SMITH BAY WHARF DRAFT ENVIRONMENTAL IMPACT STATEMENT RESPONSE by Yumbah Aquaculture

MAY 2019

DISCLAIMER CONTENTS

This report has been prepared by Yumbah Aquaculture Ltd EXECUTIVE SUMMARY ...... 5 and may only be used and relied on by the South Australian INTRODUCTION ...... 10 Department of Planning and Infrastructure for the sole purpose of providing a public comment on the Environmental EPBC ACT - MATTERS OF NATIONAL ENVIRONMENT SIGNIFICANCE (MNES) ...... 12 Impact Statement prepared by Kangaroo Island Plantation COAST AND MARINE ...... 21 Timbers Limited for a “Deep Water Port Facility at Smith Bay, Kangaroo Island”. BIOSECURITY ...... 49 All intellectual property rights, including copyright, in ECONOMY ...... 61 documents and reports created by, or for, Yumbah AIR QUALITY ...... 65 Aquaculture Ltd remain the property of the company. Except for the use by the Department stated above, any use of such ALTERNATIVE LOCATION: ...... 70 documents or reports without the prior written approval of ALTERNATIVE STRUCTURES (IN WATER) ...... 76 Yumbah Aquaculture Ltd will constitute an infringement of the rights of the company which reserves all legal rights and COMMUNITY ...... 83 remedies in respect of any such infringement. Whilst Yumbah has made reasonable efforts to ensure the accuracy of third NATIVE VEGETATION AND FAUNA ...... 89 party sources, to the extent permitted by law, it disclaims any TRAFFIC & TRANSPORT ...... 92 liability associated with such sources. In certain cases, the opinions stated are the views of Yumbah (and not any WATER ...... 96 individual employee or agent of Yumbah) and are not NOISE & LIGHT ...... 101 intended as a substitute for comprehensive professional advice. CLIMATE CHANGE & SUSTAINABILITY ...... 108 RISKS & HAZARDS ...... 111 INFRASTRUCTURE ...... 117 ABORIGINAL & OTHER HERITAGE ...... 121 GEOLOGY & SOILS ...... 125 BUILT FORM & DESIGN ...... 130 CONSTRUCTION & OPERATION ...... 135

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DISCLAIMER CONTENTS

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ABBREVIATIONS (continued) ABBREVIATIONS KICRVMP Kangaroo Island Council Roadside Vegetation Management Plan ANZECC (Australian and New Zealand Environment and Conservation Council) KIDP Kangaroo Island Development Plan ARMCANZ Agriculture and Resource Management Council of Australia and New Zealand KIFA Kangaroo Island Futures Authority AVG Abalone Viral Ganglioneuritis KIPT Kangaroo Island Plantation Timbers BGL Below Ground Level MAZ Marine Activity Zone BIA Biologically Important Area MNES Matters of National Environmental Significance CCA Copper Chrome Arsenate NAGD National Assessment Guideline for Dredging CEMP Construction Environmental Management Plan NOEC No Observed Effect Concentration COD Chemical Oxygen Demand NTU Nephelometric Turbidity Unit CSD Cutter Suction Dredge OEMP Operational Environmental Management Plan DAC Development Assessment Commission OHS Occupational Health and Safety DAWR Department of Agriculture and Water Resources OIE World Organisation for Animal Health DEW Department for Environment and Water PAR Photosynthetically Active Radiation DMP Dredge Management Plan PIRSA Primary Industries and Regions, South Australia DO Dissolved Oxygen POMS Pacific Oyster Mortality Syndrome DPTI Department of Planning, Transport and Infrastructure PSD Particle Size Distribution EEZ Exclusive Economic Zone PSP Paralytic Shellfish Poisoning EIS Environmental Impact Statement TAPM The Air Pollution Model EMP Environment Management Plan TDS Total Dissolved Solid EPA Environmental Protection Authority TOC Total Organic Carbon EPBC Environment Protection and Biodiversity Conservation TSS Total Suspended Solids FTE Full Time Equivalent Yumbah KI Yumbah Kangaroo Island GRP Gross Regional Product

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EXECUTIVE SUMMARY

THE SMITH BAY PROPOSAL It is an entity managed from Sydney that has no social licence on Kangaroo Island, Kangaroo Island Plantation Timbers (KIPT) and an overly ambitious vision it expects KI proposes a deep-water seaport at Smith ratepayers or South Australian taxpayers to Bay, in a remote corner of Kangaroo Island underwrite. (KI), just over the fence from Yumbah Aquaculture’s onshore abalone farm. A 12.5-KILOGRAM OPINION EDITORIAL This is a destructive proposal that fails the Independent experts of good academic pub test, let alone the requisite scientific and scientific standing consulted by rigour required of the proponent. Yumbah Aquaculture, whose work It’s a proposal brought by a company that appears in this document, have somehow convinced a previous South assessed the draft EIS. Australian Government that it should be accorded status as a Major Development. In polite terms, they have many questions to ask KIPT and the South Australian Having achieved that, the proponent then Government, questions that aren’t set about persistent modification and answered in the draft EIS, or have been expansion of its proposal that makes a raised in their thorough review. mockery of the Major Development In less polite terms, the expert consensus process. is that KIPT’s draft EIS is a 12.5-kilogram KIPT is a proponent with no track record opinion editorial looking for a publisher. and no capabilities in building or managing infrastructure, conducting a profitable It should be marked “fail” – but not sent business, or operating sustainably in a back for a repeat. highly sensitive natural environment. Having failed to mount a case for Smith It is an ASX-listed shell, propped up by Bay, KIPT must be directed elsewhere – sequential capital raisings, employing just as Kangaroo Island Council has voted – to one of the many possible alternative four staff in 2018, and led by a Managing Island sites its draft EIS dismisses out Director who proudly told eminent finance of hand. 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.

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EXECUTIVE SUMMARY

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

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THE CASE FOR A FREIGHT PORT This proposal is unprecedented: massive RESPONSE TO DRAFT EIS UNAVOIDABLE RISKS AHEAD infrastructure cannot co-exist with an There is no argument that improved freight aquaculture business less than 400m In our response we present evidence to The draft EIS offers silence, dismissal and options for Kangaroo Island are desirable. away. challenge KIPT’s claims against all 19 ignorance on the risks and hazards of a Guidelines, from our perspective as seaport at Smith Bay. Yumbah Aquaculture is an exporter and, successful abalone farmers and with many other local KI businesses, sees The risk of introducing marine pests and AGAIN, WHY SMITH BAY? aquaculture specialists, as well as on benefit in improved infrastructure. behalf of those who live and work on diseases to Smith Bay could be reduced to Why the dogmatic pursuit of Smith Bay what the draft EIS argues is an There is no argument that KI should be rid Kangaroo Island. when a dozen or more alternative sites are “acceptable” level by adopting “the most of the plantations. These failed Managed closer to its plantations and KIPT already The most disturbing statement in the entire rigorous biosecurity standards prescribed Investment Schemes left KI burdened with owns another former export wharf site? draft EIS is the cavalier expectation that a by Biosecurity SA”. a low-value, low-yield monocultural land seaport can be built immediately adjacent, What is an acceptable level of marine use that destroys community. This Smith Bay jetty-to-wharf-cum-seaport 400m from an on-shore aquaculture pests being introduced to Smith Bay? KIPT is a price-taker, with a small volume of cannot be safely or cost-effectively enterprise with no negative impact. serviced by a sub-standard road network. For so many of its risk mitigation cheap, no-value-add, base global KIPT also purports its seaport will have no processes, KIPT simply asks to be “trusted” commodity woodchips, and no KIPT plans A-double road trains 24 hours a “significant” impact on Matters of National to do the right thing. This from a company consideration of alternative use or higher- day, seven days a week to and from its Environmental Significance. value end use. plantations to Smith Bay, but has no plan that cannot manage a simple dredging for who pays for the roads. Our response – and others submitting their test, let alone a major infrastructure project This proposal is bad economics. informed and expert opinions – calls out a and attendant risks. KIPT acknowledges its project will bring draft EIS that relies on flawed data and KIPT undertook unlicensed test drilling in more road risk, more vehicle accidents and assumptions without the support of TAKE THE TREES, BUT DON’T DESTROY Smith Bay, setting a precedent; the more dead wildlife. evidence-based science. AQUACULTURE destruction of seagrass is yet another flag It offers a biosecurity nightmare for a The real evidence demonstrates on inability or lack of appetite to build or To take the trees off KI is a good thing. shallow, clean water bay that is currently construction and operation of the operate complex infrastructure in a To commit KI to a future of more pest-free, promising to introduce exotic proposed seaport will have a direct and sensitive environment. plantations, more harvest rotations, fewer marine pests and diseases, cause immediate negative impact on Yumbah KI’s This “garbage in-garbage out” issue is jobs in seasonal contract labour, low skills deafness in whales, dredge up to 200 000 aquaculture activities located just metres obvious across the draft EIS, but most and reduced employment diversity is not cubic metres of seafloor to make a shallow away. apparent in the sample dredging that went what the Island needs. bay “deep”. Particularly galling for Yumbah and its so wrong but was still relied upon as Why would KIPT choose to deliberately It’s a proposal that touts economic benefit independent experts is KIPT’s reliance on credible information upon which to model drop a major port project on top of to the island but fails to account for the inaccurate, inexpert characterisation of scenarios. Yumbah Aquaculture, a world-class economic hit when a business like Yumbah abalone behaviour and husbandry that is KIPT’s unlicensed dredging farce was business that employs more than 25 highly KI is forced to relocate to another State misguided, flawed and incapable of followed by a combination of attempts to skilled KI locals – and could employ many where aquaculture is respected and supporting the proponent’s claims. drill into a rock-hard seabed with survey more? supported. coordinates that changed as the proposal A business that has grown sustainably for In simple terms, supported by a suite of grew, and finished with the use of scuba more than 24 years at Smith Bay? A scientific responses, on the evidence of divers using pipes and mallets. business whose major growth and this draft EIS, this proposal cannot proceed And from this garbage input, modellers diversification plans have been shelved at Smith Bay. were expected to offer substantive because of the risk KIPT’s Smith Bay findings. Instead, garbage out. proposal presents? Chemical and fuel spills are inevitable at a seaport; timber fumigation is required at

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ports handling logs; chemical leaching THERE IS NO SHINING LIGHT increasing water temperature not more particular concern given the proponent’s from timber used in construction or stored than 300 metres from Yumbah’s intake stated aim of selling the seaport to best at the port is real. The draft EIS is particularly misleading on pipes. serve its shareholders. Who will be Smith Bay lighting. responsible then? The draft EIS suggests mitigation of some While the draft EIS says causeway gates or of these risks – and others – but KIPT claims the major source of artificial culverts will help alleviate issues for lighting at Smith Bay is Yumbah which is acknowledges it can do nothing to Yumbah, KIPT also argues such mitigation CONCLUSION: THERE ARE continuously lit at night. This “major eliminate them. is “unnecessary”. BETTER PLACES source” consists of two single outdoor security lights. They are currently the only The Smith Bay EIS planning guidelines are OTHER USERS: AN UNKNOWN light source at Smith Bay. AN ECONOMIC FALLACY well posed, with 19 clearly defined areas of UNKNOWN concern. These are minimal and shielded from the KIPT and the draft EIS make great claims of The draft EIS forecasts timber will account abalone for one simple reason – abalone economic benefit from this proposal. A collective and individual review of the for just 20 per cent of the seaport’s feed predominantly at night, and onshore draft EIS says “fail”. No genuine cross-economy impact study is capacity. production mimics natural cycles by ensuring darkness at feeding times. provided, job claims are fanciful for a This proposal cannot stand on the sparse For KIPT shareholders to earn a facility operating at 20 per cent capacity, merits of a very poor draft EIS. commercial return, KIPT must identify and Anybody who has seen a working port at and no consideration has been given to To date, we have 187 unanswered cater for alternative uses. night will tell you it is brightly lit for non-port infrastructure costs, particularly operational and safety purposes. Will Smith roads. questions. Again, the draft EIS is silent. It fails to Bay be the first 24-hour seaport to operate They appear in this document. reveal, identify or consider risks and in the dark? There’s no accounting for tourism loss, hazards of other uses for what it presents road trauma cost, opportunity already lost They should be of concern to those who Escalated noise levels during construction as a multi-use facility. through Yumbah’s shelving of investment decide if Smith Bay is to be squandered, if and operations, on land and in water, will plans – and perpetual loss from a Yumbah and the promise of aquaculture The proposed seaport will affect air quality. negatively affect amenity, native species – shutdown of Yumbah. are to be driven off the Island and out of and the wellbeing of highly sensitive Woodchipping and stockpiled timber will South Australia, and if KIPT is cleared to abalone. “Monitoring” is proposed as the one-size- distribute airborne dust and particulate fits-all solution for everything from road establish a precedent that subordinates matter across Yumbah’s abalone farm, safety and pest invasion to heritage sustainable aquaculture and community presenting substantial risks for the farm. A CAUSEWAY OF SPOIL management and air quality. benefit for needless environmental destruction. But the draft EIS data are unreliable and The seaport proposal includes a rock- Monitoring is not a proxy for managing. If a seaport is to be built on Kangaroo patchy, raising doubt about the validity of armoured solid causeway extending 250 And notably, there is no exit strategy, no Island, it must and can be built at a the air quality assessment. metres offshore, 25 per cent longer than discussion of who will foot the clean-up bill the proposal originally submitted to the more suitable location. It proposes its own “control measures” but when it all goes horribly wrong. This is of Development Assessment Commission. gives no indication as to who will monitor these control measures and oversee The causeway will be built from dredge compliance and enforcement; where the spoil. Or not. KIPT’s inadequate, outdated immense quantities of water required for dredging tests leave another unknown: just air quality mitigation will come from; who what materials are in Smith Bay to actually will pay for the water; and how associated dredge? And with what impact on the impacts of this water use will be managed. 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

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INTRODUCTION SUMMARY State more welcoming of aquaculture and cognisant of the benefits we bring to The South Australian Government regional economies. YUMBAH’S SOUTH AUSTRALIAN STORY YUMBAH PORT LINCOLN must decide. Yumbah KI and the proposed KI Seaport Yumbah Aquaculture brings together Our Port Lincoln farm employs 35 FTE, Is it ongoing, year-round world-class cannot co-exist in the proximity proposed respect for Indigenous Australians with the and has an oyster hatchery pioneering aquaculture, economic diversification, and by Kangaroo Island Plantation Timbers. unique qualities of the Southern Ocean. the rebuild of the State’s oyster industry sustainable growth in skills and jobs for KI With permission from the traditional following a 2016 outbreak of Pacific Oyster and South Australia? Its “seaport” is just 400m from Yumbah’s custodians of the Yaygirr language we call Mortality Syndrome (POMS), which intake pipes. This is a proposal unlike any Or is it a limited-purpose industrial wharf ourselves Yumbah, meaning ‘larger decimated natural populations. other. A port is incompatible stacked next- that will forever scar Smith Bay - and be shellfish’. door to an aquaculture venture. used just 20 per cent of the time. The Southern Ocean brings nutrient-rich There are many alternative sites on KI for a YUMBAH AQUAFEED Plans for ongoing expansion at Yumbah KI, currents from deep Antarctic canyons to port to remove the timber, but these have particularly a massive investment in the shores of southern Australia, in a Consistent with our philosophy of not been seriously contemplated. They increased production, have been shelved phenomenon known as the Bonney sustainable and respectful production, should be. pending the decision of the South Upwelling. Yumbah Aquaculture’s farms in Yumbah Aquaculture makes its own Australian Government over this This wharf will damage our KI business South Australia, Victoria and Tasmania are predominantly soy flour-based feed at its detrimental use for Smith Bay. from the day the dredge starts turning. placed to take advantage of these waters. production facility in Lonsdale with a staff of five FTE. Our other South Australian investments – And that explains why Yumbah presents Yumbah has its most substantial and the jobs and skills that come with them this detailed rebuttal to the draft infrastructure investments in South – are likewise at risk if we are forced to Environmental Impact Statement for Australia, where a vertically-integrated YUMBAH PROCESSING close Yumbah KI and relocate to another a Smith Bay wharf presented by the model provides reliability with opportunity proponent. to scale and diversify. In 2017 these Yumbah’s Wingfield processing is the key investments were rewarded with the to preserving the natural qualities of company winning the National Yumbah Aquaculture’s farmed abalone. Agribusiness Exporter of the Year award. With a staff of 12 FTE, Yumbah Aquaculture uses natural brine or nitrogen freezing on- farm and ships to Wingfield where grading YUMBAH KANGAROO ISLAND and packaging is centrally managed and Yumbah’s value-added product lines are We came to KI in 1995, and in 24 years of developed and produced. 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.

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GUIDELINE 1: • MNES not genuinely considered Following referral under the EPBC Act, the Department deemed the proposal to o Dismissive response for an EPBC - build and operate a deep-water port wharf controlled action facility a ‘controlled action’, likely to have o False records on whales and a ‘significant impact’ on many matters EPBC ACT - MATTERS OF NATIONAL other species of national environment significance. Facile recommendations for ENVIRONMENT SIGNIFICANCE (MNES) o The executive summary accompanying the mitigation of damage draft EIS submitted by KIPT is 78 pages DESCRIPTION: • Commonwealth marine areas (sections in length. Only two pages, less than 3 per 23 & 24A) – while it is understood the EPBC STATEMENT HOLDS TRUE cent of a document titled ‘Environmental Impact Statement’ deals with matters of The Commonwealth Minister for the action is proposed to be taken outside On 24 November 2016, Yumbah submitted national environmental significance. Those Environment and Energy has determined a Commonwealth marine area, the a formal response to the Department of two scant pages summarise the impacts as (EPBC no.2016/7814) that the proposed assessment documentation must Environment and Energy following the negligible and agree to an offset to action is likely to, or may have, a significant consider if there is a real chance or submission of KIPTs Smith Bay referral compensate for the ‘worst-case’ outcome impact on the following controlling possibility that the action will impact a under the Environment Protection and of killing of the ‘relatively common’1 provisions (matters of national Commonwealth marine area, for Biodiversity Conservation Act 1999 Kangaroo Island Echidna. This derisory and environmental significance (MNES)): example, because the action will have (EPBC Act). pitifully inadequate response is insulting to a substantial adverse effect on a • Listed threatened species and the gravity and seriousness of the population of a marine species such as At this time Yumbah expressed concerns communities (sections 18 & 18A) requirement to respond to a ruling of a a cetacean including its life cycle (e.g. about the practices employed by KIPT, and controlled action under the EPBC Act. including but not limited to: breeding, feeding, migration affirmed that the company: Yumbah has mounted a consistent case the endangered and migratory behaviours, life expectancy) and spatial o “… demonstrably failed to consult, does that this proposal presents a threat to southern right whale (Eubalaena distribution. not negotiate with concerned or even Smith Bay, to Yumbah’s operations at australis) curious Kangaroo Island stakeholders, Smith Bay, and to the wider interests dismisses the likely impacts of its proposal o the endangered Kangaroo Island of Kangaroo Island. Echidna (Tachyglossus aculeatus RESPONSE SUMMARY on the natural fabric of Kangaroo Island, and cannot argue the relative merits of multiaculeatus) • What Yumbah said in 2016 holds true: the vulnerable Hooded Plover (eastern) Smith Bay over other wharf sites on the o Island.” (Thinornis rubricollis rubricollis) o KIPT fails the EPBC requirement on rigour o the Southern Brown Bandicoot This Yumbah statement of nearly three (eastern) (Isoodon obesulus obesulus) o Evidence is ignored and falsities years ago comprehensively describes the offered cultural mindset of this company. It doesn’t • Listed migratory species (sections 20 augur well for Smith Bay let alone &20A) including but not limited to: • Precedent on Smith Bay has wide Kangaroo Island, particularly when this ramifications draft EIS is addressing only part of the the endangered and migratory o moving and expanding feast that is KIPT’s southern right whale (Eubalaena Not just Smith Bay; sustainable o Smith Bay plan. australia) aquaculture industry is threatened by KIPT o a number of species of pipefish will be lost with the removal of 10ha of seagrass (Syngnathid spp.)

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PRECEDENT THREATENS SPECIES, Nationally threatened species include: The EPBC referral and draft EIS • The Australian Sea-Lion, subject to SUSTAINABLE AQUACULTURE concentrates its attention on the “unknown impact” from the proposal • southern right whale (Eubalaena following four species: Further, and with reference to the EPBC australis) • 20 Syngnathid species recorded Act, any willingness to allow KIPT to • Southern right whale in the area proceed with this action creates a • Humpback whale (Megaptera precedent that will set back the cause of novaeangliae) • Kangaroo Island echidna • A single patch of the Kangaroo Island sustainable aquaculture around Australia. Narrow-leaved Mallee (Eucalyptus • Blue whale (Balaenoptera musculus) • Hooded plover (eastern) cneorifolia) Woodland Ecological Smith Bay’s significance as a Coastal • Southern brown bandicoot (eastern) Conservation Zone, with species of State • Australian sea-lion (Neophoca cinerea) Community on the adjacent southern and Commonwealth significance is neither property fence line that has potential • Great white shark (Carcharodon Additional EPBC-listed species that respected nor sufficiently recognised by to meet the size category for carcharias) are endemic to the region and have KIPT. the potential to inhabit or forage the a threatened community. Its draft EIS fails to appropriately value the • Loggerhead turtle (Caretta caretta) site include: The image below is of a white bellied sea- ecology of the area and seeks to diminish eagle flying past KIPT’s wave monitoring • Leatherback turtle (Dermochelys • bird species that fly over the site and the environmental values so widely buoy at the proposed site for its Smith Bay coriacea); and along the coastline, including white recognised by others – and still being bellied sea-eagles that nest within seaport. revealed by the actions of citizen scientists • Green turtle (Chelonia mydas) 3.5km of the site, sooty oystercatchers, such as AusOcean.2 In addition to nationally listed species, ruddy turnstones, Australian fairy tern, This proposal is incompatible with the state-listed marine species potentially Pacific gull and the endangered Glossy natural landscape. occurring in the area include: Back Cockatoo that inhabit two areas near the site • Pygmy right whale (Caperea KIPT TOLL ON EPBC-LISTED SPECIES marginate)

The draft EIS records 46 EPBC-listed • Pygmy sperm whale (Kogia breviceps) migratory species within 10km of Smith Bay, including: • Dusky dolphin (Lagenorhynchus obscurus); and • Eight threatened (endangered or vulnerable) marine species, which • Strap-toothed whale (Mesoplodon comprise mainly whales and turtles layardii)

• 32 nationally listed marine species, Each of these is listed as rare. which include three seal species, three The EPBC referral and draft EIS considers turtles and 26 syngnathid species only five marine mammals, one shark and (seahorses and pipefish) 15 species of pipefish are likely to occur, • 12 species of whales or dolphins or may possibly occur at times, in Smith Bay. • 12 migratory marine species

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

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

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

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

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JUST ONE DAY IN THE FIELD CHOOSE WHICH SPECIES SOUTHERN RIGHT WHALE population of the southern right whale TO RECOGNISE which is showing little evidence of Despite the ecological riches stepped The Main report (page 223) recognises: recovery, the loss of a female individual out above, and its responsibility to satisfy The draft EIS recognises that the Kangaroo 3 “Of particular conservation interest in the would be considered significant.” the needs of the EPBC referral, to fill out Island echidna is restricted to Kangaroo region are the southern right whales that the pages in its draft EIS, KIPT completed Island and its population is declining due A ferry travelling between mainland South migrate along the north coast of Kangaroo just one terrestrial ecological survey over to predation by cats, pigs and road Australia and Kangaroo Island struck and Island every winter.” one day in 2016. mortality. Echidna scratchings were killed an adult southern right whale in observed in 2016. 2001, so the population has already been Its conclusion from this walk-past is an Risks to the south-east Australian subpopulation of southern right whales impacted by vessel strikes. unequivocal confirmation (for the purpose A community of southern brown include acute industrial noise, of EPBC approval and EIS approval) that bandicoots are known to reside at the rock Data analysis for the period 2006 – 2018 infrastructure/coastal development (wharf based on one single field survey for one reserve on the western side of KIPT’s site. confirms sightings of 69 large whales in construction, dredging and pile driving), day no individuals protected under Federal Smith Bay: 57 southern right whales, nine The potential impacts of construction and vessel collisions and shipping noise. KPT and State legislation are present on its site. humpback whales and three unconfirmed operations on MNES are ignored by KIPT’s largely ignores the impact of coastal species. Of the southern right whales, 12 How can a proponent be granted draft EIS. development on cetaceans and has not Commonwealth and State approval adequately addressed the risk of injury or females and 17 calves/juveniles were for a major project requesting permission To reference Table 5-4 again: death of whales by vessel strikes because confirmed, while the gender of 28 were to destroy their preferred site and “A recovery plan exists for the southern of the seaport traffic. unconfirmed (Tony Bartram, pers. Comm). potentially affect matters of national Data regarding the dolphin populations right whale. KIPT would manage the The Draft National Strategy for Mitigating environmental significance into perpetuity also shows high levels of construction and operation of the KI Vessel Strike of Marine Mega-fauna states: based on a single survey conducted for Seaport so as to minimise the risk of transience/migration through Smith Bay. one day? any consequential harm to southern “The risk of vessel collision is a known There is no question that Smith Bay is right whales.” threat for Australia’s marine mega-fauna”, including whales, dolphins and porpoises. displaying the attributes of a Biologically THEY’LL JUST GO SOMEWHERE ELSE This statement appears to exclude and Records show southern right whales are Important Area (BIA) for southern right disregard other species this seaport will whales. BIAs are not defined under the Table 5-4 of the draft EIS (Section 5) notes: frequently struck by vessels in Australian likely impact. waters, with 12 per cent of strikes from EPBC Act, but they are areas that are “Three of the species identified in the KIPT is brazen in assuming a seaport in 1997 to 2015 affecting southern particularly important for the conservation referral notice under the EPBC Act are also Smith Bay will have negligible impact on right whales. of protected species and where protected under the National Parks and MNES. Locating a seaport of the size and aggregations of individuals display Wildlife Act. They are the southern right KPT’s assertion that incidents of vessels scale proposed in Smith Bay, within a “occasionally” striking whales are biologically important behaviour such as whale, hooded plover (eastern) and 4 widely recognised area renowned for “extremely rare and would not be capable calving, foraging, resting or migration. southern brown bandicoot (eastern).” sheltering populations of southern right of affecting the population of southern KPT’s repeated defence is that affected whales fails on science - and fails on right whales” is at odds with the species “…are likely to temporarily responsibility. Commonwealth which states: move…”; or “…being highly mobile, would

relocate to alternative habitat that is “In the case of a species that is recovering, abundant throughout the region”. 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 Smith Bay Wharf Environmental Impact Statement Yumbah Response 16 Smith Bay Wharf Environmental Impact Statement Yumbah Response 17

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DRAFT EIS IS WRONG The truth as revealed by registered whale THE WHALES OF SMITH BAY “I have noticed that once the juvenile sightings in Smith Bay since 2006 include begins to play openly, showing the The draft EIS Main report (page 247) 57 confirmed southern right whales, nine Yumbah KI’s General Manager, David strength to frolic around its mother and is definitive: humpback whales and three unconfirmed Connell, provides a personal capable of making small lunges out of the communication about his observation of “There is no evidence that Smith Bay is an species (Tony Bartram, pers. comm. water, it’s only a day or so and they will 22 May 2019). whales in Smith Bay, titled A memory never be gone. important site for southern right whales. to be forgotten. Although Smith Bay lies within an area Further, whales are regularly observed in “The most impressionable experience I described as the ‘current core coastal Smith Bay at the front of Yumbah KI. “Between 1999 and 2019 I have had the have had was in the Spring of 2011 where range’ for these animals (DSEWPaC 2012), privilege of watching the southern right a mother just following birth, lay so close it is not near a known aggregation area This is consistent with whale sightings in whales frolic, nurse and give birth in Smith to shore you could feel her breath passing and is at the edge of a ‘historic high use’ locations across the Southern Ocean Bay. As time has passed the visiting through the rocks. area. Records of southern right whale where abalone farms are located, including frequency and numbers has been on the sightings around Kangaroo Island provide Port Fairy and Narrawong (Victoria), Port increase. “On a dead calm evening, just sitting on evidence that they visit Smith Bay Lincoln and Kangaroo Island (South the ironstone shoreline while her breath only infrequently.” Australia) and Bicheno (Tasmania). “My initial encounter was a solitary mother vibrated through my body, is a memory sheltering in the bay with her calf and over never to be forgotten. This is simply not true. Whales matter, and their increasing the years the numbers grew as I became presence is affirmation that something accustomed to when to expect them and “Smith Bay has an ironstone reef that runs The draft EIS claims only ever one is right with the world. where to keep a look out. parallel to its shores. I believe the mothers registered sighting of the southern right feel this is great protection for their young. whale in Smith Bay. “At first it was birthing mothers and then The bay has minimal sand so even in the addition of mothers with juveniles. KIPT must surely have known that their onshore wind days water clarity is claim of one registered sighting was false “In 2018 a group of three played in the very good. from personal experience. In 2017 the waters for several days as if it was their “It’s common to see the dolphins and vessel commissioned to perform preferred place to be. whales interacting. It’s obvious they have investigative “drilling” of Smith Bay scared “Birthing mothers arrive and pace the bay respect for each other and do a mother and calf from the bay. just as any expecting mother paces her regularly co-exist. surroundings. “I have at times had multiple mothers in “Although I haven’t witnessed a birth, you the bay at the same time, all with young. can always tell it’s happened as by “Interestingly they will be close from morning she will be very close to shore, so evening to morning but generally will shallow her belly must be resting on the spend the day alone with their young. sea floor. It doesn’t take long before you Quite the sight to see three mothers all spot a little head close by her side. with their heads within 10 metres of each “Left alone without interruption, a mother other, as if they are up for a chat and three will remain in the bay until their juvenile is young, dashing around them like kids in strong enough to take on the open water. the playground. This time frame is usually around the 10- “To date Smith Bay is a place of refuge for day mark, but it has taken as long as 14 these whales and many other species. days for one young one, that I did think wasn’t going to make it. “Let’s hope we can keep it this way.” “Total time spent for a mother has been as long as four weeks from arrival until departure.

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

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18 Smith Bay Wharf Environmental Impact Statement Yumbah Response

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 Yumbah Response 18 Smith Bay Wharf Environmental Impact Statement Yumbah Response 19

Smith Bay Wharf Environmental Impact Statement Yumbah Response 19

GUIDELINE 2: KIPT DRAFT EIS FAILS EPBC TEST

Yumbah submits that KIPT fails to accurately represent the extant ecological values at its preferred seaport COAST AND MARINE site. The lack of consideration of the site and DESCRIPTION: This response will demonstrate that flawed scant information in the draft EIS suggest data and assumptions in the draft EIS have to Yumbah that this proponent has no As the proposed development is within, resulted in a “garbage in – garbage out” regard for Smith Bay as a Coastal and directly adjacent to, the Coastal conclusion paraded as evidence-based Conservation Zone, and lacks concern Conservation Zone of Smith Bay, there will science. for the ecological values across the be direct impacts to this sensitive environment. The environment and its The real evidence will support common development footprint that sense and demonstrate that the warrant protection. ecological values of the area must be further understood to accurately identify construction and operation of the the impacts from the construction and proposed seaport involving dredging of 3 operation of the development, and to potentially 200,000 m of environmentally determine appropriate measures to valuable seabed will have a direct negative

manage, offset or mitigate these impacts. impact on Yumbah KI’s aquaculture Although the area is not within a Marine activities located but metres away. Park (State), the construction and Furthermore, the reliance of the draft EIS operation of the proposal, including the on an inaccurate and inexpert passageway of ships to and from the port characterisation of abalone behaviour and and wharf may still have impacts on the husbandry and the likely impact of the neighbouring Marine Parks (i.e. Encounter Seaport on the Yumbah KI farm is shown to and Southern Spencer Gulf Marine). be misguided, flawed and incapable of supporting its invalid claims. SUMMARY RESPONSE Yumbah has therefore engaged marine specialists, scientists and industry experts Construction of this proposed seaport will to review the draft EIS and inform this dramatically modify the coastal habitat of section of our submission. GHD Pty Ltd Smith Bay. Impacts include alteration to (GHD) reviewed the predicted water quality sediment transport processes, both impacts outlined in the draft EIS, with a through hydrographical modifications primary focus on Appendix F (Marine caused by dredging and through reflection Water Quality) of the draft EIS, which is of waves from the seaport structures. presented in four sections: The draft EIS however attempts to • Assessment of Marine Sediments persuade the reader through the conclusions of consultants reports • Hydrodynamic Modelling that the seaport can be constructed with no negative impact on the • Marine Water Quality Baseline and immediately adjacent abalone farm. Impact Assessment It further argues that no “significant” impact will occur to matters of national • External Hydrodynamic Modelling environmental significance. Peer Review

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20 Smith Bay Wharf Environmental Impact Statement Yumbah Response

GUIDELINE 2:

COAST AND MARINE

DESCRIPTION: This response will demonstrate that flawed data and assumptions in the draft EIS have As the proposed development is within, resulted in a “garbage in – garbage out” and directly adjacent to, the Coastal conclusion paraded as evidence-based Conservation Zone of Smith Bay, there will science. be direct impacts to this sensitive environment. The environment and its The real evidence will support common ecological values of the area must be sense and demonstrate that the further understood to accurately identify construction and operation of the the impacts from the construction and proposed seaport involving dredging of 3 operation of the development, and to potentially 200,000 m of environmentally determine appropriate measures to valuable seabed will have a direct negative manage, offset or mitigate these impacts. impact on Yumbah KI’s aquaculture Although the area is not within a Marine activities located but metres away. Park (State), the construction and Furthermore, the reliance of the draft EIS operation of the proposal, including the on an inaccurate and inexpert passageway of ships to and from the port characterisation of abalone behaviour and and wharf may still have impacts on the husbandry and the likely impact of the neighbouring Marine Parks (i.e. Encounter Seaport on the Yumbah KI farm is shown to and Southern Spencer Gulf Marine). be misguided, flawed and incapable of supporting its invalid claims. SUMMARY RESPONSE Yumbah has therefore engaged marine specialists, scientists and industry experts Construction of this proposed seaport will to review the draft EIS and inform this dramatically modify the coastal habitat of section of our submission. GHD Pty Ltd Smith Bay. Impacts include alteration to (GHD) reviewed the predicted water quality sediment transport processes, both impacts outlined in the draft EIS, with a through hydrographical modifications primary focus on Appendix F (Marine caused by dredging and through reflection Water Quality) of the draft EIS, which is of waves from the seaport structures. presented in four sections: The draft EIS however attempts to • Assessment of Marine Sediments persuade the reader through the conclusions of consultants reports • Hydrodynamic Modelling that the seaport can be constructed with no negative impact on the • Marine Water Quality Baseline and immediately adjacent abalone farm. Impact Assessment It further argues that no “significant” impact will occur to matters of national • External Hydrodynamic Modelling environmental significance. Peer Review

Smith Bay Wharf Environmental Impact Statement Response 21

Smith Bay Wharf Environmental Impact Statement Yumbah Response 21

A review of Appendix G (Coastal refusal” which indicates by the proponent. Furthermore, the loss of habitat is covered elsewhere in Processes) and Appendix T (Risk unconsolidated material, possibly rock sand component of sediment this report. Smothered intake pipes, Assessment) has also been completed. that may need to be ground to achieve estimated cannot be validated as increased pumping costs, increased The findings are titled KIPT Smith Bay the desired approach and berth depth. sediment in the deeper profile has not detritus and lower oxygen Wharf Draft EIS Review of Predicted Water been assessed; in essence, less than concentration are among the impacts. The claim of equivalence of core Quality Impacts (Romero, 2019) presented 30 per cent of the sediment has in Appendix 1 of this submission. samples made with a drilling rig and • Noise and vibration been profiled. those obtained by a solitary Scuba Professor Paul McShane undertook a Noise and vibration during construction diver with a hammer and tube are Therefore, the model does not thorough technical review of Appendix H. and operation will impact marine farcical. This is further borne out by consider the full extent of impact, Professor McShane is highly regarded and mammals, potentially causing their own evidence that the seabed is distribution of sediment, plumes, settle internationally recognised for his expertise temporary or permanent hearing loss. on fisheries biology and the early life not homogenous – for example total ability, concentration, reduction in Amenity of Smith Bay will be forever history of abalone. His review is presented organic carbon (TOC) was reported at photosynthetically active radiation changed with the 24-hour continuous in Appendix 2, titled Smith Bay Wharf significantly higher concentrations in (PAR) or intake at pipes. In the light of operation of an active seaport in an Response to Draft Environmental Impact the one deeper sample. this the Dredging program and otherwise uninterrupted Coastal Statement Kangaroo Island Plantation proposed mitigation must be Yumbah does not have issue with Conservation Zone. Timbers (McShane, 2019). completely reassessed as what is the methodology of the modelling proposed in the draft EIS is Issues identified from the draft EIS as performed rather we question each • Mobilisation of fine sediments completely flawed. having a significant impact on the and every piece of input to the models. coastal and marine environments of The construction of a 250m causeway Widely attributed to an IBM In summary, due to the significant flaws Smith Bay include: in this location, a capital dredging programmer, George Fuechsel, and lack of adequate characterisation program of an unconfirmed volume of • Inadequate sediment characterisation “Garbage in – Garbage out” is an apt of sediment, Yumbah has no spoil, tailwater discharges from metaphor for what happens when confidence in the outcomes of the dewatering of sediments on land, In summary KIPT have failed to flawed data is fed into a system models and the suggested impacts maintenance dredging and shipping determine exactly the composition of producing, unsurprisingly, nonsense associated with dredging. operations will create turbid plumes the seabed that they plan to excavate. output or garbage. that will extend for kilometres. Because of this every conclusion that • Reduced circulation as a consequence the draft EIS makes relating to Even the data revealed by the of the causeway • Ecotoxicology dredging is suspect and invalid. incomplete sampling is flawed. The discovery of the hard substrate of A 250m solid impermeable causeway One assay performed on abalone Sampling results are presented where Smith Bay as evidenced by core refusal is proposed to be constructed, for 24 hours is in no way an the majority of samples are outside of suggests that Cutter Suction Dredge extending perpendicular to the coast. ecotoxicology assessment to invent the dredge area and therefore cannot (CSD) grinding may have to be used to As a consequence, oceanic currents guideline trigger values for total be claimed to be representative. excavate the seabed. The fine have been estimated to reduce by at suspended solids well in excess of least 30 per cent, changing the Sediment sampling depths are not material (Class 3) produced by the well-established and recognised hydrodynamic conditions of Smith Bay adequate as they do not extend to the grinding is not even contemplated or national water quality guidelines. modelled by the proponent. Its volume forever. depth of dredging. This is contrary to • Algal blooms the National Assessment Guidelines for is unknown and particle size • Drift algae, wrack accumulation Dredging (NAGD) (2009) which require distribution (PSD) is unknown. Changes to the light environment, Increased mortality, reduced PAR from that the full depth be characterised. Likewise, the propensity of this class 3 reduced circulation of nearshore material to remain suspended in the sediment plume and increased waters and elevated water Locals know that the seabed is hard water column for a longer duration turbidity will further compromise temperatures increase the risk of and composed of what is referred to as than the settling velocities measured survival of seagrass and macroalgae. harmful algal blooms at Smith Bay with “ironstone”. The unsurprising failure to for the shallower, unconsolidated This has not been modelled nor potential catastrophic impacts on drill into this hard floor is described in sediment has been completely ignored simulated however the destruction of Yumbah’s farmed abalone. the proponents reports as “core 10ha of seagrass and the impact of the Smith Bay Wharf Environmental Impact Statement Yumbah Aquaculture Response 22 Smith Bay Wharf Environmental Impact Statement Yumbah Aquaculture Response 23

22 Smith Bay Wharf Environmental Impact Statement Yumbah Response

Smith Bay Wharf Environmental Impact Statement Yumbah Response 23

• Light-spill onto the abalone farm INADEQUATE ASSESSMENT OF MARINE SAMPLING AND ANALYSIS Analysis of sediment has been conducted SEDIMENTS on 17 samples, 11 of which are actually The seaport will create continuous The sediment sampling is flawed and, as a located with the dredge pocket. Thus 35 night light, emanating from the The impact of suspended sediment from consequence, the results and outputs of per cent of all information presented in the proposed infrastructure in the hard- dredging has potential catastrophic the various models completed to inform EIS is derived from samples outside the standing area and along the implications for Yumbah KI. The the draft EIS cannot be relied upon. dredge area. No reason has been given for assessment of sediments proposed for wharf/causeway as well as from Appendix 1 confirms the sampling and the logic in sampling outside the dredge dredging is of critical importance. Sampling transport vehicles. Light adversely analysis of the seabed is deficient and area – in fact there can be no valid reason. and analysis of dredge spoil provides an affects feeding and growth of abalone. does not provide an adequate description The inclusion of this data by KIPT casts understanding of the environmental of the sediments to allow an assessment of doubt on their ability to mitigate other risks acceptability of dredged material, • Changes in coastal processes the potential impacts of its disturbance through management intervention. management alternatives and means to (Romero, 2019). Primarily associated with the construction minimise and manage potential impacts. Samples have been collected generally of the causeway, changes would affect The draft EIS provides detail of the results The sampling location presented in the from a maximum depth of 80cm below the nearshore circulation with potential to: of the sediment sampling for the purpose draft EIS appears to have been completed surface with one sample extracted from of characterising the geotechnical across a grid that is located both within 1.4m below the seabed. As the proposed Increase the temperature of Yumbah’s o properties for potential reuse and also and external to the proposed dredge area. dredge depth is a maximum three metres, intake water due to reduced mixing in understanding the physicochemical It is presumed the sampling, conducted sediment sampling and ultimate the vicinity of the causeway with parameters of the material that will be over two distinct events in 2017 and 2018 characterisation of the physicochemical potential lethal impact on farmed disturbed for the purpose of understanding using different methods (drilling and properties including Particle Size abalone; and potential environmental impacts and fate SCUBA) was largely based on a previous Distribution (PSD) is fundamentally flawed. o Changed sedimentation and of sediment. dredge footprint. 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.

