroalgae species including

Scaberia aghardii and several species of Cystophora and Sargassum were noted (table 3).

Table 3: Area ecology of each site. Site Area Ecology Image East Rocks East Shore West Shore

Dense macroalgae covered rocky reef.

East West Rocks

Mixed macroalgae covered rocky reef and seagrass.


West Creek Channel West Central

Mixed sponge/seagrass and patches of macroalgae covered rocky reef.

North North Central

Rubble and shell fragments with mixed seagrass/sponge and patches of rocky reef.

Across all surveyed sites within Smith Bay, 55 species of fish and 35 species of invertebrates

were noted, comprising 1124 individuals (902 fish and 222 invertebrates). Of these, 539 fish

and 162 invertebrates were noted within transects. Where multiple transects were

undertaken, data has been collated to assess each site. It should be noted that the scallop

count from the both North and North Central has been excluded due to their occurrence in

large abundances and lack of formal transects.

The Senator wrasse was the most commonly occurring species appearing at all sites followed

by the Blue throat wrasse at 7 sites and the Blackspotted wrasse at 6 sites (table 4). The most

frequently occurring invertebrates were the Western slatepencil urchin at 6 sites and both

the Painted lady mollusc and the Biscuit star noted at 5 sites (table 4).

Table 4: Frequency of Occurrence (FOO) of the most commonly sighted species.

Fish Species (FOO) Invertebrate Species (FOO) Senator Wrasse (8) Western slate pencil urchin (6) Blue throat Wrasse (7) Painted lady (5) Black-spotted Wrasse (6) Biscuit Star (5) Castelnau’s wrasse (5) Dusky Morwong, Pencil weed whiting, Magpie perch, Yellow-headed hula fish, Toadfish (4)


Almost 50% of fish species were recorded at one site only. Over 80% of invertebrate species

occurred in three or less sites (figure 2).

Figure 2: Frequency of Occurrence of fish and invertebrate species.

Plate 3: Senator wrasse (Pictilabrus laticlavius).

Plate 4: Western slatepencil urchin (Phyllacanthus irregularis).

05

101520253035404550

1 2 3 4 5 6 7 8

Spec

ies %

Frequency of Occurence (number of sites)

fish Invertebrates


The site with the highest number of species (both fish and invertebrate) surveyed was West

Central, followed by East Shore, and West Shore (figure 3).

Figure 3: Total species at each site.

Both West and West Rocks exhibited the highest number of invertebrate species and sites

East Shore, West Central and West Shore had the highest number of fish species (figure 4).

Sites with the highest number of invertebrate species exhibited the lowest number of fish

species.

Figure 4: Fish and invertebrate species occurring in each site.

0

5

10

15

20

25

East Rocks East East Shore CreekChannel

WestCentral

WestShore

West WestRocks

No. o

f spe

cies

Site (East to West)

02468

1012141618

EastRocks

East EastShore

CreekChannel

WestCentral

WestShore

West WestRocks

No. o

f spe

cies

Site (East to West)

Fish Invertebrates


Almost 50% of fish species were recorded at one site only. Over 80% of invertebrate species

occurred in three or less sites (figure 2).

Figure 2: Frequency of Occurrence of fish and invertebrate species.

Plate 3: Senator wrasse (Pictilabrus laticlavius).

Plate 4: Western slatepencil urchin (Phyllacanthus irregularis).

05

101520253035404550

1 2 3 4 5 6 7 8

Spec

ies %

Frequency of Occurence (number of sites)

fish Invertebrates


The site with the highest number of species (both fish and invertebrate) surveyed was West

Central, followed by East Shore, and West Shore (figure 3).

Figure 3: Total species at each site.

Both West and West Rocks exhibited the highest number of invertebrate species and sites

East Shore, West Central and West Shore had the highest number of fish species (figure 4).

Sites with the highest number of invertebrate species exhibited the lowest number of fish

species.

Figure 4: Fish and invertebrate species occurring in each site.

0

5

10

15

20

25


WestCentral

WestShore

West WestRocks

No. o

f spe

cies

Site (East to West)

02468

1012141618

EastRocks

East EastShore

CreekChannel

WestCentral

WestShore

West WestRocks

No. o

f spe

cies

Site (East to West)

Fish Invertebrates


The most abundant fish (highest number of individuals) was the Black-spotted wrasse

followed by the Yellow-headed hula fish and the Bluethroat wrasse. The most abundant

invertebrate was the Western slate pencil urchin followed by the Painted lady mollusc and

the Biscuit star (table 5).

Table 5: Most abundant fish and invertebrate species (* denotes schooling species).

Sites East Shore and West Central exhibited the highest number of individuals, comprising

mostly fish. These high numbers were due in part to the presence and abundance of schooling

species (table 5). East Rocks and Creek Channel exhibited the lowest number of individuals

(figure 5). However, this may be in part due to the lack of replicated transects. Sites West and

West Rocks on the western side of the bay, were the only locations where more invertebrates

than fish were surveyed.

Figure 5: Total number of fish and invertebrates recorded at each site.

Fish Species Invertebrate Species Black spotted wrasse (108) Western slate pencil urchin (23) Yellow-headed hula fish (96)* Painted lady (17) Bluethroat wrasse (68) Biscuit star (14) Zebrafish (62)* Vermillion biscuit star (11) Silverbelly (50)* Southern rock lobster (11)

0

50

100

150

200

250


WestCentral

WestShore

West WestRocks

No.o

f ind

ivid

uals

Site (East to West)

Fish Invertebrates


Species of Conservation Significance

Several species of conservation significance were noted. The Western blue groper was sighted

at East Rocks, the Long-snout boarfish was sighted at Creek Channel, West Central and North

and both the Southern blue devil and Weedy seadragons at North Central.

