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||Surf Casting and Angling Club of W.A. (Inc.)
Club's Submission to the Environment Minister on Owen Anchorage Shellsand Dredging Proposals.
Owen Anchorage Shell sand Dredging - What are the issues?
You may have seen the articles in the news or papers about this and wondered. This is just a summary of an 80 page EPA report Bulletin 1033, and cannot cover all the details, but the following are some of the statements which have caused the furore.
"Cockburn Cement Limited (CCL) has been dredging shell sand from Owen Anchorage since 1972. CCL now proposes to dredge shell sand in the long-term (to 2034) from additional specific locations on Success Bank, Parmelia Bank and West Success Bank, Owen Anchorage. The proposal is for Stage 1 (2002-2014) on Success and Parmelia Bank to create a 1.5km wide by 15m deep seaway through these banks by 2014. This would remove 168.5ha of seagrass and 264.5ha of shallow bare sand, which can be potential seagrass habitat, to recover 30 million tonnes of shell sand. Stage 2 (2015-2034) on West Success Bank would dredge about 350ha of shallow bare sand on West Success Bank, east and north of the Mewstone area, over an additional 20 years to recover 60 million tonnes of shell sand. A total area of 783ha." This area is equivalent to a square 2.8km by 2.8km.
"The EPA acknowledges that the long-term proposal has been developed from a very substantial base of new knowledge and that although some direct loss of biodiversity will occur in the vicinity of dredging in terms of seagrass, dependent fish, epiphytes and invertebrates, no species will be lost as habitat types exist elsewhere."
"In terms of cover, seagrass in Owen Anchorage was more extensive in 1999, even accounting for previous dredging losses, than at any earlier mapping period."
"The EPA recognises the important role that seagrass plays as a primary producer and a habitat and considers it is an important principle to retain seagrass in Owen Anchorage wherever possible. The EPA also recognises that Parmelia Bank borders Cockburn Sound, which has already lost 80% of its seagrass."
"The EPA notes that whilst seagrass rehabilitation is possible, it is not currently practicable at a scale comparable to the rate of loss proposed through dredging, but that the necessary technology may be developed in the future. It is also noted that seagrass distribution in Owen Anchorage is dynamic and seagrasses can establish naturally on shallow bare sand habitat."
"The EPA notes CCL has now identified additional resources of shell sand on West Success Bank with no seagrass cover. The EPA considers that dredging of unvegetated shell sand can be carried out in an environmentally acceptable manner."
"The EPA is of the view that CCL has provided sufficient new information to enable the EPA to conclude that further limited removal of some seagrass from Owen Anchorage can now be considered environmentally reasonable."
"Whilst the EPA considers that a limited loss of additional seagrass in Owen Anchorage could occur without inducing a significant impact, it wishes to ensure that any additional loss is strictly constrained. Accordingly, the relocation of CCL's dredging operations to unvegetated areas on West Success Bank should occur as quickly as practicable and in considerably less time than the 12 years as originally proposed by CCL for Stage 1 of the proposal. CCL should thus prepare for Government consideration a timetable for moving from Success Bank and Parmelia Bank to West Success Bank as quickly as practicable."
"CCL manufactures quicklime and cement and operates under the Cement Works (Cockburn Cement Limited) Agreement Act 1971. This Act was substantially amended in 1986 to require, among other matters, that the Company comply with the State's environmental laws, and to submit a "dredging management programme" (DMP) every two years for approval."
"The Act, effective to 2011 with provision for extension to 2021, entitles CCL to access shell sand sediment within a five mile (8km) radius of a point on Coogee Beach, north of Woodman Point. It also obliges the State to 'use every endeavour to find other shell sand within a reasonably economic distance from the jetty, and if other shell sand is not available, then other equivalent material.' "
"In conclusion the EPA:
(f) considers that, on balance, commercial and recreational fisheries are unlikely to be significantly compromised by the proposal; and
(g) supports the protection of seagrass on the balance of East Success Bank and Parmelia Banks, an extension to the Shoalwater Islands Marine Park......."
On the regeneration of seagrasses, the EPA noted:- "Field trials have been underway since February 1996 and seagrasses for transplantation have been taken from areas in the short and medium-terms areas prior to dredging. Transplantation has occurred into recipient sites located on eastern Success Bank. When survival over the past five years is factored (to February 2001), the area of actual rehabilitated seagrass meadow was calculated to be 2,794m2 (approx 0.28ha) comprising:
1,815m2 for Recipient site 2 (the major transplant site for the rehabilitation programme), based on 60% sod survival; and
979m2 for Recipient site 4, based on 89% sod survival (CCL, 2001a).