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24 Smith Bay Wharf Environmental Impact Statement Yumbah Response

• General impact to marine ecology The Smith Bay environment is renowned for its extensive seagrass meadows and species listed under the Commonwealth EPBC Act.

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Smith Bay Wharf Environmental Impact Statement Yumbah Response 25

POOR SEDIMENT CHARACTERISATION The first survey with core acquisition (via 10 tonnes of drilling hydraulic pressure) Target core/sediment acquisition depths yielded low penetrations prior to core are inadequate to describe the sediment refusal consistently below one metre for all quality and PSD of the proposed material samples except for site SB7.2, the one to be dredged. The sediment has been location where sediment was extracted at poorly characterised, particularly the hard 140cm. substrate (consolidated) beneath the well- characterised veneer of unconsolidated- The interpretation of the geotechnical / weakly shallower consolidated sediments. borehole data in Section 5.2 cannot be Due to the poor characterisation of confirmed for >1-3 metres of marine sediment to be dredged, the worst case for sediments because the core refusal depths PSD and settling velocity cannot be relied were at one metre (except for SB7.2 on. Estimates should be further explored outside of the dredge pocket) during the with additional sediment sampling and drilling rig sediment sampling survey. modelling. This indicates the presence of a very hard While the proposed maximum dredge substrate (possibly consolidated material) depth is about three metres, sediment was underlying a veneer of unconsolidated only sampled in depths ranging from 25cm sediments that may require Cutter Suction to 80cm, with only one sample extracted Dredge (CSD) grinding, and subsequently from 140cm. Analysis of this deeper core a third class (Class 3) of dredge material. presents a much smaller PSD for the The CSD has the potential to generate very fine particles from the dredge-header Figure 3 – Locations of sediment samples deeper sample subset. Information is lacking on the depth intervals analysed in grinding the hard substrate into material this core. This deeper sample is outside and small particle diameters not commonly the dredge footprint and hence cannot be distributed in the marine environment. relied on to characterise particle size in the Assumptions about the behaviour and ultimate fate of dredged sediment in the water column This material will ultimately have the deeper sections of the dredge footprint. cannot be drawn from an incomplete sampling program. The NAGD (2009) is the primary propensity to remain suspended in the framework and default guidance to ensure the impacts of dredged material loading and Appendix 1 provides further context for the water column for a longer duration and disposal are adequately assessed and that impacts are managed responsibly and effectively5. significant gaps in the sediment sampling distance than the settling velocities and analysis plan and interpretation based measured for the shallower, The NAGD (2009) requires that the full depth of dredging is to be characterised in order to on shallow characterisation of the dredge unconsolidated sediment. inform the dredge methodology and predict the potential environmental impact. material. Core penetration depths The draft EIS Appendix F reports that ranged from: sediment in Smith Bay consisted mainly of • ~60cm at sites ZZ3-ZZ8 (presumably sand and gravel with between 10 and 25 via diver during second survey) per cent of fine particulates (clay and silt), apart from the deeper sediment at Site SB7 • 8 of 12 sites during the first survey (SB7.2), with SB7.2 having the finest were ≤25cm particles. The evaluation of sediment as 75 per cent coarse sands is incorrect. This • 3 of 12 sites during the first survey conclusion cannot be validated as were 50-80cm sediment in the deeper profile has not been assessed; in essence, less than 30 • 1 of 12 sites (site SB7) during the first per cent of the sediment has been profiled. survey had a penetration depth >1m

(140cm)

5 http://www.environment.gov.au/marine/publications/national-assessment-guidelines-dredging-2009 Smith Bay Wharf Environmental Impact Statement Yumbah Aquaculture Response 26 Smith Bay Wharf Environmental Impact Statement Yumbah Aquaculture Response 27

26 Smith Bay Wharf Environmental Impact Statement Yumbah Response

(140cm)

Smith Bay Wharf Environmental Impact Statement Yumbah Response 27

of SB7.2. importance to understand the fate of extending perpendicular to the coastline. disturbed sediment. The causeway is the most concerning On the basis of the core refusal depth, Two dredge material sediment classes physical feature of the seaport for Yumbah. the evidence alludes to a relatively thin were configured as dredging The characterisation of sediment in the veneer of marine sediments (primarily simulation inputs. draft EIS is further discounted as the The causeway will significantly reduce sand) with perhaps some scattered settleability reported in the draft EIS is on ocean currents by up to an estimated 40 Class 1, comprising 75 per cent of the total relatively deeper pockets of finer material the basis of four shallow sediment samples per cent, which in turn will result in simulation dredge volume, was (e.g. site SB7.2), and underlying sediments with penetration depths of 20-25cm (SB3 elevated water temperatures, reduced representative PSD of all sediment comprised of a harder substrate and SB11) via the drill rig, to ~60cm (ZZ4 mixing and supply of fresh water, samples reported in Sub-Appendix F1 (consolidated material). and ZZ9) via SCUBA. accumulation of seagrass wrack and except for sample SB7.2. overall compromise the oceanic conditions If so, then this would support a third class The settleability of the sediment cannot be abalone are so reliant on. Class 2, comprising the other 25 per cent (Class 3) of dredge material. As a confirmed based on limited shallow of the total simulation dredge volume, was consequence of sampling not conducted samples collected from both within and Oceanic currents are vital to abalone based on one deep sample of SB7.2 for the full dredge depth, there is also outside of the dredge footprint. farming. Circulation and mixing of marine (maximum 1.4m). considerable uncertainty regarding the waters guarantee the high-quality Particle Size Distribution (PSD) and settling Settleability needs to consider the deeper seawater that sustains the abalone. Uncertainties highlighted in Romero’s velocities of the material generated by the unconsolidated and consolidated (noting Reduced seawater quality will significantly review with regard to the sediment CSD. The PSD of the sediments released that small particle sizes are likely to be impact Yumbah’s ability to continue its sampling core depths and extrapolation to into the marine waters will potentially pose generated during CSD grinding) sediment business. the dredge depth (core refusal generally a much greater impact/risk in terms of a horizons. The draft EIS cannot rely on <60cm) and the inclusion of sediment worst-case scenario than the duration and settleability based on a small subset of characteristics outside the dredge area, amount samples that comprise only 25 per cent of the assigned volumes of 75 per cent for of dredging. the proposed maximum dredge depth. Class 1 (primarily sand) and 25 per cent Class 2 (greater proportion of clay and silt) A potential CSD grinding of consolidated Due to the significant flaws and lack of cannot be relied upon. sediments (Class 3) scenario may lead to adequate characterisation of sediment, greater dredging related turbidity than Yumbah has no confidence in the A worst-case Class 3 of dredge material for predicted in the draft EIS and will outcomes of the models and the a reasonable worst-case estimate is valid potentially have greater impacts on suggested impacts associated with given the information available and primary producer benthic habitat (e.g. light dredging. potential interactions between the CSD reduction to proximal seagrass) and and the harder (consolidated) sediments of Yumbah KI’s inlet water. the deeper strata of the dredge area. This demands additional modelling for a worst- Further, removal of Class 3 sediment will case dredge material characterisation that result in dredging far exceeding the includes worst-case estimates from estimated worst case of 75 days. dredging of the third class and worst-case

dredge volume allocations to the three classes.

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28 Smith Bay Wharf Environmental Impact Statement Yumbah Response

To further raise doubt in the results in The issues in interpretation of the SETTLEABILITY CONCERNS IMPACTS OF THE CAUSEWAY Appendix F, total organic carbon (TOC) sediment sampling and analysis was reported at significantly higher are significant. An understanding of the settleability of the An important feature of the seaport is the concentrations in the one deeper sample dredge material is of paramount construction of a 250m solid causeway of SB7.2. importance to understand the fate of extending perpendicular to the coastline. disturbed sediment. The causeway is the most concerning On the basis of the core refusal depth, Two dredge material sediment classes physical feature of the seaport for Yumbah. the evidence alludes to a relatively thin were configured as dredging The characterisation of sediment in the veneer of marine sediments (primarily simulation inputs. draft EIS is further discounted as the The causeway will significantly reduce sand) with perhaps some scattered settleability reported in the draft EIS is on ocean currents by up to an estimated 40 Class 1, comprising 75 per cent of the total relatively deeper pockets of finer material the basis of four shallow sediment samples per cent, which in turn will result in simulation dredge volume, was (e.g. site SB7.2), and underlying sediments with penetration depths of 20-25cm (SB3 elevated water temperatures, reduced representative PSD of all sediment comprised of a harder substrate and SB11) via the drill rig, to ~60cm (ZZ4 mixing and supply of fresh water, samples reported in Sub-Appendix F1 (consolidated material). and ZZ9) via SCUBA. accumulation of seagrass wrack and except for sample SB7.2. overall compromise the oceanic conditions If so, then this would support a third class The settleability of the sediment cannot be abalone are so reliant on. Class 2, comprising the other 25 per cent (Class 3) of dredge material. As a confirmed based on limited shallow of the total simulation dredge volume, was consequence of sampling not conducted samples collected from both within and Oceanic currents are vital to abalone based on one deep sample of SB7.2 for the full dredge depth, there is also outside of the dredge footprint. farming. Circulation and mixing of marine (maximum 1.4m). considerable uncertainty regarding the waters guarantee the high-quality Particle Size Distribution (PSD) and settling Settleability needs to consider the deeper seawater that sustains the abalone. Uncertainties highlighted in Romero’s velocities of the material generated by the unconsolidated and consolidated (noting Reduced seawater quality will significantly review with regard to the sediment CSD. The PSD of the sediments released that small particle sizes are likely to be impact Yumbah’s ability to continue its sampling core depths and extrapolation to into the marine waters will potentially pose generated during CSD grinding) sediment business. the dredge depth (core refusal generally a much greater impact/risk in terms of a horizons. The draft EIS cannot rely on <60cm) and the inclusion of sediment worst-case scenario than the duration and settleability based on a small subset of characteristics outside the dredge area, amount samples that comprise only 25 per cent of the assigned volumes of 75 per cent for of dredging. the proposed maximum dredge depth. Class 1 (primarily sand) and 25 per cent Class 2 (greater proportion of clay and silt) A potential CSD grinding of consolidated Due to the significant flaws and lack of cannot be relied upon. sediments (Class 3) scenario may lead to adequate characterisation of sediment, greater dredging related turbidity than Yumbah has no confidence in the A worst-case Class 3 of dredge material for predicted in the draft EIS and will outcomes of the models and the a reasonable worst-case estimate is valid potentially have greater impacts on suggested impacts associated with given the information available and primary producer benthic habitat (e.g. light dredging. potential interactions between the CSD reduction to proximal seagrass) and and the harder (consolidated) sediments of Yumbah KI’s inlet water. the deeper strata of the dredge area. This demands additional modelling for a worst- Further, removal of Class 3 sediment will case dredge material characterisation that result in dredging far exceeding the includes worst-case estimates from estimated worst case of 75 days. dredging of the third class and worst-case dredge volume allocations to the three classes.

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Smith Bay Wharf Environmental Impact Statement Yumbah Response 29

MISCONSTRUED BENEFITS OF large discharge and sediment loads are the proposed causeway and any This is a significant gap in the draft EIS. CAUSEWAY not verifiable. The modelling of smaller impacts/risks in terms of recirculation The statement ‘Coastal circulation impacts storm events is required to demonstrate of the outlet waters into the are not expected to result in reduced Smith Creek is a freshwater catchment the frequency, magnitude and duration Yumbah KI facility’s intakes has not flushing of Smith Bay waters’ in Appendix west of Yumbah KI that has been of any suggested benefit. been addressed. G is not – and must be - demonstrated. influenced by historic land clearance and Similarly, the draft EIS Appendix G reports: agricultural activities. The draft EIS makes • A number of figures present the multiple unsubstantiated references to the VAGARIES IN MARINE WATER QUALITY modelled impacts and impact zones “Generally, impacts on coastal circulation causeway providing a benefit to Yumbah BASELINE AND IMPACT ASSESSMENT but are missing the seaport footprint are highly localised and in the immediate KI as a consequence of physically blocking and dredge area. This creates vicinity of the Project infrastructure where Smith Creek’s flows and isolating potential The draft EIS sub-appendix F3 discusses some local realignment and modification flows from the farms intake pipes. In reality baseline marine water quality and impacts confusion interpreting the many figures of current speeds will occur.” the causeway presents one of the greatest from the seaport. and claims in the draft EIS. risks to Yumbah KI’s operations. Issues with this report include: It fails to mention that Yumbah KI is in the immediate vicinity of the “Project Its presence will alter coastal processes IMPACT TO COASTAL PROCESSES • Ecological impact thresholds are infrastructure” and will be significantly and longshore currents with currents predicted for a number of water quality impacted by the realignment and estimated to reduce by up to 40 per cent, The modelling completed by BMT and modification of current speeds. creating a permanent barrier to currents parameters. Romero (2019) states the presented in the draft EIS Appendix G and thereby reducing mixing in the use of 10´ (Zone of High Impact) and indicates construction and operation of the receiving environment and subsequent 5´ (Zone of Low to Moderate Impact) seaport will alter the coastal processes in elevation of temperatures and reduced standard deviations above the 50th and Smith Bay. water quality. 80th percentile means to define Appendix G states: ecological impact thresholds from It must be explicitly stated that Yumbah KI turbidity are unjustified. Romero deems “The current circulation impacts show a has been successfully operating at this site slight reduction in current speeds flowing there to be no ecological basis for since 1995 with negligible impact from through Smith Bay nearshore waters as a these criteria. The suggested Smith Creek aside from a limited number result of the proposed development.” of storm events in 2016. Romero (2019) thresholds do not address seasonality outlines the conclusions of the review on in biotic receptors. It has been This alteration is unacceptable to Yumbah the suggested benefits of the causeway, demonstrated that ambient turbidity is and has the potential to deliver confirming that the catchment model used highly correlated to wave climate in catastrophic impacts to its operations. in the draft EIS to predict the impacts of Smith Bay (Figure 2-10 in Sub- Changes to coastal processes are likely to reduce circulation in the nearshore flood plumes from Smith Creek into the Appendix F2). The approach to define environment and compromise the health of proximal marine waters - with an emphasis the impact thresholds does not seem on the effect to Yumbah KI seawater the water which Yumbah KI is completely to account for this sensitive period intakes - is flawed. reliant upon. As highlighted previously, (mid-spring to mid-autumn), which from there is a lack of information in the draft The suggested benefit to Yumbah a benthic primary producer perspective EIS regarding impacts of nearshore KI’s inlet turbidity reduction from such is the worst-case timing to carry out the flushing and potential for recirculation of very infrequent 1:10 AEP Smith Creek dredge program. Yumbah’s outlet waters through the intake. storm events does not justify the causeway’s construction. • The placement of a solid causeway to the east has the potential to alter the According to Romero (2019), the objective typical flushing patterns with a of the draft EIS catchment modelling is potential to increase the recirculation seemingly to demonstrate the reduction in Smith Creek flood-derived suspended of the facility’s outlet waters to the sediments into Yumbah KI’s intakes from inlets. The potential for changes to the the proposed causeway. The simulated very nearshore flushing of Yumbah KI’s outlet waters due to the presence of Smith Bay Wharf Environmental Impact Statement Yumbah Aquaculture Response 30 Smith Bay Wharf Environmental Impact Statement Yumbah Aquaculture Response 31

30 Smith Bay Wharf Environmental Impact Statement Yumbah Response

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ACCUMULATION OF SEAWEED (WRACK) Amendments to the risk assessment INACCURACIES WITH CURRENT Current speed in shallow waters in front of FIELD IMPACTS the abalone farm range across the 10th to The draft EIS reports that accumulation o Though risk reference Item 8 in Table 90th percentile of 4cm/s to 13cm/s drift seagrass and macroalgae (wrack) will 4-1 of EIS Appendix G identifies the Yumbah KI deployed a tilt meter in the measured over the six-month period. occur as a consequence of the hazard, modification to seagrass wrack nearshore waters of its Smith Bay farm in construction of the causeway. This accumulation, the basis for a order to characterise the current regime Current field impacts are addressed in accumulation is unacceptable for the consequence of “minor” and likelihood just offshore from its western seawater section 4.3 the draft of EIS sub appendix F2 to assess predicted changes in the impact it will have on Yumbah KI’s of “possible” is not supported intakes in about eight metres of water over seawater intakes. the six months from 24 August 2018 to 25 proximal location to Yumbah KI inlets and Further, mitigation measures only o February 2019. outlets. The close-up figures of the Accumulation of drift seagrass and other change the residual likelihood and not differences in current velocities in the macroalgae will clog intake pipes and the residual consequence (note this Measured current speeds are presented in region of the aquaculture facility are not degrade water quality. comment also applies to reference Figure 1 of Romero (2019). Current speeds adequate. Finer current velocity intervals typically ranged between 2cm/s and 15 The extent of degradation and potential Item 6 in Table 4-1, and it is uncertain of 1-2cm/s rather than 10cm/s intervals cm/s during neap tides and 2cm/s to impacts on Yumbah KI and Smith Bay more why changes in residual likelihoods to (bottom panels of Appendix G Figures 6-8 20cm/s during spring tides. Current broadly are lacking in the EIS, and Romero references 2 and 3 are included with and 6-9) are more representative and so directions at the site periodically alternate (2019) has highlighted the need for no [nil] mitigation measures noted) should be applied. between the dominant directions of additional information, including: The inherent and residual risk for o easterly during flood tides and westerly The below diagram shows the probability seagrass wrack accumulation is • A description of the seagrass wrack during ebb tides. The minimum current distribution of the inshore currents over the not supported six-month deployment. The 10th, 20th, 50th, dynamics of Smith Bay speed of ~2cm/s is sufficient to transport a turbid plume from the proposed port to the 80th and 90th current speed percentiles are • Predictions of the effect of the The risk of wrack accumulation on the western intake of Yumbah KI’s facility, a approximately 4, 6, 8, 12 and 13cm/s. proposed development on the quality of the source waters to Yumbah distance of about just 300 metres. KI’s abalone farm is lacking and must be seagrass wrack dynamics of Smith Bay addressed, particularly given the close • Impacts of the predicted changes of proximity of the proposed development seagrass wrack dynamics on the to the inlet pipes. source waters to Yumbah KI’s abalone farm

•

Figure 5 – Probability distribution of current vector magnitudes

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

Figure 4 - Seagrass Rack accumulated at nearby Emu Bay

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32 Smith Bay Wharf Environmental Impact Statement Yumbah Response

•

Figure 5 – Probability distribution of current vector magnitudes

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

Figure 4 - Seagrass Rack accumulated at nearby Emu Bay

Smith Bay Wharf Environmental Impact Statement Yumbah Aquaculture Response 32 Smith Bay Wharf Environmental Impact Statement Yumbah Aquaculture Response 33

Smith Bay Wharf Environmental Impact Statement Yumbah Response 33

FURTHER DRAFT EIS SHORTCOMINGS CONCLUSION OF WATER QUALITY FUNDAMENTAL FLAWS IN ABALONE MISGUIDED AND INCORRECT ASSESSMENT ASSUMPTIONS ABOUT YUMBAH KI Beyond the many concerns outlined above The details in the draft EIS on water quality, regarding water quality, Yumbah further coastal processes and suspended solids is Appendix H declares the importance of Statements regarding abalone husbandry concerns about conclusions drawn from fundamentally flawed and the information it good water quality to the success and in Appendix H of the draft EIS reflect a lack the assessment that formed the draft EIS contains cannot be relied upon. viability of Yumbah KI with the statement: of expertise in the field. This concern is Appendix L Geology, Soils and Water. “In summary, the importance of good supported by Appendix 3 – a review of The draft EIS Main Report indicates the water quality to the health of the Appendix H by the peak body These include the following unacceptable assessment of the impact of dredging on abalone aquaculture sector cannot representing the abalone farm industry in risks that, if realised, will significantly water quality relies heavily on dredge be understated”. Australia (AAGA submission, 2019). impact Yumbah KI: plume modelling results that consist of time series results and percentile contour This technical report is apparently relied Incorrect, inaccurate or false inclusions in • The sediment load in the dewatering plots of turbidity. These plots indicate the upon as the scientific backbone of the Appendix H that relate to abalone discharge from the dredge slurry areas where turbidity was elevated at draft EIS, but actually works only to attempt aquaculture include: potentially could be high if not some point during the dredge campaign, to negate the significance of adverse managed effectively rather than being snapshots of the dredge impacts the seaport will create for • Feed moisture content is incorrect plume at any particular time. Yumbah KI. • Stormwater runoff could cause surface • Abalone growth increases with and beach wall erosion and could The total suspended solids (TSS) impact The EIS guidelines (DAC 2017) requested temperature transport sediment to surface water if assessment is questionable as there is the following information be reported in • Abalone broodstock are not isolated not appropriately managed considerable uncertainty in the PSD of the the draft EIS, but this is absent. The draft dredge material, and the need for deeper EIS cannot be considered a compliant • Oxygen is not an issue that even • Site activities during operations could sediment understanding, particularly to document without required information requires monitoring for health result in the release and accumulation confirm the presence of a Class 3 that includes: of chemicals which could result in site sediment of consolidated material. • Hatchery timeframes and mortality • Impacts that dredging may have on contamination (soil and groundwater) rates are incorrect; note, Yumbah The use of incorrect current field data sediment loads and the neighbouring and the contamination of stormwater produce what is needed for the coming further discounts any of the conclusions commercial land-based aquaculture runoff if not appropriately managed season, not excess outlined in the draft EIS on water quality operation. Detail measures for impacts and effects on Yumbah KI. • Leachate from the woodchip stockpile managing these impacts, including • Estimates that Yumbah’s two South and log storage could harm surface The behaviour of sediment dredged and management of dredge spoil Australian abalone farms produce 337 water via direct runoff or through potential zones of impact modelled are tonnes of abalone fall well short of the • Description of the contaminants stormwater transport, and incorrect as the data generated to support actual 402-tonne production and toxicants that may accumulate groundwater via infiltration through the assumptions is wrong, and the actual on the property and the risks during a permeable base impacts from both construction and • Nursery timeframes and filtration rates operation of the seaport to Yumbah KI stormwater events (where not are wrong KIPT’s reputation and performance to date remain unknown. managed) to the adjacent aquatic with respect to its intentions at Smith Bay environments and commercial • The hatchery operates by water

and across Kangaroo Island are industries (e.g. fisheries and flowthrough not recirculation, and questionable. aquaculture) that rely on water is filtered to 1µm those environments. While this draft EIS presents a case for • Nursery water is filtered to 50µm to permitting construction in an earlier allow natural diatoms to pass iteration of its seaport proposal, its terms of reference do not in any way seek • Stocking levels for production are protections for the natural environment, wrong during operation of its seaport. • Reported growth rates are wrong, and much slower than actual

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34 Smith Bay Wharf Environmental Impact Statement Yumbah Response

Smith Bay Wharf Environmental Impact Statement Yumbah Aquaculture Response 34 Smith Bay Wharf Environmental Impact Statement Yumbah Aquaculture Response 35

Smith Bay Wharf Environmental Impact Statement Yumbah Response 35

• Mortality statements are incorrect data for the full year, along with the Appendix H refers to: The draft EIS also reports suspended summer and spring months were below sediment particles sizes in water samples • Meat yields are incorrect; they are the ANZECC/ARMCANZ (2000) guideline “Sainsbury (1982) investigated the effects ranged from 0.2μm up to 3,000μm, with historically about 40 per cent value (0.5 NTU). During autumn and of sediments on an unfished (wild) most particle sizes around 100-200μm. winter, median turbidity (0.7 NTU) slightly population of Haliotis iris in Peraki Bay There was a higher proportion of inorganic • Grade size yields are incorrect exceeded the guideline value. In contrast, (New Zealand), in terms of population size sediment particles (53-65 per cent) the near-bed median turbidity measured and structure, growth, recruitment, compared to organic sediment particles during the summer months exceeded the mortality and reproduction. He concluded (34-46 per cent) analysed in samples. THE REAL STORY ABOUT SUSPENDED ANZECC/ARMCANZ (2000) guideline that a "major cause [of mortality]" was SOLIDS value at both the 5m depth contour (1.7 burial due to the movement of large Dredging will result in disturbance of a NTU) and 10 m depth contour (1 NTU). volumes of benthic sediments that resulted higher concentration of fine sediment, and The draft EIS Main report alleges extensive in changes in sediment depths by up to potentially Class 3 sediment. The usual cropping and grazing industries Most TSS values measured during grab 1m.” coarse sediment in Smith Bay of around “… are likely to have had adverse effects samples between September 2017 and 100-200μm reported in the draft EIS February 2018 (Table 2-7) are below the This substantively supports Yumbah’s Appendix F will be exacerbated with fine on marine water quality along the north claims that sediment which enters the tank, coast of Kangaroo Island through erosion guideline value of 10 mg/L, with over 50% silt during dredging, potentially remaining of values being <1 mg/L. The exception falls out and accumulates, will eventually in suspension for a significantly longer processes within cleared catchments and smother and kill the abalone. If TSS was at along degraded creeks during rain events, was the water sample collected on period than the worst case of 75 days 22/2/18, which had a TSS value of 41 mg/L. 10mg/l for 24 hours, each tank has the dredging if Class 3 sediment requires resulting in the transport of silt into the potential to accumulate about 2.6kg of marine environment via creeks, thereby However, this sample was collected at the dredging. shoreline following a period of strong sediment. increasing the turbidity of coastal waters.” northerly winds which resulted in visibly The draft EIS Main Report also concludes This statement by the proponent is both turbid conditions in Smith Bay. that TSS levels are predicted to increase at misleading and incorrect. As stated in the draft EIS, ultimately the the Yumbah seawater intakes by Baseline water quality of Smith Bay turbidity plumes from construction and approximately 4mg/L for the expected measured for the purpose of the draft EIS operation must be considered within the case, and up to 7mg/L under worst-case (presented in Appendix F) indicates the context of natural variability in turbidity in conditions. opposite is true. Smith Bay. TSS in Smith Bay is significantly A concerning factor with this conclusion is low and generally does not exceed 10 Water quality in Smith Bay is indeed very the PSD and the concentration of fine mg/L. healthy and lacks impact from sediment likely to be dispersed during anthropogenic influences, which explains It is not possible that the draft EIS purports dredging is unknown, given sediment why Smith Bay is an appropriate the acceptability that acute TSS levels sampling and analysis has not been environment for long-term and continuing exceeding 10 mg/L above ambient will be conducted to the complete dredge depth aquaculture at Yumbah KI – but not with a restricted to within a few hundred metres of three metres. Any resulting plume destructive seaport on its boundary. of the dredging footprint for the expected modelling is unreliable. case. TSS levels exceeding 10 mg/L above The draft EIS Appendix F (Section 2.9) ambient have been predicted to extend up reports that background concentrations of to two kilometres east of the dredging TSS and turbidity are exceedingly low, with footprint under worst-case conditions. turbidity in Smith Bay mostly below 1 NTU for the 12-month monitoring period. There Yumbah KI is less than 400m from the were frequent elevated turbidity periods dredging activity area and will be directly coincident with weather patterns, but impacted by elevated TSS. turbidity did not exceed 10 NTU at any time during 12 months of in situ monitoring. This has been reported in the draft EIS as acceptable for the proponent, but it is far Compared with the ANZECC/ARMCANZ from the case. (2000) guideline value for turbidity, the median turbidity from the monitoring buoy Smith Bay Wharf Environmental Impact Statement Yumbah Aquaculture Response 36 Smith Bay Wharf Environmental Impact Statement Yumbah Aquaculture Response 37

36 Smith Bay Wharf Environmental Impact Statement Yumbah Response

• Mortality statements are incorrect data for the full year, along with the Appendix H refers to: The draft EIS also reports suspended summer and spring months were below sediment particles sizes in water samples “Sainsbury (1982) investigated the effects • Meat yields are incorrect; they are the ANZECC/ARMCANZ (2000) guideline ranged from 0.2μm up to 3,000μm, with of sediments on an unfished (wild) historically about 40 per cent value (0.5 NTU). During autumn and most particle sizes around 100-200μm. population of Haliotis iris in Peraki Bay winter, median turbidity (0.7 NTU) slightly There was a higher proportion of inorganic • Grade size yields are incorrect exceeded the guideline value. In contrast, (New Zealand), in terms of population size sediment particles (53-65 per cent) the near-bed median turbidity measured and structure, growth, recruitment, compared to organic sediment particles during the summer months exceeded the mortality and reproduction. He concluded (34-46 per cent) analysed in samples. THE REAL STORY ABOUT SUSPENDED ANZECC/ARMCANZ (2000) guideline that a "major cause [of mortality]" was SOLIDS value at both the 5m depth contour (1.7 burial due to the movement of large Dredging will result in disturbance of a NTU) and 10 m depth contour (1 NTU). volumes of benthic sediments that resulted higher concentration of fine sediment, and The draft EIS Main report alleges extensive in changes in sediment depths by up to potentially Class 3 sediment. The usual cropping and grazing industries Most TSS values measured during grab 1m.” coarse sediment in Smith Bay of around “… are likely to have had adverse effects samples between September 2017 and 100-200μm reported in the draft EIS February 2018 (Table 2-7) are below the This substantively supports Yumbah’s Appendix F will be exacerbated with fine on marine water quality along the north claims that sediment which enters the tank, coast of Kangaroo Island through erosion guideline value of 10 mg/L, with over 50% silt during dredging, potentially remaining of values being <1 mg/L. The exception falls out and accumulates, will eventually in suspension for a significantly longer processes within cleared catchments and smother and kill the abalone. If TSS was at along degraded creeks during rain events, was the water sample collected on period than the worst case of 75 days 22/2/18, which had a TSS value of 41 mg/L. 10mg/l for 24 hours, each tank has the dredging if Class 3 sediment requires resulting in the transport of silt into the potential to accumulate about 2.6kg of marine environment via creeks, thereby However, this sample was collected at the dredging. shoreline following a period of strong sediment. increasing the turbidity of coastal waters.” northerly winds which resulted in visibly The draft EIS Main Report also concludes This statement by the proponent is both turbid conditions in Smith Bay. that TSS levels are predicted to increase at misleading and incorrect. As stated in the draft EIS, ultimately the the Yumbah seawater intakes by Baseline water quality of Smith Bay turbidity plumes from construction and approximately 4mg/L for the expected measured for the purpose of the draft EIS operation must be considered within the case, and up to 7mg/L under worst-case (presented in Appendix F) indicates the context of natural variability in turbidity in conditions. opposite is true. Smith Bay. TSS in Smith Bay is significantly A concerning factor with this conclusion is low and generally does not exceed 10 Water quality in Smith Bay is indeed very the PSD and the concentration of fine mg/L. healthy and lacks impact from sediment likely to be dispersed during anthropogenic influences, which explains It is not possible that the draft EIS purports dredging is unknown, given sediment why Smith Bay is an appropriate the acceptability that acute TSS levels sampling and analysis has not been environment for long-term and continuing exceeding 10 mg/L above ambient will be conducted to the complete dredge depth aquaculture at Yumbah KI – but not with a restricted to within a few hundred metres of three metres. Any resulting plume destructive seaport on its boundary. of the dredging footprint for the expected modelling is unreliable. case. TSS levels exceeding 10 mg/L above The draft EIS Appendix F (Section 2.9) ambient have been predicted to extend up reports that background concentrations of to two kilometres east of the dredging TSS and turbidity are exceedingly low, with footprint under worst-case conditions. turbidity in Smith Bay mostly below 1 NTU for the 12-month monitoring period. There Yumbah KI is less than 400m from the were frequent elevated turbidity periods dredging activity area and will be directly coincident with weather patterns, but impacted by elevated TSS. turbidity did not exceed 10 NTU at any time during 12 months of in situ monitoring. This has been reported in the draft EIS as acceptable for the proponent, but it is far Compared with the ANZECC/ARMCANZ from the case. (2000) guideline value for turbidity, the median turbidity from the monitoring buoy Smith Bay Wharf Environmental Impact Statement Yumbah Aquaculture Response 36 Smith Bay Wharf Environmental Impact Statement Yumbah Aquaculture Response 37

Smith Bay Wharf Environmental Impact Statement Yumbah Response 37

INTOLERANCE TO FINE SEDIMENT monitoring of water quality at a point There is confusion and direct separation Only 25 per cent is forecast to be sandy- between the dredging footprint and the between content in Appendix H and other silt. As highlighted earlier, it would be a The concern with TSS and potential for intakes. Dredging would cease if the technical reports presented in the draft EIS. stretch to state that 30% of total dredge fines to be disturbed is of greatest alarms were triggered.” volume has been accurately characterised significance when highlighting what is While Appendix H states that: for PSD. incorrect in Appendix H. The author of And this statement from the draft EIS is “… turbidity levels in Smith Bay routinely Appendix H presents false and misleading incorrect: As already noted in this submission, the reach 5–6 NTU, which would likely information relating to abalone’s modelling is flawed and cannot be relied “It is highly improbable that the dredging correspond to suspended sediment loads tolerances to TSS. on to adequately predict sediment fate and program would have adverse effects on in the range 10–20mg/L depending on behaviour. Construction of the causeway and the water quality that would affect the when and where the measurements are dredging of the berthing basin will aquaculture production of abalone.” made.” Appendix H recognises that while summer collectively entail more than six months of mortality is not fully understood there are The draft EIS recognises impact is likely. This is in direct opposition to Appendix F exposure to fine sediment loads in Smith likely to be many other factors that It states: which reports a linear correlation of Bay. Fine sediment emanating from dredge contribute to mortality, including 0.92mg/L of TSS per 1 NTU of turbidity. spoil and construction debris will enter temperature spikes, reductions in the “There are no clear environmental The Water Quality baseline reports Yumbah’s seawater intakes. This presents windows that offer the opportunity to oxygen holding capacity of water, and background TSS as generally <5mg/L, with an unacceptable risk and will significantly significantly reduce impacts associated increased disease susceptibility. >50 per cent of grab sample compromise the continuing viability of with dredging. Although dredging during measurements <1mg/L in Smith Bay. Appendix H lacks consideration of abalone farming at Yumbah KI. winter rather than summer would avoid cumulative impacts to reduced water sensitive periods for the reproduction of The comparison with a background range Thus, the risks of the seaport on abalone quality, and subsequent impacts to seagrasses and invertebrates, it would not of 10-20mg/L in Appendix H is incorrect. should be further evaluated in terms of abalone particularly during the summer benefit macroalgae, which reproduces in concentration (likely fine sediment loads) months when dredging is proposed. winter, and southern right whales, which The following claim in Appendix H is both and exposure to the hazard (duration). This Changes to water quality during summer, may visit the area during winter. far-fetched and incorrect: has not been applied to inform the draft particularly temperature elevations and Consequently, there are no persuasive EIS. Modelling and suggested zones of “Assuming the implementation of an degraded water quality, will be ecological arguments for dredging during impact are inaccurate and based on appropriate dredge management exacerbated by dredging in summer, with a particular season.” incorrect PSD data. program, there is no potential for elevated TSS further stressing abalone. Not surprisingly, there are relatively few smothering of abalone within the abalone The potential risks to Yumbah KI during the Examining the potential implications of studies which explore impacts of fine farm due to the proposed dredging.” summer months when dredging is disturbing Class 3 is the only way to sediments on abalone as these are rarely, proposed could be extreme - and even correctly anticipate the potential extent of This submission already notes the draft EIS if ever, encountered in the natural habitat catastrophic - for abalone. sediment plumes in dredging Smith Bay. modelling of sediment transport is of abalone and have not, until now, been incorrect due to a lack of actual PSD data Yumbah Kangaroo Island Pty Ltd have The following statement in the EIS does considered as an imminent risk to abalone. for the full dredge depth. recently acquired another licence (Active not constitute mitigation and management This is also acknowledged in the draft EIS as of 1 July, 2018) which is immediately of dredge impacts: Further claims from Appendix H: (Appendix H, page 33): adjacent to the Kl Seaport land holding on “It is considered that it would be possible “… the BMT (2018a) study has synthesised Kangaroo Island. This licence is not “The paucity of papers detailing negative to mitigate unacceptable effects on water data from COOE (2017) which provides a currently producing any product. effects of suspended sediments on sub- quality at Yumbah’s seawater intakes detailed analysis of sediment types and Yumbah’s intention with this licence was to adult through to adult animals is likely during capital dredging through the particularly the particle size distribution of expand production of abalone and because such impacts rarely occur in the adoption of appropriate management sediments as a basis for determining the investigate aquaculture of the other natural environment.” measures with the implementation of the likely transport pathways and volumes for permitted species, but this has been different types of sediments (Class 1 and placed on hold as a consequence of this dredging management and monitoring Class 2 sediments as defined in BMT destructive seaport and the legal litigation plan, which is a normal industry practice adopted during dredging activities. The 2018a). This work has indicated that ensuing between KIPT and Yumbah. dredging operation is likely to encounter risk of exceeding TSS thresholds at the The author of Appendix H purports that Yumbah intakes would be managed (and sediments comprising a mixture of 75% Silty-Sand and 25% Sandy-Silt.” abalone are well adapted to high reduced) by installing alarms and live suspended sediment loads, and are more Smith Bay Wharf Environmental Impact Statement Yumbah Aquaculture Response 38 Smith Bay Wharf Environmental Impact Statement Yumbah Aquaculture Response 39