Syngnathids

Three species of Syngnathidae were noted at North Central in the deeper waters of the bay

at 16-18m depth comprising two pipefish; Stigmatopora nigra and Vanacampus margaritifer,

and six Weedy seadragons; Phyllopteryx taeniolatus.

Cetaceans

Three bottlenose dolphins were sighted at West rocks outside the surveyed transect. It should

be noted, in transit through Smith Bay, Common bottlenose dolphins were present at each

site outside surveying hours.

Coral

Two colony forming corals were sighted; Plesiastrea versipora and Coscinaraea mcneilli. One

large temperate coral of P.versipora nearing 2m tall and 6m in circumference and a smaller

coral approximately 2m in circumference was located in close proximity to East rocks. Analysis

indicated that the larger coral supported at least 14 fish species visible in collected footage.

A colony of C.mcneilli was sighted at North Central.

Commercially Valuable Species

Southern rock lobsters were sighted at West Rocks, East Shore and West Shore and Abalone

at West.

Other species of interest

The only octopus sighted was located at Creek Channel outside a transect.


The most abundant fish (highest number of individuals) was the Black-spotted wrasse

followed by the Yellow-headed hula fish and the Bluethroat wrasse. The most abundant

invertebrate was the Western slate pencil urchin followed by the Painted lady mollusc and

the Biscuit star (table 5).

Table 5: Most abundant fish and invertebrate species (* denotes schooling species).

Sites East Shore and West Central exhibited the highest number of individuals, comprising

mostly fish. These high numbers were due in part to the presence and abundance of schooling

species (table 5). East Rocks and Creek Channel exhibited the lowest number of individuals

(figure 5). However, this may be in part due to the lack of replicated transects. Sites West and

West Rocks on the western side of the bay, were the only locations where more invertebrates

than fish were surveyed.

Figure 5: Total number of fish and invertebrates recorded at each site.

Fish Species Invertebrate Species Black spotted wrasse (108) Western slate pencil urchin (23) Yellow-headed hula fish (96)* Painted lady (17) Bluethroat wrasse (68) Biscuit star (14) Zebrafish (62)* Vermillion biscuit star (11) Silverbelly (50)* Southern rock lobster (11)

0

50

100

150

200

250


WestCentral

WestShore

West WestRocks

No.o

f ind

ivid

uals

Site (East to West)

Fish Invertebrates


Species of Conservation Significance

Several species of conservation significance were noted. The Western blue groper was sighted

at East Rocks, the Long-snout boarfish was sighted at Creek Channel, West Central and North

and both the Southern blue devil and Weedy seadragons at North Central.

Syngnathids

Three species of Syngnathidae were noted at North Central in the deeper waters of the bay

at 16-18m depth comprising two pipefish; Stigmatopora nigra and Vanacampus margaritifer,

and six Weedy seadragons; Phyllopteryx taeniolatus.

Cetaceans

Three bottlenose dolphins were sighted at West rocks outside the surveyed transect. It should

be noted, in transit through Smith Bay, Common bottlenose dolphins were present at each

site outside surveying hours.

Coral

Two colony forming corals were sighted; Plesiastrea versipora and Coscinaraea mcneilli. One

large temperate coral of P.versipora nearing 2m tall and 6m in circumference and a smaller

coral approximately 2m in circumference was located in close proximity to East rocks. Analysis

indicated that the larger coral supported at least 14 fish species visible in collected footage.

A colony of C.mcneilli was sighted at North Central.

Commercially Valuable Species

Southern rock lobsters were sighted at West Rocks, East Shore and West Shore and Abalone

at West.

Other species of interest

The only octopus sighted was located at Creek Channel outside a transect.


Plate 5: Common Bottlenose dolphin (Tursiops spp.) Photographed at West.

Plate 6: Weedy seadragon (Phyllopteryx taeniolatus) Photographed at North Central.

Plate 7: Mother of pearl pipefish (Vanacampus margaritifer) Photographed at North Central.


Plate 8: Western Blue groper (Achoerodus gouldii) photographed at East Rocks.

Plate 9: Long-snout boarfish (Pentaceropsis recurvirostris) photographed at Creek Channel.

Plate 10: Southern blue devil (Paraplesiops meleagris) photographed at North Central.


Plate 5: Common Bottlenose dolphin (Tursiops spp.) Photographed at West.

Plate 6: Weedy seadragon (Phyllopteryx taeniolatus) Photographed at North Central.

Plate 7: Mother of pearl pipefish (Vanacampus margaritifer) Photographed at North Central.


Plate 8: Western Blue groper (Achoerodus gouldii) photographed at East Rocks.

Plate 9: Long-snout boarfish (Pentaceropsis recurvirostris) photographed at Creek Channel.

Plate 10: Southern blue devil (Paraplesiops meleagris) photographed at North Central.


Plate 11: Coral (Plesiastrea versipora).

Plate 12: Diver surveying coral.


Discussion

The ecology within Smith bay is highly heterogeneous providing complex habitat for a myriad

of species including fishes and invertebrates. The abundance of fishes on reefs is influenced

by a variety of physical and biotic factors (Scoresby & Baker, 2008). Phillips (2001) indicates

that high macroalgal speciation rates in Southern Australia are influenced by fluctuating

environmental conditions, abundance of suitable rocky reef substrate, habitat heterogeneity

and the warm waters of the Leeuwin current. These features aid in maintaining favourable

conditions. The Leeuwin current flows South along the Western Australia coast, bringing

warmer water east through the Great Australian Bight (Middleton and Bye 2007) having a

profound effect on habitat conditions.