Based on the performance criteria, it can be concluded that CCL has demonstrated:
that it has rehabilitated 0.1ha of seagrass for at least 3 years;
that it has not met the second performance criterion - i.e. rehabilitated 1-3ha of seagrass with evidence of survival for at least 12 months; and that
direct transplantation is slow (less than 1ha/year), is not yet feasible at a rate required by the proposed long-term dredging programme, and is costly."
The EPA identified alternative sources of lime "· other than in Cockburn Sound (including Owen Anchorage) there are no identified resources of high quality carbonates in or near Perth. There are deposits of shell sand on Garden Island, but it is unlikely that these resources will be exploited;
Along the west coast, lime sands at Dongara provide one identified source of suitable quality resource for lime production. Cockburn currently operated a lime kiln in the area using this resource. In 1997, Westlime (WA) Limited also commissioned a lime kiln using this resource;
Some high quality limestone deposits have been found in the Dampier Archipelago. Conservation issues will strongly influence exploitation;
The Cape Range (Exmouth) has substantial deposits of high grade limestone. Exploitation will be heavily influenced by conservation issues and transport costs; and
Lime is produced in the Goldfields area using limestone quarried 400km east of Kalgoorlie at Loongana. Further development of this resource is limited to industrial expansion in the Goldfields area; transportation costs limiting use further afield."
"...the EPA notes the different views held by CCL, the Department of Fisheries and Recfishwest but considers that, on balance, commercial and recreational fisheries are unlikely to be significantly compromised by the long-term dredging proposal given the limited reduction in seagrass in Owen Anchorage."
"The EPA considers that all reasonable alternatives to a proposal should be considered within social and environmental constraints. EPA notes:
there is lime sand of suitable quality at Dongara, where CCL already operates kilns.
the draft State Lime Supply Strategy confirms that alternative sources of lime are available from Dongara.
no alternative proposals to the current proposal were put forward by CCL, therefore no comprehensive environmental information has been provided on which a comparative environmental assessment can be considered. It is likely, however, that an alternative based on the Dongara resource could be made to be environmentally acceptable as the existing Westlime and CCL operations at Dongara were referred to the EPA and neither required formal assessment.
The EPA considers that unvegetated deposits on West Success Bank are a real alternative source of lime sand"
Recfishwest has challenged many of these statements and the conclusions drawn from them, in a twelve page submission. Here are just some of their comments:-
"The impact of dredging and seagrass removal upon fish stocks, recreational fishing quality and the prospect of successfully colonising seagrass by transplantation or other artificial means to offset seagrass loss are the key concerns of Recfishwest."
"Recfishwest has importantly identified two principal and overriding objections to the proposal. The objections are that the proposal, as identified in the ERMP itself, fails to meet both the requirements of the Ministerial Condition 6-2, August 1994 "that seagrass can be successfully rehabilitated", and the requirement (reinterpreted in 1995), "that due to Cockburn's shell sand dredging operations on Success Bank in Owen Anchorage, there be no net loss of present ecological and cultural function in the Cockburn Sound/Owen Anchorage area." (Supplement to EMP, and referenced in EPA Bulletin 901, August 1998)."
"The expected impacts on water clarity are negative. These include some impact from the increased winter wave activity in Cockburn Sound and an increase in turbidity plumes. The ERMP says the plumes from the dredge and the onshore washing plant are not expected to change from existing levels; but as production is anticipated to increase by more than 50% over the next 20 years this seems unlikely. Water quality, particularly clarity, is one of the main problems in Cockburn Sound and therefore this is a critical issue. When the dredging is occurring on Parmelia Bank any southward drift of a turbidity plume directly affects Cockburn Sound and could significantly reduce the photosynthetic zone which could further impact on seagrasses.
"Extending the rights of Cockburn Cement to dredge shell sand from the Owen Anchorage area for another 23 years beyond 2011 is a very big commitment for any government to make on behalf of the community it represents and not one Recfishwest believes should be made. If such extension is not given, presumably on EPA advice, then all the State has to do under the Agreement Act is to use every endeavour to find other resources. The State may adopt the position that in the better interests of Western Australia, a less convenient and more costly alternative may have to be adopted."
"There is now less than two more year's lead time to the end of the medium term proposal in which to find a solution to this problem. If a solution is not found and the current ERMP is approved then Cockburn Cement and the State will encounter the same problem in 2034. Recfishwest is very disappointed that little headway has been made in developing alternatives to shell sand mining in Owen Anchorage. We believe that this slow progress has largely resulted from CCL not being committed to the development of such alternatives, as Owen Anchorage has provided a very cheap source of high quality lime with the promise of further to come."