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Smith Bay Wharf Environmental Impact Statement Yumbah Response 39

resilient than other aquaculture species irrevocably confirms that TSS fine sediment that will be created during physiological impacts become that have been investigated. A further concentrations are <10mg/L 91 percent of a dredge plume. exacerbated in abalone. claim is that abalone are routinely the time. Ninety four percent of water subjected to high levels of suspended coming into Yumbah Narrawong contains To challenge the statement: This detail on the relationship of exposure time and duration is a significant gap sediments in their natural habitat when no more 15mg/L of suspended solid. “It is evident from the very nature of their in the draft EIS and demands further material is entrained into the water column environment that abalone must be Interpretation of Yumbah Narrawong’s investigation. of high energy subtidal coastal adapted to suspended sediments simply environments. data collected concludes that 5 per cent of the time, TSS results could be anywhere because they rely upon drift algae, The author of Appendix H says This is misleading. between 15 and 30mg/L, that’s 1.4 days a suspended in the water column, as their temperature-dependent mortality reported month. principal source of food.” by Chung et al. (1993), 5 to 7.5 per cent In their natural habitat, abalone are over four days to sediment is low. In the exposed to course sand, particularly in This elevation is experienced with This statement is incorrect and misleading. context of an abalone farming operation, highly active coastal zones. The behaviour inclement weather patterns that are Fine clays can be 1000 times smaller than mortalities of this rate would not be viable. and impact of larger suspended matter to particularly common along the exposed drift weed. abalone is unrepresentative of fine and rugged coastline where Yumbah’s It must be noted that mortality was et al. sediments, characteristic of dredge spoil. Narrawong farm is located. Abalone can tolerate course suspended observed by Chung (1993) following Abalone can tolerate coarser sediment but sediment in moderation, but health is three days exposure. Trending data would are demonstrably not well adapted to fine The one measurement of 37mg/L was compromised when exposed to fine silt. indicate that continued exposure would sediments (silt and clay particles). measured when wind gusts were result in exacerbating physiological exceedingly strong reaching 81km on the As highlighted in McShane (2019), a impacts to abalone that would result in The information presented in Appendix H day of sampling. number of studies are referenced in exponential abalone mortalities as the blatantly misconceives that data from Appendix F that purport to show a duration of exposure continued. This is hardly a scenario that can be used Yumbah Narrawong (88 data sampling relatively benign effect of suspended in the attempt to convince readers that events since 2001) “provide additional solids on abalone. Most studies cited McShane (2019) refers to the Tissot (1992) evidence that elevated levels of abalone can tolerate high concentrations expose abalone to high total suspended study quoted extensively in Appendix H, suspended sediments during storm events of fine dredge spoil as the inexperienced solid concentrations, but few studies presenting some adaptive strategies of are not likely to be the cause of elevated author of Appendix H attempts to purport. examine the specific impact of various abalone species to tolerate high Dredging will create a highly turbid plume mortalities, at least at the levels fine sediments. water movement – that is, to mitigate shear of fine sediment that will stretch for experienced at Yumbah’s Narrawong stress in adhering to reef surfaces. hundreds of metres, if not kilometres for Studies cited that examine fine sediments (Victoria) farm which would otherwise more than seventy-five consecutive days. (e.g. Chung et al. 19936) clearly This is not evidence of tolerance to high experience much more frequent and demonstrate that silt and clay can have a suspended sediment loads as claimed in presumably more debilitating mortality Inclement coastal weather result in coarse significant and negative impact on abalone Appendix H. Rather, such adaptations events.” sand entering grow out tanks through inlet survival, with mortality increasing with relate to withstanding the shear stress Surface water in Smith Bay has been water, and sand build up in the farming exposure time and concentration. Many created by wave-induced turbulence in reported in the draft EIS to range from system is obvious. These events are given experimental studies of sediment impacts typical coastal subtidal habitat. high priority in any abalone farm and 30μm to 300micron (with some larger examine concentration (of sediment) intensified cleaning and husbandry is particles around 1,000-3,000 micron), with alone and duration of exposure is required to ensure tanks are adequately a median sediment particle size (D50) of not considered. void of sediment in a timely manner. This 89 microns (Appendix F3 p27). increases labour costs and consumption of The impact of extended exposure to The reported ambient grain size in Smith resources such as water and electricity. concentrations of fine sediment likely to be Bay is generally equivalent to sediment at disturbed during dredging is predicted to Yumbah’s existing and future abalone The generalisations and ambiguous result in additional mortality as farms in Portland Bay. Fifty per cent of references in Appendix H to sediment in abalone habitat are flawed and do not sediment entering Yumbah Narrawong is reflect the reality that abalone are 100 to 200 microns in size. invariably exposed to coarser grain sizes A review of TSS measured since 2001 in which behave distinctly differently to the Yumbah Narrawong’s intake waters 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 Smith Bay Wharf Environmental Impact Statement Yumbah Aquaculture Response 40 Smith Bay Wharf Environmental Impact Statement Yumbah Aquaculture Response 41

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SEDIMENT IMPACTS TO ABALONE In summary, following both storms, ERRORS IN ECOTOXICITY ASSUMPTIONS Comments in Appendix H regarding abalone appeared moribund two days after sediment loads in the natural environment In the review of the draft EIS, McShane the storm and mortality occurred over six The draft EIS claims the ANZECC (2000) of abalone misses the point that it is the (2019) explores the impacts of sediment to weeks following initial impact from storm TSS trigger value of 10 mg/L for fine sediment (particularly clay) that does abalone. The review confirms exposure to suspension of fine sediment. aquaculture is overly conservative for the damage to abalone. These fine fine sediment can have an adverse impact abalone. The author attempts to justify a sediments are rarely present in abalone on abalone anatomy and physiology in a Histopathological analysis by Dr Richmond new guideline value of 25 mg/L: natural habitat, as is stated in Appendix H. number of ways. Abalone are primitive Loh, an aquatic animal health specialist, suspended sediment levels are not gastropods having a weak capacity to concluded: expected to exceed values of the defined The test conditions applied in the single, actively extract oxygen from the water threshold (25 mg/L) at which no chronic or short-sighted bioassay are completely “Mortalities were worst in 3 to 4-year old column and ventilate their gills and, acute effects are likely irrelevant to the practice of abalone group (harvest class), though 1-year olds instead, rely on passive water movement in (Appendix H, Page 69). farming. In a farming tank system, were also affected. Clinical signs reported their natural habitat to drive water into the sediments concentrate in the shallow in abalone include swollen head, swollen National Water Quality Guidelines brachial chambers and to the mantle cavity raceways and maze tanks and smother the foot, and difficulty holding onto substrate, (ANZECC/ARMCANZ (2000)) state: (Ragg and Taylor 2006, Morash and Alter abalone. and death within 2 days of showing clinical 2016). signs. Storms and abalone deaths “Guideline trigger values are A claim in Appendix H that tippers will concentrations that, if exceeded, will Thus, abalone typically inhabit high energy coincided with higher frequency of adequately deal with additional sediment indicate a potential environmental sublittoral environments where water clogging of their 1µm water filters loads from dredging with no adverse movement generated by waves and tide (in their hatchery).“ problem, and so ‘trigger’ further effects on farming operations is incorrect. provide for the necessary gill ventilation. investigation. The investigation aims to Tippers are not used in a large proportion Further detail is presented in McShane both assess whether exceedance of a of grow out tanks at Yumbah KI. The (2019), yet a conclusion was: Associated with the gills of abalone is a trigger value will result in environmental testing environment is further flawed as hypobranchial gland which functions to harm and refine a guideline value, by “Upon examination, these affected test abalone were fed natural feed and produce mucus to keep the gills and the accounting for environmental factors that abalone had inflammation throughout, but tests were conducted at the optimal mantle cavity clean (Wanichanon et al. can modify the effect of the chemical. more severe in the muscle of the foot and temperature of 18°C which is not 2004). When foreign particles from turbid Although in some cases this will require head regions. The inflammation in the representative of the likely water water enter the mantle cavity, the mucus more work, it will result in much more head probably reflects increased silt in the temperatures in Smith Bay during the cells bind particles that can be expelled realistic goals for management and environment of these animals, including proposed dredging period of warmer through the ciliary action of the epithelial therefore has the potential to reduce both increased silt in the mouth.” summer months. cells. Abalone have limited capacity to costs for industry and confrontation.” clear fine sediment and associated mucus. Furthermore, McShane (2019) rightfully The purported ecotoxicology results highlights that abalone cultivated at The author of Appendix H raises questions in the draft EIS are not generated from Yumbah KI have been selectively bred for about “mass mortality” events at Yumbah an ecotoxicology assay. Yumbah’s farming conditions from brood KI associated with resuspension of Results based on acute exposure to fine stock that have been genetically selected sediments within Smith Bay during storm for optimal farming conditions. Juvenile events. The extent of mortality during the sediments over twenty-four hours are not representative of toxicity. abalone exposed to sediment in the storm events in 2016 did not trigger the laboratory test described by Springer notifiable level for compulsory reporting Abalone (even juveniles) can tolerate (2018b) were sourced from wild to PIRSA. occasional elevated sediment loads. Short- populations and their behaviour cannot be McShane (2019) presents results from term responses include increased mucous directly compared to farmed abalone due qualified histopathologists following two production (with subsequent energy to the genetic optimisation of Yumbah’s distinct storm events which resulted in demand). More importantly, exposure will farmed stock. elevated suspended solids from Smith create physiological impacts to feeding

Creek entering Yumbah KI’s intake water. and respiration with the consequences of reduced growth rates and increased mortality.

Smith Bay Wharf Environmental Impact Statement Yumbah Aquaculture Response 42 Smith Bay Wharf Environmental Impact Statement Yumbah Aquaculture Response 43

42 Smith Bay Wharf Environmental Impact Statement Yumbah Response

Creek entering Yumbah KI’s intake water. and respiration with the consequences of reduced growth rates and increased mortality.

Smith Bay Wharf Environmental Impact Statement Yumbah Aquaculture Response 42 Smith Bay Wharf Environmental Impact Statement Yumbah Aquaculture Response 43

Smith Bay Wharf Environmental Impact Statement Yumbah Response 43

ANZECC/ARMCANZ (2000) explicitly Given that there is no evidence in the draft Further considerations are required Changes to light climate in Smith Bay, states that thorough assessments are EIS regarding acute or chronic effects of in the draft EIS to reflect additional sources coupled with the potential introduction of required that are site specific and that fine sediment on abalone, and the of contamination and ecotoxicity impacts exotic dinoflagellates via ballast water, consider all environmental factors. At a absolute necessity for further investigation, to abalone. Leachate entering stormwater increases the risk of harmful algal blooms. minimum, the establishment of adequate, there is no justified basis for setting trigger and then the marine environment presents more appropriate bioassays are required values higher than the ANZECC/ARMCANZ a significant risk to Yumbah KI that should Yumbah KI relies on a mix of natural to quantify the true impact on abalone of aquaculture guideline of <10m/L. be reflected in the draft EIS Risk diatoms and tank algal growth. sediment to be dredged. Exposure and Assessment. Appendix H attempts to negate the duration within any bioassay must reflect importance of diatoms in abalone farming. the potential dredging activity. TIMBER TOXINS NOT CONSIDERED IMPACTS TO DIATOMS This is incorrect. Additional assessment to correctly quantify The draft EIS fails to address potential acute and chronic impacts of dredge toxicity to the marine environment from McShane (2019) highlights dredge spoil as The risk of harmful algal blooms will be sediment will inform the risk assessment timber chemicals. Likely chemicals that a risk to the viability of diatoms in the enhanced by reduction of nearshore relating to potential dredge impacts on may be used or introduced to the Smith subtidal environment of Smith Bay by currents following construction of a 250m abalone (Appendix H, Table H-12, Page 71) Bay seaport from KIPT timber operations decreasing available light and affecting solid causeway in Smith Bay. The draft EIS to justify any deviation from the include - but are not limited to - herbicides, light quality. indicates that reduction in current speed at ANZECC/ARMCANZ (2000) guideline fumigants and preservatives. The draft EIS Yumbah’s westerly seawater intake will be Appendix H of the draft EIS makes value for suspended solids concentration. appears to indicate that at this point in the about 30-40 per cent. This will lead to regulatory approvals process, timber- unsubstantiated claims in relation to potential recirculation of Yumbah effluent Consensus among technical specialists associated chemicals are unlikely to be diatoms and dredge effects, including: and an increase in ambient water engaged by Yumbah to review the draft used on site. • Diatoms are only important in diet of temperature: conditions favourable for EIS confirm that the crude conclusion of a dinoflagellate blooms. water quality guidelines of 25mg/L for An operations base (to be known as the early stages of abalone suspended sediment in Smith Bay is Heartland Hub) is located at the site of the The risk of recirculation and elevated • Algae exhibit a high level of plasticity in indeed significantly flawed. former sawmill (owned by KIPT) on KI’s temperature have not been adequately their adaptation to ambient light Timber Creek Road and, if required, would addressed in the draft EIS using coastal This value has been derived from one be subject to separate planning approvals environments allowing adjustments to data representative of existing and bioassay that exposes abalone to a given outside the scope of the EIS. adverse light climate ‘changed’ conditions at Yumbah KI. concentration of 250 mg/L (reported as the NOEC) for one day, which is unrelated to The existing site consists of timber • Changes in turbidity at shallow depths the actual exposure resulting from products treatment works and a number of are small and will not have an adverse dredging. larger machinery sheds, currently effect on diatom production containing disused sawmilling equipment. The findings presented in the draft EIS do The timber treatment works may be • Conditions that would promote harmful not constitute an ecotoxicological retained but the sawmilling equipment algal blooms (red tides) are not likely to evaluation of fine sediments on abalone. would be disposed of. occur in Smith Bay As the short-term tests revealed no mortalities (after 24 hours exposure and 48 The KIPT Timber Creek Road facility has an The benthic diatoms preferred as food for hours recovery) these results do not EPA SA licence from 2016 to enable use farmed abalone lack the motility to migrate constitute an ecotoxicological assessment. Copper Chrome Arsenate (CCA). The KIPT to surface waters where the full spectrum Acute and chronic impacts were not Main Report and Appendix C do not of photosynthetically active radiation (PAR) observed (e.g. feeding rates, respiration). mention if timber and woodchips will be is available (Ault 2000). As highlighted previously, results of Chung treated with CCA or other chemical agents Attenuation of light through suspension of et al. (1993) indicate continued exposure at Smith Bay. Its possible timber will be fine sediments during construction of the will likely result in exponential mortality. treated at Timber Creek Road and transported to Smith Bay, creating proposed seaport and during maintenance implications for contamination of dredging activities will have a deleterious stormwater in KIPT’s land-based effect on those benthic diatoms favoured storage area. in the diet of abalone farmed at Yumbah.

Smith Bay Wharf Environmental Impact Statement Yumbah Aquaculture Response 44 Smith Bay Wharf Environmental Impact Statement Yumbah Aquaculture Response 45

44 Smith Bay Wharf Environmental Impact Statement Yumbah Response

Smith Bay Wharf Environmental Impact Statement Yumbah Aquaculture Response 44 Smith Bay Wharf Environmental Impact Statement Yumbah Aquaculture Response 45

Smith Bay Wharf Environmental Impact Statement Yumbah Response 45

TEMPERATURE INTOLERANCES Appendix H reports a maximum ADDITIONAL ERRORS AND OMISSIONS • “The hydrodynamic modelling temperature increase of 0.1°C when it is outcomes suggest that the worst case Appendix H further claims: • Information in the EIS has been largely stated that a maximum increase could increases in suspended sediments at based on the original seaport plan. The “The study also concluded that land-based actually be 0.2°C. Further inaccuracies Yumbah’s seawater intakes are wharf and its associated footprint have abalone farms in South Australia are suggest abalone at Yumbah KI are unlikely to have any adverse effects on since been extended from the original particularly vulnerable to climate change increasingly at risk of elevated the health of abalone within the farm.”9 impacts that have resulted in increased temperatures because of climate change design and now sits 420m out to sea sea water temperatures. It should be impacts. Smith Bay has experienced The drill core sample is not reflective of • Sediment to be dredged has not been noted that the predicted changes in minimal change in the rate of temperature what 100 000 tonnes (or 200 000 fully characterised by KPT coastal processes associated with the charge over the last 14 years. Similarly, tonnes – to be confirmed to some summer dissolved oxygen (DO) do not causeway may result in a very slight • “Fuel/oil spills will be minimised point in the future) will release and increase in water temperature at the pose a problem to Yumbah Ki as DO is on through mandated compliance with bring up from the seafloor Yumbah seawater intakes (maximum average higher in summer compared with established storage and handling effect less than 0.1 °C). Such an increase winter concentrations. • “If local areas of hard substrate not standards/protocols.”7 may provide benefits during winter but indicated in the geophysical or Appendix H: may increase the risk of summer No clarification of who geotechnical assessment was found to mortality events.” “… the future viability of the industry is monitors/enforces/assumes risk. be too strong for cutter suction clearly threatened by rises in summer Additional modelling of this expected Who sets standards and protocols? dredging methods, a long-arm water temperature and ocean acidification temperature increase is required to excavator mounted on a jack-up barge (Doubleday et al. 2013) and unless a • “The risk of exceeding TSS thresholds 10 determine the pattern and frequency to may be employed.” substantial improvement in temperature understand if there is reduction in mixing in at the Yumbah intakes would be tolerance of cultivated abalone can be Have excavator impacts on sediment the immediate shallow inshore managed (and reduced) by installing achieved the viability of the South plume been modelled? environment that will result in greater alarms and live monitoring of water Australian industry will be at risk over atmospheric influence on diurnal quality at a point between the coming years.” temperature variation of water; that is, the dredging footprint and the intakes. variation between a high temperature and The increase in temperature as a Dredging would cease if the alarms a low temperature that occurs during the consequence of the causeway has been were triggered.”8 same day. widely reported in the draft EIS. The above statement, though inflated and distorting, The plan is to stop dredging when an In winter the cold spikes may get colder confirms KIPT is aware of the potential alarm rings. Does this assume and in summer the warm spikes might implications of the seaport affecting somehow the abalone will know to get hotter. Yumbah KI. stop eating at the same time? There And again from Appendix H: will be unacceptable effects on water Abalone are extremely sensitive to quality at Yumbah’s seawater intakes. “Notably, in 2012/2013, the Kangaroo temperature differentials. It is not known This will happen. The risks may be Island farm experienced losses of 50% of if the reported changes in temperature are all animals in a growth trial under cumulative, which could have a deleterious reduced but not eliminated. Alarms conditions of elevated temperatures impact to farmed abalone. Alterations and may sound when TSS thresholds are (Stone et al. 2014).” increases in temperature due to reduced reached, but containing unacceptable mixing have not been sufficiently modelled dredge plumes will be difficult Truth is, this mortality was under controlled to incorporate the farm’s exit water conditions solely for the purpose of temperature. understanding feed rates during various

temperature regimes.

7 EIS Executive Summary p32 8 EIS Executive Summary p32 9 EIS Executive Summary p53 10 EIS Main Report p74 Smith Bay Wharf Environmental Impact Statement Yumbah Aquaculture Response 46 Smith Bay Wharf Environmental Impact Statement Yumbah Aquaculture Response 47

46 Smith Bay Wharf Environmental Impact Statement Yumbah Response

Smith Bay Wharf Environmental Impact Statement Yumbah Response 47

relatively small westerly swells that • “Winter minimum temperatures were refract around the island and decline around 14°c.”12 in size and energy as they travel east. DESCRIPTION: Yumbah simply makes the point there is no The north coast is also sheltered from Smith Bay water temperature gets acceptable level that can be demonstrated as having “no negative impact” on the waves generated by strong south- colder than 14°C Kangaroo Island’s remoteness and abalone farm. westerly winds in winter, and the isolation has created a unique prevailing south-easterly winds and environment, free from many of the pests • Smith Bay is currently free of exotic sea breezes in summer. It is, however, and diseases found on mainland Australia. marine pests. KIPT admits construction exposed to waves generated by The development of a port will inevitably and operational activities, which occasional strong northerly winds.”11 introduce pest and nuisance species (both include dredging and the movement of terrestrial and marine) to Smith Bay which domestic shipping vessels into Smith will be a major threat to Yumbah KI and Bay, have the potential to introduce can have devastating impacts on the marine pests and/or aquatic diseases Island’s environment and agricultural industries. Smith Bay is a Coastal • Biosecurity is a major risk with ballast Conservation Zone without threat from water exchange and ship fouling, exotic pests and diseases and its introducing exotic species and disease existing state of health is vital to agents to the pristine environment of Yumbah’s livelihood. Smith Bay

• Complying with national ballast water SUMMARY RESPONSE exchange and the legally sanctioned Marine pests are coming and KIPT appears mechanisms does little to mitigate risk to suggest there’s nothing they can do to the environment. There is not a about it. The risk of introducing exotic seaport in the world that is void of invasive pest species and diseases to significant issues associated with Smith Bay is the single biggest hazard for introduced marine pests. There are Yumbah KI, and its livelihood. whimsical suggestions in the draft EIS KIPT recognises construction and about how to “minimise” the spread of operation of its port is highly likely to exotic marine pests, but no discussion introduce marine pests and aquatic of eliminating the possibility of them diseases to Smith Bay which is, through arriving at Smith Bay. KIPT admits its careful stewardship and relative isolation, activities will introduce problems to currently free of exotic marine pests. Smith Bay 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 11 EIS Appendix I p3 standards prescribed by Biosecurity SA”. 12 EIS Appendix G p12 Smith Bay Wharf Environmental Impact Statement Yumbah Aquaculture Response 48 Smith Bay Wharf Environmental Impact Statement Yumbah Aquaculture Response 49

48 Smith Bay Wharf Environmental Impact Statement Yumbah Response

• ”The north coast is a relatively Statement of sheltered calm location is GUIDELINE 3: moderate to low energy environment false. North-west and westerly winds as it is largely sheltered from the are the strongest winds Kangaroo prevailing south westerly swells in the Island experiences. Westerly swells Southern Ocean (Edyvane 1999). regularly reach a height of five metres BIOSECURITY Nevertheless, it does at times receive relatively small westerly swells that • “Winter minimum temperatures were refract around the island and decline around 14°c.”12 in size and energy as they travel east. DESCRIPTION: Yumbah simply makes the point there is no The north coast is also sheltered from Smith Bay water temperature gets acceptable level that can be demonstrated as having “no negative impact” on the waves generated by strong south- colder than 14°C Kangaroo Island’s remoteness and abalone farm. westerly winds in winter, and the isolation has created a unique prevailing south-easterly winds and environment, free from many of the pests • Smith Bay is currently free of exotic sea breezes in summer. It is, however, and diseases found on mainland Australia. marine pests. KIPT admits construction exposed to waves generated by The development of a port will inevitably and operational activities, which occasional strong northerly winds.”11 introduce pest and nuisance species (both include dredging and the movement of terrestrial and marine) to Smith Bay which domestic shipping vessels into Smith will be a major threat to Yumbah KI and Bay, have the potential to introduce can have devastating impacts on the marine pests and/or aquatic diseases Island’s environment and agricultural industries. Smith Bay is a Coastal • Biosecurity is a major risk with ballast Conservation Zone without threat from water exchange and ship fouling, exotic pests and diseases and its introducing exotic species and disease existing state of health is vital to agents to the pristine environment of Yumbah’s livelihood. Smith Bay

Smith Bay Wharf Environmental Impact Statement Yumbah Response 49

• KIPT consider that the risk of The Federal Government’s Department of tourism. The application revealed there SEPARATION DISTANCES introducing marine pests and/or Agriculture and Water Resources (DAWR) would be an expected 13 truck movements Buffer zones or separation distances diseases to Smith Bay could “be has published the National Guidelines - per hour both ways between Strathblane Biosecurity Plan Guidelines for land based and Judbury if the operation ran 10 hours a between sensitive uses are commonly reduced to an acceptable level by applied across Australia. As an example, adopting the most rigorous biosecurity abalone farms (the Guideline). An day, six days a week. There would also be objective of this is to strengthen existing 800 additional truck movements per week the government of Western Australia has standards prescribed by Biosecurity biosecurity within abalone farms and delivering wood to Southwood for adopted a framework for effective SA”. Yumbah disagrees and references implement preventative biosecurity chipping. management of risks, contemporary the report by Industry specialists measures, rather than reacting to a biosecurity management practices and Professor Chad Hewitt and Professor disease outbreak. Community opposed the proposed port practical measures to improve abalone Marnie Campbell (see below). due to threat to the area’s “clean green” health management based on sound The DAWR Guideline recognises ports as tourism credentials, and environmental epidemiological principles for disease • The unanswered questions include: high-risk sites with the potential to impacts on native flora and fauna, prevention and control13. compromise biosecurity3 of aquaculture. including protected species, both marine o What’s an acceptable level of marine and terrestrial. The key principles considered in this pests arriving in Smith Bay? Eliminating biosecurity risks associated guideline when assessing applications for with ballast water, biofouling and imported The state’s biggest salmon producer abalone aquaculture are a risk based o What happens when “the most rigorous standards prescribed by seafood products, maintaining water Tassal opposed the proposed plant due to approach and the precautionary principle. Biosecurity SA” aren’t met? quality and disease-free status are the close proximity to its fish farms. Tassal essential to the success of aquaculture expressly opposed the location and close The precautionary principle defined is a Who will implement a marine pest o industries, including Yumbah KI. proximity of the woodchip facility as the legal and policy principle addressing the management program? Introduced two operations could "simply not co-exist" problem of scientific uncertainty in marine pests are impossible to The proximity of the proposed KIPT as immediate neighbours. environmental decision-making. It is of eradicate seaport at Smith Bay to Yumbah KI great concern that the draft EIS does not constitutes a significant risk to the existing Tassal’s concerns were explicitly related contemplate any possibility of scientific o Which cop on the beat will be resourced and located to oversee this and ongoing operation of the abalone to fish health and biosecurity issues. uncertainty clouding its findings and and drive compliance by this company, farm. The impending seaport fraught with Bio-security risks, including contaminated proceeds to recommend an outcome free which has a poor track record of all its issues hanging in the shadows bilge release and introduction of pests and of precaution. curtails any possibility of Yumbah’s diseases were regarded as unacceptable. regulatory compliance. ongoing investment in KI. This WA guideline recognises that spatial Tassal refused to accept the impending separation is of significance in abalone risk to its aquaculture operations. biosecurity management and is an WITHOUT BIOSECURITY, EXAMPLE CASE As a consequence of the impasse between important biosecurity tool. It focuses on AQUACULTURE FAILS In 2017, Southwood Fibre lodged a Tassal and Southwood Fibre, the Tasmania proximity to alternative aquaculture farms government committed to assist to productive reefs, and the principles can Biosecurity of aquaculture is one of the development plan to establish a $42 Southwood Fibre with finding a new site be applied to other commercial land uses most significant factors affecting the million export facility for woodchips at for the woodchip export facility recognising such as ports. success of an aquaculture facility. Dover, in the Huon Valley of the proximity of the salmon lease right out southern Tasmania. As stated in the WA guideline “The risk of The biosecurity risks to South Australia the front of the proposed disease agents being transported along posed by animal and plant pests and Similar to KIPT seaport, the Dover proposal woodchip location. various distances can be described as a diseases, food-borne illnesses and misuse included an onshore loading facility and This case provides a firm example that continuum, in which the number of of rural chemicals is managed by Primary amenities, woodchip pile site, access roads Yumbah’s concerns as an aquaculture infectious particles drops steeply with Industries and Regions SA (PIRSA). PIRSA and a ship loading conveyor belt to facility are not unfounded and biosecurity distance from the source, with only a few has developed the Biosecurity Standards transport the woodchips to waiting bulk is a universally recognised risk. infectious particles travelling relatively (abalone aquaculture) which outline carrier ships, which was set to dock long distances. Although the likelihood of biosecurity standards for abalone between the shore and Tassal's salmon disease spread is reduced almost aquaculture with the objective to minimise farm lease areas. the risk of outbreaks and spread of The proposal raised a number of concerns disease. from the community, particularly relating to truck movements, safety and local 13 http://www.fish.wa.gov.au/Documents/occasional_publications/fop132.pdf Smith Bay Wharf Environmental Impact Statement Yumbah Response 50 Smith Bay Wharf Environmental Impact Statement Yumbah Response 51

50 Smith Bay Wharf Environmental Impact Statement Yumbah Response

Smith Bay Wharf Environmental Impact Statement Yumbah Response 51

exponentially with distance from the Yumbah Aquaculture operates a farm in AN EXPERT REVIEW Realistically Smith Bay should be awarded source, extensive distances are required Allestree, Victoria which is known as the highest level of conservation status on before the likelihood of infection Yumbah Narrawong. It operates in the An independent expert assessment of the Kangaroo Island due to its relatively approaches zero. Other factors that Portland Bay and is located five nautical potential biosecurity risks to Yumbah KI if untainted environment. In essence, its influence the level of risk are the number miles from the Port of Portland. A frequent the KIPT seaport is established directly status as a Coastal Conservation Zone is in of infectious particles, host density and the ill-informed argument made to denigrate adjacent the farm in Smith Bay was place to do just this. strength and direction of water currents.” our biosecurity concerns is that “you completed by industry specialists operate next to a port in Victoria and don’t Professor Chad Hewitt and Professor This environment will significantly change Of importance is the comment “the have a problem”. Clearly at five nautical Marnie Campbell, titled Review of Marine if the seaport is established. likelihood of disease spread is reduced Biosecurity Aspects of Smith Bay Wharf, miles the principle of separation is The Victorian Government has recognised almost exponentially with distance from Draft Environmental Impact Statement respected by the Narrawong farm and the need to protect aquaculture zones by the source, extensive distances are (May 2019) (Hewitt and Campbell, 2019). clearly violated by the KI Seaport planned restricting non-aquaculture activities within required before the likelihood of infection just a few hundred metres from Yumbah KI. designated reserves. approaches zero”. This report is presented as Appendix 4 At this proximity the biosecurity risk of this document. The report outlines the The same approach should be applied to The WA guideline then recommends: becomes a certainty. biosecurity risks to Yumbah and critiques protect existing aquaculture and the content of the EIS Marine Biosecurity “As a guide to reduce the likelihood of The proximity of the KIPT seaport therefore encourage such sustainable investment in section and Appendix I. Many issues and disease spread, the distance between provides an unprecedented extreme risk South Australia. concerns with the content of the EIS were abalone farms, and between abalone to an abalone farm that should be afforded highlighted in Hewitt and Campbell (2019) farms and productive reef areas, five a significantly greater separation distance and are discussed further, below. nautical miles (measured over water) is from this considered a suitably precautionary incompatible use. Notably, the author/s of the biosecurity distance. However, based on risk Based on precautional principles a risk report presented by KIPT, primarily assessments, a distance greater than based approach should be applied to Appendix I5 that the draft EIS has heavily or less than five nautical miles may be define an adequate separation distance relied on, have not been identified. The required or acceptable, as the case between the KIPT seaport and Yumbah KI. experience or qualifications to undertake may be.” The location of the seaport does not such an important assessment of potential risks to Smith Bay cannot be verified. The The distance of five nautical miles is provide an effective buffer between port assessment of biosecurity risks in the draft arbitrarily picked – put simply further away operations and the sensitive use of EIS is further questionable as disease risks is better and closer is worse but aquaculture and as such, impact to are further discussed in Appendix H by an presumably has been chosen such that at amenity on land adjacent to the proposed author that is not an expert in this distance the “likelihood of infection port is unacceptable. contemporary onshore abalone approaches zero”. Likewise, at 0km the Traditionally, Australian state governments aquaculture. Further he has previously maths tells us the likelihood of infection have provided an effective buffer between advised and been involved in high-profile approaches 100%. port operations and sensitive uses. failed offshore abalone investment schemes. Maintaining appropriate threshold distances and preventing encroachment Smith Bay is a pristine environment and is of sensitive use and development is free from invasive marine species and important to the long-term sustainability exotic diseases. It needs to be maintained of Yumbah. in this state to protect its environmental values that are so heavily relied on by all

its users.

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52 Smith Bay Wharf Environmental Impact Statement Yumbah Response

its users.

Smith Bay Wharf Environmental Impact Statement Yumbah Response 52 Smith Bay Wharf Environmental Impact Statement Yumbah Response 53

Smith Bay Wharf Environmental Impact Statement Yumbah Response 53

REAL RISKS Lack of Priority Pest Species As the risk is considered high, Yumbah introduced to the Northwest Pacific expected to see an identification of source bioregion (107 of which are not present in Biosecurity risks to Yumbah are imminent Introduced marine pests are marine plants ports for vessel transfer during the Australia) and 645 native species that have during the seaport construction and or animals that are not native to Australia construction phase, and explicit statements been introduced to other parts of the world operation. In a previous report, Hewitt and but have been introduced by human surrounding species known from those (266 of which are not present in Australia). Campbell (2010) highlighted a large activities such as shipping. They have the ports/regions that might pose a risk of majority of recognised global marine potential to significantly impact our natural transfer. The 373 species with an invasion history invaders are capable of being transported environment and marine industries, and known to be present in the Northwest by multiple vectors, with ballast water (of particularly impacting the viability of Biosecurity risks during operation are far Pacific but not present in Australasia 15 commercial vessels) and biofouling (of aquaculture . greater and assessment of biosecurity represent a significant risk to Smith Bay commercial and recreational vessels) risks in the EIS is restricted to the that have not been considered in the EIS. The EIS notes that “all exotic species presenting the greatest contribution. It operation phase with a primary focus on are of concern to the South Australian Concern is raised by Hewitt and Campbell must be highlighted that the risks of bilge ballast water and biofouling. Government”. (2019) that threat of toxic dinoflagellates in water are not discussed in any detail in the There is no discussion of the risks from the genus Alexandrium and the Pacific EIS, which was required by DAC. The EIS does not clearly articulate the bilge water, which was a required inclusion oyster, Crassostrea gigas, establishing in extent of potential invasive species that The biosecurity risks to Smith Bay and of the EIS. Smith Bay is considered ‘unlikely’. may be introduced by ballast water and Yumbah KI are real. If realised, they will be biofouling to Smith Bay during both The draft EIS is further deficient as it has This is in direct contrast to Appendix H catastrophic to the Yumbah KI business. construction and operation of the limited description of the methods used to Aquaculture Studies (pg 67) that states: The EIS has recognised that risk of proposed seaport. identify risk species other than a reference introducing invasive pest species and to the previously developed generic “The risk of red-tide species being disease-causing agents is highly likely in Hewitt and Campbell (2019) confirm the Commonwealth and South Australian pest introduced via ballast water is real. Smith Bay if the seaport is established. Such species have been transported seaport construction creates a high identification. The assessment of It will be inevitable. around the world in ballast water and potential for species transfer due to the biosecurity risks used to inform the draft movement and arrival of slow-moving most introductions have been to Ports The EIS highlights shipping vectors (ballast EIS is restricted to a standard list of vessels with long port residence times, and Harbors.” water and biofouling) and acknowledges species. including the potential for sediment other vectors are relevant during transport (dredges and barges) which may It should be noted that many of the species Both agents represent significant threats construction but provides no discussion of lead to the transfer of invasive marine identified in Table 1 (draft EIS Appendix I5) to coastal waters and warrant risks from sediment associated with species and harmful algal blooms. are not native to, nor currently introduced consideration, particularly as Smith Bay dredge or hopper barges. to, the Northwest Pacific. As the Northwest will provide ideal conditions for both Dredges and supporting vessels are agents to proliferate. Appendix H (pg 67) The most recent article published on Pacific is proposed as the main market for explicitly linked to the transfer and spread further continues to state: biosecurity (Choi May 2019)14 recognises the timber exports, it is critical for Smith of non-native marine species, particularly that with the imminent increase of maritime Bay that species from this geographic “While dinoflagellates are present in biofouling species such as Sabella traffic by a staggering 240 to 1,209 percent region should feature heavily in the almost every marine system in the world, spallanzanii, and dinoflagellate cysts in by 2005, the risk of marine invasions is biosecurity risk profile. retained sediments from the last port the presence of red-tide species is likely to risk 3 to 20-fold. This risk is of of operations. This may be an accidental oversight or an normally restricted to areas where greatest importance to the large, fast- omission from the EIS, but it cannot be dinoflagellate blooms can occur; this growing economies such as north-east There is no explicit assessment of species’ stressed strongly enough: as the main port particularly includes protected/ sheltered Asia. KIPT is expecting the majority of its transfer risk associated with the traffic is proposed to originate from the embayments with high levels of nutrient seaport traffic from this region. construction phase, despite this Northwest Pacific the exclusion of invasive pollution. Such conditions are not present representing a very high potential due to marine species native to the Northwest in Smith Bay (BMT 2018b) where water the movement and arrival of slow-moving Pacific is of paramount concern. quality is very good due to the normally vessels with long port residence times. low levels of nitrogen and phosphorus.” 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 14 https://www.hakaimagazine.com/news/as-global-shipping-grows-prepare-for-a-surge-of-invasive-species/ (2009) identified 324 marine species 15 http://www.agriculture.gov.au/pests-diseases-weeds/marine-pests Smith Bay Wharf Environmental Impact Statement Yumbah Response 54 Smith Bay Wharf Environmental Impact Statement Yumbah Response 55

54 Smith Bay Wharf Environmental Impact Statement Yumbah Response

species native to the Northwest Pacific not

Smith Bay Wharf Environmental Impact Statement Yumbah Response 55

It has been verified in the EIS that the In the last decade Abalone Viral INADEQUATE MANAGEMENT AND Given that domestic voyages are unlikely construction of the causeway will alter Ganglioneuritis (AVG) and Pacific Oyster MITIGATION MEASURES to have sufficient time, or attain "high seas" circulation patterns, and reduce currents. Mortality Syndrome (POMS) have caused for exchange, they are unlikely to meet the These are the conditions that require substantial economic impacts in Australia Hewitt and Campbell (2019) reviewed "safe" standards. further consideration to assess the and now present trade barriers for the management and mitigation measures Yumbah has grave concerns that the likelihood of dinoflagellate bloom movement of livestock17. outlined in the draft EIS and these are formation. Additionally, the introduction insufficiently defined to determine "Same area" concept used at Port Adelaide of toxic dinoflagellates leading to uptake AVG and POMS have been noted as the level of biosecurity protection required. will be pursued at Smith Bay, despite sureties in the draft EIS that this will not be within the Yumbah facility creates significant diseases in the draft EIS, Management and mitigation measures sought. imminent internal biosecurity risks for however no methodology is presented that suggests a rigorous process was have been provided for two elements: Yumbah KI that do not currently exist. employed to determine either the • Discharges and Ballast Already established pests also lacking significance or likelihood of these two CONCLUSION Water Management, and consideration in the EIS include toxic, species being introduced to Smith Bay by It is Yumbah’s submission that establishing bloom forming microalga, Gymnodinium KIPT. The imminent risk of paralytic • Biofouling a seaport in Smith Bay will result in catenatum; European fan worm, Sabella shellfish poisoning (PSP) and its impact on significant biosecurity risks to the marine spallanzanii; Codium fragile ssp Yumbah KI’s operations is also considered The draft EIS argues compliance with ecology of Smith Bay, and be catastrophic tomentosoides; the Northern Pacific a significant threat that demands further international and Commonwealth law as to the ongoing operations and any Seastar, Asterias amurensis; and the and well-informed consideration. mitigation for discharges and ballast water possible investment at Yumbah KI. Japanese kelp, Undaria pinnatifida. management. As the stakeholder with the The draft EIS selection of disease-causing most at risk, Yumbah believes this is Hewitt and Campbell (2019) conclude: POOR DISEASE ASSESSMENT agents appears to have ignored the inadequate. It will result in failure to protect likelihood of introduction from the • methodology for determining marine Australia has a relative advantage through the marine ecology of Smith Bay and prospective trading locations in the Yumbah KI. Additional risks with biosecurity risk activities, vectors and its freedom from many aquatic animal Northwest Pacific (China, Japan). diseases that occur in other countries. construction and operation of the seaport - species is unclear and, based on the Maintaining this status is important for the Several abalone diseases resulting in not included in the draft EIS - are to be material presented in the draft EIS, aquaculture industry to ensure growth and abalone mass mortalities and hatchery considered. inadequate profitability is not jeopardised by exotic losses are known to originate from this Standard ballast water management • species assessments do not pathogens or the emergence of region. These include a number of Vibrio- practices are insufficient for ballast water 16 appropriately consider either the endemic pathogens. related outbreaks causing mass abalone sediments, and do not provide protection domestic or international source mortalities. The extent to which these from domestic ballast water. The emergence and spread of significant disease agents pose a risk to Australian locations to determine the species (and known and unknown aquatic animal native species has not been investigated Similarly, it remains unclear how vessels disease agents and parasites) likely to diseases has posed, and will continue or discussed in the draft EIS. that do not complete ballast water be transported into Smith Bay waters to pose, an increasing threat to Australia’s exchange; undertake ballast water relatively favourable aquatic animal health Vibrio is widely considered a significant exchange in coastal waters; or do not • risk mitigation measures proposed are status. Inadvertent transfers via biofouling and real threat to abalone. Consideration undertake ballast water exchange due to generic and meet the letter, rather than or water-borne mechanisms are of transfer through ballast water (including safety of life at sea considerations, will be the intent, of international, recognised as significant risk pathways for retention after ballast water exchange), or treated. Commonwealth and State the introduction of new diseases. via biofouling is lacking in this draft EIS. requirements Yumbah would like to know if these The abalone and oyster industries are vessels will be allowed entry to Smith Bay • two sectors with first-hand experience measures for discharges and ballast and therefore be able to release water management focus explicitly on of the devastating impacts of infectious "untreated" water? Will domestic ballast the operational phase using animal diseases. water be allowed to be released in Smith commercial trading vessels and are Bay? insufficiently detailed to address the construction phase, particularly for the