Smith Bay is part of a highly connected marine environment. To the east are Emu Bay and

Boxing Bay and to the west is Dashwood Bay. The latter is particularly noteworthy as a

location frequented by dolphins, which were observed in great numbers during our second

expedition. High dolphin presence on the north coast is supported by new evidence that

suggests population connectivity of bottlenose dolphins between Kangaroo Island and South

Australian mainland waters (Cribb et al. 2018). The bay’s diverse assemblage of organisms

may be influenced in part, due to its unique location ideally situated between two marine

parks. To the east lies the Encounter marine park and the southern Spencer Gulf marine park

to the west (Natural Resources Kangaroo Island, 2018). Marine parks are known to influence

adjacent marine environments via the ‘spillover’ effect, involving the movement of individuals

across reserve boundaries (Rowley 1994) and exportation of larvae and recruits (McClanahan

and Mangi 2000). However, the spatial extent of these effects vary considerably (Harmelin-

Vivien et al. 2008; da Silva et al. 2015).

A total of 55 species of fish and 35 invertebrates were surveyed, including several species

listed as ‘In peril” by the conservation council (Reef Watch, 2019). The most commonly

occurring species comprising the wrasses were also the most abundant appearing at survey

locations in both sides of the bay. Fish exhibited strong habitat association with almost 50%

recorded as single site associated species, due in part to the unique ecology of sites across

Smith Bay. These ecological variations are influenced by physical complexities such as

substrate composition and topography and presence and abundance of macroalgal and


Plate 11: Coral (Plesiastrea versipora).

Plate 12: Diver surveying coral.


Discussion

The ecology within Smith bay is highly heterogeneous providing complex habitat for a myriad

of species including fishes and invertebrates. The abundance of fishes on reefs is influenced

by a variety of physical and biotic factors (Scoresby & Baker, 2008). Phillips (2001) indicates

that high macroalgal speciation rates in Southern Australia are influenced by fluctuating

environmental conditions, abundance of suitable rocky reef substrate, habitat heterogeneity

and the warm waters of the Leeuwin current. These features aid in maintaining favourable

conditions. The Leeuwin current flows South along the Western Australia coast, bringing

warmer water east through the Great Australian Bight (Middleton and Bye 2007) having a

profound effect on habitat conditions.

Smith Bay is part of a highly connected marine environment. To the east are Emu Bay and

Boxing Bay and to the west is Dashwood Bay. The latter is particularly noteworthy as a

location frequented by dolphins, which were observed in great numbers during our second

expedition. High dolphin presence on the north coast is supported by new evidence that

suggests population connectivity of bottlenose dolphins between Kangaroo Island and South

Australian mainland waters (Cribb et al. 2018). The bay’s diverse assemblage of organisms

may be influenced in part, due to its unique location ideally situated between two marine

parks. To the east lies the Encounter marine park and the southern Spencer Gulf marine park

to the west (Natural Resources Kangaroo Island, 2018). Marine parks are known to influence

adjacent marine environments via the ‘spillover’ effect, involving the movement of individuals

across reserve boundaries (Rowley 1994) and exportation of larvae and recruits (McClanahan

and Mangi 2000). However, the spatial extent of these effects vary considerably (Harmelin-

Vivien et al. 2008; da Silva et al. 2015).

A total of 55 species of fish and 35 invertebrates were surveyed, including several species

listed as ‘In peril” by the conservation council (Reef Watch, 2019). The most commonly

occurring species comprising the wrasses were also the most abundant appearing at survey

locations in both sides of the bay. Fish exhibited strong habitat association with almost 50%

recorded as single site associated species, due in part to the unique ecology of sites across

Smith Bay. These ecological variations are influenced by physical complexities such as

substrate composition and topography and presence and abundance of macroalgal and


seagrass communities. Many species surveyed in this study appear in earlier documents

pertaining to fish and invertebrate biodiversity assessments (McArdle et al. 2015, Reinhold et

al. 2013, Scoresby & Baker, 2008).

Sites dominated by dense macroalgae cover, supported species such as the Zebra fish and

Silver drummer, which were not noted anywhere else in the Bay. These species frequent high

algal biomass areas due to their herbivorous diets consisting of a variety of green, brown and

red algae (Clements & Choat, 1997). Environments with high macroalgal cover also provide

habitat complexity and protection from predation making them ideal refuges for a variety of

fishes (Dayton 1985). East Shore, characterised by dense macroalgae cover supported both

the highest abundance of individuals and number of fish species.

Sites consisting of a mixed sponge/seagrass/rocky reef habitat often neighboured patches of

high density seagrasses. Species such as the Longtail weed whiting, Sharpnose weed whiting

and Slender weed whiting were surveyed only at these sites. Research indicates weed whiting

species show strong habitat association to seagrass near reef edges (Shepherd et al. 2009).

This is consistent with the area ecology exhibited at sites where these species were noted.

High numbers of invertebrates were surveyed in the western sites of the bay including West

Central, West and West Rocks. This is likely due to the absence of canopy-forming

macroalgae, and associated habitat structure and food webs (Grutter & Irving 2007). In

support of this, research indicates areas of high density seagrass aid in sustaining large

macroinvertebrate communities (Attrill et al. 2000). Interstitial seagrass habitats are

important ecological components ensuring reef interconnectivity (Heck et al. 2008) whilst

providing essential ‘nursery’ habitat for a variety of fishes (Jenkins and Wheatley 1998;

McDevitt-Irwin et al. 2016).

At surveyed sites North and North Central reef shelfs and sponge gardens provide protection

and habitat for a diverse range of species. 19 species of fish and 14 species of invertebrates

present at these sites were not noted anywhere else in the bay. Although the environment is

somewhat fragmented, these unique pockets of varied topography are integral components

of the wider marine environment and provide important refuges for fishes. These sites were

not included in the main data analysis, however, a number of species of conservation concern

such as the Southern blue devil and Weedy seadragon were noted, as well as two species of

protected pipefish.


