Archived page, Submission on James Point Port Stage 1 and Livestock Holding Facility

Submitted to the Environmental Protection Authority June 2001

General objections

Recfishwest represents the many thousands of Western Australians who fish in Cockburn Sound. It is estimated that Cockburn Sound is probably the most intensively used recreational boat fishing location in Western Australia (Fisheries WA Research Report no. 117, 1999). This is despite the problems of access and water quality discussed later in this submission. The potential use of Cockburn Sound would be higher if these problems could be ameliorated. In recent years recreational fishers have joined many other community groups in objecting to the way continuing industrial development is dominating Cockburn Sound despite repeated government commitments that it should remain available for multiple use including recreational fishing.

The Environmental Protection Authority has pointed to the need to consider cumulative impacts of developments in Cockburn Sound. The assessment guidelines for the James Point Port Stage 1 proposal requested the proponent to provide preliminary assessment of the likely cumulative impact assessment of the ultimate port development and other developments. The proponent has not provided this assessment. The excuse that this can be provided separately because it primarily addresses Stage 2 of this development is totally unacceptable; because if Stage 1 proceeds other alternatives are eliminated and it will be argued that a commitment has been made to Stage 2. On this basis alone Recfishwest believes that this proposal as presented must be rejected.

A major problem for the recreational use of Cockburn Sound is that there is very little access available to the Sound between Woodman Point and Wells Park at Kwinana Beach, a distance of about 14km. Only two beaches are accessible between these two points. Challenger Beach at Naval Base has a boat ramp and beach which has recently been destroyed by dumping rock all over it. Barter Beach is on the site of James Point Stage 1; it is currently used informally as a horse exercise beach.

The situation has been made worse because what was supposed to be a recreational access point in Jervoise Bay has been seriously degraded by the Northern Harbour breakwater extension. This has turned the area around the Cockburn Power Boats Association launching ramp into a potentially eutrophic backwater. Added to this, recent rezoning has taken the adjacent beach to the south and rock-walled it for an extension of the boat building area. The outcome is that although boats can still be launched there, there is not an associated recreation area. Further west, Woodman Point is eroding and offers virtually no recreational access.

It is suggested that if Cockburn Sound is to be available for shared recreational use there must be some places where families can have access to the Sound. The need is for a site where some family members can recreate on shore and others can launch small boats, which do not travel far or fast, to fish for small fish and crabs within a few kilometres of the launch point. The waters just off the beach north of James point were excellent for recreational crabbing in the past and Transect 2 of the James Point marine survey (Appendix 2 of the James Point Port PER) indicates that blue swimmer crabs are still common in the area.

Retaining the "Barter Road" beach would keep the possibility of such a site available for the future. Possibly when the port of Fremantle needs to expand (2020 AD according to current Fremantle Port Authority estimates) the technology of cargo handling may have reached a stage where the current BHP waterfront area is adequate for the additional needs after proper integrated planning and negotiations on land tenure. It would be totally against the principles of inter-generational equity to close off the possibility of recreational access at one of the two remaining potential sites at this early stage.

Specific Issues

Reclamation

Approximately 20 ha of Cockburn Sound is to be reclaimed and turned into dry land. The current management proposals for Cockburn Sound include Environmental Quality Objectives for the ecology, swimming, water clarity etc. It is hard to imagine that turning water into dry land can be held to be compatible with any environmental quality objectives. Similarly, considering the aspect of cumulative impact, surely any proposal that involves filling in the Sound must be considered to lead to an unacceptable cumulative impact.

The proposed reclamation not only destroys part of the water area of the Sound but it destroys part of its natural shoreline. The shallow inshore waters of Cockburn Sound serve as a nursery area for juvenile fish (1998, Hyndes et al. Fisheries Bulletin 96: 258-270 and Tony Cappelluti, Fisheries WA pers comm). Any dredging and reclamation of the shore reduces this valuable zone.

The proposed reclamation for land backed berths will further interfere with coastal processes and lateral sand movement.

Dredging and construction impacts

Approximately 57 ha are to be dredged for additional shipping access. This will be done in two stages, first to 11.7 m and subsequently to 13.7 and 14 m. Provision is also made for construction of a breakwater. This will not be constructed initially but may be constructed in two years time (pers comm James Port Point Pty Ltd). This breakwater would be about one kilometre long and would involve over 700 000 m3 of rock, some of which would have to be moved twice when the temporary connection to the shore was removed.

It seems very likely that there will be a prolonged period of two stages of dredging and then possibly breakwater construction during which turbidity plumes will affect water quality in the area. The proponent's reassurances on this topic are not very comforting. A monitoring program will be implemented and the dredging contractor will be told that minimisation of turbidity is a significant issue. Highly visible plumes have been seen moving considerable distances from the breakwater construction of the Jervoise Bay Southern Harbour.

Although the proponent suggests on p 101 that the closest seagrass areas are 2 km north-west of the development; transect 2 of the James Point Marine Survey (Appendix 2) shows seagrass well within 1 km of the area which is to be dredged (Figure 7.2). Such small areas of seagrass are of key importance if the shallow water seagrass meadows of Cockburn Sound are to be re-established in the longer term.

Not only will some areas of seagrass be put at risk, but also other benthic fauna and flora will suffer directly from the dredging and indirectly from the turbidity and sedimentation.