16 agriculture.gov.au/fisheries/aquaculture/national-aquaculture-strategy 17 http://www.frdc.com.au/Archived-Reports/FRDC%20Projects/2016-245-DLD.pdf Smith Bay Wharf Environmental Impact Statement Yumbah Response 56 Smith Bay Wharf Environmental Impact Statement Yumbah Response 57

56 Smith Bay Wharf Environmental Impact Statement Yumbah Response

It has been verified in the EIS that the In the last decade Abalone Viral INADEQUATE MANAGEMENT AND Given that domestic voyages are unlikely construction of the causeway will alter Ganglioneuritis (AVG) and Pacific Oyster MITIGATION MEASURES to have sufficient time, or attain "high seas" circulation patterns, and reduce currents. Mortality Syndrome (POMS) have caused for exchange, they are unlikely to meet the These are the conditions that require substantial economic impacts in Australia Hewitt and Campbell (2019) reviewed "safe" standards. further consideration to assess the and now present trade barriers for the management and mitigation measures likelihood of dinoflagellate bloom movement of livestock17. outlined in the draft EIS and these are Yumbah has grave concerns that the formation. Additionally, the introduction insufficiently defined to determine "Same area" concept used at Port Adelaide of toxic dinoflagellates leading to uptake AVG and POMS have been noted as the level of biosecurity protection required. will be pursued at Smith Bay, despite within the Yumbah facility creates significant diseases in the draft EIS, sureties in the draft EIS that this will not be however no methodology is presented that Management and mitigation measures sought. imminent internal biosecurity risks for have been provided for two elements: Yumbah KI that do not currently exist. suggests a rigorous process was employed to determine either the • Discharges and Ballast Already established pests also lacking significance or likelihood of these two CONCLUSION Water Management, and consideration in the EIS include toxic, species being introduced to Smith Bay by It is Yumbah’s submission that establishing bloom forming microalga, Gymnodinium KIPT. The imminent risk of paralytic • Biofouling a seaport in Smith Bay will result in catenatum; European fan worm, Sabella shellfish poisoning (PSP) and its impact on significant biosecurity risks to the marine spallanzanii; Codium fragile ssp Yumbah KI’s operations is also considered The draft EIS argues compliance with ecology of Smith Bay, and be catastrophic tomentosoides; the Northern Pacific a significant threat that demands further international and Commonwealth law as to the ongoing operations and any Seastar, Asterias amurensis; and the and well-informed consideration. mitigation for discharges and ballast water possible investment at Yumbah KI. Japanese kelp, Undaria pinnatifida. management. As the stakeholder with the The draft EIS selection of disease-causing most at risk, Yumbah believes this is Hewitt and Campbell (2019) conclude: POOR DISEASE ASSESSMENT agents appears to have ignored the inadequate. It will result in failure to protect likelihood of introduction from the • methodology for determining marine Australia has a relative advantage through the marine ecology of Smith Bay and prospective trading locations in the Yumbah KI. Additional risks with biosecurity risk activities, vectors and its freedom from many aquatic animal Northwest Pacific (China, Japan). diseases that occur in other countries. construction and operation of the seaport - species is unclear and, based on the Maintaining this status is important for the Several abalone diseases resulting in not included in the draft EIS - are to be material presented in the draft EIS, aquaculture industry to ensure growth and abalone mass mortalities and hatchery considered. inadequate profitability is not jeopardised by exotic losses are known to originate from this Standard ballast water management • species assessments do not pathogens or the emergence of region. These include a number of Vibrio- practices are insufficient for ballast water 16 appropriately consider either the endemic pathogens. related outbreaks causing mass abalone sediments, and do not provide protection domestic or international source mortalities. The extent to which these from domestic ballast water. The emergence and spread of significant disease agents pose a risk to Australian locations to determine the species (and known and unknown aquatic animal native species has not been investigated Similarly, it remains unclear how vessels disease agents and parasites) likely to diseases has posed, and will continue or discussed in the draft EIS. that do not complete ballast water be transported into Smith Bay waters to pose, an increasing threat to Australia’s exchange; undertake ballast water relatively favourable aquatic animal health Vibrio is widely considered a significant exchange in coastal waters; or do not • risk mitigation measures proposed are status. Inadvertent transfers via biofouling and real threat to abalone. Consideration undertake ballast water exchange due to generic and meet the letter, rather than or water-borne mechanisms are of transfer through ballast water (including safety of life at sea considerations, will be the intent, of international, recognised as significant risk pathways for retention after ballast water exchange), or treated. Commonwealth and State the introduction of new diseases. via biofouling is lacking in this draft EIS. requirements Yumbah would like to know if these The abalone and oyster industries are vessels will be allowed entry to Smith Bay • two sectors with first-hand experience measures for discharges and ballast and therefore be able to release water management focus explicitly on of the devastating impacts of infectious "untreated" water? Will domestic ballast the operational phase using animal diseases. water be allowed to be released in Smith commercial trading vessels and are Bay? insufficiently detailed to address the construction phase, particularly for the

Smith Bay Wharf Environmental Impact Statement Yumbah Response 57

risks associated with slow moving provide a competitive advantage in some ERRORS AND OMISSIONS • Tugs and/or bow and stern thrusters (if vessels including dredges and barges markets and allow entry into others.” available) would bring the vessel into • Movement of domestic ships into Smith the wharf where it would be secured • lack of mitigation measures that The proximity of this proposed seaport to Bay from Port Adelaide is considered prior to ship loading activities.22 consider sediment transfer risk either Yumbah KI provides a significant risk to the to pose a higher biosecurity risk than in the dredges and barges, or in the biosecurity of the farm and its subsequent international shipping and would be These tugs present a sizeable accreditation with Abalone Health commercial trading vessels, is managed accordingly.19 biosecurity threat, especially from Accreditation Plan (AHAP). This formally insufficient to provide harmful algal Vic AVG. recognised accreditation provides What does ‘managed accordingly’ bloom protections Australian land-based abalone farms with mean? How will this be managed? • Other than in exceptional the tools and templates to create fully • Domestic ballast water movement is circumstances, vessels would auditable biosecurity plans. • It is considered that the risk of unlikely to attain distances offshore to discharge foreign-sourced ballast introducing marine pests and/or meet the definition of “high seas” and “The relationship between the natural water on the high seas (that is, further diseases to Smith Bay could be therefore will not be able to undertake environment and aquaculture is critical than 200 nautical miles from the reduced to an acceptable level by adequate protections because aquaculture relies on a clean and Australian shoreline) before entering adopting the most rigorous biosecurity healthy environment”. the Australian EEZ, in conformance • standards prescribed by Biosecurity Biofouling species hazards associated with the Biosecurity Act 2015.23 with both construction and operational It must be reinforced that mitigation of risks SA.20 phases will continue to pose does not guarantee removal of the risk. To propose such discharge is Another hypothetical: “…could be unmitigated risks. A restriction on in- To protect Yumbah KI’s thriving business unacceptable in itself. reduced.” What is an acceptable water or dry dock cleaning at Smith and its future growth, and the natural number of marine pests arriving in • The pontoon (purchased in Korea as Bay will not prevent mature species environment of Smith Bay, appropriate Smith Bay? What happens when the a barge) has been sandblasted and from spawning or being dislodged into controls must be placed on the most rigorous standards aren’t in repainted with anti-fouling paint and Smith Bay introduction and movement of aquatic organisms. place? would be inspected by Australian • Mature biofouling assemblages are engineers before arrival at Smith Bay.24 Controls help manage risks associated • More than 20 introduced marine likely to pose the additional risk of with emergence and invasion of exotic species have been recorded around Pontoon is coated with anti-fouling transferring disease agents and species, and disease incursions. Applying Kangaroo Island, but none at Smith paint. What chemicals are in the paint parasites into Smith Bay waters a robust risk-based approach to managing Bay.21 and what study has been done to biosecurity for all industries is central to prove no harm and that the pontoon It is necessary to list and detail exotic The Kangaroo Island Biosecurity Strategy ensuring the biosecurity of Australia’s will be incapable of becoming a pests - and include paralytic shellfish 2017-202718 is clear: aquaculture industry. massive host for marine pests. poisoning. In Yumbah’s view, the only control to “…the financial impact on primary production and tourism could be eliminate the introduction and movement significant if particular pests were to of aquatic organisms and ultimate impact establish on Kangaroo Island, with the on Yumbah KI is not to establish a seaport success of niche agricultural enterprises adjacent to the abalone farm at Smith Bay. relying heavily on freedom from pests and disease. Kangaroo Island’s biosecurity system supports the export of higher quality primary products, which may

19 EIS Executive Summary p46 20 EIS Executive Summary p50 21 EIS Executive Summary p46 22 EIS Main Report p80 18 Triggs, AS. 2017. Biosecurity Strategy for Kangaroo Island 2017–2027. Department of Environment, Water and Natural 23 EIS Appendix U p21 Resources, South Australia 24 EIS Appendix U p19 Smith Bay Wharf Environmental Impact Statement Yumbah Response 58 Smith Bay Wharf Environmental Impact Statement Yumbah Response 59

58 Smith Bay Wharf Environmental Impact Statement Yumbah Response

Smith Bay Wharf Environmental Impact Statement Yumbah Response 59

• Regarding the proposed KI Seaport GUIDELINE 4: and the existing adjacent abalone farm, it would be essential that measures were taken to ensure that no abalone-related diseases were ECONOMY introduced. The two most significant diseases are Abalone Viral Ganglioneuritis and the parasite Perkinsus.25 DESCRIPTION: o Only KIPT arguing aquaculture and a deep-water port can co-exist next door Nine OIE-listed reportable diseases or to each other etiological agents are recognised from The proposal is likely to generate jobs on Kangaroo Island, directly and indirectly, o Peak community representative body, Japan or China that cause impacts to during both the construction and KI Council, says no KIPT at Smith Bay one or more of the approved operational phases of the proposed o Proponent encouraged to move aquaculture genera. These include two development. Given the proximity to the proposal further west, closer to its abalone diseases, one oyster disease nearby existing aquaculture operation, trees and six fish diseases. consideration needs to be given to how the proposed development and use of the • Benefits to Kangaroo Island calculated Eight are not considered in the EIS. port and wharf may impact on the to show…benefit Abalone Viral Ganglioneuritis is operation of this established business, and considered, but only as a domestic No assessment of dispersed losses, how any such impacts will be managed. o threat, not a threat from Japan where As the facility is proposed to be a multi- including social and economic amenity the etiological agent has been user facility, this may have potential o No socio-economic analysis of detected. positive impacts on other components of alternative sites, only site visits by the Kangaroo Island economy. Google Earth o No accounting for tourism loss, road trauma cost RESPONSE SUMMARY o No consultation with community to • Proposal’s economic benefit over- realise shared benefit stated

o No genuine cross-economy impact ECONOMIC CLAIMS DON’T STACK UP study completed The economic projections of Appendix O Jobs claims fanciful for facility o Economic Assessment of the draft EIS can operating at 20 per cent capacity only be accepted on face value. The o No consideration of non-port discounting of KIPT’s estimation and infrastructure costs, particularly roads calculation of negative effect can be left to others. • Claimed economic contribution ignores direct losses Yumbah has engaged expert analysis to assess the economic impact of its current o Project approval jeopardises Yumbah activity at Smith Bay, and the future impact KI, endangers other small businesses of its own – stalled, on account of KIPT – investment plans. o Aquaculture investment at threat if KIPT creates planning precedent

25 EIS Appendix I4 p7 Smith Bay Wharf Environmental Impact Statement Yumbah Response 60 Smith Bay Wharf Environmental Impact Statement Yumbah Response 61

60 Smith Bay Wharf Environmental Impact Statement Yumbah Response

25 EIS Appendix I4 p7 Smith Bay Wharf Environmental Impact Statement Yumbah Response 60 Smith Bay Wharf Environmental Impact Statement Yumbah Response 61

Smith Bay Wharf Environmental Impact Statement Yumbah Response 61

JOB CREATION CLAIMS DON’T STACK UP SAY IT AGAIN: THERE ARE OTHER, It is difficult to estimate the net negative Add a tourism-education facility, and it BETTER SITES effect on KI’s tourism industry of a adds an additional $1.15m annually. The draft EIS estimates 45 construction woodchip mountain dominating the Smith Yumbah’s planned expansions are on hold jobs at the seaport, but apparently only 15 The arguments have been presented Bay landscape and seascape. at a time. It suggests 160 jobs will be elsewhere and by others, including because of the threat of KIPT’s seaport. created for KI at the port and in forestry, Kangaroo Island Shire Council, for a more It’s equally challenging to determine the For the past four years, all KI-based but 140 of these will be filled by people sensible relocation of this project to a more cost of industrialising the North Coast investment proposals presented to the from the mainland. appropriate site. marine tourist experience. Yumbah Board have been dismissed KIPT has explained in the past that KI There are many alternative sites, all Or to assess the impact of perpetual heavy because of the overwhelming risk posed residents don’t have the skills it needs and dismissed summarily by the draft EIS. truck traffic on the tourist experience, the by KIPT. it will instead import these as it needs them cost of roads KIPT assumes ratepayers or Because of this threat Yumbah as seasonal or project labour. To direct KIPT elsewhere on KI will allow taxpayers will bear – or the tragic cost of the Island to benefit from the substantial inevitable road trauma. Aquaculture had to look elsewhere for It’s also unclear as to how many jobs are growth trajectory of Yumbah and expansion opportunities, and has recently full time, given the draft EIS reports the aquaculture generally. At the same time, it What can be said is that the combined gained planning and EPA approval for a possibility of as few as 10 or as many as 20 will facilitate the removal of plantations that effects of KIPT’s Smith Bay proposal 1000-tonne farm and aligned production vessels using the port annually. have blighted Kangaroo Island and stalled provide are a negative transformation infrastructure near Portland in Victoria. its economic performance for more than for KI. Yumbah Aquaculture actively practises risk 20 years. JOB LOSSES NOT FACTORED mitigation through diversification of its farm YUMBAH’S KI VISION assets across geographically distant areas. The draft EIS builds an assumption that ALTERNATIVE ASSESSMENT: NET KIPT’s proposal will somehow benefit Dench McLean Carlson’s modelling Imminent construction of the Nyamat farm ECONOMIC EFFECT Yumbah. The reality is the opposite. assessed Yumbah’s contribution to the creates the need for 1000 tonnes of production elsewhere. This is the base To contrast the economic claims of the Kangaroo Island economy under three In simple terms, the first sediment plume for the stage 2 proposal to find appropriate draft EIS, Yumbah engaged Dench McLean scenarios: generated by KIPT’s unmanaged dredging land on Kangaroo Island to expand Carlson to complete an econometric program – barely detailed in the draft EIS – • Current operation – Yumbah KI’s production. analysis of Yumbah’s current economic that enters Yumbah’s intake pipes marks contribution today contribution to KI, and the greater the end of Yumbah KI. With it go more than The economic value added to the local contribution that would accompany 25 direct and seven associated FTE jobs, • Stage 1, Licenced state – a plan to economy in these scenarios are Yumbah’s stalled investment program. and a local economic contribution of more expand the current Yumbah KI site to estimated as: than $4 million annually. This analysis is presented as Appendix 5. the maximum production permitted by • Current – $4 .1m annually current licences Gone also is a long-term growth plan This investment program includes • Stage 1 + tourism – $14.85m annually (shelved by the appearance of KIPT’s significantly expanded abalone production • Stage 2, Desired state – an expansion (includes current) Smith Bay proposal), that would see and a Discovery Centre at Smith Bay. The to 1000 tonnes production, with Yumbah driving an 8.9% increase on all Discovery Centre concept has been accompanying public access, • Stage 2 – $35.4m annually (includes current FTE jobs in the Kangaroo Island discussed with Ministers of both the education and tourism infrastructure current, Stage 1 + tourism) local economy. These FTEs are KI resident current State Government and their workers – on the Island, year-round. predecessors. In simple terms, the Yumbah KI as it is today value adds to the Any economic benefit projected by the Discovery Centre combines an aquaculture KI economy some $ 4.11m annually. proponent for the seaport in its draft EIS education facility, a global research base, must be discounted by the unmeasured Although the farm has grown over its 24 and a high-end “cellar door” tourism model loss of tourist dollars and the projected years of operation, simple mathematics showcasing Yumbah product and the best loss of up to $ 35.4 million of potential shows an historic contribution to KI of KI’s gourmet food and high-end fibre input to the local economy, every year. nearing $100m. producers.

Smith Bay Wharf Environmental Impact Statement Yumbah Response 62 Smith Bay Wharf Environmental Impact Statement Yumbah Response 63

62 Smith Bay Wharf Environmental Impact Statement Yumbah Response

Smith Bay Wharf Environmental Impact Statement Yumbah Response 62 Smith Bay Wharf Environmental Impact Statement Yumbah Response 63

Smith Bay Wharf Environmental Impact Statement Yumbah Response 63

ERRORS AND OMISSIONS • There are unlikely to be sufficient GUIDELINE 5: skilled workers on Kangaroo Island to • An expected annual average fill the new positions. Consequently, at contribution to Kangaroo Island’s GRP least 60 per cent of the workers (140 over the first five years of $41.7 million FTE jobs) would be recruited from the each year, of which $34.9 million is AIR QUALITY mainland, increasing the Island's direct investment and $6.8 million is population by an estimated 330.29 26 from flow-on effects. DESCRIPTION: o woodchip ship loading conveyor 140 jobs to go to people not from or on covered These dollar figures don’t include the KI. Not exactly a positive employment vehicle speeds within the site limited negative effect of losing Yumbah, one It is expected that air pollution (in particular o outcome for KI to 15km/h of KI’s largest employers dust) will occur during the construction phase as a result of the use of earthmoving The draft EIS gives no indication as to who • A boost in Kangaroo Island’s GRP of equipment and the physical construction of will monitor control measures and oversee around 16 per cent.27 the port infrastructure. Post construction, compliance and enforcement; where the the movement of vehicles to and from the required immense quantities of water Again, doesn’t include losses suffered proposed site, stockpiling and ship loading required for air quality mitigation will come from Yumbah’s demise or lost tourism operations onsite at Smith Bay will from; who will pay for the water; and how revenue generate air pollution (in particular dust). associated impacts of this water use will be There exists a sensitive receptor managed • More than 230 new full-time jobs (aquaculture/abalone farm) immediately would be created on the Island; 160 at adjacent to the site that is critically • Abalone are extremely sensitive to the port and in forest operations (e.g. sensitive to dust. environmental conditions and any harvesting, haulage, forest change to the equilibrium established management etc.) and a further 70 at Yumbah KI can be catastrophic for RESPONSE SUMMARY jobs would be created from the its operations and viability flow-on benefits associated with this The activity of woodchipping and 28 • new activity. stockpiled timber will distribute airborne Dust from trucks, timber and woodchip dust and particulate matter across Yumbah storage, plus unpaved site pans will be 160 jobs ‘at the port and in forest Aquaculture’s KI abalone farm, presenting a significant issue for the abalone farm. operations’ to service 10 ships a year? substantial risks for the farm. Dust will settle on the farm’s Most of these jobs are relatively low- permeable shade cloth roofing paid seasonal timber workers The draft EIS presentation and changing carefully calibrated light interpretation of available data is unreliable contracted through labour hire filtration and during rain events will be and patchy. The obvious omission of washed directly into grow out tanks critical data and interpretation is of concern for Yumbah and raises doubt • There is no discussion in the draft EIS about the validity of the air quality about the particle size of dust or the assessment in the draft EIS. chemical composition of the dust. Fine • The opinion in the draft EIS is quite airborne dust will compromise health firm, that air quality will not be affected and productivity of abalone by the proposal, if the following control

measures are in place:

o unpaved roads watered during construction and operation 26 EIS Executive Summary p60 27 EIS Executive Summary p60 o cleared areas watered during 28 EIS Executive Summary p i construction and land clearing activities 29 EIS Executive Summary p66 Smith Bay Wharf Environmental Impact Statement Yumbah Response 64 Smith Bay Wharf Environmental Impact Statement Yumbah Response 65

64 Smith Bay Wharf Environmental Impact Statement Yumbah Response

measures are in place:

Smith Bay Wharf Environmental Impact Statement Yumbah Response 65

• It is impossible to control The findings indicate concerns with the the deposition modelling assumes a • There is no description of the meteorological conditions and modelled inputs and outputs: particle density that needs to be prevailing winds for direction resulting airborne dust. Cumulative different from the other sources. or speed at all hours and all seasons • Appendix M purely presents the output dust gathering on shade cloth is the This is not discussed and should be data from the air quality modelling. The closest analysis in the reporting is the biggest issue. If concentrations of re-modelled correctly. The input data used for modelling is a contour plots for annual total dust accumulated dust became high and big unknown • Both assumptions have the potential deposition (figure 17-11d (EIS, p.395). This heavy rains occurred, events such as to cause inaccurate predictions. indicates the greatest proportion of wind the mass mortality that occurred during • Assessment against compliance with going to the north-north-west (NNW) with a an intense sediment plume from Smith air quality standards and guidelines • There are differences in measurement “secondary lobe” to the east-south-east Creek are likely with potential effects of dust emissions method (wind) and exposure (ESE), directly from KIPT’s proposed on neighbours is primarily focused on (temperature and rain) at the two sites woodchip piles and log stacks across the • The absence from this draft EIS of impacts to human health and amenity, used to model air quality, raising abalone farm boundary. discussion and accurate consideration with little relevance to Yumbah KI questions about the reliance on of prevailing winds, and the influences The results of the TAPM modelling are not meteorological inland data as of climate and seasons, is stark. The • The Air Pollution Model under-predicts available to confirm the validity of the representative of the coastal location predominant winds are most wind speed data. at Smith Bay. problematic for Yumbah KI with the Doubt is compounded as it appears the • Wind erosion emissions are considered seaport, unloading and log and The draft EIS refers to wind-blown dust annualised analysis of woodchip dust has overly conservative and do not woodchip storage piles are directly currently being deposited “onto the shade been modelled incorrectly as soil. upwind of Yumbah’s abalone tanks adequately predict impact cloth which covers the existing raceway The lack of discussion and accurate and nursery tank systems” (Main report • Emission factors for dust-generating consideration of prevailing winds, and the page 222). How this information is gained activities and assumptions for both influences of climate and seasons has not AIR QUALITY is not known; suffice to say it cannot be construction and operations are based been discussed in the draft EIS. The substantiated. Abalone farming is highly biologically on conservative assumptions and assumed predominant winds are the most sensitive and environmental stabilisation is again do not adequately predict impact The draft EIS also recognises that dust may problematic for Yumbah KI as the timber critical to success. fall into raceways and mix with seawater to will be located directly upwind of prevailing • Modelling assumes unsealed dirt roads potentially contaminate water with already winds. Air quality results are presented in will be constantly dampened, which is increased sediment loads. Appendix M of the draft EIS and clearly impossible interpretation of air quality modelling is in Due to the paucity of substantive WOODCHIP OMISSIONS Section 17 of the main report. The impacts • Broad assumptions have been made information proffered by KIPT to support its of change in air quality on human health, for the handling of woodchips, which position in this draft EIS, the resulting air A range of assumptions around woodchip emission factors (including the – incorrect - amenity and ecology have reportedly been invites errors in the accuracy of any quality impact from the seaport to Yumbah assessed. The not surprising assumption of particle size distribution being similar to draft EIS claims KI cannot be substantiated. The data is the draft EIS is that there will be no likely poor, inconsistent and lacks accurate crustal soil and fibrous material), an significant nearby impacts from the • Rigor has been applied to partition the interpretation. investigation of particulate matter fallout construction or operation of this seaport. data into size fractions - but these across port boundaries is considered more • There is no reference, discussion or accurate than the modelling approach in assume soil characteristics and not Yumbah engaged GHD to review the Air consideration of prevailing winds at the draft EIS. fibrous/cellulous material relevant for Quality impacts, inclusive of dust, claimed Kangaroo Island and Smith Bay. in the draft EIS. timber products The draft EIS indicate that changes to air • There is a discussion that afternoon quality because of the proposed seaport This review is presented as a letter titled • Wind erosion from the woodchip winds are stronger than morning which are likely to be limited to minor increases Smith Bay Aquaculture Assessment stockpile has assumed the same might be considered a universal truth in ground-level concentrations of dust Review of Air Quality Impacts (Cook, 2019) default NPI emission factor as that (modelled as soil, not woodchips) and are in Appendix 6. used for mine-site overburden. Further,

Smith Bay Wharf Environmental Impact Statement Yumbah Response 66 Smith Bay Wharf Environmental Impact Statement Yumbah Response 67

66 Smith Bay Wharf Environmental Impact Statement Yumbah Response

Smith Bay Wharf Environmental Impact Statement Yumbah Response 66 Smith Bay Wharf Environmental Impact Statement Yumbah Response 67

Smith Bay Wharf Environmental Impact Statement Yumbah Response 67

confined to within one to two kilometres of compared to the reported tolerance of THIS IS WRONG, AND MISLEADING. ERRORS AND OMISSIONS the operations. abalone species (25mg/L). Dust accumulating on the shade cloth and • Modelling assumed that the following The nature of impact across one to two As discussed substantively in Yumbah’s a worst-case scenario if this dust is then control measures were in place30: kilometres is not “confined”. response to Guideline 2 (Coast and washed into the farm during rain was Marine) the revised TSS figure of 25mg/L considered. It was noted longer gaps Unpaved roads were watered during The draft EIS does not consider the o has been invented by the proponent and between rain would create more intense construction and operation sensitive receptors across this wide contrary to the National Water Quality dust deposits. Cleared areas were watered during radius of impact. o Guidelines (ANZECC/ARMCANZ (2000)). construction/land clearing activities As evidenced elsewhere in this Yumbah The bioassays using woodchip dust The woodchip ship loading conveyor response document, the assumptions o performed by Stringer (2018c) do not about abalone husbandry presented in the was covered provide any indication of ecotoxicity of draft EIS are generally ill-informed and are o Vehicle speeds within the site were woodchip dust and cannot be relied on to not provided from either a position of well- limited to 15km/h. indicate acute or chronic impacts informed knowledge or robust scientific of airborne dust on abalone. There is no place for assumption under analysis. They are, at best, opinion the requirements the South Australian favourable to the proponent. Further consideration of biological impacts Government has placed on the proponent from dust to farmed abalone is required. The physiology and behaviour of abalone • The following mitigation methods are intimately known to Yumbah. Abalone may be implemented.31 DUST DURING CONSTRUCTION remain in Yumbah’s farming system for three years and the cumulative impact of A draft EIS built on assumptions that strict The risk of airborne dust during such dust accumulation to stock could be control measures will be in place with no construction and operation to air quality on catastrophic. reference to who will implement them, human health and the sensitive biological As such, the conclusion in the draft EIS who will pay for them and who will system of farming abalone cannot be maintain them. underestimated. (Main Report, p223) that the “small increase” in the rate of dust deposition • The proximity of the abalone farm to on the Yumbah facility because of the the primary dust source places it at proposed development would have only severe risk a “very marginal effect” on the farm’s water quality, and would have no effect on • The risks to the farm will be the health of abalone, cannot meet the test

exacerbated during summer when required of a valid Environmental

cumulative environmental impacts from Impact Statement. 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 30 EIS Executive Summary p38 31 EIS Executive Summary p39 Smith Bay Wharf Environmental Impact Statement Yumbah Response 68 Smith Bay Wharf Environmental Impact Statement Yumbah Response 69

68 Smith Bay Wharf Environmental Impact Statement Yumbah Response

• These combined risks are unacceptable to Yumbah KI

Smith Bay Wharf Environmental Impact Statement Yumbah Response 69

GUIDELINE 6: and community), and the estimated capital KIPT wouldn’t want to bestow financial and operating costs (economic).”32 hardship on the good people of KI, yet it doesn’t hesitate to dismiss a KIPT says it conducted desktop successful aquaculture business of assessments using Google Earth Pro to long-standing corporate, social and ALTERNATIVE LOCATION: arrive at these evaluations. Yumbah has sustainable credentials, which has stalled significant concerns that none of the significant growth plans due to KIPT’s 12 sites was physically assessed with intent. a studious review to verify the desktop findings. KIPT mapped the following locations: DESCRIPTION: • In its draft EIS for a Smith Bay seaport, KIPT states: The selection of Smith Bay appears to be • American River To enable a thorough assessment, based on KIPT’s economic factors and and a comparative basis of the suitability “The construction and operation of the financial return, with the social and • Ballast Head (owned by KIPT of the location of the proposal, information facility, with appropriate management environmental impacts assessed with and established in the past should be included on alternative locations measures, would have no negative effects minimal weight. as an export facility) that have been considered for the on the land-based abalone farm …” • Cape Dutton development. This information should • The basis of KIPT’s absolute “no negative In its draft EIS, KIPT states: include investigations that have been impact” claim is fundamentally flawed. • De Mole River undertaken and reasoning behind why the “Smith Bay was considered to have a proponent has deemed them less suitable • There are at least three other sites on KI number of advantages that make it the • Kangaroo Head than the proposed location. that would allow for the removal of timber best site on Kangaroo Island for a deep- water port. It is the closest practicable • Kingscote from the island, and allow Yumbah to sheltered north coast site to the timber continue operating. These must be more • Penneshaw RESPONSE SUMMARY resource that is suitable for deep-draft comprehensively addressed. ocean-going vessels to transport timber KIPT is absolutely dogmatic about its • Point Morrison products directly to Asian markets.”33 choice of Smith Bay. It discounts at least • Smith Bay four other locations that could be used to ALTERNATIVE LOCATIONS KIPT means Smith Bay is transport timber from Kangaroo Island by ‘the cheapest’ location rather than • The draft EIS states: Snug Cove sea. It is only at Smith Bay that KIPT will “the most appropriate”. “Initially, 16 different options at 12 potential • Vivonne Bay undertake industrial-level environmental The draft EIS notes alternative sites were locations and sites were evaluated to destruction, destroy adjacent businesses capable of exporting woodchips • Western River Cove determine their suitability for use as a and create Island-wide environmental and but not logs. It stated: safety threats. Why Smith Bay? Because deep-water export facility. A shortlist of It must be noted that two additional KIPT says it is the “most practicable”, four options was chosen for more detailed “… the inability to export logs would suitable locations were not assessed, evaluation … in terms of distance to deep represent a material loss of value cheapest option – which comes at the Point Marsden and D’estrees Bay. water from shore, the topography of the and income for KIPT and leave the highest cost for KI and its people. coastal environment, the ability to independent growers w ho have KIPT’s assessment was conducted using Google Earth Pro, no actual site inspection • KIPT identified 12 sites, and shortlisted four establish a multi-user, multi-cargo 100 per cent pine facing 34 was performed. This has resulted in a sites with a desktop assessment. None of operation (physical), the impact on financial hardship.” sensitive receptors (environmental), failure to properly assess the most the 12 sites were physically assessed. potential impacts on neighbours (social appropriate locations at each site (see Rather, the company used Google to further detail below about the alternative discount every other option, including one sites that question the validity and existing export wharf site it already owns.

32 EIS Executive Summary p17 Smith Bay Wharf Environmental Impact Statement Yumbah Response 70 33 EIS Executive Summary p17 34 EIS Executive Summary p17 Smith Bay Wharf Environmental Impact Statement Yumbah Response 71

70 Smith Bay Wharf Environmental Impact Statement Yumbah Response

Smith Bay Wharf Environmental Impact Statement Yumbah Response 71

accuracy of KIPT’s desktop assessment). • Significant amount of residential • This location also provides KIPT with • A significant decline to the water's With the application of local knowledge development (American River) exists to the option to move the development surface exists, with a maximum slope and physical site evaluations, the viability the south-west in the region, (Figure 5, just 100m to the north, which would of -36.3% and elevation loss of 75m of the alternative sites dramatically Appendix B). allow for a multi-user facility with just over 350m. changes. a significantly reduced A more thorough overview of the site • Majority of the coastline in this area is The responses below question KIPT’s coastline gradient. would reveal: steeply sloping to the ocean floor, as assumptions, highlight considerations for • Despite KIPT’s claims, the nearest shown in Figure 5 and Figure 6 other sites on Kangaroo Island and • KIPT currently own the Ballast Head private vessel mooring is located (Appendix C). illustrate why Smith Bay is not the best site location for the seaport. 3km away. • Depth data shows that the coast is • Ballast Head is an existing deep-water • KIPT uses the oyster lease/s just south lined with marine vegetation and rocky port, close to shore, which is ideally of this site is an argument against this outcroppings, followed by a drop ALTERNATIVE LOCATIONS ASSESSMENT suited for woodchip export due to the location, however the oyster leases are to a 20m depth. easy access to a ship loading located 2km south of Ballast Head. Ballast Head conveyer. A more thorough overview of the site

• The draft EIS also mentions residential would reveal: Draft EIS Summary: • New Forests, after ranking eight development (American River) located options, selected Ballast Head as its • A site inspection of Cape Dutton shows • Location of an old gypsum export south-west from the site. However, this preferred wharf proposal site35. Their a clear path to the most suitable facility. township is 3km from Ballast Head with Forestry Investment trust estate (now location, with a land elevation of only no direct line of sight. • Historic clearing (still visible). owned by KIPT) comprised of 10,700 10m from the shore in the valley. acres of hardwood and 8,300 acres of • The location is close to KIPT’s • Vegetation abuts the site. softwood36. Clearly New Forests had Cape Dutton plantations and would be ideal for a compelling business case sustaining • Cleared (potentially agricultural) land Draft EIS Summary: conveyor or jetty construction due to both log and woodchip export from and interconnected pockets of the deep-water close to shore – with Ballast Head. • The coastline is banded by a strip of vegetation exists a distance away from vegetation, with agricultural land no dredging required. the location. • As the site was used by bulk carriers directly behind it • Cape Dutton offers a very large area from the mid ‘50s until 1986, the site is • Private vessels moor within the (Figure 1, Appendix C). for the development and is located already contaminated with exotic protected waters south-west of the adjacent to a DPTI approved and marine pests, and therefore KIPT’s • Consists of very steep cliffs, dropping location (Figure 5, Appendix B). Council operated quarry which would development doesn’t pose a significant from a height of almost 75 m down to provide cost savings for KIPT’s • Cross-section shows a steep decline biosecurity risk. the water's surface in just over 250m construction. from the top of the site, with a max with a maximum slope of -36.3 per cent • This is the most sheltered deep-water slope of -28 per cent and an elevation (Figure 3, Appendix C). • There is minimal tourism interaction on location on Kangaroo Island, and has loss of 69m (Figure 3, Appendix B). the roads around Cape Dutton, with no been earmarked as a port on the DPTI • Marine vegetation and rock exists township in direct line of sight. • Nearby oyster lease/s can be seen in development plan for KI since the close to shore, before dropping to a shallow (3.6m) waters just south of 1940s. 20m depth (Figure 4, Appendix C). Ballast Head (Figure 4, Appendix B). • On a regional scale, the coastline vegetation is somewhat interconnected with other areas of vegetation but surrounded by agricultural lands (Figure 2, Appendix C).

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

Smith Bay Wharf Environmental Impact Statement Yumbah Response 72 Smith Bay Wharf Environmental Impact Statement Yumbah Response 73

72 Smith Bay Wharf Environmental Impact Statement Yumbah Response

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

Smith Bay Wharf Environmental Impact Statement Yumbah Response 72 Smith Bay Wharf Environmental Impact Statement Yumbah Response 73

Smith Bay Wharf Environmental Impact Statement Yumbah Response 73

Kingscote • Coastal imagery confirms the slight A more thorough overview of the site It begs the question why KIPT thinks it decline to the water's edge, with depth would reveal: necessary to compensate oyster lease Draft EIS Summary: data showing a gradual decline in holders 3km from the seaport when it is • A development at Vivonne Bay could • Significant residential and commercial water depth to the 9.9m mark and sand happy to place a port within metres of an utilise the existing jetty located just development and a jetty and pockets marked close to the central established land-based abalone farm. south of the assessed area, which was associated infrastructure exists (Figure location marker. once used to service the defence force ROAD COSTS 1, Appendix F) A more thorough overview of the site in deep-water. The jetty could be KIPT estimates “road upgrade costs” of $5 • Slightly sloping with a total elevation would reveal: extended to its original length out to million to $7.5 million for any site (table 3-3 loss of 29m and a maximum slope of - deep-water which would remove the of the Project Alternatives) to be paid for • This would the ideal location for land- 6.6 per cent, that presents as a need for any dredging. by government. KIPT states it requires a based infrastructure and a multi-user consistent decline from about 250m to contribution from government of $22.5 - port. The site offers access to deep- • This location would be the closest to the 1.1km point (Figure 3, Appendix F) $27 million to make the other options water close to land. KIPT’s plantations, and the “viable” as compared to $5 million needed • On a regional scale, the location is at infrastructure could also be utilised by for Smith Bay. However, there is no • Port Morrison is located away from the end of a low headland on the the local fishing fleet. explanation or substance supplied to existing aquatic industries, and is close southern side of Bay of Shoals, with a back up these estimates. to areas already contaminated with • Vivonne Bay is the most utilised large sand bar providing protection exotic marine pests. location on Kangaroo Island for its local Cape Dutton, for example, has deep water from ocean swell and agricultural land fishing industry, and would be ideal for close to shore which would alleviate extending a distance away from the other users including cruise ships – dredging costs and a DPTI-controlled coast (Figure Z, Appendix F) Vivonne Bay quarry which could reduce construction due to its proximity to Kangaroo Island costs. This site already manages industrial Draft EIS Summary: national parks. • Public foreshore infrastructure such as elements including dust, noise and other walking tracks, ocean pool and • Highly vegetated coastal area with KIPT’s draft EIS also conducted intrusions currently not present at Smith parkland visible along the coastline. some residential development and a assessments of American River, De Mole Bay. An independent detailed costing river entering the bay. River, Kangaroo Head and Penneshaw. should be supplied. Port Morrison Yumbah Aquaculture agrees these sites • Agricultural land beyond the vegetated are unsuitable for this development. Draft EIS Summary: coastline (Figure Z, Appendix K). OTHER ERRORS AND OMISSIONS In its draft EIS for a Smith Bay seaport, • Cleared agricultural land with two • Large naturally vegetated areas to both KIPT states: • The site at Smith Bay is also cleared visible residential dwellings (Figure 1, the east and west of the location. and degraded, and there are no Appendix H) (Appendix B – Desktop “The construction and operation of the material conflicts with tourism or 37 visual assessment of locations 8). • Cross-section information shows a total facility, with appropriate management marine parks. elevation loss of 21m with a maximum measures, would have no negative effects This is categorically untrue, with tourism • Surrounded by agricultural land, slope of-7.4 per cent, that shows small on the land-based abalone farm …” ventures such as KI Marine Adventures disconnected stand of vegetation (to rises in elevation at three points (Figure KIPT is less confident with the Ballast Head and Molly’s Run clearly conflicted by the south-east) and vegetation can be 3, Appendix K). site option where the EIS states that this proposal. seen adjacent to the coastline and compensation of the oyster leaseholder • Depth data shows shallow marine throughout agricultural areas (Figure 2, located 3km away may be necessary. Appendix H). vegetation, followed by almost immediate water depth of 9.5 m (Figure • Cross-sectional data shows a steady 4, Appendix K). 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). 37 EIS Executive Summary p17 Smith Bay Wharf Environmental Impact Statement Yumbah Response 74 Smith Bay Wharf Environmental Impact Statement Yumbah Response 75

74 Smith Bay Wharf Environmental Impact Statement Yumbah Response

Smith Bay Wharf Environmental Impact Statement Yumbah Response 75

GUIDELINE 7:

ALTERNATIVE STRUCTURES (IN WATER)

DESCRIPTION: • Draft EIS does not consider revised proposal and circumstances The proposal includes the construction of a solid causeway that will extend o Causeway in new design 50m longer approximately 200m into the ocean for the than stipulated in DAC Guidelines purpose of loading the timber products onto the ships at the attached floating berth. A solid causeway, as proposed, is IMPACTS ON ECOSYSTEMS, likely to inhibit the natural water flow within RECREATIONAL AND COMMERCIAL Smith Bay, and potentially lead to pooling OPERATIONS of water upstream. The nature and level of impacts of the proposed causeway on the KIPT’s EPBC referral of proposed action, marine environment (including water dated July 2016, states: temperature), and the ecosystems, ”The Smith Bay site is within the Coastal recreational and commercial operations Conservation Zone of the KIDP (Kangaroo reliant upon the waters of Smith Bay, have Island Development Plan), which means not been detailed. Merits of alternative in- that the proposed development is non- Figure 6 – Early impressionist wharf image showing "descoped" public access water structures (including a jetty) should complying. Under this plan, non-complying be investigated to determine the most developments are not prohibited per se, On this alone, the proposal is in direct The draft EIS talks of a “Marine Exclusion appropriate structure for the area and but must be considered on their merits.” conflict with the natural attributes of the Zone” and diagrams of the seaport operation. Coastal Conservation Zone of Smith Bay published to local media show security and is an industrial activity incompatible fences extending into the water making RESPONSE SUMMARY with existing land uses. the traversal of the Smith Bay foreshore along the beach or by sea impossible. • Minimising cost is the primary The wharf location is in front of a public determinant driving KIPT to choose a road which has traditionally provided solid causeway in Smith Bay access to a rocky beach that the local community frequently accesses. Locals Proponent summarily eliminates all o were promised a boat ramp and fishing other options wharf. These have been “descoped” 38 o Location and seaport fail to consider along with the promise of servicing cruise wider negative social, economic and ships. As such, the infrastructure proposed environmental implications in the seaport has no net benefit to the o Proponent crafts a flawed catchment community. model to build a misleading case that a cheap solid causeway would be beneficial for Yumbah KI

Acknowledges environmental impact o could be reduced, but refuses to pay to do so 38 KIPT Executive Summary p 11 Smith Bay Wharf Environmental Impact Statement Yumbah Response 77

Smith Bay Wharf Environmental Impact Statement Yumbah Response 76

76 Smith Bay Wharf Environmental Impact Statement Yumbah Response

GUIDELINE 7:

ALTERNATIVE STRUCTURES (IN WATER)

Acknowledges environmental impact o could be reduced, but refuses to pay to do so 38 KIPT Executive Summary p 11 Smith Bay Wharf Environmental Impact Statement Yumbah Response 77

Smith Bay Wharf Environmental Impact Statement Yumbah Response 76

Smith Bay Wharf Environmental Impact Statement Yumbah Response 77

WRACK ISSUES • Amendments to the risk assessment. The photo below depicts the magnitude of Coastal structure (e.g. groynes, causeways) Though risk reference item 8 in Table wrack accumulation at the Emu Bay boat often cause the accumulation of seagrass The draft EIS reports that accumulated drift 4-1 of EIS Appendix G identifies the ramp. This structure is minute and extends wrack and degradation of seawater quality seagrass and macroalgae (wrack) will hazard, modification to seagrass wrack a few metres offshore. The solid causeway that did not occur prior to their placement. occur as a consequence of the accumulation, the basis for a proposed by KIPT at Smith Bay will extend The proximity of the causeway to the Yumbah KI facility’s intakes may cause construction of the causeway. This consequence of ‘minor’ and likelihood 250m offshore. potential accumulation is absolutely wrack accumulation and water quality of ‘possible’ is not supported. Further, unacceptable as it has the potential to degradation of source water entering the mitigation measures only change the The significant risk of wrack accumulation significantly impact Yumbah KI’s intakes abalone farm. residual likelihood and not the residual on the quality of the source waters to and abalone health. Yumbah KI’s abalone farm is critically consequence (note this comment also The report by Romero (2019) (Appendix 1) lacking and needs to be addressed as a applies to reference item 6 in Table 4-1, shows the draft EIS Appendix G is lacking Accumulation of drift seagrass and other priority, particularly given the close and it is uncertain why changes in the information to address the potential macroalgae will clog intake pipes and proximity of the proposed solid causeway impacts of seagrass wrack on the residual likelihoods to references 2 degrade water quality. The extent of to the inlet pipes. abalone farm. and 3 are included with no [nil] degradation and potential impacts on Seagrass wrack accumulation has the mitigation measures noted). The Yumbah KI and Smith Bay are lacking in potential to impact Yumbah KI’s intakes. the EIS, and Romero (2019) has highlighted inherent and residual risk for seagrass the need for additional information, wrack accumulation is not supported. including: The draft EIS admits issues will be prevalent around the causeway “Drift • A description of the seagrass wrack seagrass and macroalgae (wrack) may dynamics of Smith Bay sometimes accumulate against the • Predictions of the effect of the causeway in response to prevailing winds proposed development on the and currents, but is likely to disperse seagrass wrack dynamics of Smith Bay naturally. The situation would be monitored and managed if and when • Impacts of the predicted changes required”. Where will it disperse if a big of seagrass wrack dynamics on the solid eyesore of a causeway is blocking its source waters to Yumbah KI’s natural passage? Will it dissolve or abalone farm 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?