A large temperate coral - Plesiastrea versipora was located in close proximity to surveyed site

East rocks, with a smaller coral noted less than 100m away. The larger coral was

approximately 6m in circumference and supported at least 14 species of fish. The smaller

coral was approximately 2m in circumference. Large colonies of this coral were first

discovered in South Australia over 100 years ago (Howchin 1909). Hard corals such as these

are very slow growing in temperate waters, with varying rates of less than 1cm per year

(Burgess et al. 2009). Due to the rarity of long-lived specimens in temperate waters, there

have been few studies of environmental records (Burgess et al. 2009). Growth of these corals

is dependent on upon a multitude of environmental factors including temperature, nutrient

availability, turbidity, depth and light availability (Burgess et al. 2009). Historically, many of

these larger colonies were dredged up by trawlers (Edyvane, 1999) and impacted through

ecological modifications such as breakwater construction (The Register, 1909).

Species of interest such as the Long snout boarfish, Western blue groper, Southern blue devil

and Weedy seadragon were noted in the bay and are listed as species of conservation

concern. In Addition, two more species from the Syngnathidae family protected under the

EPBC Act 1999 were also noted. Syngnathids exhibit life histories and behaviours which makes

them vulnerable to decline (Foster and Vincent 2004) hence their notable protected status.

Studies tracking Phyllopteryx taeniolatus indicate small home ranges and high site fidelity

which has major implications for effective habitat management and conservation of this

protected species (Sanchez-Camara and Booth 2004).


seagrass communities. Many species surveyed in this study appear in earlier documents

pertaining to fish and invertebrate biodiversity assessments (McArdle et al. 2015, Reinhold et

al. 2013, Scoresby & Baker, 2008).

Sites dominated by dense macroalgae cover, supported species such as the Zebra fish and

Silver drummer, which were not noted anywhere else in the Bay. These species frequent high

algal biomass areas due to their herbivorous diets consisting of a variety of green, brown and

red algae (Clements & Choat, 1997). Environments with high macroalgal cover also provide

habitat complexity and protection from predation making them ideal refuges for a variety of

fishes (Dayton 1985). East Shore, characterised by dense macroalgae cover supported both

the highest abundance of individuals and number of fish species.

Sites consisting of a mixed sponge/seagrass/rocky reef habitat often neighboured patches of

high density seagrasses. Species such as the Longtail weed whiting, Sharpnose weed whiting

and Slender weed whiting were surveyed only at these sites. Research indicates weed whiting

species show strong habitat association to seagrass near reef edges (Shepherd et al. 2009).

This is consistent with the area ecology exhibited at sites where these species were noted.

High numbers of invertebrates were surveyed in the western sites of the bay including West

Central, West and West Rocks. This is likely due to the absence of canopy-forming

macroalgae, and associated habitat structure and food webs (Grutter & Irving 2007). In

support of this, research indicates areas of high density seagrass aid in sustaining large

macroinvertebrate communities (Attrill et al. 2000). Interstitial seagrass habitats are

important ecological components ensuring reef interconnectivity (Heck et al. 2008) whilst

providing essential ‘nursery’ habitat for a variety of fishes (Jenkins and Wheatley 1998;

McDevitt-Irwin et al. 2016).

At surveyed sites North and North Central reef shelfs and sponge gardens provide protection

and habitat for a diverse range of species. 19 species of fish and 14 species of invertebrates

present at these sites were not noted anywhere else in the bay. Although the environment is

somewhat fragmented, these unique pockets of varied topography are integral components

of the wider marine environment and provide important refuges for fishes. These sites were

not included in the main data analysis, however, a number of species of conservation concern

such as the Southern blue devil and Weedy seadragon were noted, as well as two species of

protected pipefish.


A large temperate coral - Plesiastrea versipora was located in close proximity to surveyed site

East rocks, with a smaller coral noted less than 100m away. The larger coral was

approximately 6m in circumference and supported at least 14 species of fish. The smaller

coral was approximately 2m in circumference. Large colonies of this coral were first

discovered in South Australia over 100 years ago (Howchin 1909). Hard corals such as these

are very slow growing in temperate waters, with varying rates of less than 1cm per year

(Burgess et al. 2009). Due to the rarity of long-lived specimens in temperate waters, there

have been few studies of environmental records (Burgess et al. 2009). Growth of these corals

is dependent on upon a multitude of environmental factors including temperature, nutrient

availability, turbidity, depth and light availability (Burgess et al. 2009). Historically, many of

these larger colonies were dredged up by trawlers (Edyvane, 1999) and impacted through

ecological modifications such as breakwater construction (The Register, 1909).

Species of interest such as the Long snout boarfish, Western blue groper, Southern blue devil

and Weedy seadragon were noted in the bay and are listed as species of conservation

concern. In Addition, two more species from the Syngnathidae family protected under the

EPBC Act 1999 were also noted. Syngnathids exhibit life histories and behaviours which makes

them vulnerable to decline (Foster and Vincent 2004) hence their notable protected status.

Studies tracking Phyllopteryx taeniolatus indicate small home ranges and high site fidelity

which has major implications for effective habitat management and conservation of this

protected species (Sanchez-Camara and Booth 2004).


Limitations Multiple transects were unable to be surveyed at every site. This reduced our overall data

collection affecting species counts and the overall results. This should be taken into

consideration when comparing data from East rocks and Creek channel where only one

transect was undertaken. Additionally, the more central parts of the bay were not surveyed.

This was due to both weather and time restrictions that inhibited further data collection.

All dives were undertaken during the day. As species behaviours vary at night, it would have

been valuable to undertake surveys both during the day and at night.

The trips consisted of four divers, three of which were new to the RLS survey method and

species identification. It was evident that diver’s observational capabilities and species

identification skills improved extensively during in situ activities. Therefore, it is likely that

there are discrepancies between earlier and later conducted surveys. Variability in local

conditions such as currents and/or visibility also affected surveying capabilities, which may

have influenced the final results.