Effects on water quality

There will be some adverse effect on water quality from the construction and operation of the James Point Port. The PER suggests that the magnitude of these effects will not be such as to compromise the water quality of the eastern margin or the main portion of Cockburn Sound.

The PER for the construction of the Northern Breakwater Extension of Jervoise Bay Harbour predicted that there would be no adverse effect on water quality. Subsequently, this proved to be wrong and there was a disastrous effect. It has become clear to members of the public that the precautionary principle must be applied more rigorously. Recfishwest believes that in the case of the James Point Port construction, a general deterioration in water quality in the area cannot be discounted.

The water quality problem in the Northern Jervoise Bay Harbour has not been overcome. The construction of the Southern Jervoise Bay Harbour is now in progress and it remains to be seen what the impact on water quality will be. Dredging to a greater depth in the James Point Port harbour, sediment disturbance, and some restriction in along-shore water flow could all adversely affect water quality by increasing residence times or by direct nutrient input. It seems quite inappropriate to commit to further development along the eastern margin of Cockburn Sound that could impact deleteriously on water quality at any level at all until a clear improvement in overall water quality in the area has been achieved.

Impacts from shipping movements

It is predicted that there will be an increase of about 120 ship visits per annum to the proposed James Point wharf. This will increase tributyl tin contamination in the area, quite probably above national guidelines. The proponents say that port operations will be managed so that the input of contaminants will be minimised.

Additional ship movements can increase the risk of introducing further exotic marine organisms.

One factor, which concerns Recfishwest, is the way in which ship movements in the dredged channels and ship basin will stir up sediments and continue to cause turbidity in the adjacent area. This is a part of Cockburn Sound in which seagrass flourished in the past. It is hoped that water quality in future will be good enough for seagrass to eventually re-establish. However, if continued shipping movement through this area increases turbidity and reduces light penetration it could prevent seagrass from ever growing again over a substantial area.

Conclusion

Recfishwest considers that the proposal would unquestionably harm the environment of Cockburn Sound. Recfishwest further considers that any firm decisions on additional port capacity in Fremantle/Cockburn Sound should be deferred until closer to the time when it is needed so that planning can be carried out in the full knowledge of the best technology then available. This would also enable the current community consensus to be taken into account.

Livestock Holding Facility

General objection

Cockburn Sound is the only large marine embayment on the coast of Western Australia south of Shark Bay. The community of Perth uses it for marine recreation including fishing and sailing. Most of the bulk cargo for the Perth area is handled through Cockburn Sound. There is a substantial industry building small ships on its shore. These uses compete for the very limited space in Cockburn Sound - particularly along the mainland shore. That anyone could propose that a large livestock holding and feeding facility should be constructed on the shore and over the shallow waters of Cockburn Sound is extraordinary. It certainly demonstrates blindness to the broader and longer-term interests of the present and future community of the Perth metropolitan area. Recfishwest believes very strongly that the livestock holding facility must not be approved either in association with the port or without it.

Recfishwest found the documentation of this proposal in the PER to be deficient in specific information in various areas. In one example it proved quite impossible to reconcile Figure 3.3 with Figure 3.2 to actually determine the layout of the proposal. Another example is the lack of information on the method of loading sheep from the sheds to the ships.

Specific issues

Odour

Most of the discussion on odour is oriented to the dispersion of odour towards residential areas. Recfishwest wishes to draw attention to the impact on recreational users of Cockburn Sound of odour from the livestock holding facility and from the ship being loaded.

Most outdoor recreation is affected by the characteristics of the environment in which it is undertaken. Recreational fishers generally like to pursue their activity under the conditions natural to a marine environment. Recfishwest has prepared a brochure on "Recreational Fishing Habitat"; actually this was initially done at the suggestion of the Department of Environmental protection. This brochure was prepared long before the James Point Livestock proposal; but it emphasizes the importance of total environmental quality. A copy of the brochure is enclosed.

The PER shows modelling in terms of odour units and there have been doubts about the appropriate parameters. However, Recfishwest is in a position to make specific comparisons because one Board member lives 3.5 km north of the most common live sheep ship berth at Fremantle. Very strong odours are noticeable at this location on occasions with a south-west wind. Given that there would be more sheep held at James Point, it would expected that strong odours would be noticed 3.5 km out into the Sound with east to south-east winds. This is about half way to Garden Island.

In regard to odour, the PER describes the pens as having concrete floors, which will be cleaned between cycles. The PER also says that the waste will be dry because urine will be absorbed or evaporated. In traditional sheep handling facilities sheep used to be kept on gratings which allowed faeces and urine to drop through the grating, thus keeping the sheep dry and the area cleaner. If the sheep are walking in wet faeces and urine the odour may be worse.

Storm water

Potentially contaminated stormwater from the area is proposed for disposal in a fully lined evaporation basin. This will provide 1m3 of basin to every 45m2 of catchment area. This is obviously deficient. In Perth's heaviest rainfall day (in summer) this would have filled and overflowed about six times. A single very wet winter day would cause it to overflow and in a wet July it would overflow many times. If lay people can detect simple mistakes such as this in the PER does it not throw some doubt on many of the general assurances given in the document?

Another inadequacy is that it would be difficult if not impossible to clean out such a basin without risking damage to the liner. The PER says that monitoring will be undertaken to assess the integrity of the liner. What happens if it fails? The only proper solution would be a concrete basin of ten times the volume with machine access to the bottom.

Conclusion

The proposal should be rejected completely as environmentally unacceptable



This page last updated on 30 December 2003.