Figure 7 - Seagrass wrack at nearby Emu Bay

Smith Bay Wharf Environmental Impact Statement Yumbah Response 78 Smith Bay Wharf Environmental Impact Statement Yumbah Response 79

78 Smith Bay Wharf Environmental Impact Statement Yumbah Response

Figure 7 - Seagrass wrack at nearby Emu Bay

Smith Bay Wharf Environmental Impact Statement Yumbah Response 78 Smith Bay Wharf Environmental Impact Statement Yumbah Response 79

Smith Bay Wharf Environmental Impact Statement Yumbah Response 79

ALTERNATIVE LOCATIONS THE EVER-CHANGING CAUSEWAY FAR FROM BENEFICIAL discharge and sediment loads are not verifiable. Yumbah’s response to Guideline 6 notes The proposed in-water infrastructure In Yumbah’s view it is misleading to claim alternative locations for this infrastructure involves construction of a 250m long solid the causeway will somehow benefit The modelling of smaller storms is required with a more positive outcome for causeway - not 200m as in the Guidelines. Yumbah KI as the draft EIS suggests. to demonstrate accurately the frequency, community and reduced environmental This increased length has not been magnitude and duration of any impact. accounted for in modelling and dredging KIPT purports the causeway will aid suggested benefit. tests. Yumbah KI by creating an impermeable Kangaroo Island Council, as the wall, physically blocking Smith Creek’s The repeated misuse of modelling data in representative body of the KI community, The causeway is extended with a linkspan flows to the west and isolating flows from the draft EIS discounts claims across the agrees. bridge to a floating pontoon for vessel the farm’s intake pipes. entire document. mooring and timber loading. It is Yumbah’s The alternative locations have a view that this scale and intrusion is clearly Construction of the causeway is an combination of existing and adaptable at odds with the coastal landscape of escalated threat to Yumbah because it is CHEAPEST ISN’T BEST infrastructure including port facilities, safer Smith Bay. an impermeable wall blocking oceanic road networks, proximity to KIPT’s currents, reducing mixing in the receiving The draft EIS presents findings from an plantations and greater linkages to The causeway will reduce ocean currents environment and subsequently elevating evaluation of alternative structures (in- workforce and community hubs. by an estimated 30-40 per cent, which, in water temperatures and reducing water). turn, will elevate water temperatures, water quality. By contrast, Smith Bay is remote, requires The preference for the solid causeway reduce mixing of oceanic water, considerable and unfunded upgrades to combined with a suspended deck is accumulate drift seaweed (wrack) and Yumbah KI has been successfully roads and transport routes, and is within described as: compromise oceanic conditions. operating at Smith Bay since 1995 with a Coastal Conservation Zone and Rural negligible impact from Smith Creek. One “… the most cost-effective option for the Living Zone. These are all prerequisite and currently exception is a limited number of storms causeway to approximately eight metre stable conditions for Yumbah KI’s in 2016. depth, after which a suspended deck in ongoing operation. Romero (2019) (Appendix 1) reviewed the deeper water would be more cost- opinions in the draft EIS attempting to effective”. justify a solid causeway. It concluded the The EIS Main report (page 43) discusses catchment model used in the draft EIS to the evaluation of: predict the impacts of flood plumes from Smith Creek on the marine waters near “… twelve possible combinations of Yumbah’s seawater intakes is flawed. approach structure (three alternatives) and berth face (four alternatives), and a wide The suggested benefit to Yumbah KI, range of approach lengths, giving rise to notably reducing water turbidity near the considerable variation in the resulting inlet pipes created by a very infrequent 1:10 dredge volume. The main considerations 39 storm at Smith Bay does not justify the in the evaluation were the anticipated causeway’s construction. environmental impact and the expected According to Romero (2019), the construction cost”. catchment modelling is designed to It considers environmental and economic demonstrate how the causeway reduces factors as relevant, yet ignores the suspended sediments created by flooding existence of Yumbah’s abalone farm in Smith Creek. The simulated large immediately adjacent.

39 AEP states a storm that created this issues in 2016 are 1:10 and as such, extremely rare. Smith Bay Wharf Environmental Impact Statement Yumbah Response 80 Smith Bay Wharf Environmental Impact Statement Yumbah Response 81

80 Smith Bay Wharf Environmental Impact Statement Yumbah Response

Smith Bay Wharf Environmental Impact Statement Yumbah Response 81

makes inadequate consideration of on the Island at various times. EFFECTS ON OTHER BUSINESSES • KIPT’s proposed seaport Yumbah KI’s needs, and discounts without Beyond the massive threat to Yumbah’s due consideration both alternative sites A mortal threat to Yumbah KI RESPONSE SUMMARY o operation, the visual amenity of KIPT’s and alternative structures in water. seaport proposal will also have major • Yumbah has been operating at Smith CLOSEST NEIGHBOUR impacts on the nearby luxury bed and Bay since 1995 breakfast, Molly’s Run located just 750m Yumbah KI’s abalone farm is the closest from the proposed seaport. 100 per cent Australian-owned o neighbour to the proposed KIPT seaport. and operated Molly’s Run has operated at Smith Bay for It shares a fence with the site owned by employs more than 100 full-time staff the past seven years, and hosts around o KIPT, and the wharf is proposed at some across regional Australia 1,000 guests every year. This proposal will 300m from Yumbah’s seawater

have a significant effect on this tourism o annual combined revenue of about intake pipes. business, and no amount of buffer $30 million Each of Yumbah’s four farms is tailored for vegetation, or blending colours will prevent the environment in which it has been the major loss of view for tourists who stay • Investment freeze on KI established and operates in accordance as Molly’s Run. o Smith Bay is an optimum site for with respective licences and permits. onshore aquaculture Smith Bay was selected for the quality threat of KIPT “seaport” has stalled o of its water, appropriate tidal flow, the investment, with other states set to structure of Smith Bay’s sea floor, benefit remoteness, freedom from marine pests and other threats to sensitive receptors • A good corporate citizen like abalone, and a welcoming community.

o Yumbah has always employed more than 20 people on KI o Develops staff skills and expertise o Supports local professionals and tradespeople

Smith Bay Wharf Environmental Impact Statement Yumbah Response 82 Smith Bay Wharf Environmental Impact Statement Yumbah Response 83

82 Smith Bay Wharf Environmental Impact Statement Yumbah Response

The draft EIS (page 44) states: BETTER THAN A CAUSEWAY GUIDELINE 8: The most favoured structure (a combined The suggestion of open culverts or bridge approach with a causeway leading to a sections with the causeway provides little suspended deck jetty and floating advantage. pontoon) would also be the least COMMUNITY expensive to construct and would have The only option to protect coastal currents relatively low environmental impact. A is an open-piled jetty with the berth pocket significant and unjustified increase in extended further offshore. DESCRIPTION: o Advance aquaculture as a positive, sustainable export business for construction cost would be required to Reducing the solid nature of the seaport The proposal is likely to lead to a change reduce the environmental impact will assist also with reducing the incidence KI and the State in the Kangaroo Island population (short- any further. of marine biofouling of invasive marine Contribute to business and community term and long-term) both during the o species and concentration of disease development groups on KI It is Yumbah’s view that KIPT could reduce construction and operational phases of the agents such as toxic dinoflagellates within Generous with financial and other the impact on the environment, it just proposed development. This will lead to a o the nearshore environment. support to sports and community doesn’t want to pay the bill. change in demand for various services, interests However, the argument of the draft EIS infrastructure and accommodation needs makes inadequate consideration of on the Island at various times. EFFECTS ON OTHER BUSINESSES • KIPT’s proposed seaport Yumbah KI’s needs, and discounts without Beyond the massive threat to Yumbah’s due consideration both alternative sites A mortal threat to Yumbah KI RESPONSE SUMMARY o operation, the visual amenity of KIPT’s and alternative structures in water. seaport proposal will also have major • Yumbah has been operating at Smith CLOSEST NEIGHBOUR impacts on the nearby luxury bed and Bay since 1995 breakfast, Molly’s Run located just 750m Yumbah KI’s abalone farm is the closest from the proposed seaport. 100 per cent Australian-owned o neighbour to the proposed KIPT seaport. and operated Molly’s Run has operated at Smith Bay for It shares a fence with the site owned by employs more than 100 full-time staff the past seven years, and hosts around o KIPT, and the wharf is proposed at some across regional Australia 1,000 guests every year. This proposal will 300m from Yumbah’s seawater have a significant effect on this tourism o annual combined revenue of about intake pipes. business, and no amount of buffer $30 million Each of Yumbah’s four farms is tailored for vegetation, or blending colours will prevent the environment in which it has been the major loss of view for tourists who stay • Investment freeze on KI established and operates in accordance as Molly’s Run. o Smith Bay is an optimum site for with respective licences and permits. onshore aquaculture Smith Bay was selected for the quality threat of KIPT “seaport” has stalled o of its water, appropriate tidal flow, the investment, with other states set to structure of Smith Bay’s sea floor, benefit remoteness, freedom from marine pests and other threats to sensitive receptors • A good corporate citizen like abalone, and a welcoming community.

o Yumbah has always employed more than 20 people on KI o Develops staff skills and expertise o Supports local professionals and tradespeople

Smith Bay Wharf Environmental Impact Statement Yumbah Response 82 Smith Bay Wharf Environmental Impact Statement Yumbah Response 83

Smith Bay Wharf Environmental Impact Statement Yumbah Response 83

This environment is threatened and trust Yumbah reduces this pressure by breeding KIPT IN OPEN ‘LAWFARE’ In 9 March 2018 KIPT disclosed to the has been destroyed by the arrival of KIPT from internal farm broodstock to produce AGAINST YUMBAH ASX:41 as an aggressive, careless neighbour juvenile abalone which are grown to “… none of the easements affecting the willing to litigate without pause to market size using a controlled but natural KIPT’s draft EIS indicates that the Smith company’s land prevents it from negotiate for a “shared” understanding production system. Bay site has “… several recognised proceeding with the development” and benefit40. easements and its wharf infrastructure has Yumbah utilises seawater pumped from been designed to ensure the rights Further, the company declared it: the open ocean, which flows over the conferred by these easements are not YUMBAH AQUACULTURE tanks and delivers oxygen to the abalone compromised” (draft EIS Main report, page “… does not believe any of the matters before returning to the ocean. Abalone are 110). are material.” Yumbah is the only Australian abalone reliant on fresh, high quality seawater and producer to own and control every aspect are sensitive to changes in water quality. However, the draft EIS omits details of the KIPT has spent a year waging expensive of its operations, from breeding, Alterations in water quality such as easement rights detailed on the full legal action in the South Australian on-growing and feed production through elevation in temperature, increased Certificates of Title as can be seen in Supreme Court in an attempt to strip to processing/value adding, marketing nutrients, anthropogenic contaminants Appendix 7. One easement referred to in Yumbah of these easement rights. and sales. the draft EIS is a drainage easement in and suspended fine sediment can have The as yet unanswered question is: if these lethal consequence and at sub-lethal levels favour of Yumbah. This gives Yumbah More than 70 per cent of the 700 tonnes of easement rights have no impact on this compromise health and growth. rights to access the easement at any time abalone grown annually by Yumbah is to: proposed development, why is the exported to Southeast Asia, North America company spending shareholders’ funds “… break the surface of, dig, open up and and Europe. YUMBAH KANGAROO ISLAND and diverting senior management use” the easement for “the purpose of resources at this time in its development In recognition of Yumbah’s commitment to Yumbah KI operates under two Crown land laying down, fixing, taking up, repairing, re- to pursue unnecessary legal action? cultivating premium abalone, Yumbah licenses issued by the previous South laying or examining pipes thereon and for

Aquaculture received the 2017 National Australian Department for Environment the purpose of transferring water to and Agribusiness Award at the Australian and Water. Yumbah KI owns Allotments the storage of water in a dam thereon, Export Awards. The company also won 50, I2, 200. It has two current licences for affixing thereon and maintaining pumps the Governor of Victoria Export Awards pump and pipeline purposes, Licence # and electrical switch gear and of using (GOVEA) in 2017. OL022375 (Crown lands 467 and 361) and and maintaining those pipe pumps and Licence # OL21749 (Crown lands 471 and electrical switch gear for water supply purposes.” SUSTAINABILITY 362). Yumbah holds land based Aquaculture Responsible aquaculture is caring for the licences not only for a range of Abalone environment by reducing harvest pressure species but also for Bream, Flounder, on wild fish stocks. As with so many of the Kingfish, Lobster, Mulloway, Oysters, ocean’s fish species, wild abalone has Scallops, Sea Urchin, Seahorse, Snapper, been exploited to near extinction in many Brown and Rainbow Trout and Whiting. countries across the globe. The draft EIS is silent on the impact of the Seaport on the cultivation of these species.

40 Whilst professing a desire to co-exist with its neighbor KIPT have launched action in the Supreme Court of South Australia 41 https://www.asx.com.au/asxpdf/20180309/pdf/43sb28v6nl7cf0.pdf whose impact, if successful, will strip Yumbah of some of its ability to carry out its fundamental business of abalone aquaculture. Smith Bay Wharf Environmental Impact Statement Yumbah Response 84 Smith Bay Wharf Environmental Impact Statement Yumbah Response 85

84 Smith Bay Wharf Environmental Impact Statement Yumbah Response

Smith Bay Wharf Environmental Impact Statement Yumbah Response 85

KIPT LAND USE The draft EIS attempts to raise a robust argument diminishing potential The draft EIS makes no comment on future environmental consequences of a timber uses of the 225ha of land KIPT owns at export seaport built on Yumbah KI’s Smith Bay. doorstep. The significant and undisclosed On 4 September 2018 KIPT announced an risks of further establishing a multi-use port option to acquire 41ha south of and cannot be ignored in an EIS – but they are adjoining its existing land at Smith Bay. in this draft EIS. It told the ASX the control of this land gave it flexibility to: KIPT CLAIMS AGAINST YUMBAH • Change intersection geometry at the KIPT claims it is a significant contributor to turn-off from the main road to the economic viability of Kangaroo Island accommodate high productivity and provided optimistic forecasts of jobs, vehicles, and economic activity associated with its proposal. • Create a truck parking and driver rest area or an additional pine log storage; To support its case, KIPT has made many and claims about Yumbah in private and in the public domain. • Realign the heavy vehicle route from the main road to the KI Seaport It hasn’t hesitated to work to dirty Yumbah’s standing with Government and • Possibly dispose of some surplus land community. and seek to acquire other land parcels It has raised red herring arguments about in the area Yumbah KI’s survival at Smith Bay. Despite disclosures to the market, the draft It has argued Yumbah’s failure to invest is EIS is silent on these matters. (1) an indication of a struggling business, and the action of investing in site maintenance and (2) an indication Yumbah KIPT’S TRUE INTENTION? is confident it can prosper with KIPT as its Did KIPT buy these parcels to make an overshadowing neighbour. approved Smith Bay project attractive to KIPT has even postulated Yumbah faces a foreign bidder? impending closure thanks to climate Is this Major Development Process simply change impact. a play to offload an approved infrastructure The real and absolute threat to project to a third party? Yumbah KI is KIPT. Why would the company require such

large parcels of land around Smith Bay, Figure 8 - Rendering of KIPT proposal at Smith Bay showing Yumbah’s easement rights when according to its draft EIS the development will be fully contained in the 11ha parcel of land directly adjacent to Yumbah?

Smith Bay Wharf Environmental Impact Statement Yumbah Response 86 Smith Bay Wharf Environmental Impact Statement Yumbah Response 87

86 Smith Bay Wharf Environmental Impact Statement Yumbah Response

Smith Bay Wharf Environmental Impact Statement Yumbah Response 86 Smith Bay Wharf Environmental Impact Statement Yumbah Response 87

Smith Bay Wharf Environmental Impact Statement Yumbah Response 87

ERRORS AND OMISSIONS • A Marine Activity Zone (MAZ) would be GUIDELINE 9: prescribed for the Smith Bay site • There are unlikely to be sufficient during construction to warn the public skilled workers on Kangaroo Island to fill the new positions. Consequently, at to avoid a clearly defined area to 43 least 60 per cent of the workers (140 reduce navigational risks. NATIVE VEGETATION AND FAUNA FTE jobs) would be recruited from the How will Yumbah operate in what KIPT mainland, increasing the Island's will seek to have declared a ‘Marine population by an estimated 330.42 Activity Zone’ with temporary exclusion DESCRIPTION: An estimated population increase of zones? How will KIPT respect the NOTHING TO SEE HERE 330 suggests workers will bring their licences and easements that Yumbah The proposed site is in an area that is mostly cleared of native vegetation, Despite the ecological riches of Smith Bay families with them. With 20 per cent holds, some of which intersect and however patches of vegetation remain, and the native vegetation and fauna utilisation of infrastructure and surround the wharf site? and although fragmented these may guidelines above, plus its responsibility to seasonal work programs, the bulk provide critical habitat for fauna. satisfy the needs of an EPBC Act referral, of these will turn out to be low-skilled Investigation into vegetation on KIPT’s draft EIS is premised on just one contractors on fly-in/fly-out surrounding properties and within the ecological survey over one day in 2016. engagement adjacent marine environment should also Its conclusion from a walk-past is that there be undertaken to determine if the is nothing to see, nothing to manage or proposed development and associated protect at Smith Bay. activities will impact upon these habitat areas and the species, including migratory As example, a patch of the Kangaroo species, that may be reliant upon them. Island Narrow-leaved Mallee (Eucalyptus cneorifolia) Woodland Ecological Community on the adjacent southern RESPONSE SUMMARY property fence line has potential to meet the size category for a threatened • A single ecological survey community. conducted over one day in 2016 is not sufficient Likewise, no observation of the daily flight of the magnificent White-bellied Sea Eagle • KIPT has not considered across the subject development site. behavioural impacts on white High-disturbance developments have bellied sea-eagles or southern right been shown to affect fledgling outcomes whales of this endangered species.44 • The arguments in the draft EIS And having even further understated the appear to be based on personal nature of what is in the marine judgement, not an evidence-based environment, the proponents lists shortfall scientific conclusion mitigation measures, some of which Yumbah responds to below.

42 EIS Executive Summary p66 44 Effects of human disturbance on productivity of White-bellied Sea-Eagles (Haliaeetus leucogaster), Terry E. Dennis A D, 43 EIS Executive Summary p63 Rebecca R. McIntosh B and Peter D. Shaughnessy C - http://www.publish.csiro.au/mu/mu10044 Smith Bay Wharf Environmental Impact Statement Yumbah Response 88 Smith Bay Wharf Environmental Impact Statement Yumbah Response 89

88 Smith Bay Wharf Environmental Impact Statement Yumbah Response

Smith Bay Wharf Environmental Impact Statement Yumbah Response 89

cargo? What impacts? What mitigation wharf at Smith Bay would fragment or was absent. • A medium level of risk associated with and management? decrease the size of populations of impact piling potentially resulting in any species of pipefish, affect their Are the rules for “seaports” different permanent hearing damage to No answers in the draft EIS. critical habitat or disrupt their breeding to those for aquaculture? southern right whales within 900 cycles. It is concluded that the project • • metres of the piling, and temporary The construction of a causeway (0.95 proses no credible risk to the viability It is concluded that the project poses hearing damage within 6.5 km of ha) and the dredging of the berthing of pipefish on the north coast.48 – no credible risk to any of the piling.45 pocket and approaches (9.2 ha) would threatened marine species.50 result in the direct loss of about 10 ha of A “reasonable or foreseeable How has KIPT reached the prognosis The method for determining that there mixed habitat, including the seagrasses possibility” is that dredging, that hearing loss will be permanent or is “no credible risk” is a personal Posidonia sinuosa, Amphibolis disturbance, noise, water quality loss temporary? judgement in support of the proponent, antarctica and A. griffithii, and and a suite of other short-term and not an evidence-based scientific Consideration is only given to the associated invertebrate communities.47 perpetual interferences in Smith Bay by physical damage that close-proximity KIPT will have immeasurable impact on conclusion. Confirmed sea grass loss, best practice to noise generating sources may pipefish – and many other native fauna • Noise interference sources include biosecurity does not eradicate the risk. cause. There is no discussion of the and flora. some types of dredging, infrastructure behavioural impacts of exposure to By the tone of this draft EIS, losing • The seagrasses Posidonia sinuosa and construction and operation (particularly noise at levels below that causing seagrass is okay because there is more Amphibolis spp. (A. antarctica and A. pile driving and explosives) and vessel physical damage. along Kangaroo Island’s north coast griflithi1), which are long-lived and noise (including tender activity), but the There is much recent literature about and animals can move there. But sites considered to be particularly important cumulative impacts of all sources of these impacts particularly on like Smith Bay have niche ecosystems ecologically, grow in patches among noise interference need to be rock bottom in depths up to 9 metres, 51 behavioural changes resulting from specific to site, and the variation and considered. and continuously over a mixed exposure to piling activities. This ongoing discovery of what Smith Bay is and has continues with the work of substrate of sand, pebble and shell There is no further mention at all of any should be discussed in this draft EIS; 49 citizen science organisations like fragment at depths of 9-15 metres. noise impacts on marine fauna. It’s it is not. understood that underwater noise AusOcean. Posidonia sp. is a seagrass the EPA is modelling was undertaken for the draft • Shipping activity (approximately 10–20 particularly predisposed to protecting. vessels per annum) to and from Smith On a specific point, the draft EIS fails EIS but this has not been incorporated Bay is unlikely to result in an increase to mention the severe impact on the In Yumbah’s experience, if KIPT was into the marine ecology analysis in whale strikes.46 critically endangered pipefish, with proposing an aquaculture venture despite the identification of this issue estimated elimination of 5000 and Posidonia sp. was present, South in Appendix 12. If we’re to believe KIPT, it’s seaport will Syngnathid spp. as a result of the Australia’s peak environmental operate at just 20 per cent capacity. seaport construction. regulator would not support the We don’t know what it will do, what proposal. 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.

48 EIS Appendix I1 p 27 45 EIS Executive Summary p41 49 EIS Appendix I1 p11 46 EIS Main Document p40 50 EIS Appendix 11 p26 47 EIS Executive Summary p50 51 EIS Appendix 12 p5

Smith Bay Wharf Environmental Impact Statement Yumbah Response 90 Smith Bay Wharf Environmental Impact Statement Yumbah Response 91 90 Smith Bay Wharf Environmental Impact Statement Yumbah Response

ERRORS AND OMISSIONS How many more ships or other vessels • There is no reasonable or foreseeable The proponent would be directed to will berth? What sorts of vessels? What possibility that construction of the relocate to a site where Posidonia sp. cargo? What impacts? What mitigation wharf at Smith Bay would fragment or was absent. • A medium level of risk associated with and management? decrease the size of populations of impact piling potentially resulting in any species of pipefish, affect their Are the rules for “seaports” different permanent hearing damage to No answers in the draft EIS. critical habitat or disrupt their breeding to those for aquaculture? southern right whales within 900 cycles. It is concluded that the project • • metres of the piling, and temporary The construction of a causeway (0.95 proses no credible risk to the viability It is concluded that the project poses hearing damage within 6.5 km of ha) and the dredging of the berthing of pipefish on the north coast.48 – no credible risk to any of the piling.45 pocket and approaches (9.2 ha) would threatened marine species.50 result in the direct loss of about 10 ha of A “reasonable or foreseeable How has KIPT reached the prognosis The method for determining that there mixed habitat, including the seagrasses possibility” is that dredging, that hearing loss will be permanent or is “no credible risk” is a personal Posidonia sinuosa, Amphibolis disturbance, noise, water quality loss temporary? judgement in support of the proponent, antarctica and A. griffithii, and and a suite of other short-term and not an evidence-based scientific Consideration is only given to the associated invertebrate communities.47 perpetual interferences in Smith Bay by physical damage that close-proximity KIPT will have immeasurable impact on conclusion. Confirmed sea grass loss, best practice to noise generating sources may pipefish – and many other native fauna • Noise interference sources include biosecurity does not eradicate the risk. cause. There is no discussion of the and flora. some types of dredging, infrastructure behavioural impacts of exposure to By the tone of this draft EIS, losing • The seagrasses Posidonia sinuosa and construction and operation (particularly noise at levels below that causing seagrass is okay because there is more Amphibolis spp. (A. antarctica and A. pile driving and explosives) and vessel physical damage. along Kangaroo Island’s north coast griflithi1), which are long-lived and noise (including tender activity), but the There is much recent literature about and animals can move there. But sites considered to be particularly important cumulative impacts of all sources of these impacts particularly on like Smith Bay have niche ecosystems ecologically, grow in patches among noise interference need to be rock bottom in depths up to 9 metres, 51 behavioural changes resulting from specific to site, and the variation and considered. and continuously over a mixed exposure to piling activities. This ongoing discovery of what Smith Bay is and has continues with the work of substrate of sand, pebble and shell There is no further mention at all of any should be discussed in this draft EIS; 49 citizen science organisations like fragment at depths of 9-15 metres. noise impacts on marine fauna. It’s it is not. understood that underwater noise AusOcean. Posidonia sp. is a seagrass the EPA is modelling was undertaken for the draft • Shipping activity (approximately 10–20 particularly predisposed to protecting. vessels per annum) to and from Smith On a specific point, the draft EIS fails EIS but this has not been incorporated Bay is unlikely to result in an increase to mention the severe impact on the In Yumbah’s experience, if KIPT was into the marine ecology analysis in whale strikes.46 critically endangered pipefish, with proposing an aquaculture venture despite the identification of this issue estimated elimination of 5000 and Posidonia sp. was present, South in Appendix 12. If we’re to believe KIPT, it’s seaport will Syngnathid spp. as a result of the Australia’s peak environmental operate at just 20 per cent capacity. seaport construction. regulator would not support the We don’t know what it will do, what proposal. 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.

48 EIS Appendix I1 p 27 45 EIS Executive Summary p41 49 EIS Appendix I1 p11 46 EIS Main Document p40 50 EIS Appendix 11 p26 47 EIS Executive Summary p50 51 EIS Appendix 12 p5

Smith Bay Wharf Environmental Impact Statement Yumbah Response 90 Smith Bay Wharf Environmental Impact Statement Yumbah Response 91 Smith Bay Wharf Environmental Impact Statement Yumbah Response 91

GUIDELINE 10: INCREASED TRAFFIC ISSUES The EIS states:

Timber haulage will see A-Double trucks – “During the operational phase, heavy TRAFFIC & TRANSPORT semi-trailers with two trailers – driving vehicle movements are likely to reach continuously on KI roads 24 hours a day, a daily maximum of about 130 and an 53 seven days a week. At peak production, a average of about 85.” The impact on KI and its residents will be DESCRIPTION: truck would be expected to pass along the massive, and to date there is no The EIS also states: transport route in each direction information as to who will pay for the The proposed port, and associated approximately every 22 minutes. “The proportion of heavy vehicles using necessary road upgrades and infrastructure, will generate traffic, in the roads would increase from the existing maintenance, the inevitable road trauma, 6 to 15 per cent up to approximately 11 to particular for the export of timber. The These heavy vehicles will increase surface or the effect on native fauna. 22 per cent near the major population proponent estimates that there will be wear on unpaved and poor conditioned approximately 14 shipments of harvested centres, and up to 28 per cent on Playford • Timber haulage vehicles will increase roads unsuitable for this kind of heavy, 54 timber per year from KIPT operated land, Highway. consistent traffic. Yet KIPT says it has no and that the wharf will be used 50-75 days wear on poor roads that are not built to idea who will pay for the constant road per annum in total for all Kangaroo Island carry heavy traffic. Yet there is no This effectively doubles the proportion of maintenance and upgrades – assuming it timber exports (including from other timber established plan as to who will pay for heavy vehicles using KI roads. Meanwhile, operators on the Island). As it is proposed the constant road maintenance and will be council ratepayers or taxpayers the exact nature of the heavy vehicles is to be a multi-user wharf, traffic will also be upgrades. KIPT says it won’t pay. That through government funding. yet to be defined nor has the exact route taken nor the specific activities these generated from a range of potential other leaves KI ratepayers or South The EIS states: uses including, but not limited to, Australian taxpayers footing the bill. vehicles will be carrying out. agricultural exports and tourist and/or “During the construction phase, the cruise ships. – DAC Guidelines. • The impact and heightened risk of increase in traffic (up to about 10 vehicle such careless planning on road safety, movements a day over the 15-month community amenity and public construction period) is likely to be RESPONSE SUMMARY infrastructure is a matter of record in indistinguishable from existing volumes.”52

A-Double trucks, also known as a short The Green Triangle plantation region. This EIS does not reveal the traffic baseline road train 30m long carrying up to 60 • Road safety guidelines will be required, so it is impossible to evaluate the nature of tonnes, will haul timber on KI roads, 24 to reduce, but notably not eliminate, the increase in traffic – it simply cannot be hours a day, seven days a week. At peak the increased number of accidents that defined or dismissed as production, a truck is expected to pass will occur on KI roads due to timber “indistinguishable”. along KIPT’s transport route to Smith Bay, haulage. Again, there is no suggestion in each direction, every 22 minutes. This as to who will pay and who will huge volume of traffic will travel on roads implement these. not fit for purpose, in areas not accustomed to dealing with timber haulage • In pursuing Smith Bay for its seaport, vehicles, among tourists and school buses. KIPT is forcing timber haulage vehicles to drive further than necessary, given there are suitable wharf sites closer to its timber plantations.

52 EIS Executive Summary p62 53 EIS Executive Summary p62 54 EIS Executive Summary p62

Smith Bay Wharf Environmental Impact Statement Yumbah Response 92 Smith Bay Wharf Environmental Impact Statement Yumbah Response 93 92 Smith Bay Wharf Environmental Impact Statement Yumbah Response

GUIDELINE 10: INCREASED TRAFFIC ISSUES The EIS states:

52 EIS Executive Summary p62 53 EIS Executive Summary p62 54 EIS Executive Summary p62

Smith Bay Wharf Environmental Impact Statement Yumbah Response 92 Smith Bay Wharf Environmental Impact Statement Yumbah Response 93 Smith Bay Wharf Environmental Impact Statement Yumbah Response 93

TRAFFIC SAFETY ISSUES and collisions will be a consistent NATIVE FLORA AND FAUNA • Managing the spread of Phytopthora annoyance to life on Kangaroo Island. (a soil based root fungus) KIPT says it will need: The EIS estimates up to 21 endangered The EIS states: Kangaroo Island echidnas will be killed • Preserving threatened species “A set of road safety guidelines developed NATIVE FLORA AND FAUNA each year as a result of the timber haulage, • Managing the spread of Phytopthora by the University of Adelaide’s Centre for “training and safety initiatives” (15 EPBC identified Nationally while other animals including the southern (a soil based root fungus) Automotive Safety Research for KIPT, to The EIS estimates up to 21 endangered threatened plant species) will be required to minimise incidents, Kangaroobrown bandicoot Island echidnas and the hooded will be killed plover • Preserving threatened species improve the safety of the timber haulage The EIS is silent on these issues. operations, through safer roads and noting that there is absolutely nothing eachwill also year be as affected. a result Byof thebuilding timber the haulage, (15 EPBC identified Nationally speeds, driver competency and training anyone can do to stop them if the seaport whileseaport other at a animals location including closer to thethe southerntree threatened plant species) is constructed. There is no discussion and in-vehicle technological aids”. brownplantations, bandicoot the distance and thes hoodedtravelled plover by OTHER ERRORS AND OMISSIONS regarding who is going to implement any willtimber also trucks be affected. would be By reduced building and,the as a The EIS is silent on these issues. This is a dangerous operation. Timber “initiatives”, who will ensure they happen seaportresult, the at impacta location on nativecloser faunato the wouldtree • The EIS states the exact nature of the haulage vehicle near misses, incidents and who will pay for these. also be reduced. traffic on KI and the number of plantations, the distances travelled by OTHER ERRORS AND OMISSIONS timber trucks would be reduced and, as a The EIS provides no plans or specifications “vessels visiting each year depends result, the impact on native fauna would • The EIS states the exact nature of the for the road upgrades that will be on the sequence of plantation harvesting, also be reduced. traffic on KI and the number of necessary to support the traffic from commodity prices and availability of shipping.”56 construction vehicles and timber haulage “vessels visiting each year depends The EIS provides no plans or specifications trucks. It is therefore not possible to on the sequence of plantation harvesting, for the road upgrades that will be The economic viability of the proposed estimatenecessary the to impactsupport on the roadside traffic from commodity prices and availability of shipping.”seaport depends56 entirely on the sequence vegetationconstruction and vehicles the extent and timberto which haulage any of plantation harvesting, commodity prices trucks.such upgrades It is therefore would not comply possible with to or be Theand availabilityeconomic viabilityof ships, of none the proposed of which is in denied by the KIC Roadside Vegetation estimate the impact on roadside seaportthe control depends of KIPT entirely. on the sequence Management Plan55 (KICRVMP) which vegetation and the extent to which any of plantation harvesting, commodity prices suchoperates upgrades under wouldthe legislative comply withframework or be and availability of ships, none of which is in deniedof the Local by the Government KIC Roadside Act, Vegetation Native the control of KIPT. ManagementVegetation Act Plan and55 the(KICRVMP Environment) which Figure 9 - Image from www.kangarooisland.sa.gov.au/vegetation operatesProtection under and Biodiversity the legislative Conservation framework ofAct the. Key Local considerations Government listed Act, Native by the VegetationKICRVMP for Act managing and the Environmentroadside Protectionvegetation andinclude: 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%202 007.pdf 56 EIS Executive Summary p21

55http://www.kangarooisland.sa.gov.au/webdata/resources/files/KIC%20Roadside%20Vegetation%20Management%20Plan%202 Smith007.pdf Bay Wharf Environmental Impact Statement Yumbah Response 95 56 EIS Executive Summary p21

Smith Bay Wharf Environmental Impact Statement Yumbah Response 94 Smith Bay Wharf Environmental Impact Statement Yumbah Response 95 94 Smith Bay Wharf Environmental Impact Statement Yumbah Response

TRAFFIC SAFETY ISSUES and collisions will be a consistent NATIVE FLORA AND FAUNA • Managing the spread of Phytopthora annoyance to life on Kangaroo Island. (a soil based root fungus) KIPT says it will need: The EIS estimates up to 21 endangered The EIS states: Kangaroo Island echidnas will be killed • Preserving threatened species “A set of road safety guidelines developed NATIVE FLORA AND FAUNA each year as a result of the timber haulage, • Managing the spread of Phytopthora by the University of Adelaide’s Centre for “training and safety initiatives” (15 EPBC identified Nationally while other animals including the southern (a soil based root fungus) Automotive Safety Research for KIPT, to The EIS estimates up to 21 endangered threatened plant species) will be required to minimise incidents, Kangaroobrown bandicoot Island echidnas and the hooded will be killed plover • Preserving threatened species improve the safety of the timber haulage The EIS is silent on these issues. operations, through safer roads and noting that there is absolutely nothing eachwill also year be as affected. a result Byof thebuilding timber the haulage, (15 EPBC identified Nationally speeds, driver competency and training anyone can do to stop them if the seaport whileseaport other at a animals location including closer to thethe southerntree threatened plant species) is constructed. There is no discussion and in-vehicle technological aids”. brownplantations, bandicoot the distance and thes hoodedtravelled plover by OTHER ERRORS AND OMISSIONS regarding who is going to implement any willtimber also trucks be affected. would be By reduced building and,the as a The EIS is silent on these issues. This is a dangerous operation. Timber “initiatives”, who will ensure they happen seaportresult, the at impacta location on nativecloser faunato the wouldtree • The EIS states the exact nature of the haulage vehicle near misses, incidents and who will pay for these. also be reduced. traffic on KI and the number of plantations, the distances travelled by OTHER ERRORS AND OMISSIONS timber trucks would be reduced and, as a The EIS provides no plans or specifications “vessels visiting each year depends result, the impact on native fauna would • The EIS states the exact nature of the for the road upgrades that will be on the sequence of plantation harvesting, also be reduced. traffic on KI and the number of necessary to support the traffic from commodity prices and availability of shipping.”56 construction vehicles and timber haulage “vessels visiting each year depends The EIS provides no plans or specifications trucks. It is therefore not possible to on the sequence of plantation harvesting, for the road upgrades that will be The economic viability of the proposed estimatenecessary the to impactsupport on the roadside traffic from commodity prices and availability of shipping.”seaport depends56 entirely on the sequence vegetationconstruction and vehicles the extent and timberto which haulage any of plantation harvesting, commodity prices trucks.such upgrades It is therefore would not comply possible with to or be Theand availabilityeconomic viabilityof ships, of none the proposed of which is in denied by the KIC Roadside Vegetation estimate the impact on roadside seaportthe control depends of KIPT entirely. on the sequence Management Plan55 (KICRVMP) which vegetation and the extent to which any of plantation harvesting, commodity prices suchoperates upgrades under wouldthe legislative comply withframework or be and availability of ships, none of which is in deniedof the Local by the Government KIC Roadside Act, Vegetation Native the control of KIPT. ManagementVegetation Act Plan and55 the(KICRVMP Environment) which Figure 9 - Image from www.kangarooisland.sa.gov.au/vegetation Protectionoperates under and Biodiversity the legislative Conservation framework Actof the. Key Local considerations Government listed Act, Native by the KICRVMPVegetation for Act managing and the Environmentroadside Protectionvegetation andinclude: 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%202 007.pdf 56 EIS Executive Summary p21