Utilising the RLS transect method is effective in standardising data collection methods,

however many ‘skittish’ species of fish were likely missed due to divers presence and transect

restrictions (i.e. 5m wide band).


Conclusions and Future Research The ecology within Smith bay is highly heterogeneous providing complex habitat for a myriad

of species both fishes and invertebrates. The distribution and abundance of species is

influenced by a variety of physical and biotic factors including but not limited to, substrate

composition and topography and, presence and abundance of macroalgal and seagrass

communities. The unique ecology of sites across the bay is reflected in the high number of

single site associated species.

Macroalgal covered reefs provide key ecological services, habitat protection and are an

important food source for many species. Interstitial seagrass habitats are essential ecological

components ensuring reef interconnectivity whilst providing vital ‘nursery’ habitat for a

variety of fishes. These systems are integral components of the wider Great Southern Reef

System spanning the entire southern coastline of Australia. Although Southern Australia

marine macroalgal flora has the highest levels of species richness and endemism of any

regional macroalgal flora in the world, current levels of both scientific and public engagement

threaten the health and longevity of these significant systems.

Much like the rest of Kangaroo Island, Smith Bay’s marine environment exhibits high species

richness and endemism supporting an abundance of emblematic and threatened species with

high conservation value. The now documented presence of numerous large temperate corals

and a number of protected species, including those from the Syngnathidae family, outlines

the importance of ongoing marine life surveys, with much left to be discovered. AusOcean

aims to increase public awareness, perception and appreciation of these magnificent

temperate ecosystems that are often overlooked by their tropical reef counterparts. These

were the first of many Kangaroo Island expeditions highlighting the diversity and richness of

Smith Bay and the north coast. Future research will involve additional marine life surveys,

substantial footage collection via camera sled and/or ROV and potential analysis of the

internal compositions (via coral core drilled sampling) of the coral, which can provide historic

climate data of the area.


Limitations Multiple transects were unable to be surveyed at every site. This reduced our overall data

collection affecting species counts and the overall results. This should be taken into

consideration when comparing data from East rocks and Creek channel where only one

transect was undertaken. Additionally, the more central parts of the bay were not surveyed.

This was due to both weather and time restrictions that inhibited further data collection.

All dives were undertaken during the day. As species behaviours vary at night, it would have

been valuable to undertake surveys both during the day and at night.

The trips consisted of four divers, three of which were new to the RLS survey method and

species identification. It was evident that diver’s observational capabilities and species

identification skills improved extensively during in situ activities. Therefore, it is likely that

there are discrepancies between earlier and later conducted surveys. Variability in local

conditions such as currents and/or visibility also affected surveying capabilities, which may

have influenced the final results.

Utilising the RLS transect method is effective in standardising data collection methods,

however many ‘skittish’ species of fish were likely missed due to divers presence and transect

restrictions (i.e. 5m wide band).


Conclusions and Future Research The ecology within Smith bay is highly heterogeneous providing complex habitat for a myriad

of species both fishes and invertebrates. The distribution and abundance of species is

influenced by a variety of physical and biotic factors including but not limited to, substrate

composition and topography and, presence and abundance of macroalgal and seagrass

communities. The unique ecology of sites across the bay is reflected in the high number of

single site associated species.

Macroalgal covered reefs provide key ecological services, habitat protection and are an

important food source for many species. Interstitial seagrass habitats are essential ecological

components ensuring reef interconnectivity whilst providing vital ‘nursery’ habitat for a

variety of fishes. These systems are integral components of the wider Great Southern Reef

System spanning the entire southern coastline of Australia. Although Southern Australia

marine macroalgal flora has the highest levels of species richness and endemism of any

regional macroalgal flora in the world, current levels of both scientific and public engagement

threaten the health and longevity of these significant systems.

Much like the rest of Kangaroo Island, Smith Bay’s marine environment exhibits high species

richness and endemism supporting an abundance of emblematic and threatened species with

high conservation value. The now documented presence of numerous large temperate corals

and a number of protected species, including those from the Syngnathidae family, outlines

the importance of ongoing marine life surveys, with much left to be discovered. AusOcean

aims to increase public awareness, perception and appreciation of these magnificent

temperate ecosystems that are often overlooked by their tropical reef counterparts. These

were the first of many Kangaroo Island expeditions highlighting the diversity and richness of

Smith Bay and the north coast. Future research will involve additional marine life surveys,

substantial footage collection via camera sled and/or ROV and potential analysis of the

internal compositions (via coral core drilled sampling) of the coral, which can provide historic

climate data of the area.


References Attrill, MJ, Strong, JA, Rowden, AA (2000) Are macroinvertebrate communities influenced by

seagrass structural complexity? Ecography 23, 114-121.

Bennett, S, Wernberg, T, Connell, SD, Hobday, AJ, Johnson, CR, Poloczanska, ES (2015) The

‘Great Southern Reef’: social, ecological and economic value of Australia’s neglected

kelp forests. Marine and Freshwater Research 67, 47-56.

Burgess, SN, McCulloch, MT, Mortimer, GE, Ward, TM (2009) Structure and growth rates of

the high-latitude coral: Plesiastrea versipora. Coral Reefs 28, 1005.

Choat, JH, Gillanders, B, Pollard, D (2010) Achoerodus gouldii. The IUCN Red List of

Threatened Species 2010: e.T187520A8556943, viewed 18 January

2019<.http://dx.doi.org/10.2305/IUCN.UK.2010-4.RLTS.T187520A8556943.en.>

Clements, KD, Choat, JH (1997) Comparison of herbivory in the closely-related marine fish

genera Girella and Kyphosus. Marine Biology 137, 379-386.