"Recfishwest understands that there is a benefit to State/society in having convenient access, as has been the situation in the manufacturing of lime/cement for many years. We further understand that developing alternative resources may well come with an additional economic cost, as is indicated in the ERMP. However we believe that this cost will be significantly outweighed by the greater benefit of reserving the remainder of the shallow waters for future generations as an excision from the State Agreement Act and gazetted as an "A" class reserve."
"Recfishwest believes that the time has now come to draw the line. The environmental values cannot continue to be compromised in favour of economic values to the point that irrecoverable damage and impacts have been produced."
Recfishwest challenged the EPA statements that "the seagrasses of Owen Anchorage do not support any commercial or recreational fishery" and "the view that there is a close, direct link between seagrasses and fisheries is a generalisation only and that the views of scientists are changing" with several paragraphs, including:-
"We contend that the type of fishing gear used in the ERMP sampling program was inappropriate, or at the least not optimal, for sampling fish species, particularly those species found in a seagrass or demersal habitat. As a consequence Recfishwest rejects the findings of the ERMP in respect to the fish populations present in Owen Anchorage area."
"... a direct quote from the CSIRO Division of Fisheries brochure 'Seagrasses': is "Seagrasses play a vital role in the marine food web....." and "In recognition of the importance of seagrass in respect to fish and fisheries, NSW Fisheries has published Habitat Protection Plan No 2, Seagrasses which was gazetted in September 1997. This plan aims to ensure that there is no net loss of seagrasses within the coastal and estuarine waters of New South Wales, and it prohibits or limits a wide range of damaging activities (such as dredging, reclamation, aquaculture and the construction of wharves and breakwaters) to help protect seagrass habitat."
1. It is the position of Recfishwest that the Cockburn Cement Long-Term Dredging proposal be rejected.
2. That Shellsand dredging in Owen Anchorage be phased out within a reasonable timeframe with CCL having to provide a statement of support as to which areas it wishes to access for this period. This statement must be available for community consultation and, at minimum, by way of a Public Environmental Review.
3. That the remaining areas of Parmelia and Success Banks must be given formal reserve status, preferably A class."
The club has written to the Enviroment Minister, in support of the Recfishwest position, as follows:-
20 January 2002
The Honourable Judy Edwards, Minister for Environment.
29th. Floor, Allendale Square, 77 St. George's Tce, Perth WA 6000
Owen Anchorage Shellsand Dredging Proposals.
This letter has been prepared on behalf of the members of the Surf Casting and Angling Club of W.A. The club currently has 74 adult and 13 junior members.
The club members are concerned at recent proposals covered by the Environmental Protection Agencies Bulletin 1033 on Long Term Shellsand Dredging in Owen Anchorage by Cockburn Cement Limited.
The club fully supports Recfishwest's appeal against these proposals, which was made on behalf of all recreational fishers.
In particular, the club is concerned at the very long term nature of the proposals. Extending the rights of Cockburn Cement to dredge shellsand from Owen Anchorage area for another twenty three years beyond 2011 is a very big commitment for any government to make on behalf of the community it represents and is not a commitment we believe should be made. We believe it is time for the true cost of such dredging to be recognised, and plans made for alternative sources of raw materials to be used as soon as possible. Any commitment should be for short periods only.
We believe that the proposal, as identified in the ERMP itself, fails to meet both the requirements of the Ministerial condition "that seagrass can be successfully rehabilitated", and the requirement "that due to Cockburn's shell sand dredging operations on Success Bank in Owen Anchorage, there be no net loss of present ecological and cultural function in the Cockburn Sound/Owen Anchorage area."
The report has identified that seagrass removed by dredging cannot be replaced, since it cannot be regrown economically, so the loss is effectively permanent. We also believe that seagrass is unlikely to re-establish naturally to any significant extent on dredged areas. We believe any further loss of seagrass from Owen Anchorage, on top of the 80% of seagrass which has already been lost from the nearby Cockburn Sound, is environmentally unacceptable. We cannot accept that plans for dredging should include areas containing seagrass, when it is also claimed that there are suitable areas without seagrass. These bare areas should be used until alternative sources are used.
The club urges that you do not commit the State and it's citizens to any further dredging beyond that which is essential to obtain the raw materials until the alternative sources are ready.
I can be contacted on for any queries.
Secretary, Surf Casting and Angling Club of WA (Inc.)
Some material summarised from published EPA Bulletin 1033 and Recfishwest's submission as shown. Remainder Copyright © 2002, Surf Casting and Angling Club of W.A. (Inc.)
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This page last updated 7 February 2002.
Display of this page was updated on 12 February 2009. Contents updated as above.