55http://www.kangarooisland.sa.gov.au/webdata/resources/files/KIC%20Roadside%20Vegetation%20Management%20Plan%202 007.pdfSmith Bay Wharf Environmental Impact Statement Yumbah Response 95 56 EIS Executive Summary p21

Smith Bay Wharf Environmental Impact Statement Yumbah Response 94 Smith Bay Wharf Environmental Impact Statement Yumbah Response 95 Smith Bay Wharf Environmental Impact Statement Yumbah Response 95

GUIDELINE 11: WATER IS CRITICAL • Watering unpaved roads during construction and operation and cleared Water availability is critical on Kangaroo areas during construction/land clearing Island. Smith Bay has no access to 59 reticulated water from SA Water and activities WATER groundwater is highly saline, which means But where is the water coming from, and in the project will rely on capturing and what volumes, requiring what treatment to reusing surface water. DESCRIPTION: • KIPT will need water for dust make it fit for purpose? suppression, fire hazard reduction The only water supply for its immediate The draft EIS reports ongoing water Water availability and use is a critical issue and firefighting neighbour, Yumbah KI, is obtained from demands to be: on Kangaroo Island and is fundamental to rainfall captured into a dam. The silence the livelihood and sustainability of the o The source of this reliable supply of the draft EIS on the matter of sourcing a • (enough to spray) up to approximately community and local industry. SA Water is not known water supply seems, ignorantly, to assume 0.5ha of roadways and up to 5ha of supplies reticulated water to some areas o Water for dust suppression will be the availability of a metropolitan, city level, timber storage areas requiring a peak on the island, however Kangaroo Island is contaminated with dust, chemicals and supply of water to remote Smith Bay. of approximately 10,000 litres per day heavily reliant on the capture and reuse of organic matter that will negatively Water is required for: surface water. The proponent should affect Yumbah • fire suppression water only required in indicate how it is intended to source, reuse • Dust suppression emergencies and training/readiness and treat water for, and at, the proposed • Such contaminated water may find its drills site, to minimise impact on existing water way into groundwater or Smith Bay • Dredge spoil watering resources and quality. • up to approximately 500 litres per day There is evidence the groundwater is • Hazard reduction (woodchips and logs) of potable water associated with staff o connected to the marine environment ablutions and drinking water RESPONSE SUMMARY • Fire suppression (emergency)

• KIPT will needs massive volumes of • KIPT’s proposed industrial stormwater • Potable supplies for staff amenities The draft EIS offers storage of up to water during construction and ongoing ponds are 125m from Smith Bay The draft EIS states water is required for: 54,000 litres of dust suppression water (in operations addition to storage within the site retention o EPA requires wastewater lagoons • Mitigation measures to reduce basin) in a high-density polyethylene tank Draft EIS has no information about to be at least 500m from a high tide o emissions during construction and (or series of tanks), with separate firewater water sources, rights or licensing mark operations, including using water storage. o There is no information about who will pay for water delivery and removal sprinklers on cleared areas before Using the utilisation figures above, this infrastructure construction during infrastructure means KIPT will hold enough water for just periods of adverse (hot and windy) 5.4 days of spraying the timber storage 57 • Spray run-off is a contaminant risk for weather area. Yumbah KI • Using water sprays on bare timber What happens after this? during hot and windy weather and o Draft EIS is silent on water treatment The amount of water available for dust using water sprays during woodchip and containment on-site suppression and firefighting is most likely and log handling and loading58 o The reasonable assumption is that inadequate. contaminated water will go either

back to the water table or to pollute Smith Bay

57 EIS Executive Summary p37 58 EIS Executive Summary p37 59 EIS Executive Summary p38 Smith Bay Wharf Environmental Impact Statement Response 96 Smith Bay Wharf Environmental Impact Statement Yumbah Response 97

96 Smith Bay Wharf Environmental Impact Statement Yumbah Response

Smith Bay Wharf Environmental Impact Statement Yumbah Response 97

FIREFIGHTING AND DUST The proposed use of contaminated HIGHLY SALINE NEGATIVE EFFECTS ON GROUNDWATER SUPPRESSION INADEQUATE industrial stormwater for landscape watering and dust suppression gives no The use of groundwater and seawater as Potential impacts of site activities to Dust generation and combustion of consideration to the threat of this activity to potential emergency water supplies should groundwater below the site and stockpiled timber or woodchips at the the ongoing operations of Yumbah KI. be prohibited due to elevated salinity in connectivity with regional aquifers seaport will present a new threat to both sources. demands further investigation. Yumbah KI, particularly given its primarily The draft EIS states: A single grab sample taken towards the “down-wind” positioning from the sources WATER FOR DUST SUPRESSION northern boundary of the site identified the of these threats. INNAPROPRIATE “groundwater is unlikely to be in use in the groundwater to be 1.65m below ground immediate Smith Bay region and there is The impact of fire is exacerbated by Smith level (BGL) (Appendix L, Section 4.3). The draft EIS fails to provide adequate no intent to use groundwater for site Bay’s isolation and the absence of readily understanding of potential contamination activities”. The total dissolved solid (TDS) available local emergency services. of the captured stormwater and timber concentration was 18,000 mg/L, indicative “Unlikely” suggests “possibility” and must Kangaroo Island is experiencing more leachate generated within the hard stand of saline conditions, inferring that be confirmed or denied. If there is frequent extreme weather conditions areas of the seaport. groundwater is potentially connected to possibility, there is intent to extract where summer temperatures consistently the marine environment. Contaminants Logs and woodchips (without additional groundwater for on-site activities, and a reach mid-40s for extended periods. including iron, lead, cobalt, copper, chemical treatment) can leach high organic hence a comprehensive groundwater Under these scenarios, there is no sulphate and nitrite were measured in the matter and correspondingly high chemical assessment is required. guarantee a reliable water supply will be oxygen demand (COD), both of which are sampled groundwater. This single sample available for firefighting. known to decrease oxygen levels in is scientifically insufficient to adequately receiving waters. They can also leach characterise baseline groundwater quality at the site. The draft EIS reports: phosphorous, nitrogen, phenols, resin acids and ammonium and alter soil and The potential impact on groundwater from “…. timber log and woodchip storage yards water pH. stormwater management and industrial are isolated from the general stormwater water reused for dust suppression and system. Each yard will drain via a concrete Of the organic compounds extracted from softwood, those of greatest concern as landscape watering must be further forebay to intercept sediment and debris. investigated. Stormwater will then enter the retention likely contributors to toxic runoff include basin (holding pond)”60. tannins, lignins, phenols, tropolones, volatile fatty acids and resin acids. Increased irrigation intensities and Water from the retention basin will be: pollutants can exceed the infiltration absorption and degradation capacity of “used for irrigation of adjacent landscape soil, resulting in leaching to groundwater. buffer (where contaminants will biodegrade) and for dust suppression An ecotoxicological analysis of the (within wood storage areas)”61. stormwater must be conducted to understand the effect of any proposed Dust suppression using industrial reuse. 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 Smith Bay Wharf Environmental Impact Statement Yumbah Response 98 Smith Bay Wharf Environmental Impact Statement Yumbah Response 99

98 Smith Bay Wharf Environmental Impact Statement Yumbah Response

60 Main report pg.73 61 Main report pg.371 Smith Bay Wharf Environmental Impact Statement Yumbah Response 98 Smith Bay Wharf Environmental Impact Statement Yumbah Response 99

Smith Bay Wharf Environmental Impact Statement Yumbah Response 99

STORMWATER PONDS: TOO CLOSE FOR NOT THE SOLUTION: MORE TRUCKS COMFORT It has been suggested fresh water be GUIDELINE 12: SA EPA509/19 Wastewater lagoon brought to the site by a third-party to construction guidelines state: supplement short supply. “To minimise the impacts of odour, the risk Further, reclaimed seawater may be used of leakage to groundwater and the risk of during extended periods without rainfall. NOISE & LIGHT polluting groundwater or surface waters, This brings even more trucks to an the construction of wastewater lagoons incapable road network – and has not • KIPT claims the major source of should be avoided … within 500 m of a been considered by the draft EIS traffic DESCRIPTION: artificial lighting at Smith Bay is high tide mark. impact assessment. It is expected that both underwater and associated with the existing land-based The draft EIS proposes industrial terrestrial noise pollution will occur during aquaculture operation which is the construction phase as a result of stormwater be ponded 125 metres from continuously lit at night. This “major securing the mooring and retaining Smith Bay. The draft EIS Appendix C3 source” at the abalone farm consists of structures to the seabed, the use of identifies this location due to the low two single outdoor lights for security topography of the land. earthmoving equipment and physical construction of the structures. Post purposes The location of this contaminated construction, the movement of vehicles to • The two security lights are minimal and stormwater storage presents risk to both and from the proposed site, stockpiling shielded from abalone production Smith Bay and groundwater beneath the and ship-loading operations onsite at site, and is just metres of Yumbah KI’s Smith Bay will also generate noise. If • Abalone feed predominantly at night, grow-out tanks (see Figure 10). construction and/or operations are to and onshore production mimics natural occur at night there will also be light cycles by ensuring darkness at pollution impacts on the surrounding area. feeding times

• Light spill expected from the port RESPONSE SUMMARY construction and ongoing operation The lighting required for the proposed will further jeopardise Yumbah’s seaport to operate safely and commercially ongoing business in Smith Bay is not compatible with the operations of an adjacent onshore abalone farm, nor for KIPT agree that construction may cause guests at high-end accommodation who permanent hearing damage to whales that stay at Smith Bay for its peaceful isolation. come within one kilometre of the wharf, Further, escalated noise levels during and temporary damage for those that construction and operations, both on land come within 6.5km. and in the Smith Bay marine environment, will have a negative effect on amenity, on • There is no existing regulatory native species – and the wellbeing of requirement regarding underwater highly sensitive abalone. noise to drive standards and compliance by KIPT

• KIPT admits that there will be significant underwater noise during the construction phase

Figure 10 – Graphic from KIPT’s draft EIS showing the locations of contaminated stormwater storage

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• KIPT admits that there will be significant underwater noise during the construction phase

Figure 10 – Graphic from KIPT’s draft EIS showing the locations of contaminated stormwater storage

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LIGHT The most viable comparison is a night ABALONE FEEDING This opinion, like so much of the opinion photo of the woodchip/wharf area at the offered by KIPT in the draft EIS, is partially KIPT claims that the wharf will be lit Port of Portland in Victoria whose activities Abalone are disturbed by light, they true in some way, but simply incorrect in similarly to the abalone farm. Apart from would be subject to similar OH&S actively feed at night and are sedentary context. small external security lights Yumbah KI requirements as the proposed KI wharf. during the day. Any light emitted by the does not emit light at night. Light from the seaport will compromise their feeding There are at this point in time no lights at seaport however will be emitted The amenity that sustains the nearby behaviour, significantly reducing animal Smith Bay other than security lighting on continuously at night, and it is expected premium accommodation business, health, compromising welfare, and the Yumbah KI office building to illuminate large flood lights will brightly illuminate the Molly’s Run, will be ruined which currently reducing the productivity and viability a small area of the farm for security entire port area pre-dusk to post-dawn for invites guests to “enjoy beautiful night of Yumbah KI. purposes. safety and ongoing operations. skies, sunsets, dawns”. The draft EIS states Abalone are extremely sensitive and largely intolerant to night-time light. “The major source of artificial lighting at Literature indicating abalone’s sensitivity to Smith Bay is associated with the existing light is missing from the draft EIS. 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.”

Figure 11 - Port of Portland at night.

Figure 12 - Drone photo of Yumbah KI at night.

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Figure 11 - Port of Portland at night.

Figure 12 - Drone photo of Yumbah KI at night.

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McShane (2019) confirms that light-spill The time of feed introduction and light The high proportion of quiescent NOISE onto the abalone farm from KIPT’s intensity have also been shown to affect behaviour displayed by greenlip abalone proposed infrastructure in the hard- abalone feeding behaviour, with darkness during the light period in the study of Buss A number of misleading and erroneous standing area and along the stimulating both higher grazing and growth et al. (2015) may be an evolutionary statements are suggested throughout the wharf/causeway as well as from transport rates compared to light exposure for post- response to increased vulnerability to Main Report and Appendix N that purport vehicles will create significant difficulties larvae, six-day-old red abalone (Haliotis predation on active wild abalone during Yumbah as a significant noise source for Yumbah KI. rufescens) in static conditions (Searcy- daylight hours (Shepherd 1973; Hahn 1989; through its stationery equipment and Bernal & Gorrostieta-Hurtado 2007). Jenkins 2004). Feed ration and heavy vehicles movements. The vague and misleading assessment photoperiod had far greater impacts on the Feed intake and growth rates have been The very nature of abalone farming creates regarding abalone tolerance to extraneous feeding behaviour of abalone than diet light attempts to relate abalone’s reported to increase by 24 and 260 per minimal noise, equivalent to ambient in the type (Buss et al. 2015). In regards to marine environment and does not impact propensity to preferring dark environments cent, respectively, for red abalone photoperiod, greenlip abalone exhibited as their defence mechanism to avoiding juveniles (40mm) when cultivated in amenity. There are a number of noise the most movement and feeding behaviour sources within an abalone farm that create predation. Abalone are cryptic complete darkness (Ebert & Houk 1984). during darkness, supporting the notion that gastropods, preferring to hide in crevices isolated noise within close proximity to the No feeding activity was observed during nocturnal feeding is preferred source, but generally noise is comparable and against ledges. They are nocturnal (Buss et al. 2015). feeders and feeding rates decrease in the daylight hours in ass’s ear abalone to background. (Haliotis asinina). The highest feeding presence of light (e.g. Ebert & Houk 1984; So, the conclusions in Appendix H Section activity occurred during darkness between Heavy vehicle movements do not occur Tutschulte & Connell 1988; Tahil & Juino- 4.3.2 should indeed state that light at night 1800 and 0200 h and ceased entirely with abalone farming. The operational Menez 1999; Garcia-Esquivel et al. 2007; will decrease feeding as the abalone do before sunrise (Tahil & Juino-Menez 1999). noise sources particularly bulldozers, Searcy-Bernal & Gorrostieta-Hurtado 2007; not feed during daylight. This will chippers, woodchip stackers (to name a Lloyd & Bates 2008). Quiescent behaviour was dominant in all consequently have a debilitating decrease few) that will be operating constantly for 24 greenlip abalone (Haliotis laevigata) from in abalone growth and farm productivity. hour 7 days within the seaport will create If an accurate interpretation of literature Extraneous night-time light will cause was indeed conducted for extraneous light 0400 h until the following evening (Buss et significant operational noise that cannot be al. 2015). The cessation of movement changes in behaviour and movement as impacts to abalone, Section 4.3.2 of compared to the benign activity of growing during this period has previously been the abalone are active only during dark Appendix H would otherwise have abalone. noted for other Haliotis spp. (Shepherd conditions. Abalone will become stressed accurately presented the evidence to 1973; Tutschulte & Connell 1988; Tahil & when the photoperiod becomes a 24-hour The statement that there is “no established conclude night-time light is detrimental to period of intensified light, as is the special need for quiet at the Yumbah abalone in a farming environment. Juino-Menez 1999; Pereira et al. 2007; Lloyd & Bates 2008), demonstrating that as potential from the seaport. Oxygen Aquaculture site” in Appendix N (pg 21) is Appendix H concludes that in a study by daytime approaches, the presence or consumption and ammonia excretion rates pure negligence and offensive. KIPT Alter et al. (2004) there was no absence of food has minimal effect on are higher under light versus dark continue to show complete disregard for measurable effect of light vs dark abalone movement. conditions, indicating that environmental Yumbah’s staff and its operations. conditions on the oxygen consumption alterations will have physiological effects Yumbah KI operates in a Coastal Juvenile abalone, in particular, have been rates (used as a direct index of stress) for (Ahmed et al., 2008). Conservation Zone with a negligible reported to follow this trend, displaying these animals. The outcomes of this study environmental footprint and the quiescent behaviour during daylight, The published findings are consistent with environmental values and health of its staff were blatantly misrepresented, tests were the observations of Yumbah’s hatchery conducted on abalone larvae in a hatchery. actively feeding during darkness and require protection. resuming quiescent behaviour before manager and the practice of reducing light Reference to Pereira et al (2007) is dawn (Tutschulte & Connell 1988; Pereira to optimise feeding and growth in the Yumbah engaged GHD to complete a misleading. The results of the experiment et al. 2007). farming of abalone. Light has a technical review of the predicted noise and were inconclusive as to which light regime demonstrable and adverse effect on vibration impacts of the seaport. The was most favourable when considering the feeding and growth of abalone. review has focused primarily on Appendix N of the draft EIS. growth patterns and comparative mortality rates within the systems. GHD’s findings in the Smith Bay Aquaculture Assessment Noise & Vibration Review (Lenchine, 2019) have been included in Appendix 8 of this submission.

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The findings highlight concerns with the • The main report in the draft EIS The draft EIS reports that underwater noise The proposed lighting system at the assessment of noise and vibration in the summarises a traffic noise assessment, impact is likely to be high during the new facility is likely to be similar to draft EIS, including: yet data on traffic inputs relevant to construction phase of the project. As existing lighting from the nearby KIPT’s draft EIS does not provide detailed onshore aquaculture facility. The KI • Assessment of construction noise has predicting noise impact are not provided. The draft EIS simply claims information about the nature of its Seaport’s lights would likely blend into not been completed. The lack of this construction activities, the effect of traffic noise complies with the existing lighting of the abalone demands KIPT take the impact of its underwater noise and any vibration to requirements in the DPTI Road Traffic farm and thus the cumulative impact of proposal on neighbours, amenity and marine species cannot be estimated. additional lighting is expected to be environment more seriously Noise Guidelines. But the proponent A much more considered approached 63 fails to present the method of its traffic is warranted. low . • An assessment of the efficiency of noise predictions, locations of affected Comparing the proposed operational proposed noise mitigation measures is receivers and predicted traffic seaport’s expected flood of light – necessary noise levels ADDITIONAL ERRORS AND OMMISIONS evidenced by the operations at the • Information in the main report • More information is required to validate • The major source of artificial lighting at Port of Portland – to the small security contradicts the recommendations of KIPT’s assumptions Smith Bay is associated with the lights of Yumbah is disingenuous. In the acoustic report regarding what existing land-based aquaculture the claimed accumulation of impact, noise mitigation measures should be operation, which is continuously lit at the baseline is zero, and the implemented to meet the relevant UNDERWATER NOISE night, illuminating the beachfront north cumulative effect is all KIPT. noise criteria for the nearest residential An underwater noise assessment forms of the facility and the abalone tanks, 62 receivers part of KIPT’s acoustic report (Appendix N). and the western side of the facility. However, there are no regulatory • Noise from the development is not Manifestly incorrect. Yumbah is the documents applicable to the company’s only present light source, comprising expected to meet the applicable assessment that establish standards for two small security lights. criteria for Yumbah’s abalone farm. The compliance. acoustic report in the draft EIS does not adequately explain why it is not The South Australian Government’s practicable to achieve the criteria and Underwater Piling Noise Guidelines 2012 report provides details on pile driving how this will affect the abalone farm noise. Underwater vibration assessment is • Local meteorological conditions, not mandated by any regulatory particularly background conditions, documents, and guidance on this kind of have not been adequately considered impact is lacking. Therefore, it does not in the assessment. The criteria under form part of the submitted draft EIS. SA Noise EPP does not depend on the The acoustic report details an underwater pre-existing background level but background noise assessment. Levels rather on the zoning of the noise typical for the current environment are source and the relevant receivers around 90-120 dB depending on weather conditions and other environmental factors.

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GUIDELINE 13: The adverse consequences of increased Abalone are less adaptive to sudden water temperature on abalone are changes in water temperature which is acknowledged in Appendix H: “Likely more likely with the impact of the solid increases in water temperature causeway on mixing and circulation of CLIMATE CHANGE & SUSTAINABILITY accentuated by recirculation of Yumbah water close to Yumbah KI’s intake pipes. effluent water will also have a harmful effect on abalone. Data collected for the AGAIN, WHY SMITH BAY? DESCRIPTION: Yumbah has observed climatic variability in EIS throughout 2017, using moored data Smith Bay over more than 20 years. It buoys that were equipped with a suite of KIPT’S strident advocacy for a Smith Bay Climate change is of State, National and holds water quality data from the start of its water quality and hydrodynamic sensors seaport is more unusual for the fact that it global importance. This proposal includes operations, with correlating weather, tide (detailed in Chapter 10), show that mean is the most remote site of all those on offer, elements adjacent to, and within, the coast and storm event information far away from the timber plantations. For a and seabed. Measures need to be taken to and observations. seawater temperature during the monitoring period at Smith Bay within 300 company intent on being a “green” both protect the proposed infrastructure in industry, KIPT is imposing on itself an It’s clear Yumbah knows Smith Bay. m of shore during summer was around 21- the longer term from the impacts of a unnecessary carbon debt from transport KIPT does not. 22oC but there were spikes up to 25oC changing climate and reduce any emissions. greenhouse gas emissions associated with Climate change won’t force Yumbah out of recorded during heatwaves (see Chapter its construction and use. business. The accumulated shocks and 9) (Appendix H, Page 27). As Cheshire Its choice of Smith Bay does not support massive risk profile of KIPT being granted (2018) further notes: many farms across the principles of resource efficiency and a green light for its proposed Smith Bay South Australia have reported substantial sustainability. RESPONSE SUMMARY project will force Yumbah KI out of mortality events at much lower A seaport closer to the timber resource, o • The proposed solid causeway will business and irrevocably damage Smith temperatures (22-23 C; Vandepeer and connected to the electricity grid, produce a “Climate Change” event for Bay on land, sea and in the air. 2006).” would produce fewer direct greenhouse Yumbah KI The draft EIS provides further self-serving gas emissions, cut the fuel bill (and commentary by KIPT in relation emissions) from KIPT’s round-number • STORMWATER MANAGEMENT Yumbah is expert on Smith Bay to climate change. estimate of 500 000 litres of diesel. This is NOT UP TO THE TASK an estimate that assumes no connection to Yumbah manages climate risks for its o the electricity grid and generators being own operation The setback of stormwater retention ponds SOLID CAUSWAY IMPACTS in the draft EIS is not adequate to protect the primary power supply. o Water temperature and quality are under a continuous monitoring regime The predicted modelled effects of the against storm events and sea-level rise. The influence of interconnectivity of Smith Increased frequency of storm events proposal on water circulation, flushing and COASTAL BLUE CARBON ECOSYSTEMS o Bay with shallow groundwater aquifers and tidal extremities is noted water temperatures are provided in KIPT’s beneath the site may impact stormwater The term ‘coastal blue carbon ecosystems’ Infrastructure is built and upgraded to draft EIS Appendix G (Coastal Processes). o retention ponds. refers to three main types of vegetated

meet conditions coastal habitats: mangroves, tidal marshes According to Romero (2019) KIPT’s and seagrasses. • KIPT is the greatest and immediate proposed construction of a 250m ABALONE ARE “SENSITIVE RECEPTORS” threat to Yumbah causeway will substantially affect In recent years, there has been significant Abalone are adaptive and will evolve with nearshore water movement in Smith Bay. development in the science – with Climate change presents a expected increases in temperature o The draft EIS indicates that reduction in associated policy development – to global threat projected at 0.5°C by 2030, and by 0.2°C current speed at Yumbah’s westerly understand the role of the intertidal marine Yumbah tracks change and factors and 2.2°C by 2090 under the intermediate- ecosystems of seagrasses, mangroves and o seawater intake will be about 30–40 per this in its daily operations and and high-emissions scenario, respectively. saltmarshes and their contribution cent (Appendix H, page 65): this will Genetic selection of broodstock to tolerate long-term planning coincide with an increase in ambient higher temperatures and improvements in KIPT is the immediate, mortal threat to o seawater temperature (Appendix G, page husbandry and diet are expected to Smith Bay environment and business 23). improve tolerance to warming average

temperatures.

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temperatures.

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to carbon dioxide bio-sequestration and ERRORS AND OMISSIONS GUIDELINE 14: emissions reduction64. • The total carbon sequestration of the Improved management of carbon rich KIPT-managed plantations is ecosystems can also improve fisheries and conservatively estimated to be increase resilience of coasts to rising sea approximately 6.8 million tonnes of RISKS & HAZARDS levels and storm surges. CO2 -e. Intertidal habitats, particularly seagrass Obviously, for KIPT shareholders to earn a As individual plantations are expected DESCRIPTION: meadows, are recognised globally as commercial return, KIPT will have to having the greatest carbon sequestration to be replanted or coppiced following identify and cater for alternative uses for The Kangaroo Island Development Plan, potential, far greater than sequestration first harvest, this amount of the port. and the South Australian Planning Strategy potential by terrestrial forests. sequestration would remain relatively constant over the life of the promote development, including But on these alternative uses, the draft EIS infrastructure, to be located away from is silent. The draft EIS’s intent to remove 10 operation.65 hectares of seagrass and create trails of areas that are vulnerable to the risk of KIPT and the draft EIS fail to reveal, identify sediment in Smith Bay will contribute large hazards for both the protection of human or consider the risks and hazards amounts of CO into the atmosphere. health and the environment. Given the 2 associated with other uses for its which will continue into a future well location of the proposed development, the multi-use facility. beyond that which KIPT foresees. following hazards include, but are not limited to: spills (including oil), flooding, fire • Chemical spills The seagrass meadow cannot be (in particular heavy vehicle, timber yard replanted in the hope of acting as a new and bushfire), site contamination, storage o KIPT admits that fuel/oil and chemical carbon sink. and movement of hazardous materials and spills will be an inevitable part of the As part of a more comprehensive and landslip/coastal erosion. All risks and development hazards need to be detailed and accountable EIS than the existing draft, o The company suggests it will be able KIPT must assess the carbon sequestration consideration given to how these risks and to minimise these with “standards and of their timber plantation compared with hazards will be avoided and managed. protocols”, but not stop them the carbon capture potential in the seabed o Who sets the standards and protocols? it proposes to dredge. RESPONSE SUMMARY Who agrees, who monitors them, who assumes responsibility and accounts The risks and hazards associated with a for risk when things go wrong? seaport at Smith Bay are many - and potentially devastating. Chemical spills and • Alternative uses of the port fuel spills are an inevitable part of seaport operations, timber fumigation is a standard o KIPT admits timber exporting from the feature of ports handling logs, as is seaport will put the port at 20 per cent chemical leaching from timber used in capacity construction or stored at the port. The draft o There is vague mention in the draft EIS EIS suggests mitigation of some of these that the seaport design has capacity for risks but acknowledges there is nothing additional vessels and associated that can be done to eliminate them. cargo The infrastructure will be established It’s curious and worrying that the draft EIS o expects timber exporting at KIPT’s seaport for the timber industry and will be to account for just 20 per cent of the inappropriate for other uses. Yet it – and the company arguing its seaport’s capacity. o case in the draft EIS – is silent on what these other uses may be, meaning any 64 https://www.environment.gov.au/climate-change/government/australia-work-on-blue-carbon subsequent economic, social and 65 EIS Executive Summary p42 Smith Bay Wharf Environmental Impact Statement Response 110 Smith Bay Wharf Environmental Impact Statement Response 111

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environmental impact or implications o A responsible proponent would include o Vehicle strikes already kill on Yumbah KI is already compatible and well- for KI are also absent this possibility in its draft EIS, detailing average 35 Kangaroo Island aligned with the Rural Living Zone. Its footprint and proven performance over o A credible business has a Plan B and a the project itself, its location – Echidnas each year, this number Plan C especially if at Smith Bay, and its will increase significantly with more than 20 years have had no impact on the Coastal Conservation Zone that makes o In the absence of a complete business impact, particularly a traffic and air/land increased traffic from timber case for this seaport, there is no means pollution analysis transport to Smith Bay Smith Bay such an idyllic location. of testing the environmental impact of To justify its dogma on Smith Bay as the Whales have the potential to be this proposal running at 20 per cent • Leaching from treated timber used o only location it will consider on KI, KIPT severely impacted by the seaport, capacity in construction argues for this location, infrastructure, with predicted behavioural It simply doesn’t stack up particularly construction methodology, operational o The draft EIS fails to address the changes in response to noise, when KIPT now owns a significant o conditions and apparent benefits in a Risk impacts of treated timber used in wharf including construction and vessel 225ha of coastal land abutting Smith Assessment as Appendix T in its draft EIS. construction noise if in a proximal location Bay Fundamentally, this risk assessment does KIPT has not accounted for any o not accurately nor adequately reflect chemical leaching from timber stored • Woodchip mill/QA UNACCEPTABLE HAZARDS AND RISKS actual and perceived risks and hazards of at the seaport screening/bioenergy its Smith Bay proposal. The Risk o The concentration of leachate Safe Work Australia describes hazards and Assessment does not align with the details o KIPT’s Project Description says discharged stormwater retention risks as66: and conclusions of the technical “…woodchipping may be undertaken basins into the marine environment is assessments in the draft EIS, and proposed • Hazards – Situations or things that at an off-plantation woodchipping unknown risk mitigation and management measures facility located along the core transport have the potential to harm are negligent and unconvincing. route between the plantation and • Fumigation at the port • Risks – The possibility that harm Smith Bay” Will the port handle raw timber or is might occur when exposed to a A POOR TRACK RECORD It may argue such a development o o there a treatment process prior to hazard would be subject to other planning The consequences of a realised risk from export? measures The multiple hazards – some known, many KIPT’s seaport constitute an overwhelming Will KIPT fumigate logs in future as The seaport proposal has already o unknown – in establishing and operating economic threat to the existing business of o occurs at other ports around the morphed into something different to KIPT’s proposed seaport at Smith Bay Yumbah KI. country? that addressed in the draft EIS directly adjacent to Yumbah KI cannot be These create additional significant risks satisfactorily addressed to provide Put simply, mitigation and management Whether this possible woodchip mill o o to Smith Bay’s integrity and the confidence for Yumbah to confidently measures are not always effective. In the is off Smith Bay or on Smith Bay, operations of Yumbah KI continue its business. case of KIPT, it has already set an it must be detailed and assessed exceedingly low bar in in preparing its draft What approvals or permits are required in this draft EIS o KIPT’s draft EIS is negligent in assessments EIS. if future fumigation is considered? KIPT’s Project Description says, of social, economic and environmental o What is KIPT’s plan for consultation In 2017, KIPT was issued a “cease and “Woodchip quality control processes o risks of its proposed seaport at Smith Bay. with regulators, neighbours and wider desist” order from the South Australian may be undertaken at the plantation The company’s draft EIS consideration and community? respect of potential hazards and Government after it failed to obtain the following primary woodchipping, 67 These are neither mentioned nor subsequent risks to Yumbah KI is required approvals to drill in Smith Bay . or at an intermediate facility” o acknowledged in KIPT’s draft EIS patchwork, disorganised and routinely When the company later managed to gain As above, particularly if this activity o presents misleading opinion as science. the required approval, its activities caused is to be at Smith Bay, it should be significant damage to the seagrass floor of detailed in the draft EIS • MNES

o KIPT and Kangaroo Island Council have Impacts to MNES, namely southern o discussed using timber by-product in a right whales and echidnas, are of bioenergy plant paramount concern to the wider 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 community

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Smith Bay68 apparently because its another of the many appropriate and marine species, including construction and operations is contractors were using “the wrong type available locations on an island with endangered and threatened being off-shored by KIPT of anchor”. 500km of coastline. species

With this incident alone as its starting point, • Economic – significant economic MISSING DREDGE MANAGEMENT PLAN we have no confidence this company can implications exist with the proximity meet even its own commitments on risk KIPT admits that a “chips only” operation of the seaport to Yumbah KI and The draft EIS clearly recognises that there management. can be established at three alternative sites other than Smith Bay69. the operations of many adjacent are no clear environmental windows that Further, all management measures would and Smith Bay-dependent small offer the opportunity to significantly reduce KIPT says 80 per cent of its plantation need to be effective in perpetuity as the business impacts associated with dredging. Further estate is hardwood and 20 per cent recognition is granted to that although risks posed to Yumbah KI by this seaport 70 are perpetual to Yumbah. softwood , with just a small proportion • Biosecurity – KIPT’s actions at dredging during winter rather than summer of softwood to be exported as logs71. Smith Bay will inevitably introduce would avoid sensitive periods for the This is a high bar even for the best invasive marine pests and disease reproduction of seagrasses and proponent. If woodchips are where the business is, and other sites are possible and available agents that will immediately invertebrates, it would not benefit For a proponent with no experience of the – then why is there such intent to make jeopardise Yumbah KI’s operations macroalgae, which reproduces in winter, infrastructure it plans and deliberately Yumbah KI unviable and, with it, Smith and southern right whales, which may visit ignorant of the highly-specialised business Bay? • Suspended solids – the zone of the area during winter. Consequently, the it most threatens – Yumbah – it’s an influence (i.e. extent of detectable draft EIS concludes there are no impossible ask. plumes with no predicted persuasive ecological arguments for HAZARDS FOR YUMBAH ecological impact) is predicted to dredging during a particular season. For a company that outsources its forestry extend east and west along the Yumbah has identified multiple hazards operation, has agreements with Mitsui to coastline for approximately 5–6km posed to its operations by KIPT’s Smith How can a Dredge Management Plan run its port operation, has separated its for the expected case and Bay seaport proposal. Below is not an consider the risks that will result at varying wharf assets to facilitate an easy sale and approximately 8km for the worst exhaustive list, and detail is addressed degrees no matter what time of the year wants others to assist it with managing case biosecurity risks, it is far from clear who will elsewhere in this document. The list would this hazardous activity will be performed? be around to clean up the mess caused by likely be longer if KIPT’s actual intent was • Oceanic circulation – causeway A Dredge Management Plan has been excluded from KIPT’s draft EIS. This is a the manifestation of risk and who will be known, and its draft EIS considered more construction will significantly major concern for Yumbah given KIPT’s held accountable. recent expansions of its plans for Smith impact sea currents and the deficient performance during what should Bay. accumulation of wrack To set and to comply with, and simply have been straightforward sediment aspiring to, best practice is no remedy. • Preferred location – a seaport at • Contamination – potential to likely investigations in 2017. Smith Bay presents social, Saying “sorry” for destruction of an existing contamination of the environment Yumbah has no confidence, nor does it economic and environmental risks successful, growing business through a from stored logs and woodchip believe should the South Australian and that may be catastrophic to human management oversight will be costly. piles Australian Governments, in the potential health and the environment performance of this proponent. The very high probability of catastrophic • Reliance on third parties – KIPT • Environment – as a Coastal consequence from a seaport at Smith Bay alleges it has secured supply chain Conservation Zone, the is the result of KIPT’s failure to prove that partnerships that effectively RISK OF PROJECT FAILURE the task of removing its trees from environment of Smith Bay is outsource many of the IN EITHER THE CONSTRUCTION Kangaroo Island cannot be achieved at populated with terrestrial and accountabilities that would be OR OPERATION PHASE assumed by a responsible entity. If the Seaport project fails financially in There is no accommodation of this either the construction or operation phase 68 https://www.theislanderonline.com.au/story/5659505/commercial-fishermen-voice-concerns-over-proposed-smith-bay- third-party dependence in the draft there is the real prospect of a dangerous seaport/ EIS, which seems more than an and unmaintained shipwreck wharf 69 EIS Main Report, Page 18 oversight given so much risk in structure posing a physical hazard to those 70 EIS Main Report, Page 32 71 EIS Main Report, Page 5. who work and recreate in Smith Bay. The Smith Bay Wharf Environmental Impact Statement Response 114 Smith Bay Wharf Environmental Impact Statement Response 115

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draft EIS is silent on reserving funding to A RE-ASSESSMENT IS REQUIRED GUIDELINE 15: guarantee the decommission of the wharf and the return of the coast and the seabed KIPT’s draft EIS emphasises tangible risks to its former condition. 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 QUESTIONABLE EXPERT OPINION uninformed. INFRASTRUCTURE A more detailed, accurate risk assessment Yumbah knows its highly specialised • Impermeable barrier will block, change of actual construction and operations must DESCRIPTION: business. Yumbah has grave concerns oceanic currents about KIPT’s knowledge of such a highly be demanded of KIPT with consideration of Yumbah KI’s review of the inadequate risk The construction and operation of a port specialised area, and the knowledge of its o Current directions periodically alternate advisors, including its employment of assessment in the draft EIS. and wharf, such as that proposed at Smith between the dominant directions of Professor Anthony Cheshire as the author Bay, will require specific infrastructure, easterly during flood tides and westerly The risk assessment and corresponding equipment and utility needs. These need of sections of the draft EIS. during ebb tides matrix in Appendix T are problematic. to be identified and consideration given to Draft EIS says currents will reduce by Professor Cheshire does not have Inclusion of rudimentary mitigation and how these requirements will be met, and o recognised expertise in contemporary management measures often result in how any increased demand will impact 30-40 per cent reductions to residual likelihood and onshore abalone farming which is clear upon existing users. o Changed ocean mixing and flushing from the numerous mistakes and flawed consequence. However, management increase water temperature assumptions contained in his report 72. His measures can only reduce residual role advising a collapsed offshore abalone likelihood, not residual consequence. As RESPONSE SUMMARY • Draft EIS proposes ineffective farm investment is well known. The such the residual risks are misleading and mitigation, says it’s “unnecessary” impacts of this venture are still being felt do not reflect the actual risk level. • Yumbah Aquaculture pre-existing Draft EIS indicates causeway gates or by investors, community and a jailed infrastructure o Several mitigation and management culverts will help water exchange former chief executive. measures have been specified that are Draft EIS fails to recognise highly- o o Proponent doesn’t provide detail In this draft EIS, his contribution should unlikely to be firm commitments of KIPT. specialised abalone farm infrastructure – but further indicates it doesn’t not be regarded as any better than In its current format, particularly the support this personal observation. outcomes based on the risk categorisation, • Causeway incompatible with Yumbah the draft EIS cannot be relied on to inform KI operation the project. 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

72 See AAGA document Smith Bay Wharf Environmental Impact Statement Response 116 Smith Bay Wharf Environmental Impact Statement Response 117

116 Smith Bay Wharf Environmental Impact Statement Yumbah Response

72 See AAGA document Smith Bay Wharf Environmental Impact Statement Response 116 Smith Bay Wharf Environmental Impact Statement Response 117

Smith Bay Wharf Environmental Impact Statement Yumbah Response 117

INFRASTRUCTURE YUMBAH’S INFRASTRUCTURE WILL STAY WHAT IS KIPT HIDING? KIPT has purchased an additional 173 hectares of land to the west that adjoins The DAC Guidelines require KIPT to KIPT claim to be a significant contributor to KIPT claims superiority for land use at the 12-hectare site purchased in 2014. present comprehensive information on the the economic viability of Kangaroo Island Smith Bay and assumes the activity of a What are the true intentions of KIPT? KIPT infrastructure proposed at the seaport. and have questioned the long-term seaport is a compatible land use in this continue to hide their true intentions for Information requested by DAC is quite viability of abalone farming in South Rural Living Zone and Coastal the seaport and surrounding lands. extensive and is requested to add value Australia. They have insolently raised Conservation Zone. KIPT has implied that and articulate the ‘nuts and bolts’ of the questions of Yumbah KI’s survival at Smith Yumbah KI and our established business An article in Business News states The design. Bay and impending closure due to and associated infrastructure is not additional land provides the company with futuristic climate change impacts. compatible by making the following greater flexibility in the layout and Unfortunately, information is lacking which statement in Section 6.3 Appendix N (pg capability of its onshore facilities and in is not surprising as this is the general Yumbah KI is a permanent fixture at Smith 21) “Land use at the Yumbah Aquaculture managing the actual and perceived theme of the draft EIS. Bay, now and for years to come. We have site is generally consistent with Primary impacts of its proposed development. It a long and prosperous future at the Production or Rural Industry. The land use also gives room for the facility to expand in Issues exist with the infrastructure existing site irrespective of the modelled is not consistent with the type of the future, should this be required. All proposed for the seaport. KIPT is not impacts of climate change, with exciting development envisaged in the Coastal these benefits are subject to government applying best practice principles to the plans for future expansion. design of the seaport. The infrastructure, Conservation Zone, or with typical consent73. activities associated with the Rural Living equipment and utilities proposed have Unfortunately, Yumbah has suspended The deceit displayed by KIPT to the land use category.” been based on KIPT’s own selfish agenda significant upgrades and growth of its KI community and misrepresentation of and have only focussed on their own farm due to the impending prospect of a The significant risks that KIPT present with information is endemic behaviour. KIPT corporate profitability of the project and seaport at Smith Bay. not only developing a timber export was described in the South Australian have ignored social and environment The seaport presents risks that are seaport but also further establishing a Parliament on 16 November 2016 as having elements. They have ignored those that multi-use port adjacent to the proposed “… fed out a fair degree of spin and intrinsically rely heavily on the values that potentially catastrophic to Yumbah KI’s infrastructure and business. timber export seaport cannot be ignored. rubbish….” in its overt promotion of this exist at Smith Bay. These values will be Lack of information relating to additional proposal. destroyed by the seaport. future uses further compounds the risks to KIPT has unknown, unreported long-term Yumbah and the community. Infrastructure concerns have been plans for future expansion of the seaport discussed in more detail throughout Section 7.3.1 of Stakeholder Consultation with the purchase of significantly large Yumbah’s submission, and these include: and Engagement (draft EIS Main Report) tracts of land to the west. states “KIPT acknowledges the importance • Causeway KIPT cannot and will not provide any of being an active member of Kangaroo details about other potential multi-users of • Wastewater retention and detention Island’s community and is committed to the seaport. The DAC EIS Guidelines developing a sustainable timber business basins states The construction and operation of a that considers and responds to community port and wharf, such as that proposed at • Lighting needs.” Why won’t KIPT disclose Smith Bay, will require specific intentions now as part of this EIS process? • Potable water infrastructure, equipment and utility needs. These need to be identified and • Firefighting and dust suppression consideration given to how these water requirements will be met, and how any increased demand will impact upon • Road networks and transit routes existing users.