Cribb, N, Bartram, P, Bartram, T, Seuront, L (2018) New Evidence for Bottlenose Dolphin

(Tursiops spp.) Population Connectivity between Kangaroo Island and South

Australian Mainland Waters. Open Journal of Marine Science 8, 13.

da Silva, IM, Hill, N, Shimadzu, H, Soares, AMVM, Dornelas, M (2015) Spillover Effects of a

Community-Managed Marine Reserve. PLoS One 10, e0111774.

Dayton, PK (1985) Ecology of Kelp Communities. Annual Review of Ecology and Systematics

16, 215-245.

Foster, SJ, Vincent, ACJ (2004) Life history and ecology of seahorses: implications for

conservation and management. Journal of Fish Biology 65, 1-61.

Gomon, M, Bray, D, Kuiter, R (2008) ‘Fishes of Australia's southern coast.’ (New Holland

Publishers Pty Ltd: Sydney).

Harmelin-Vivien, M, Le Diréach, L, Bayle-Sempere, J, Charbonnel, E, García-Charton, JA, Ody,

D, Pérez-Ruzafa, A, Reñones, O, Sánchez-Jerez, P, Valle, C (2008) Gradients of

abundance and biomass across reserve boundaries in six Mediterranean marine

protected areas: Evidence of fish spillover? Biological Conservation 141, 1829-1839.


Heck, KL, Carruthers, TJB, Duarte, CM, Hughes, AR, Kendrick, G, Orth, RJ, Williams, SW

(2008) Trophic Transfers from Seagrass Meadows Subsidize Diverse Marine and

Terrestrial Consumers. Ecosystems 11, 1198-1210.

Howchin, W (1909) Notes on the discovery of a large mass of living coral in Gulf St Vincent

with bibliographical references to the recent corals of South Australia. Transactions

of the Royal Society South Australia 3, 242–253.

Jenkins, GP, Wheatley, MJ (1998) The influence of habitat structure on nearshore fish

assemblages in a southern Australian embayment: Comparison of shallow seagrass,

reef-algal and unvegetated sand habitats, with emphasis on their importance to

recruitment. Journal of Experimental Marine Biology and Ecology 221, 147-172.

Kinloch, M. A. (2005). Review of Kangaroo Island Marine, Coastal and Estuarine Biodiversity

Monitoring and Research Programs. Kangaroo Island Natural Resources Board,

Kingscote.

McArdle, A, Lashmar, K, Klein, H (2015) Diving deeper: a community assessment of

Kangaroo Island’s rocky reefs. Final report, Caring for our Country Community Action

Grants No. CEG-1217992-261.

McClanahan, TR, Mangi, S (2000) Spillover of exploitable fishes from a marine park and its

effects on the adjacent fishery. Ecological Applications 10, 1792-1805.

McDevitt-Irwin, JM, Iacarella, JC, Baum, JK (2016) Reassessing the nursery role of seagrass

habitats from temperate to tropical regions: a meta-analysis. Marine Ecology

Progress Series 557, 133-143.

Middleton, JF, Bye, JAT (2007) A review of the shelf-slope circulation along Australia’s

southern shelves: Cape Leeuwin to Portland. Progress in Oceanography 75, 1-41.

Natural Resources Kangaroo Island (2018) Marine Parks, Natural Resources Kangaroo Island,

viewed 12 March 2019 <https://www.naturalresources.sa.gov.au/kangarooisland

/park s-and-places/marine-parks>.

Orth, RJ, Carruthers, TJB, Dennison, WC, Duarte, CM, Fourqurean, JW, Heck, KL, Hughes, AR,

Kendrick, GA, Kenworthy, WJ, Olyarnik, S, Short, FT, Waycott, M, Williams, SL (2006)

A Global Crisis for Seagrass Ecosystems. BioScience 56, 987-996.


References Attrill, MJ, Strong, JA, Rowden, AA (2000) Are macroinvertebrate communities influenced by

seagrass structural complexity? Ecography 23, 114-121.

Bennett, S, Wernberg, T, Connell, SD, Hobday, AJ, Johnson, CR, Poloczanska, ES (2015) The

‘Great Southern Reef’: social, ecological and economic value of Australia’s neglected

kelp forests. Marine and Freshwater Research 67, 47-56.

Burgess, SN, McCulloch, MT, Mortimer, GE, Ward, TM (2009) Structure and growth rates of

the high-latitude coral: Plesiastrea versipora. Coral Reefs 28, 1005.

Choat, JH, Gillanders, B, Pollard, D (2010) Achoerodus gouldii. The IUCN Red List of

Threatened Species 2010: e.T187520A8556943, viewed 18 January

2019<.http://dx.doi.org/10.2305/IUCN.UK.2010-4.RLTS.T187520A8556943.en.>

Clements, KD, Choat, JH (1997) Comparison of herbivory in the closely-related marine fish

genera Girella and Kyphosus. Marine Biology 137, 379-386.

Cribb, N, Bartram, P, Bartram, T, Seuront, L (2018) New Evidence for Bottlenose Dolphin

(Tursiops spp.) Population Connectivity between Kangaroo Island and South

Australian Mainland Waters. Open Journal of Marine Science 8, 13.

da Silva, IM, Hill, N, Shimadzu, H, Soares, AMVM, Dornelas, M (2015) Spillover Effects of a

Community-Managed Marine Reserve. PLoS One 10, e0111774.

Dayton, PK (1985) Ecology of Kelp Communities. Annual Review of Ecology and Systematics

16, 215-245.

Foster, SJ, Vincent, ACJ (2004) Life history and ecology of seahorses: implications for

conservation and management. Journal of Fish Biology 65, 1-61.

Gomon, M, Bray, D, Kuiter, R (2008) ‘Fishes of Australia's southern coast.’ (New Holland

Publishers Pty Ltd: Sydney).

Harmelin-Vivien, M, Le Diréach, L, Bayle-Sempere, J, Charbonnel, E, García-Charton, JA, Ody,

D, Pérez-Ruzafa, A, Reñones, O, Sánchez-Jerez, P, Valle, C (2008) Gradients of

abundance and biomass across reserve boundaries in six Mediterranean marine

protected areas: Evidence of fish spillover? Biological Conservation 141, 1829-1839.


Heck, KL, Carruthers, TJB, Duarte, CM, Hughes, AR, Kendrick, G, Orth, RJ, Williams, SW

(2008) Trophic Transfers from Seagrass Meadows Subsidize Diverse Marine and

Terrestrial Consumers. Ecosystems 11, 1198-1210.

Howchin, W (1909) Notes on the discovery of a large mass of living coral in Gulf St Vincent

with bibliographical references to the recent corals of South Australia. Transactions

of the Royal Society South Australia 3, 242–253.

Jenkins, GP, Wheatley, MJ (1998) The influence of habitat structure on nearshore fish

assemblages in a southern Australian embayment: Comparison of shallow seagrass,

reef-algal and unvegetated sand habitats, with emphasis on their importance to

recruitment. Journal of Experimental Marine Biology and Ecology 221, 147-172.

Kinloch, M. A. (2005). Review of Kangaroo Island Marine, Coastal and Estuarine Biodiversity

Monitoring and Research Programs. Kangaroo Island Natural Resources Board,

Kingscote.

McArdle, A, Lashmar, K, Klein, H (2015) Diving deeper: a community assessment of

Kangaroo Island’s rocky reefs. Final report, Caring for our Country Community Action

Grants No. CEG-1217992-261.

McClanahan, TR, Mangi, S (2000) Spillover of exploitable fishes from a marine park and its

effects on the adjacent fishery. Ecological Applications 10, 1792-1805.

McDevitt-Irwin, JM, Iacarella, JC, Baum, JK (2016) Reassessing the nursery role of seagrass

habitats from temperate to tropical regions: a meta-analysis. Marine Ecology

Progress Series 557, 133-143.

Middleton, JF, Bye, JAT (2007) A review of the shelf-slope circulation along Australia’s

southern shelves: Cape Leeuwin to Portland. Progress in Oceanography 75, 1-41.

Natural Resources Kangaroo Island (2018) Marine Parks, Natural Resources Kangaroo Island,

viewed 12 March 2019 <https://www.naturalresources.sa.gov.au/kangarooisland

/park s-and-places/marine-parks>.

Orth, RJ, Carruthers, TJB, Dennison, WC, Duarte, CM, Fourqurean, JW, Heck, KL, Hughes, AR,

Kendrick, GA, Kenworthy, WJ, Olyarnik, S, Short, FT, Waycott, M, Williams, SL (2006)

A Global Crisis for Seagrass Ecosystems. BioScience 56, 987-996.


Phillips, JA (2001) Marine macroalgal biodiversity hotspots: why is there high species

richness and endemism in southern Australian marine benthic flora? Biodiversity &

Conservation 10, 1555-1577.

Prowse, TAA, Gillanders, BM, Brook, BW, Fowler, AJ, Hall, KC, Steer, MA, Mellin, C, Clisby, N,

Tanner, JE, Ward, TM, Fordham, DA (2015) Evidence for a broad-scale decline in

giant Australian cuttlefish (<i>Sepia apama</i>) abundance from non-targeted

survey data. Marine and Freshwater Research 66, 692-700.

Reef Life Survey Foundation (2013) Standardised Survey Procedures for Monitoring Rocky &

Coral Reef Ecological Communities, Hobart, Tasmania, Australia.

Reef Watch (2019) Feral or in peril South Australia, viewed 29 January 2019

<https://d3n8a8pro7vhmx.cloudfront.net/conservationsa/pages/310/attachments/o

riginal/1453091193/Feral_or_in_Peril_Guide_2012_low_res.pdf?1453091193>

Ricart, AM, Dalmau, A, Pérez, M, Romero, J (2015) Effects of landscape configuration on the

exchange of materials in seagrass ecosystems. Marine Ecology Progress Series 532,

89-100.

Reinhold, S, Kinloch, M, Lashmar, K, McArdle, A & Brock, D (2013) Community Assessment

of Reef Biodiversity on Kangaroo Island. Natural Resources Kangaroo Island Coast

and Marine Program Report No. CMP13/01

Rowley, RJ (1994) Marine reserves in fisheries management. Aquatic Conservation: Marine

and Freshwater Ecosystems 4, 233-254.

Sanchez-Camara, J, Booth, DJ (2004) Movement, Home Range and Site Fidelity of the Weedy

Seadragon Phyllopteryx taeniolatus (Teleostei: Syngnathidae). Environmental Biology

of Fishes 70, 31-41.

Shepherd, SA, Baker JL (2008) Reef fishes of lower Gulf St Vincent. In ‘Natural history of Gulf

St Vincent.’ (Eds SA Shepherd, S Bryars, I Kirkegaard, P Harbison, JT Jennings) pp.

297-310 (Royal Society of South Australia: Adelaide).

Shepherd, SA, Baker JL, Brown AR, Crawford, HM (2009) Reef fishes of NE Kangaroo Island: a

nursery role for Eastern Cove? Supplementary Report for Commonwealth

Department of the Environment, Water, Heritage and the Arts Envirofund Project

63120.


Smale, DA, Burrows, MT, Moore, P, O'Connor, N, Hawkins, SJ (2013) Threats and knowledge

gaps for ecosystem services provided by kelp forests: a northeast Atlantic

perspective. Ecology and Evolution 3, 4016-4038.

Tanaka, H, Chiba, S, Yusa, T, Shoji, J (2018) Day–night change in fish community structure in

a seagrass bed in subarctic waters. Fisheries science 84, 275-281.