73 https://finance.nine.com.au/business-news/kipt-buys-additional-land-at-smith-bay/e3b0f43a-f4f0-43b6-91b3- aeb927052ee2 Smith Bay Wharf Environmental Impact Statement Response 118 Smith Bay Wharf Environmental Impact Statement Response 119

118 Smith Bay Wharf Environmental Impact Statement Yumbah Response

Smith Bay Wharf Environmental Impact Statement Yumbah Response 119

The draft EIS does not include future Questions that need to be answered prospects for KIPT’s additional freehold include: land equating to 173ha west of the GUIDELINE 16: What is the long-term plan for the proposed seaport. The acquisition of this additional 173ha? What will the site look land is likely part of a long-term plan to expand the seaport and or establish like if it is developed? What infrastructure will be extending through the increasingly associated port related infrastructure on ABORIGINAL & OTHER HERITAGE the additional land to the west of the wider Coastal Conservation Zone that separates the freehold 173ha from the seaport. marine foreshore? What infrastructure will DESCRIPTION: • No record of communication, The proposed seaport extending offshore extend into the marine environment? How consultation, negotiation with infrastructure including the solid far will infrastructure extend into the sea? Aboriginal and other heritage can include causeway is solely for the timber export What are the baseline characteristics of the o Recognised Aboriginal Representative business of KIPT. The infrastructure seabed? What ecological values are matters such as archaeological sites and Body of Smith Bay not referenced Aboriginal remains, Aboriginal sites and proposed for the seaport will be exclusive present on land and in the marine Potential violation of South Australian objects of significance according to o for woodchip and timber log handling. The environment? What will be the impact to heritage law Aboriginal tradition, archaeology, infrastructure will not be functional for any the native flora and fauna? What depth will No contact with long-term adjacent anthropology or history, caves, mines, o other maritime use other than the timber be required for the approaching vessels? landholder, Yumbah, on its industry. This is of vital relevance and How many more hundreds of thousand volcanic features, geological sites, fossils, understanding of site cultural heritage raises concerns about the degree of cubic meters of dredging will be required? historical buildings and monuments, relics of agricultural and industrial heritage, disclosure or rather, significant lack of What are the characteristics of the • Known European heritage sites not shipwrecks, lighthouses, whaling stations, disclosure by KIPT on future plans for the sediment? Where will the sediment be valued wider environs of Smith Bay. dumped? The list goes on … wilderness and coastlines. Significant sites are known widely but The introductory page to section 20 There is confusion in Section 4.8 of the Coastal areas in particular are prone to o disregarded in draft EIS Economic Environment of the draft EIS Main Report regarding power sources at discovery of items of Aboriginal heritage and significance. Main Report states the seaport. A statement that the • Draft EIS considers a previous wharf electricity supply strategy for the “The potential for the facility to be a multi- All development should consider the proposal, not the current proposal development would consist of a impacts it may have upon Aboriginal and user facility is acknowledged and remains connection to the mains electricity system Underwater heritage study must be an integral feature of the proposed other heritage matters (land and marine). o for the delivery of grid-source electricity. resubmitted for KIPT’s revised, larger development. However, following Then the section follows by referring to a wharf discussions with DPTI, it has been agreed primary and backup generator for the RESPONSE SUMMARY the requirement to analyse the potential o Raises questions about veracity of materials handling infrastructure. Solar proposed Heritage Management Plan impacts of such other users and uses is panels will be fitted for staff amenities. • No credible site assessment not required.” It is unclear if grid sourced electricity will for draft EIS KIPT has not detailed in the draft EIS any be supplying the power for the site. ABORIGINAL AND OTHER HERITAGE No intrusive site assessment for site consultations with the community on future ERRORS AND OMISSIONS o identified by its own experts as worthy freight and cargo opportunities, and likely Yumbah Aquaculture recognises and infrastructure that may be required. This is of “high risk” status appreciates the history of Kangaroo Island Only this would determine Indigenous, and both the indigenous and European a significant issue and any potential The causeway crest would be wide o European and maritime archaeological archaeological significance that is expansion at Smith Bay has serious enough for one-way vehicular access, implications to the community, the significance prevalent across the whole island. with two passing areas along the environment and Yumbah. Dependence on desktop without site causeway length.1 o Information relating to heritage is included assessment a defining characteristic Prospective plans for multi-users need to in the draft EIS Main Report Chapter 24 of draft EIS be presented now. This information is Causeway road to be 5m wide, but it’s to and Appendix S. have two passing areas alongside it. The critical to determining the applicability of It is disappointing and somewhat two areas need to be 10m wide. This Smith Bay as the preferred location. perplexing why KIPT has not completed an cannot be seen on the current plans. Smith Bay Wharf Environmental Impact Statement Response 120 Smith Bay Wharf Environmental Impact Statement Response 121

120 Smith Bay Wharf Environmental Impact Statement Yumbah Response

121 Smith Bay Wharf Environmental Impact Statement Yumbah Response

intrusive site assessment to determine the the area should be treated as a 'high risk “To further manage heritage risk, KIPT / EP to trust KIPT in its protection of heritage extent of Indigenous, European and area' to manage heritage risk. may wish to engage with the relevant values on site. maritime archaeological significance that Aboriginal group(s) to monitor earthworks.” An intrusive site assessment should be may be present across the proposed conducted on this high-risk area to identify development site. As due respect, the report should at least UNDERWATER CULTURAL HERITAGE whether archaeological significance is have named who the relevant Aboriginal present in order to adequately manage group(s) are, and correctly referred to the Underwater cultural heritage is reported in INDIGENOUS HERITAGE any heritage risk. How can you manage a group as Recognised Aboriginal Appendix S3. The objective of the risk when you do not even know it is Representative Body(ies) in Appendix S1 reported desktop investigation is to assess To inform the draft EIS, a desktop present? and the Main Report. the potential for any impact on any actual indigenous heritage assessment has been or potential sites. The existence and completed and is presented as Appendix Archaeologists can monitor changes in soil location of underwater cultural heritage is profiles to assess the likelihood of works S1. This report is what can only be HISTORY OF EUROPEAN SETTLEMENT unknown prior to development works. described as significantly lacking, and encountering Aboriginal heritage sites. The report states: inadequate. This document presents little, How can an Archaeologist monitor minute The European history of Smith Bay is if any, valid information to delineate the changes in soil lithology and identity presented in Appendix S2. This document “This report has looked for the possibility likelihood of Aboriginal archaeological potential Indigenous heritage sites when outlines the history of Smith Bay, the of historic shipwrecks being within 500m sites across the site. bulk earthworks will be occurring with region and the site. This report does not of the development impact area. The outline the physical features that are 500m distance reflects the required Appendix S1 does not acknowledge the large front-end loads, excavators, bulldozers, trenchers (to name a few) will known to be present on site. A number of distance by the relevant Acts, which is Recognised Aboriginal Representative heritage values do exist on the site of the Body of Smith Bay, and whether there has be ripping up the site at an unprecedented sufficient to protect against indirect proposed seaport. These include the ruins been any communication, consultation, rate? impacts.” of the original house of Harry Smith and negotiation or agreement with the The following recommendations are one of the few historic European A flaw in this report is the design and recognised body. This appears to be a provided in Appendix S1 Heritage: residences at Kangaroo Island. A second footprint of the seaport, and its alignment violation of South Australian Aboriginal associated ruin is also present on the in Smith Bay is incorrect. It appears the “No Aboriginal heritage sites are Heritage Act 1988 and significant proposed development site, known as the footprint may be the previous seaport disrespect for the Traditional Owners of 'damaged, disturbed, or interfered' with as Jacka family home ruin. design. Hence the findings in this the land. part of the proposed works.” investigation that were to understand the The Main report (p522) states neither In its scant and lacking content, Appendix How can you know if you are damaging, possibility of wrecks do not correctly of these ruins will be affected by the S1 states: disturbing or interfering with an Indigenous capture 500 meters of the study area. proposal. heritage site when you do not even know it “Cultural Heritage sites are often found to “The outcome of this investigation will be is there? It is of high concern that these heritage be associated with very specific used to assess the Governmental heritage sites were reported anonymously to the environmental features.” “All workers should remain vigilant as any needs before consent is granted for work South Australian government in early July work into previously undisturbed soils has to be initiated.” 2017 sometime after KIPT had purchased The site is bounded to the north by an the potential to impact insitu cultural the development site. It begs the question As the investigation has been conducted extensive marine foreshore. Smith Creek heritage. A heritage induction may be what other heritage values exist on the site for a development footprint that does not runs through the site. These landforms are beneficial to ensure contractors are aware that have yet to be reported by KIPT. exist, this report cannot be relied on for the very specific environmental features and of what to look for in regards to heritage.” commonly sites of archaeological consent. A revised report is required The lack of site investigation creates significance. Why was an intrusive site Realistically, a driver or controller of bulk reflecting the actual seaport development significant doubt about the extent of assessment to survey the likely presence earthworks equipment will be concerned footprint and an investigation within the heritage that may remain unreported. of Indigenous significance not completed? with maximum productivity and health and actual 500 m development impact area. safety of themselves and colleagues. The history of KIPT and already proven The proposed project is located in an area “In terms of known cultural heritage, the Unfortunately, their last priority will be failings to conduct its operation both planning application may be made more with no recorded/registered Aboriginal keeping watch for minute changes and ethically and within the confines of law, robust with the provision of evidence sites. There is insufficient information on characteristics of soil lithology that could and the obvious propensity to present rather than assumptions.” the archaeology of Kangaroo Island to indicate presence of Indigenous cultural misleading and flawed technical clearly delineate areas of risk, and as such significance. information further compounds the ability Smith Bay Wharf Environmental Impact Statement Response 122 Smith Bay Wharf Environmental Impact Statement Response 123

122 Smith Bay Wharf Environmental Impact Statement Yumbah Response

Smith Bay Wharf Environmental Impact Statement Yumbah Response 123

This is the only sensical statement in all of “The shipwreck databases show four GUIDELINE 17: Appendix S. Yes, evidence is required to points indicating known wrecks from the be collected by completing intrusive field historic records in the vicinity of Smith work to substantiate the extent of all Bay.” potential heritage across the entire development footprint. However, none of the four sites have been GEOLOGY & SOILS marked as 'found'. “Below low water mark, Smith Bay is • considered to be within Commonwealth Figure 3 in Appendix S3 indicates the DESCRIPTION: Water contamination likely jurisdiction, indicating any historic shipwreck Chum is on land. o Further investigations of the potential shipwrecks and associated relics in the The development footprint is in The proposal will require the construction impacts to groundwater are required, bay are covered by the Commonwealth Investigator Strait. Appendix S3 (pg 15) of structures on and/or adjacent to coastal including likely groundwater contour Historic Shipwrecks Act 1976. geological formation, this may have recognises that from the middle of the 19th flows and connectivity to Smith Bay century Investigator Strait has played an impacts on those formations and their Section 13 of the Commonwealth Act The condition and quantity of important part in the trade and natural processes. o prohibits damage or destruction of historic groundwater resources seems unlikely communications network of South shipwrecks or relics. This also prohibits satisfy the high-intensity water demand Australia as a natural route for shipping. any interference, or removal or disposal RESPONSE SUMMARY necessary to achieve site construction of objects. A breach as such will incur As stated in Appendix S3 (page 2), and operational management and substantial fines.” characteristics of the environment, mitigation described in the draft EIS although not ideal for preservation, do not • Contradictions between KIPT’s claims The relevant Government authority and draft EIS “science” and local regarding underwater cultural heritage on exclude the chance for heritage materials • Causeway impact on having survived. The disturbance of knowledge raise questions about the or within the seabed of Smith Bay is coastal processes thoroughness of proponent’s Department of Environment and Energy. sediment using the cutter suction dredge The outcomes of the investigation in will likely remove any maritime cultural investigations The causeway will reduce ocean Appendix S3 have concluded that “in view heritage material before discovery. It is o Locals know that Smith Bay is shallow currents by an estimated 30-40 per of the nearby historic major sea lane in vital that the history of Smith Bay is better and the seabed is hard. cent, which, in turn, will bring elevated Investigator Strait, the high degree of local understood, and not merely by using reports that present reports with water temperatures, reduced mixing of shipping traffic historically and the current Continued misrepresentation of a flat invalidated and vague conclusions. o oceanic water, accumulation of drift lack of relevant heritage data about the coastline that continues into a shallow seaweed (wrack) and compromised development footprint and surroundings, ERRORS AND OMISSIONS bay as being deep oceanic conditions. the presence of such heritage materials Continued inaccurate reference to the • o cannot be ruled out completely.” A Heritage Management Plan would seabed being a “mixture of cobbles be developed and implemented during KIPT has no idea if historic shipwrecks or and sediment”75 construction (including dredging) to relics are present within the direct dredge o Claims that there is “no indication that area or the 500 m wider radius that may ensure that workers remained on the hard rock is present at depths that be influenced by indirect impacts. lookout for heritage items, particularly would cause concern in the area that during earthmoving and excavation will form the berth pocket” KIPT cannot irrevocably confirm that activities. The Plan would prescribe the contradicted by evidence of core damage, destruction, interference, procedures to be followed in the event refusal in the draft EIS76 removal, or disposal of objects of historic of potential heritage items being shipwrecks or relics will not occur as part discovered.74 – When it comes to the of the construction and operation of the area’s heritage, KPT is going to make seaport. plans up on the fly.

75 https://www.asx.com.au/asxpdf/20180221/pdf/43rrfmyt34xfc4.pdf 76 https://www.asx.com.au/asxpdf/20180221/pdf/43rrfmyt34xfc4.pdf 74 EIS Executive Summary p69 Smith Bay Wharf Environmental Impact Statement Response 124 Smith Bay Wharf Environmental Impact Statement Response 125

124 Smith Bay Wharf Environmental Impact Statement Yumbah Response

Smith Bay Wharf Environmental Impact Statement Yumbah Response 125

GROUNDWATER HIGHLY SALINE, The draft EIS is lacking in describing GEOTECHNICAL ANALYSIS FALLS SHORT ARE DREDGE VOLUMES ADEQUATE FOR LOW YIELD the groundwater flow contours and THE CAUSEWAY? connectivity of aquifers across the region. Sub-Appendix C1 (Geotechnical The draft EIS assessment notes a single The risk is contaminated stormwater and Investigation Report) provides no Estimated dredge volumes are from 100 3 3 grab sample towards the northern leachate leaking from proposed storage interpretation of the geotechnical cores 000m to 200 000m , but the actual boundary of the site identified depth to ponds, dredge spoil dewatering ponds, and the geotechnical integrity. It presents minimum volume of spoil required to groundwater at 1.65 metres below ground and settlement ponds into groundwater. only the core logs. construct a causeway 250m long and five level (BGL) (Appendix L, Section 4.3). metres high is not quantified. This would likely create additional The proposed material to be dredged has Total dissolved solid (TDS) concentration contamination of the nearshore not been aptly characterised due to core There is risk that volumes of dredged spoil was 18 000mg/L, indicative of saline environment as groundwater flows are refusal above design dredge depths and may not be enough to construct the conditions, inferring that groundwater is inferred towards Smith Bay. the anecdotal information that hard rock causeway. Alternatively, surplus spoil may potentially connected to the marine obstructed drilling. be dredged in excess of causeway environment. Contaminants including iron, Further investigations of the potential construction requirements. The draft EIS Main Report (page 367) refers lead, cobalt, copper, sulphate and nitrite impacts to groundwater are required, to sediment depth overlaying the hard sea were measured in sampled groundwater. including likely groundwater contour What is the intention if either of these flows and connectivity to Smith Bay. floor ranging from zero to 140 centimetres. scenarios is encountered? It must be stressed that: Conclusions about the geotechnical This weakness in the draft EIS demands “The results did not suggest that previous properties of the sediment that was further exploration and requires an CAUSEWAY CAUSES MANY PROBLEMS site activities had caused groundwater sampled, the potential nature of the hard adequate understanding of the sediment contamination and detected Yumbah has many concerns – expressed substrate below the unconsolidated upper characteristics, which is yet to be achieved. concentrations were considered to be throughout this document - and the layers of sediment, and its ultimate background levels for saline water.” negative impacts of the proposed applicability for construction of the 250 metre causeway: its construction, proposed causeway, has been based on PAST PERFORMANCE AN INDICATOR The results from groundwater assessment its integrity and its impact on coastal just 13 core samples extracted for OF FUTURE PERFORMANCE? suggest the shallow aquifer has little processes. geotechnical analysis, of which only five beneficial use due to high salinity and are in the actual dredge pocket. Yumbah is intimately aware of previous low yield. The draft EIS proposes that dredge spoil geotechnical investigations in Smith Bay. will be stockpiled on land, dewatered and During October 2017 KIPT commissioned a used to construct the 250-metre WHAT IF THE SEAFLOOR IS HARD? drill barge to conduct seabed sampling to DEPTH TO GROUNDWATER causeway. But there are gaps in the inform the draft EIS. Yumbah closely information KIPT relies upon in its The draft EIS has not addressed the Depth to groundwater is also of concern, observed these activities and remained on geotechnical assessment of the likelihood or consequences of as KIPT’s site footprint involves encountering the hard sea floor, otherwise high alert to what was considered an considerable bulk earthworks to create dredge material. referred to as Class 3 unconsolidated extreme risk to business continuity. benches across the site, form storage These gaps preclude an adequate sediment elsewhere in this document. During this time, it was obvious the vessel areas, build stormwater management understanding of the geotechnical It does not account for the risk of not and drill rig were experiencing problems. infrastructure (settlement ponds), dredge properties of the dredge spoil and achieving the desired dredge depth of spoil dewatering ponds and cut access confirmation of whether the material will Following extended periods of heavy three metres. roads. even support the causeway, the proposed grinding, a loud bang was often heard, The interception of the shallow rock armouring and be able to withstand followed by the extraction of the drilling groundwater table presents risks to constant oceanic impacts the causeway equipment and a lengthy delay prior to the Yumbah KI and the adjacent marine will be exposed to. activity re commencing. environment. 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.

Smith Bay Wharf Environmental Impact Statement Response 126 Smith Bay Wharf Environmental Impact Statement Response 127

126 Smith Bay Wharf Environmental Impact Statement Yumbah Response

Smith Bay Wharf Environmental Impact Statement Response 126 Smith Bay Wharf Environmental Impact Statement Response 127

Smith Bay Wharf Environmental Impact Statement Yumbah Response 127

In a conversation between Yumbah senior KIPT has not presented plans to dredge to ERRORS AND OMISSIONS site management and the drill operator the required three metres with the following a day’s drilling, the operator assumed presence of 1.6 m of the seabed • The sediment load in the dewatering shared the problem: being hard sea floor. discharge from the dredge slurry potentially could be high if not “It’s just straight stone, so hard Its 2017 drilling rig sediment sampling managed effectively.77 the drill heads were getting stuck survey conducted for core acquisition via and snapping off.” 10 tonnes of drilling hydraulic pressure “If not managed effectively”. It’s a yielded low penetrations prior to core phrase repeated through the draft EIS, The drill operator said drilling would be refusal consistently below one metre for all relied upon by an accident-prone delayed while they sourced a different samples except for site SB7.2 (Appendix F) drill head. He expressed frustration and proponent to support its case for an which was sampled to 1.4 metres below ill-founded, poorly-planned investment commented that usually when solid rock is the seabed. hit the location is changed, but his in the wrong place. instructions were to persist regardless of The interpretation of the The question for the proponent is: any difficulties. geotechnical/borehole data cannot be confirmed for >1-3 metres of marine “Who ensures effective management?” Irrespective of these significant limitations sediments due to core refusal by the hard to sampling and analysis in this draft EIS sea floor. KIPT is attempting to build an argument on inaccurate, flawed data. The presence of a very hard substrate (possibly consolidated material) underlying For Yumbah – and, we expect, for a veneer of unconsolidated sediments that regulators and the science they should be may require Cutter Suction Dredge (CSD) able to rely on - this is a serious breach of grinding, and subsequently a better corporate and ethical responsibility. understanding of this third class (Class 3) of dredge material. DREDGING PILES UNKNOWNS ON The CSD has the potential to generate UNKNOWNS very fine particles from the dredge-header grinding the hard substrate into material The proponent has a patchy record on and small particle diameters. This will lead dredge sampling that only raises doubt to a greater dispersion of fine sediment about its information and its claimed beyond the current Impact Zones reported capabilities. throughout the draft EIS. 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.

77 EIS Executive Summary p37 Smith Bay Wharf Environmental Impact Statement Response 128 Smith Bay Wharf Environmental Impact Statement Response 129

128 Smith Bay Wharf Environmental Impact Statement Yumbah Response

77 EIS Executive Summary p37 Smith Bay Wharf Environmental Impact Statement Response 128 Smith Bay Wharf Environmental Impact Statement Response 129

Smith Bay Wharf Environmental Impact Statement Yumbah Response 129

GUIDELINE 18:

BUILT FORM & DESIGN

DESCRIPTION: RESPONSE SUMMARY Kangaroo Island is one of Australia’s The development is proposed in an area largest off-shore islands. Due to its relative that is a relatively remote coastal isolation from the rest of the State it faces landscape that is natural in appearance. unique economic, environmental and There are no other developments of this social circumstances, challenges and scale or type situated along this portion of opportunities. In a strategic plan created coastline. The proposed development will for Kangaroo Island, development Figure 13 - Actual Pontoon to be used for the Seaport establish a prominent visual feature along proposals are required to reflect the the coastline. Kangaroo Island is importance of retaining economic benefits internationally known for its natural beauty on the island, balanced with the protection BUILT FORM Kangaroo Island is one of Australia’s and this must be considered in the built of the island’s natural resources. largest off-shore islands. Due to its relative form and design of the proposed The DPTI EIS Guidelines acknowledge that isolation from the rest of the State it faces development. • The built form and design proposed is the seaport is proposed in a relatively remote unique economic, environmental and in direct contrast to the natural coastal landscape that is natural in social circumstances, challenges and landscape of Smith Bay, and will appearance. The KIPT EPBC referral of opportunities78. In 2011, the Kangaroo negatively affect the widely-distributed proposed action from July 2016 states: Island Plan1 was created as a statutory economic benefits of Yumbah policy document to guide the type of Aquaculture “The Smith Bay site is within the Coastal development in the Kangaroo Island Conservation Zone of the KIDP (Kangaroo Council Area. • Suitable port and marina infrastructure Island Development Plan), which means and port opportunities already exist on that the proposed development is non- The Plan outlines strategic land use directions to better align with priorities of Kangaroo Island that would provide complying. Under this plan, non-complying the Kangaroo Island Futures Authority greater benefit when establishing a developments are not prohibited per se, but must be considered on their merits.” (KIFA) to provide an overarching seaport for KIPT to export trees framework for sustainability. The Plan is The built form and design proposed is in supported by a number of other jarring contrast to the natural landscape documents developed to inform future of the Coastal Conservation Zone of development opportunities on the Island. Smith Bay.

78https://www.dpti.sa.gov.au/__data/assets/pdf_file/0009/249975/Kangaroo_Island_Council_Development_Plan.pdf Smith Bay Wharf Environmental Impact Statement Response 130 Smith Bay Wharf Environmental Impact Statement Response 131

130 Smith Bay Wharf Environmental Impact Statement Yumbah Response

GUIDELINE 18:

BUILT FORM & DESIGN

Smith Bay Wharf Environmental Impact Statement Yumbah Response 131

A major thread in these strategic plans for On land the Yumbah KI abalone farm has control potential conflicts of use and/or the Coastal Conservation Zone, or with typical Kangaroo Island is the importance of been at Smith Bay since 1995 and with its environmental impacts that can arise from activities associated with the Rural Living retaining economic benefits on the island, low profile, quiet operations and barely use and development in marine and land use category. balanced with the protection of the island’s registered presence at night, it blends well coastal areas82. natural resources. Diversification and with topography and natural land, and This is again purely remiss of KIPT and value-adding is required across the Island marine assets. Planning for Kangaroo Island has ignores that the aquaculture farm has been in relation to tourism and agriculture that a focus to: established within the planning framework ensure sustainable coastal development The Kangaroo Island Plan Addendum and is an activity consistent with Rural 81 • encourage sustainable growth and protect natural and industry assets. (January 2014) notes that the ability for Living and the Coastal Conservation Zone. commercial forestry to contribute to the particularly in Kingscote, Penneshaw, The Island’s economic base continues Island’s international reputation by Parndana and American River and The seaport is clearly at odds with this to expand and is targeting increased providing value-added opportunities, farm- make the best use of their existing and zoning. tourism and new industries in the areas gate experiences and local employment is expanded infrastructure Ports are widely recognised as an of horticulture, aquaculture and low in comparison with other agricultural industrial activity and ‘high risk’ for • reinforce the expanded role of renewable energy. uses, thus providing lower social and aquaculture, especially when planned to economic benefits to the Island. Kingscote and Penneshaw as the main be built less than a few hundred metres The island’s clean, green reputation passenger and freight gateways to the 79 from a long-standing, successful underpins these industries. The Plan confirms that further expansion of Island forestry on the Island should be restricted aquaculture business. and replacement of forestry with other • incorporate high-quality design to The National Biosecurity Plan Guidelines DESIGN farming and horticultural land uses should protect coastal landscapes for the Australian land-based abalone be encouraged, especially where located 83 The many strategic plans for Kangaroo industry explicitly refers to ‘ports’ as high on land with high capability to support The Kangaroo Island Council Development Island observe that developments should risk in relation to farm locality and features. such uses. Plan (September 2015) states an objective be appropriately located, sited and for Aquaculture Development as Marine The Kangaroo Island Council at its meeting designed to fit in with and be subservient It also notes that a clear hierarchy of aquaculture development in marine waters on May 15, 2019 strongly opposed Smith to the environment and not to compromise environmental areas to be protected from that ensures fair and equitable sharing of Bay as the location for KI Plantation the scenic and landscape experience or or used for development should be marine and coastal resources and Timbers' proposed timber exporting the Island’s natural assets. developed and existing infrastructure minimises conflict with water-based and port8485. At that meeting, Councillors – as assets should be utilised instead of Smith Bay is one such location on land-based uses. elected representatives of their community expanding areas used for forestry. Kangaroo Island that should be afforded – made their position very clear. Yumbah Aquaculture in South Australia is afforded Aquaculture is an industry that fits well with better protection. This must be considered for the proposed protection from conflicting and seaport at Smith Bay, since port and the image of Kangaroo Island, supporting From the sea Smith Bay is the coda to the incompatible land use activities. The marina infrastructure and port the seafood, primary production and food environmental ballet danced along the activities of ports are widely recognised as opportunities already exist across the industry sectors of the island. North Coast which attracts tourists who, on a conflicting land use with aquaculture. Island that would provide a greater benefit a three-hour journey ending in Smith Bay80, when establishing a wharf from which KIPT Section 6.3 Appendix N (pg 21) of the draft see seals, dolphins, sea eagles and can export logs and potentially woodchips. EIS states Land use at the Yumbah possibly whales. That ending will be Aquaculture site is generally consistent forever destroyed by the surprise of a Governments have an important role in with Primary Production or Rural Industry. wharf reaching out hundreds of metres into resource planning for marine and coastal The land use is not consistent with the Smith Bay overshadowed by a woodchip areas. The rationale for Government type of development envisaged in the mountain as you enter the Bay. intervention stems from the need to

82 https://www.pc.gov.au/research/completed/aquaculture/aquaculture.pdf 79 https://www.sa.gov.au/__data/assets/pdf_file/0019/72802/DOCS_AND_FILES-8251751-v5- 83Spark, E., Roberts, S., Deveney, M., Bradley, T., Dang, C., Wronski, E., Walker, M., and Savva, N., PIRSA Fisheries and Formatted_Kangaroo_Island_Plan_Addendum_January_2014_low_res.PDF Aquaculture, 2018. National Biosecurity Plan Guidelines for the Land Based Abalone Industry. Department of Agriculture and 80 https://kimarineadventures.com.au/ Water Resources, Canberra August 2018. CC BY 3.0 81 https://www.sa.gov.au/__data/assets/pdf_file/0019/72802/DOCS_AND_FILES-8251751-v5- 84https://www.theislanderonline.com.au/story/6126068/ki-council-rejects-smith-bay-as-location-for-kipt-port/ Formatted_Kangaroo_Island_Plan_Addendum_January_2014_low_res.PDF 85https://www.kangarooisland.sa.gov.au/webdata/resources/minutesAgendas/20190515%20Council%20Minutes.pdf Smith Bay Wharf Environmental Impact Statement Response 132 Smith Bay Wharf Environmental Impact Statement Response 133

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Council also confirmed its view that it was GUIDELINE 19: 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 CONSTRUCTION & OPERATION port was not hidden and its location on North Coast Road would impact on tourism DESCRIPTION: and locals in that region of the Island. o Unacceptable hazards and risks

It should therefore, according to Council During the construction and operation

representatives, not proceed at Smith Bay. of a large infrastructure project, such as o Smith Bay is an inappropriate location what is proposed at Smith Bay, there will for the KIPT’s proposed seaport be a range of standard impacts that can occur. Many of these can be adequately o Poor quality of draft EIS gives no managed through construction and confidence Construction and operational environmental management Operation impacts are considered plans. As the wharf is proposed to be adequately multi-user, information is needed on who the other potential users may be and how o Track record of proponent a primary often it is anticipated to be used for consideration other purposes. o Unlicensed test drilling in Smith Bay RESPONSE SUMMARY sets a precedent

The draft EIS does not profile the potential o Destruction of seagrass raises flag on users of the wharf. In fact, it simply proponent’s ability and appetite to describes a major customer often build or operate complex infrastructure promoted in earlier misleading press in a sensitive environment 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 Smith Bay Wharf Environmental Impact Statement Response 134 Smith Bay Wharf Environmental Impact Statement Response 135

134 Smith Bay Wharf Environmental Impact Statement Yumbah Response

It should therefore, according to Council During the construction and operation representatives, not proceed at Smith Bay. of a large infrastructure project, such as o Smith Bay is an inappropriate location what is proposed at Smith Bay, there will for the KIPT’s proposed seaport be a range of standard impacts that can occur. Many of these can be adequately o Poor quality of draft EIS gives no managed through construction and confidence Construction and operational environmental management Operation impacts are considered plans. As the wharf is proposed to be adequately multi-user, information is needed on who the other potential users may be and how o Track record of proponent a primary often it is anticipated to be used for consideration other purposes. o Unlicensed test drilling in Smith Bay RESPONSE SUMMARY sets a precedent

"Trust us" does not cut it

Further discrepancies between draft EIS Main report and Appendices (see below)

Smith Bay Wharf Environmental Impact Statement Yumbah Response 135

TRACK RECORD LEAVES PROPONENT’S PROPONENT FAILS TO COMPLY WITH Similarly, a Traffic Management Plan will be of the site for archaeological CAPABILITY EXPOSED DAC REQUIREMENTS required as a condition of any approvals significance? document. In considering Appendix U - Environmental The draft EIS attempts to present o Where in the EIS is proper regard for Management of the draft EIS, it’s information that corresponds with what’s The Site Control Plan is not yet completed, the original dwelling of Harry Smith the impossible to ignore the previous actions required of the EIS guidelines, but fails to and so strategies to apply across the entire resident for which Smith Bay was of the proponent: meet this challenge. Smith Bay project footprint have not been named. The ruins of his house, one of developed. Supporting appendices for the first dwellings on Kangaroo Island, • disregarding licence conditions, The information requested must be re- quality control, reporting and continuous are remnant on the site proposed for undertaking illegal drilling in Smith Bay assessed and compiled correctly as a set improvement procedures don’t exist. of comprehensive and all-encompassing the wharf development. KIPT’s • demonstrable miscommunication management plans to be rigorously These missing links limit the capacity to website records their intention to between field operators and reviewed prior to any project approvals. properly review and comment on this EIS; respect this site: management leading to mass their absence should also preclude the The DAC EIS guidelines require ““The ruins of Harry Smith’s cottage destruction of seagrass in Smith Bay South Australian Government accepting Construction (CEMP) and Operational this is a valid document on which to base were nominated as a heritage place. • incomplete dredging analysis Environmental Management Plans (OEMP) such a significant decision. The Heritage Council of SA decided at for all components of the proposed its July meeting not to list the ruins as a • development. incomplete information about dredge heritage place after an investigation spoil utilisation INCONSISTENCY BETWEEN DRAFT The draft EIS includes a draft CEMP and and site visit by its officers. Kangaroo EIS DOCUMENTS • over-stated beneficial claims regarding OEMP but these are inadequate Island Plantation Timbers will consider Smith Creek considering the Risk Assessment does not Concerns have been identified in the its site plans to assess whether the sufficiently reflect the full extent of the CEMP that are inconsistent with the ruins can be preserved.”86 • demonstrable ignorance about the hazards associated with the construction content of the draft EIS and its supporting operations of a successful onshore and operation of the seaport. technical assessment. These include: o Sadly, that respect has not extended to abalone farm even the smallest reference in the draft The potential for interaction with Smith • An objective of Land Disturbance on EIS which bulldozers this heritage relic. Bay’s shallow groundwater table during • failure to professionally consider page 5 of the draft CEMP bulk earthworks is not considered alternative sites that meet the purpose • Potential impacts of marine adequately in either EMP. The CEMP No introduction of new weeds or pests, of this infrastructure o disturbance includes groundwater and surface water nor material increase in the The list is longer than the points above, subheadings as Management Measures abundance or area of existing weed o Loss of small area of pipefish habitat but these accumulate to the point of no tables, but the corresponding measures or pest species. No loss of abundance and some individuals of ring-backed confidence that the proponent could are not relevant to groundwater protection. or diversity of native vegetation. pipefish capably manage the detailed processes The EMP shows impact to Yumbah KI This objective should be applied for o This reference to some equates to >10 listed in the Appendix, when it cannot during both construction and operation, biosecurity and marine disturbance competently manage the demands of hectares, plus a 500m radius of the but the extent and duration of impact dredging site. This is estimated to an EIS process. No disturbance to Aboriginal or cannot be adequately quantified. Hence, o destroy the habitat of 5000 pipefish any potential impact is completely European heritage items (unless prior (Appendix 9). unacceptable to Yumbah KI. approval obtained from relevant legislation). A Dredge Management Plan (DMP) is referenced throughout the draft EIS with some supporting technical documents, but o How can this disturbance be avoided this critical plan is not provided to show without a comprehensive assessment activity and associated management considerations Yumbah must confront.

86 https://kipt.com.au/2017/07/05/harry-smiths-ruins-not-listed-heritage-site/

Smith Bay Wharf Environmental Impact Statement Response 136 Smith Bay Wharf Environmental Impact Statement Response 137

136 Smith Bay Wharf Environmental Impact Statement Yumbah Response

86 https://kipt.com.au/2017/07/05/harry-smiths-ruins-not-listed-heritage-site/

Smith Bay Wharf Environmental Impact Statement Response 136 Smith Bay Wharf Environmental Impact Statement Response 137

Smith Bay Wharf Environmental Impact Statement Yumbah Response 137

• Interactions with terrestrial fauna Australian shoreline) before entering a contaminating activity into a Coastal recognise there will be impact on the Australian EEZ, in conformance Conservation Zone? echidnas that occasionally forage with the Biosecurity Act 2015. • Drivers would be encouraged to report on site. native fauna vehicle strikes during What are the exceptional o timber haulage. circumstances? Who will control these? Who is responsible for any DRAFT OEMP DOES NOT PROTECT o Encouraged? YUMBAH damage caused by the “exceptional circumstance”? Where in the EIS is an • If a hooded plover nest was discovered KIPT’s draft OEMP cannot protect Yumbah estimation of frequency for such in Smith Bay during operations, a KI from the risks of this seaport in Smith exceptional circumstance? protection zone (determined in Bay. The raft of management and consultation with DEW) would be mitigation measures suggested in the plan imposed around the location for the • All vessels using the KI Seaport would cannot guarantee risks will be prevented, entire breeding season. and so Yumbah cannot have confidence in be required to comply with state policies relevant to the management of the security of its Smith Bay business. o Is this irrespective of location biofouling and pollution prevention and impact to the productivity The draft OEMP includes details of ((SA EPA Code of Practice for vessel of the seaport? possible alterations to the causeway, and facility maintenance (marine and reluctantly if necessary to minimise the inland waters) 2017)). interruption of tidal currents (Draft OEMP, o Nowhere in the EIS is any page 23). Are these measures proposed as consideration given to the nesting o Who will mandate these? a reactive measure once the causeway is endangered white bellied sea eagles, constructed? What will be the trigger for which fly over the wharf site each day. • If a new (including suspected) exotic redesigning a causeway once it is deemed organism was identified during this 250-metre tidal barrier does indeed operation, the marine biosecurity create a critical issue for Yumbah? How much stock must Yumbah lose to trigger response procedure would be remedial action by KIPT? Who will direct implemented (see Appendix S2 – KIPT to re-engineer and reconfigure the OEMP for further detail). The organism causeway? What legal protection will would be reported to the relevant Yumbah have, to ensure that action is authorities via the Fishwatch 24-hour taken and future threat is removed? What hotline and all directions issued by reassurance does Yumbah have that the PIRSA would be followed. If there was KIPT will have the financial resources to a biosecurity incident, PIRSA would remedy any damage caused by the take over the on-ground management manifestation of the many risks posed by of the incident, including any the wharf development and operation? information that would be provided Inclusions in the draft OEMP cannot be to the media. enforced and reduce the responsibility Too little too late. Given the fuzzy chain KIPT bears to manage the multiple impacts o of its operation: of responsibility evidenced by KIPT outsourcing and looking to sell off • Other than in exceptional operational aspects of their project circumstances, vessels would where exactly “does the buck stop?”. discharge foreign-sourced ballast water on the high seas (that is, further o Where is the legal liability of KIPT and than 200 nautical miles from the corporate responsibility of introducing

Smith Bay Wharf Environmental Impact Statement Response 138 Smith Bay Wharf Environmental Impact Statement Response 139

138 Smith Bay Wharf Environmental Impact Statement Yumbah Response

Smith Bay Wharf Environmental Impact Statement Response 138 Smith Bay Wharf Environmental Impact Statement Response 139

Smith Bay Wharf Environmental Impact Statement Yumbah Response 139

APPENDICES

APPENDIX 1 Review of Predicted Water Quality Impacts APPENDICES APPENDIX 2 Global Marine Resource Management Response to EIS APPENDIX 3 Australian Abalone Growers Association (AAGA) Submission APPENDIX 4 Marine Biosecurity Review APPENDIX 5 Economic Impact Statement APPENDIX 6 Review of Air Quality Impacts APPENDIX 7 Easements - Certificates of Title APPENDIX 8 Review of Noise and Vibration APPENDIX 9 AusOcean Marine Ecology Report

140 Smith Bay Wharf Environmental Impact Statement Yumbah Response

APPENDICES

APPENDIX 1 Review of Predicted Water Quality Impacts APPENDIX 2 Global Marine Resource Management Response to EIS APPENDIX 3 Australian Abalone Growers Association (AAGA) Submission APPENDIX 4 Marine Biosecurity Review APPENDIX 5 Economic Impact Statement APPENDIX 6 Review of Air Quality Impacts APPENDIX 7 Easements - Certificates of Title APPENDIX 8 Review of Noise and Vibration APPENDIX 9 AusOcean Marine Ecology Report

Smith Bay Wharf Environmental Impact Statement Yumbah Response 141 22 May 2019

David Connell Our ref: 6137616-98313 Your ref: General Manager Yumbah Kangaroo Island

APPENDIX 1 – Dear David

KIPT Smith Bay Wharf Draft EIS REVIEW OF PREDICTED Review of Predicted Water Quality Impacts

WATER QUALITY IMPACTS 1 Introduction Romero 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 2019 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:

142 Smith Bay Wharf Environmental Impact Statement Yumbah Response 22 May 2019

David Connell Our ref: 6137616-98313 Your ref: General Manager Yumbah Kangaroo Island

Dear David

KIPT Smith Bay Wharf Draft EIS Review of Predicted Water Quality Impacts

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.