The Register (1909) ‘The Glenelg Corals’, 7 July, p.4, viewed 29 January 2019,

<https://trove.nla.gov.au/newspaper/article/56725711>


Phillips, JA (2001) Marine macroalgal biodiversity hotspots: why is there high species

richness and endemism in southern Australian marine benthic flora? Biodiversity &

Conservation 10, 1555-1577.

Prowse, TAA, Gillanders, BM, Brook, BW, Fowler, AJ, Hall, KC, Steer, MA, Mellin, C, Clisby, N,

Tanner, JE, Ward, TM, Fordham, DA (2015) Evidence for a broad-scale decline in

giant Australian cuttlefish (<i>Sepia apama</i>) abundance from non-targeted

survey data. Marine and Freshwater Research 66, 692-700.

Reef Life Survey Foundation (2013) Standardised Survey Procedures for Monitoring Rocky &

Coral Reef Ecological Communities, Hobart, Tasmania, Australia.

Reef Watch (2019) Feral or in peril South Australia, viewed 29 January 2019

<https://d3n8a8pro7vhmx.cloudfront.net/conservationsa/pages/310/attachments/o

riginal/1453091193/Feral_or_in_Peril_Guide_2012_low_res.pdf?1453091193>

Ricart, AM, Dalmau, A, Pérez, M, Romero, J (2015) Effects of landscape configuration on the

exchange of materials in seagrass ecosystems. Marine Ecology Progress Series 532,

89-100.

Reinhold, S, Kinloch, M, Lashmar, K, McArdle, A & Brock, D (2013) Community Assessment

of Reef Biodiversity on Kangaroo Island. Natural Resources Kangaroo Island Coast

and Marine Program Report No. CMP13/01

Rowley, RJ (1994) Marine reserves in fisheries management. Aquatic Conservation: Marine

and Freshwater Ecosystems 4, 233-254.

Sanchez-Camara, J, Booth, DJ (2004) Movement, Home Range and Site Fidelity of the Weedy

Seadragon Phyllopteryx taeniolatus (Teleostei: Syngnathidae). Environmental Biology

of Fishes 70, 31-41.

Shepherd, SA, Baker JL (2008) Reef fishes of lower Gulf St Vincent. In ‘Natural history of Gulf

St Vincent.’ (Eds SA Shepherd, S Bryars, I Kirkegaard, P Harbison, JT Jennings) pp.

297-310 (Royal Society of South Australia: Adelaide).

Shepherd, SA, Baker JL, Brown AR, Crawford, HM (2009) Reef fishes of NE Kangaroo Island: a

nursery role for Eastern Cove? Supplementary Report for Commonwealth

Department of the Environment, Water, Heritage and the Arts Envirofund Project

63120.


Smale, DA, Burrows, MT, Moore, P, O'Connor, N, Hawkins, SJ (2013) Threats and knowledge

gaps for ecosystem services provided by kelp forests: a northeast Atlantic

perspective. Ecology and Evolution 3, 4016-4038.

Tanaka, H, Chiba, S, Yusa, T, Shoji, J (2018) Day–night change in fish community structure in

a seagrass bed in subarctic waters. Fisheries science 84, 275-281.

The Register (1909) ‘The Glenelg Corals’, 7 July, p.4, viewed 29 January 2019,

<https://trove.nla.gov.au/newspaper/article/56725711>

Smith

Bay

Mar

ine

Ecol

ogy

Repo

rt

32

Appe

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Appe

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nven

tory

of s

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th C

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whi

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Bay

Mar

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Ecol

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Bay

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Ecol

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rt

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Bay

Mar

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Ecol

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Repo

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Smith

Bay

Mar

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Ecol

ogy

Repo

rt

34

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Bay

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Ecol

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rt

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to cu

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ies

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11

29

35

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l Cou

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and

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rteb

rate

s 30

40

20

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44

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45

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70

1

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To

tal n

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ish a

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vert

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s 13

13

23

45

15

15

24

20

18

18

66

90


Appendix 2: Expedition images

Plate 13: Reef ledge photographed at North Central. Plate 14: Old Wives (Enoplosus armatus) photographed at West Central.

Plate 15: Basket star’s (Astroboa ernae & Concocladus australis) photographed at North Central.

Plate 16: Widebody pipefish (Stigmatopora nigra) photographed at North Central.

Plate 17: Shaws cowfish (Aracana aurita) photographed at North Central.

Plate 18: Weedy seadragon (Phyllopteryx taeniolatus) & Ornate cowfish (Aracana ornata) photographed at North Central.


Plate 19: Diver and sponge Photographed at West Central.

Plate 21: Pink lace bryozoan (Iodictyum phoeniceum) photographed at North Central.

Plate 22: Coral (Coscinaraea mcneilli) photographed at North Central.

Plate 23: Diver and Coral (Plesiastrea versipora). Plate 24: Coral (Plesiastrea versipora).

Plate 20: Doughby scallops (Mimachlamys asperrima) photographed at North Central.


Appendix 2: Expedition images

Plate 13: Reef ledge photographed at North Central. Plate 14: Old Wives (Enoplosus armatus) photographed at West Central.

Plate 15: Basket star’s (Astroboa ernae & Concocladus australis) photographed at North Central.

Plate 16: Widebody pipefish (Stigmatopora nigra) photographed at North Central.

Plate 17: Shaws cowfish (Aracana aurita) photographed at North Central.

Plate 18: Weedy seadragon (Phyllopteryx taeniolatus) & Ornate cowfish (Aracana ornata) photographed at North Central.


Plate 19: Diver and sponge Photographed at West Central.

Plate 21: Pink lace bryozoan (Iodictyum phoeniceum) photographed at North Central.

Plate 22: Coral (Coscinaraea mcneilli) photographed at North Central.

Plate 23: Diver and Coral (Plesiastrea versipora). Plate 24: Coral (Plesiastrea versipora).

Plate 20: Doughby scallops (Mimachlamys asperrima) photographed at North Central.