2 Sub-Appendix F1 – Assessment of Marine Sediments

 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.  Target core / sediment acquisition depths required to describe the sediment quality and PSD of the material. This has implications for the construction modelling inputs and also determination of the proposed material to be dredged. As per NAGD, the full depth of dredging needs to be characterised suitability of dredge spoil as onshore fill and the causeway’s core material.

 Details/justification of change in the sediment sampling acquisition methodology from drilling (original dredge footprint) to SCUBA (revised dredged footprint), 2.3 Core SB.7 and Setteability Measurements (Section 3.2) The following is also of concern in Appendix F1: 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  Split sediment samples for the first drill-core acquisition event were done for QA/QC to test within much smaller characteristic particle diameters than any of the other samples. Presumably this is a sample variability, but not for the second SCUBA-core acquisition event. However, no replicate sample from the deeper portion of the SB7.2 core. Sample SB7.2 is potentially the only sample to samples were collected to evaluate within site variability. Justification for the reliability of the SCUBA- characterise pockets of unconsolidated sediment that extend to similar depths. Site SB7 is outside of the core acquisition samples is purely based on a comparison with the previous sampling event. revised dredge area (see Section 8.1) and it may not be indicative of the deeper sediment in the actual  It is unknown if the sampling was also meant to ascertain the suitability of the sediments for use as dredge footprint. onshore fill and/or material for the causeway’s core. Sub-Appendix C1 (Geotechnical Investigation Setteability reported in Table 2 is on the basis of four shallow sediment samples with penetration depths Report) does not provide any interpretation of the geotechnical cores and thereby their geotechnical of 20-25 cm (SB3 and SB11) (via the drill rig) to ~60 cm (ZZ4 and ZZ9) (via SCUBA). The settleability of integrity, and only presents the core logs. There is no information that reports if the dredged material the sediment cannot be confirmed based on limited shallow samples collected from both within and is suitable for onshore infill and/or the causeway’s core material. The proposed material to be outside of the dredge footprint. Settleability needs to consider the deeper unconsolidated and dredged has not been aptly characterised due to core refusal above design dredge depths. 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 2.2 Core Penetration Depths and Worst Case Uncertainty Implications (Section 3.1, Table 1) ascertain the lower bound of measurements for the deeper unconsolidated sediments. Further, The proposed maximum dredge depth is approximately 3m. Sediment was only sampled to a maximum setteability of deeper consolidated sediments are not characterised due to no acquisition of samples depth of 80 cm, with one sample extracted from 140 cm. Core penetration depths ranged from: (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  ~60 cm at sites ZZ3-ZZ8 (presumably via diver during second survey). maximum dredge depth.  8 of 12 sites during the first survey were ≤25 cm.

 3 of 12 sites during the first survey 50-80 cm 3 Sub-Appendix F2 – Hydrodynamic Modelling

 1 of 12 sites (site SB7) during the first survey had a penetration depth >1 m (140 cm). 3.1 Catchment Modelling and Smith Creek Flow Scenario (Sections 2.7 and 6.5) 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 Catchment modelling of a 1:10 AEP storm event is described in Section 2.7 of Sub-Appendix F1. The unconsolidated sediments that may require Cutter Suction Dredge (CSD) grinding. The CSD has the objective of the catchment modelling in the context of the EIS is for impact prediction of flood plumes potential to generate very fine particles from the dredge header grinding the hard substrate into material from Smith Creek into the proximal marine waters with an emphasis on the effect to the Yumbah KI with small particle diameters and thereby a propensity to remain suspended in the water column for a seawater intakes. longer duration than the settling velocities measured for the overlying veneer of unconsolidated Yumbah has been operating successfully with minimal impact to operation with the exception of a limited sediment. number of storm events in 2016. The following issues are identified with the catchment model:

Sediment has not been characterised to the extent of dredging depth estimated at 3 m. There is also  The use of a 1:10 AEP storm event does not provide a realistic representation of the impact of Smith considerable uncertainty in regards to the Particle Size Distribution (PSD) (and settling velocities) of the Creek to Yumbah KI. A smaller design event on a more frequent basis is considered more material that would be generated by the CSD. The PSD of the sediments released into the marine representative if benefits are being claimed for Yumbah KI intake water. 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  The even split between clay and silt for such a large event and the exclusion of coarser size to greater dredging related turbidity than predicted in the EIS, and will potentially have greater impacts on fractions to comprise the TSS model input concentration of 140 mg/L is not justified. primary producer benthic habitat (e.g. light reduction to proximal seagrass) and Yumbah KI’s inlet water.  The sizeable peak flow rates (30-55 m3/s) of the 1:10 AEP storm event are unverifiable. The sediment has been poorly characterised, particularly the hard substrate (consolidated) strata Appendix B of the Draft EIS Sub-Appendix F2 provides the nearbed TSS time series for the 1:10 AEP beneath the well characterised veneer of unconsolidated-weakly consolidated sediments. Due to the storm event during summer and winter conditions, which predict with the modelling input uncertainty poor characterisation of the extent of sediment to be dredged, the worst case for PSD and settling highlighted above that: velocity estimates should be further explored with additional sediment sampling and modelling.  For the winter simulation peak TSS at the western and middle intakes is substantially greater, but of In summary, the low core penetration depths of the sediment and the lack of adequate characterisation shorter duration, for the existing case (30-45 mg/L, 12 hours) than the proposed causeway of the full dredge depth, introduce uncertainty in the characterisation of PSD of the proposed dredge

6137616/6137616-LET-0_Review of KIPT EIS Water Quality 2 6137616/6137616-LET-0_Review of KIPT EIS Water Quality 3 Predictions_JRR Final (22-May-2019) Predictions_JRR Final (22-May-2019)  Target core / sediment acquisition depths required to describe the sediment quality and PSD of the material. This has implications for the construction modelling inputs and also determination of the proposed material to be dredged. As per NAGD, the full depth of dredging needs to be characterised suitability of dredge spoil as onshore fill and the causeway’s core material.

 3 of 12 sites during the first survey 50-80 cm 3 Sub-Appendix F2 – Hydrodynamic Modelling

 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

6137616/6137616-LET-0_Review of KIPT EIS Water Quality 4 Predictions_JRR Final (22-May-2019) development (5-15 mg/L, 24 hours). Hence, there is a trade-off between intensity of impact and because the core refusal depths were well less than 1 m (except for SB7.2 outside of the dredge duration. pocket) during the drilling rig sediment sampling survey.

 There is a clearer benefit during the summer case, generally with higher TSS levels and longer  An alternative interpretation on the basis of the core refusal depth evidence is that a relatively thin duration for the existing versus proposed development cases, although the intensity of impact as veneer of marine sediments (primarily sand) with perhaps some scattered relatively deeper pockets indexed by peak TSS levels (7-9 mg/L for existing case and 4-7 mg/L for proposed causeway) is of finer material (e.g. site SB7.2) occurs, and the underlying sediments are comprised of a harder substantially less than for the winter case. substrate (consolidated material?). If so, then this would support a third class (class 3) of dredge material. 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  If the alternative interpretation is plausible, a worst case third class of dredge material for a catchment modelling is seemingly to demonstrate the reduction in Smith Creek flood-derived suspended reasonable worst case estimate is valid given the information available and potential interactions sediments into Yumbah KI’s intakes from the proposed causeway. The simulated large discharge and between the CSD and the harder (consolidated) sediments of the deeper strata of the dredge area. sediment loads are not verifiable. The modelling of smaller storm events is required to demonstrate the This requires additional modelling for a worst case dredge material characterisation that includes frequency, magnitude and duration of any suggested benefit. worst case estimates from dredging of the third class and worst case dredge volume allocations to the three classes. 3.2 Model Validation of Temperature and PAR (Sections 4.3.3. and 4.4) In summary, the characterisation of the sediments to be dredged has considerable uncertainty in terms Statistics (as with Figures 4-1 to 4-3, 4-5) and/or scatter plots (Figure 4-4) of simulated versus measured of the potential PSD composition of the deeper sediments, which ought to be a third class of sediments values are lacking for temperature (Figure 4-6) and PAR (Figure 4-7). These statistics and plots that has not been modelled. The evidence indicates this a strongly consolidated deeper layer supported characterise the model’s skill in predicting these key marine impact parameters. 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 3.3 Dredge Material Specifications for Modelling (Section 5.2.1) 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 The dredge material is not sufficiently characterised to adequately configure the simulation inputs and deeper sediments that has not been adequately characterised. These deeper, uncharacterised thereby to simulate the intensity and extent of sediment plumes from the dredge activity. On the basis of sediments potentially yield greater dredge-related turbidity impacts than modelled to date. 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 3.4 DMPA Tailwater Discharge (Section 5.2.3) 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 A 50 mg/ TSS concentrations is modelled for the DMPA tailwater discharge. This model input parameter the majority of sediment to be removed will be surface marine sediments.’ 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. 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 3.5 Impact Assessment Framework (Section 5.2.6.3) 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 The dredge plume modelling assessment has assessed impact prediction variability by considering an (sediment depth interval unknown, refer to previous comments regarding Sub-Appendix F2). 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 The issues in regards to the interpretation of the sediment sampling and analysis include: dredging scenarios is likely most impacted by the uncertainty in the PSD characterisation of the Class 3  This review’s Section 8.1 and attachment (Sediment and Borehole Sampling Locations) show that dredge material (underlying harder [consolidated?] substrate under a veneer of marine sediments) much of the sediment characterisation data is for locations outside of the dredge area, and thereby described previously in this review in Section 3.3, which ought to be addressed. This dredging scenario does not provide an accurate characterisation of the sediments to be dredged (particularly in regards factor of Class 3 PSD uncertainty is likely to have greater impact than variations in the dredging volume- to the consolidated component), and thereby the ability to predict its behaviour during dredging. footprint-duration as a 30-day assessment window is used. Hence, the assessment with a 30-day

 Uncertainties highlighted in this review’s Section 2 in regards to the sediment sampling core depths window does not materially change with the same dredge plant over a longer duration dredging program and extrapolation to the dredge depth (core refusal generally <60 cm), and the inclusion of sediment and relatively minor change to the dredge footprint. 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. 3.6 Current Field Impacts (Section 6.3.2)

 Following on from this, the purported hydraulic pressure of the drill was 10 tonnes, yet core refusal Current speed measurements by Yumbah KI in the shallow waters in front of the abalone farm range 4- was consistently well below 1 m for all samples except for site SB7.2. The interpretation of the 13 cm/s across the 10th to 90th percentiles over a period of 6 months measurements from 24 August geotechnical/borehole data in Section 5.2 cannot be confirmed for >1 - 3 m of marine sediments 2018 to 25 February 2019 (see Section 8.2 of this review). Material changes to the nearshore current

6137616/6137616-LET-0_Review of KIPT EIS Water Quality 4 6137616/6137616-LET-0_Review of KIPT EIS Water Quality 5 Predictions_JRR Final (22-May-2019) Predictions_JRR Final (22-May-2019) regime may have potential implications to the flushing of Yumbah KI’s outlet waters into the nearshore 4.4 Residual Impacts and Assessment Summary (Section 5) waters and potentially increased recirculation into the facility’s intakes, which is of concern to Yumbah KI. In terms of capital dredging mitigation measures, the following mitigation measure is a suggestion in It is recognised that this section addresses coastal processes, so please refer to Section 4.3 for further Sub-Appendix F3 Section 4, not a recommendation, and hence should not be considered in the Risk comments on this operational risk/impact associated with the proposed causeway. As this is the only Assessment Summary unless it is a firm pre-approval KIPT commitment: section in the Draft EIS where current field impacts are addressed, for the purposes of assessing  Dredging should be limited from October to March to limit impacts to ecological receptors and predicted changes in the proximal location to the Yumbah KI inlets and outlets. The close-up figures of Yumbah KI’s intake water. the differences in current velocities in the region of the aquaculture facility are not adequate as finer If not a firm commitment, remove this measure from the risk assessment and reassess the residual current velocity intervals of 1-2 cm/s rather than 10 cm/s intervals (bottom panels of Figures 6-8 and 6-9) likelihood. is more representative and should instead be applied. The Ballast Water hazard risk assessment and the inherent and residual consequence rating of minor 4 Sub-Appendix F3 – Marine Water Quality Baseline and Impact Assessment 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 4.1 Impact Thresholds (Section 3.2.1) the proposed development and the potential impacts to increased recirculation of outlet to inlet waters of The use of 10 (Zone of High Impact) and 5 (Zone of Low to Moderate Impact) standard deviations the Yumbah KI facility. 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 5 Sub-Appendix F4 – External Hydrodynamic Modelling Peer Review receptors. It has been demonstrated that ambient turbidity is highly correlated to wave climate in Smith Bay (Figure 2-10 in Sub-Appendix F2). 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 Peak seasonal insolation (mid-spring to mid-autumn) corresponds to a seasonally low wave climate proposed dredged material and the respective volumes of the existing Class 1 and Class 2 sediment (Figure 3-3 in Sub-Appendix F2) with resultant low seasonal ambient turbidity (again Figure 2-10 in Sub- types, and suggested need for modelling of a Class 3 sediment type. The difficulty in confirming the Appendix F2). This is a sensitive period for benthic primary producers (e.g. seagrass) with seasonal adequacy of the modelled outputs aligns with the limited characterisation of the deeper sediment strata maxima in benthic PAR harvesting. The approach to define the impact thresholds does not seemingly during the two surveys of the superficial sediments in or in proximity to the dredge pocket. 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. 6 Appendix G – Coastal Processes

4.2 Plume Modelling Scenarios (Section 3.4.1.1) 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: 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  Please refer to this review’s Sections 3.6 and 4.3 for Yumbah KI’s view on potential changes to predicted construction impacts, and that environmental conditions do so. The PSD uncertainty of the ‘nearshore’ flushing and currents, and potential implications for recirculation of the aquaculture proposed sediment material to be dredged has been addressed previously in this review (Sections 3.3 facility’s outlet water to the intakes. The statement ‘Coastal circulation impacts are not expected to and 3.5). The TSS impact assessment is questionable as there is considerable uncertainty in the PSD of result in reduced flushing of Smith Bay waters’ needs to be demonstrated. the dredge material, and the need for deeper sediment understanding, particularly to confirm the  Seagrass wrack accumulation has the potential to impact Yumbah KI’s intakes. Coastal structure presence of a Class 3 sediment of consolidated material. (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 4.3 Lack of Nearshore Flushing and Yumbah KI Intake-Outlet Recirculation Assessment Yumbah KI facility’s intakes may cause wrack accumulation and water quality degradation of source (Section 3.5) waters to its abalone farm. EIS Appendix G is lacking the following information to address the No impacts to the flushing of Smith Bay and effects on recirculation of the aquaculture’s outflows to the potential impacts of seagrass wrack on the abalone farm: intakes were evaluated as indicated in Section 3.6 of this review. The placement of a solid causeway to o A description of the seagrass wrack dynamics of Smith Bay. the east has the potential to alter the typical flushing patterns with a potential to increase the recirculation o of the facility’s outlet waters to the inlets. The potential for changes to the very nearshore flushing of Predictions of the effect of the proposed development on the seagrass wrack dynamics Yumbah KI’s outlet waters due to the presence of the proposed causeway and any impacts/risks in terms of Smith Bay. of recirculation of the outlet waters into the Yumbah KI facility’s intakes has not been addressed. 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

6137616/6137616-LET-0_Review of KIPT EIS Water Quality 6 6137616/6137616-LET-0_Review of KIPT EIS Water Quality 7 Predictions_JRR Final (22-May-2019) Predictions_JRR Final (22-May-2019) regime may have potential implications to the flushing of Yumbah KI’s outlet waters into the nearshore 4.4 Residual Impacts and Assessment Summary (Section 5) waters and potentially increased recirculation into the facility’s intakes, which is of concern to Yumbah KI. In terms of capital dredging mitigation measures, the following mitigation measure is a suggestion in It is recognised that this section addresses coastal processes, so please refer to Section 4.3 for further Sub-Appendix F3 Section 4, not a recommendation, and hence should not be considered in the Risk comments on this operational risk/impact associated with the proposed causeway. As this is the only Assessment Summary unless it is a firm pre-approval KIPT commitment: section in the Draft EIS where current field impacts are addressed, for the purposes of assessing  Dredging should be limited from October to March to limit impacts to ecological receptors and predicted changes in the proximal location to the Yumbah KI inlets and outlets. The close-up figures of Yumbah KI’s intake water. the differences in current velocities in the region of the aquaculture facility are not adequate as finer If not a firm commitment, remove this measure from the risk assessment and reassess the residual current velocity intervals of 1-2 cm/s rather than 10 cm/s intervals (bottom panels of Figures 6-8 and 6-9) likelihood. is more representative and should instead be applied. The Ballast Water hazard risk assessment and the inherent and residual consequence rating of minor 4 Sub-Appendix F3 – Marine Water Quality Baseline and Impact Assessment 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 4.1 Impact Thresholds (Section 3.2.1) the proposed development and the potential impacts to increased recirculation of outlet to inlet waters of The use of 10 (Zone of High Impact) and 5 (Zone of Low to Moderate Impact) standard deviations the Yumbah KI facility. 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 5 Sub-Appendix F4 – External Hydrodynamic Modelling Peer Review receptors. It has been demonstrated that ambient turbidity is highly correlated to wave climate in Smith Bay (Figure 2-10 in Sub-Appendix F2). 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 Peak seasonal insolation (mid-spring to mid-autumn) corresponds to a seasonally low wave climate proposed dredged material and the respective volumes of the existing Class 1 and Class 2 sediment (Figure 3-3 in Sub-Appendix F2) with resultant low seasonal ambient turbidity (again Figure 2-10 in Sub- types, and suggested need for modelling of a Class 3 sediment type. The difficulty in confirming the Appendix F2). This is a sensitive period for benthic primary producers (e.g. seagrass) with seasonal adequacy of the modelled outputs aligns with the limited characterisation of the deeper sediment strata maxima in benthic PAR harvesting. The approach to define the impact thresholds does not seemingly during the two surveys of the superficial sediments in or in proximity to the dredge pocket. 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. 6 Appendix G – Coastal Processes

6137616/6137616-LET-0_Review of KIPT EIS Water Quality 6 6137616/6137616-LET-0_Review of KIPT EIS Water Quality 7 Predictions_JRR Final (22-May-2019) Predictions_JRR Final (22-May-2019) likelihood of ‘possible’ is not supported. Further, mitigation measures only change the site was ~32 cm/s on 21 November 2018, coinciding with a storm event that moved through the region. residual likelihood and not the residual consequence (note this comment also applies to The climate statistics for Kingscote, South Australia, obtained from the Bureau of Meteorology indicate reference item 6 in Table 4-1, and it is uncertain why changes in residual likelihoods to maximum wind gusts of 94 km/h on this day, which would have a significant influence on current speeds references 2 and 3 are included with no [nil] mitigation measures noted). The inherent in these shallow coastal waters. and residual risk for seagrass wrack accumulation is not supported. Current directions at the site periodically alternate between the dominant directions of easterly during o The risk of seagrass wrack accumulation on the quality of the source waters to Yumbah flood tides and westerly during ebb tides (Figure 1). Further, the minimum current speed of ~2 cm/s is KI’s abalone farm is lacking and needs to be addressed, particularly given the close sufficient to transport a turbid plume from the proposed port to the western intake of Yumbah KI’s facility, proximity of the proposed development to the inlets. 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 7 Appendix T – Risk Assessment cycles. Westerly currents are slightly more frequent than easterly currents. In total, currents with an The following is noted in regards to the Appendix T Risk Assessment. 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  Appendix T would benefit from descriptors of the consequence and likelihood, and a risk matrix the west of Yumbah’s facility, the high frequency (44%) of easterly currents provides a mechanism by table. which suspended sediments and pollutants generated at the port may enter the seawater intakes of the  The risk assessment is problematic in many instances in that mitigation measures have often aquaculture facility. resulted in reductions to the residual likelihood and residual consequence. Management measures Figure 3 shows the probability distribution of the inshore currents over the 6 month deployment. The 10th, can only reduce the residual likelihood, not the residual consequence. Please revise the risk 20th, 50th, 80th and 90th current speed percentiles are approximately 4, 6, 8, 12 and 13 cm/s. 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

6137616/6137616-LET-0_Review of KIPT EIS Water Quality 8 6137616/6137616-LET-0_Review of KIPT EIS Water Quality 9 Predictions_JRR Final (22-May-2019) Predictions_JRR Final (22-May-2019) likelihood of ‘possible’ is not supported. Further, mitigation measures only change the site was ~32 cm/s on 21 November 2018, coinciding with a storm event that moved through the region. residual likelihood and not the residual consequence (note this comment also applies to The climate statistics for Kingscote, South Australia, obtained from the Bureau of Meteorology indicate reference item 6 in Table 4-1, and it is uncertain why changes in residual likelihoods to maximum wind gusts of 94 km/h on this day, which would have a significant influence on current speeds references 2 and 3 are included with no [nil] mitigation measures noted). The inherent in these shallow coastal waters. and residual risk for seagrass wrack accumulation is not supported. Current directions at the site periodically alternate between the dominant directions of easterly during o The risk of seagrass wrack accumulation on the quality of the source waters to Yumbah flood tides and westerly during ebb tides (Figure 1). Further, the minimum current speed of ~2 cm/s is KI’s abalone farm is lacking and needs to be addressed, particularly given the close sufficient to transport a turbid plume from the proposed port to the western intake of Yumbah KI’s facility, proximity of the proposed development to the inlets. 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 7 Appendix T – Risk Assessment cycles. Westerly currents are slightly more frequent than easterly currents. In total, currents with an The following is noted in regards to the Appendix T Risk Assessment. 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  Appendix T would benefit from descriptors of the consequence and likelihood, and a risk matrix the west of Yumbah’s facility, the high frequency (44%) of easterly currents provides a mechanism by table. which suspended sediments and pollutants generated at the port may enter the seawater intakes of the  The risk assessment is problematic in many instances in that mitigation measures have often aquaculture facility. resulted in reductions to the residual likelihood and residual consequence. Management measures Figure 3 shows the probability distribution of the inshore currents over the 6 month deployment. The 10th, can only reduce the residual likelihood, not the residual consequence. Please revise the risk 20th, 50th, 80th and 90th current speed percentiles are approximately 4, 6, 8, 12 and 13 cm/s. 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

6137616/6137616-LET-0_Review of KIPT EIS Water Quality 8 6137616/6137616-LET-0_Review of KIPT EIS Water Quality 9 Predictions_JRR Final (22-May-2019) Predictions_JRR Final (22-May-2019) 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 Figure 1 Time series of current speeds (top), directions (middle) at the western site and Team Leader, Marine and Aquatic Services predicted tides at Emu Bay (bottom) +61 8 6222 8992

6137616/6137616-LET-0_Review of KIPT EIS Water Quality 10 6137616/6137616-LET-0_Review of KIPT EIS Water Quality 11 Predictions_JRR Final (22-May-2019) Predictions_JRR Final (22-May-2019) 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 Figure 1 Time series of current speeds (top), directions (middle) at the western site and Team Leader, Marine and Aquatic Services predicted tides at Emu Bay (bottom) +61 8 6222 8992

6137616/6137616-LET-0_Review of KIPT EIS Water Quality 10 6137616/6137616-LET-0_Review of KIPT EIS Water Quality 11 Predictions_JRR Final (22-May-2019) Predictions_JRR Final (22-May-2019) Smith Bay Seaport Response to Draft Environmental Impact Statement APPENDIX 2 – Kangaroo Island Plantation Timbers GLOBAL MARINE RESOURCE MANAGEMENT RESPONSE TO EIS

McShane

2019

Professor Paul McShane

Global Marine Resource Management Pty Ltd.

May 2019

154 Smith Bay Wharf Environmental Impact Statement Yumbah Response Smith Bay Seaport Response to Draft Environmental Impact Statement Kangaroo Island Plantation Timbers

Professor Paul McShane

Global Marine Resource Management Pty Ltd.

May 2019

Professor Paul McShane

Smith Bay Seaport Response to Draft Environmental Impact Statement Kangaroo Island Plantation Timbers May 2019.

Disclaimer www.globalmarineresourcemanagement.com.au 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. 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 Cover photograph development. Professor McShane is also currently a Professorial Research Fellow (Aquaculture) in the College of Science and Engineering, James Cook University. Looking north from Yumbah Aquaculture Smith Bay His past roles include:

Photo: Paul McShane • 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 Page 3 of 17 Global Marine Resource Management Pty Ltd Global Marine Resource Management Pty Ltd Professor Paul McShane

Smith Bay Seaport Response to Draft Environmental Impact Statement Kangaroo Island Plantation Timbers May 2019.

Photo: Paul McShane • Research Fellow, School of Social Sciences, Faculty of Arts, Monash University; • Chief Research Officer, Monash Sustainability Institute, Monash University;

marine science, including in Australia, New Zealand, Canada, Japan and the United States.

Page 2 of 17 Page 3 of 17 Global Marine Resource Management Pty Ltd Global Marine Resource Management Pty Ltd CONTENTS INTRODUCTION

Introduction ...... 5 Smith Bay is a shallow coastal embayment located within a Coastal Conservation Zone (Department of Planning, Fine sediment in the context of impacts on abalone...... 6 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 Abalone and their natural environment ...... 6 accommodating large bulk carriers (www.kipt.com.au). The proposed seaport is less than 500 metres from Review of sediment impacts on abalone ...... 7 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 Lack of ecotoxicological tests ...... 9 have been raised, KPT has produced a draft environmental impact statement (KIPT 2019). Fine sediment effects on abalone ...... 9 This report builds on previous work which identified and characterised the likely impacts of, and extant Adverse temperature effects on abalone: likely consequences of reduced local currents ...... 11 risks associated with, the proposed seaport (McShane 2017). It addresses issues raised in the draft Sediment impacts on diatoms and risk of harmful algal blooms ...... 11 Environmental Impact Statement (EIS) released in March 2019. It focuses on key hazards and extant Extraneous light impacts on abalone ...... 12 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 Marine ecological impacts: seagrasses and listed marine species ...... 12 existing licences). This report does not address other risks presented by the proposed seaport including References ...... 13 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 Page 5 of 17 Global Marine Resource Management Pty Ltd Global Marine Resource Management Pty Ltd CONTENTS INTRODUCTION

Page 4 of 17 Page 5 of 17 Global Marine Resource Management Pty Ltd Global Marine Resource Management Pty Ltd FINE SEDIMENT IN THE CONTEXT OF IMPACTS ON ABALONE 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. 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 Not surprisingly, there are relatively few studies which explore impacts of fine sediments on abalone as these impacts, including management of dredge spoil (Guideline No. 2.7, Table H-1, Appendix H, Page 13). 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 Due to the proximity of the proposed seaport to Yumbah Kangaroo Island (KI), there will be detrimental impacts of papers detailing negative effects of suspended sediments on sub-adult through to adult animals is likely of increased suspended sediments arising from the construction and operation of the proposed seaport on because such impacts rarely occur in the natural environment. This statement is further qualified by Cheshire Yumbah’s abalone farming activities. The draft EIS has recognised that impact is likely. The capital dredging (2018): Most southern Australian abalone species (with the exception of H. cyclobates), live in environments program has the potential to affect water quality, principally suspended sediment loads, at the Yumbah where they are frequently exposed to high levels of suspended sediments (Appendix H, Pages 33,34). Yet these seawater intakes under some dredging scenarios (Appendix H, Page 9). “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 Furthermore, in relation to the potential ecotoxicity of suspended sediments: Sediments used in the test were have evolved to live in an environment where, in order to feed and grow, they need to be able to deal with the obtained from Smith Bay but were dried and then sieved through a 64 µm sieve to ensure that the material used associated suspension of sand and other forms of detritus (see e.g. Melville-Smith et al. 2017) (Appendix H, Page for testing comprised only the finer sediment fraction which would both remain in suspension (i.e. not settle out) 38). 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 REVIEW OF SEDIMENT IMPACTS ON ABALONE 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). 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 There are a number of statements throughout Appendix H (Cheshire 2018) and elsewhere throughout the EIS examine the specific impact of fine sediments. Such impacts are directly relevant to the evaluation of fine that state that abalone are well adapted to high sediment loads in their natural habitat. These references are sediment impacts on farmed abalone at Yumbah. Those studies that do examine fine sediments (e.g. Chung et inflated and misleading. In fact, abalone are demonstrably not well adapted to fine sediments (silt and clay al. 1993) indicate a relationship between concentration (fine sediment loads) and exposure. Many experimental particles). Again, this finding is reinforced by Cheshire (2018). Such resilience (of abalone to high suspended studies of sediment impacts examine concentration (of sediment) alone and duration of exposure is not sediment loads) is likely to be skewed towards the coarser sediment fractions because, in the abalone’s natural considered. Acute exposure (48 h) of Haliotis discus to 50 mg/l fine sediments caused no mortality whereas environment, finer materials would be winnowed out of the system (Appendix H, Page 42). 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 ABALONE AND THEIR NATURAL ENVIRONMENT strongly associated with fish response (Wilber and Clark 2001). There are numerous statements in the EIS that suggest abalone (including Haliotis laevigata) are well adapted Construction of the causeway and the dredging of the berthing basin will collectively entail more than six to high suspended sediment loads because they live in high energy subtidal coastal environments which provide months of exposure to fine sediment loads in Smith Bay (KIPT 2019 main report, page 52). Fine sediment suspended material such as seaweed particles upon which abalone rely on for food (McShane et al. 1994). Yet emanating from dredge spoil and construction debris will enter Yumbah’s seawater intakes. This presents an Cheshire (2018) consistently understates that the tolerance is only to larger suspended matter unrepresentative unacceptable risk and will significantly compromise the continuing viability of abalone farming at Yumbah, Smith of fine sediments characteristic of dredge spoil. Bay. Thus, risks of the seaport on abalone should be evaluated in terms of concentration (likely fine sediment It is true that abalone are well adapted to high energy coastal environments (Tissot 1992, Shepherd 1973). As loads) and exposure to the hazard (duration). This has not been done in the draft EIS (KIPT 2019). marine gastropods in their natural environment, abalone cling to rocky substrata and aggregate in areas where Extremely high concentrations of fine sediment (1,000 mg/l) caused substantial mortality (> 80%) in abalone seaweed particles accumulate (Shepherd 1973). Tissot’s (1992) study, quoted extensively by Cheshire (2018), (Chung et al. 1993). Stringer (2018a) draws attention to the lack of controls and replication of many of the presents some adaptative strategies of various abalone species to tolerate high water movement (i.e. to studies cited in Table H-7 but notes greater rigor in the design of Yoon and Park (2011). However, Yoon and mitigate shear stress in adhering to reef surfaces). This is not evidence of tolerance to high suspended sediment Park’s (2001) study did not examine specific impacts of fine sediments and, as Stringer (2018a) points out, may loads as claimed by Cheshire (2018). Rather, such adaptations relate to withstanding the sheer stress created have little relevance to likely impacts on H. laevigata (… further investigation is required before any guideline by wave-induced turbulence in typical coastal subtidal habitat. The ability of abalone to maintain adherence to value is derived for greenlip abalone). 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 Stringer (2018a) citing Cheshire (2018) claims that the ANZECC (2000) trigger value of 10 mg/l total suspended movement (Ragg and Taylor 2006, Voltzow 2015). Thus, abalone are poorly adapted to low water movement solids for aquaculture is overly conservative for abalone. They attempt to justify a new guideline value of 25 (Tissot 1992): conditions in which fine sediment fractions accumulate (Airoldi 2003, Blott and Pye 2012). 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 Under turbulent conditions typical of sub littoral coastal environments, only large particles are found among regarding chronic effects of fine sediment on abalone, and their own claim that further investigation is required suspended solids in seawater (Thomas and Ridd 2004, Blott and Pye 2012) including the drift seaweed particles (see above), there is no objective basis for setting trigger values higher than the aquaculture guideline of favoured by abalone as food (Shepherd 1973). Indeed, this is acknowledged by the Cheshire (2018) (Appendix <10m/L. ANZECC (2000) states that Guideline trigger values are concentrations that, if exceeded, will indicate a H, page 47): These finer sediments are also representative of the fraction that would be transported from the potential environmental problem, and so ‘trigger’ further investigation. The investigation aims to both assess

Page 6 of 17 Page 7 of 17 Global Marine Resource Management Pty Ltd Global Marine Resource Management Pty Ltd FINE SEDIMENT IN THE CONTEXT OF IMPACTS ON ABALONE 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. 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 Not surprisingly, there are relatively few studies which explore impacts of fine sediments on abalone as these impacts, including management of dredge spoil (Guideline No. 2.7, Table H-1, Appendix H, Page 13). 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 Due to the proximity of the proposed seaport to Yumbah Kangaroo Island (KI), there will be detrimental impacts of papers detailing negative effects of suspended sediments on sub-adult through to adult animals is likely of increased suspended sediments arising from the construction and operation of the proposed seaport on because such impacts rarely occur in the natural environment. This statement is further qualified by Cheshire Yumbah’s abalone farming activities. The draft EIS has recognised that impact is likely. The capital dredging (2018): Most southern Australian abalone species (with the exception of H. cyclobates), live in environments program has the potential to affect water quality, principally suspended sediment loads, at the Yumbah where they are frequently exposed to high levels of suspended sediments (Appendix H, Pages 33,34). Yet these seawater intakes under some dredging scenarios (Appendix H, Page 9). “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 Furthermore, in relation to the potential ecotoxicity of suspended sediments: Sediments used in the test were have evolved to live in an environment where, in order to feed and grow, they need to be able to deal with the obtained from Smith Bay but were dried and then sieved through a 64 µm sieve to ensure that the material used associated suspension of sand and other forms of detritus (see e.g. Melville-Smith et al. 2017) (Appendix H, Page for testing comprised only the finer sediment fraction which would both remain in suspension (i.e. not settle out) 38). 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 REVIEW OF SEDIMENT IMPACTS ON ABALONE 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). 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 There are a number of statements throughout Appendix H (Cheshire 2018) and elsewhere throughout the EIS examine the specific impact of fine sediments. Such impacts are directly relevant to the evaluation of fine that state that abalone are well adapted to high sediment loads in their natural habitat. These references are sediment impacts on farmed abalone at Yumbah. Those studies that do examine fine sediments (e.g. Chung et inflated and misleading. In fact, abalone are demonstrably not well adapted to fine sediments (silt and clay al. 1993) indicate a relationship between concentration (fine sediment loads) and exposure. Many experimental particles). Again, this finding is reinforced by Cheshire (2018). Such resilience (of abalone to high suspended studies of sediment impacts examine concentration (of sediment) alone and duration of exposure is not sediment loads) is likely to be skewed towards the coarser sediment fractions because, in the abalone’s natural considered. Acute exposure (48 h) of Haliotis discus to 50 mg/l fine sediments caused no mortality whereas environment, finer materials would be winnowed out of the system (Appendix H, Page 42). 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 ABALONE AND THEIR NATURAL ENVIRONMENT strongly associated with fish response (Wilber and Clark 2001). There are numerous statements in the EIS that suggest abalone (including Haliotis laevigata) are well adapted Construction of the causeway and the dredging of the berthing basin will collectively entail more than six to high suspended sediment loads because they live in high energy subtidal coastal environments which provide months of exposure to fine sediment loads in Smith Bay (KIPT 2019 main report, page 52). Fine sediment suspended material such as seaweed particles upon which abalone rely on for food (McShane et al. 1994). Yet emanating from dredge spoil and construction debris will enter Yumbah’s seawater intakes. This presents an Cheshire (2018) consistently understates that the tolerance is only to larger suspended matter unrepresentative unacceptable risk and will significantly compromise the continuing viability of abalone farming at Yumbah, Smith of fine sediments characteristic of dredge spoil. Bay. Thus, risks of the seaport on abalone should be evaluated in terms of concentration (likely fine sediment It is true that abalone are well adapted to high energy coastal environments (Tissot 1992, Shepherd 1973). As loads) and exposure to the hazard (duration). This has not been done in the draft EIS (KIPT 2019). marine gastropods in their natural environment, abalone cling to rocky substrata and aggregate in areas where Extremely high concentrations of fine sediment (1,000 mg/l) caused substantial mortality (> 80%) in abalone seaweed particles accumulate (Shepherd 1973). Tissot’s (1992) study, quoted extensively by Cheshire (2018), (Chung et al. 1993). Stringer (2018a) draws attention to the lack of controls and replication of many of the presents some adaptative strategies of various abalone species to tolerate high water movement (i.e. to studies cited in Table H-7 but notes greater rigor in the design of Yoon and Park (2011). However, Yoon and mitigate shear stress in adhering to reef surfaces). This is not evidence of tolerance to high suspended sediment Park’s (2001) study did not examine specific impacts of fine sediments and, as Stringer (2018a) points out, may loads as claimed by Cheshire (2018). Rather, such adaptations relate to withstanding the sheer stress created have little relevance to likely impacts on H. laevigata (… further investigation is required before any guideline by wave-induced turbulence in typical coastal subtidal habitat. The ability of abalone to maintain adherence to value is derived for greenlip abalone). 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 Stringer (2018a) citing Cheshire (2018) claims that the ANZECC (2000) trigger value of 10 mg/l total suspended movement (Ragg and Taylor 2006, Voltzow 2015). Thus, abalone are poorly adapted to low water movement solids for aquaculture is overly conservative for abalone. They attempt to justify a new guideline value of 25 (Tissot 1992): conditions in which fine sediment fractions accumulate (Airoldi 2003, Blott and Pye 2012). 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 Under turbulent conditions typical of sub littoral coastal environments, only large particles are found among regarding chronic effects of fine sediment on abalone, and their own claim that further investigation is required suspended solids in seawater (Thomas and Ridd 2004, Blott and Pye 2012) including the drift seaweed particles (see above), there is no objective basis for setting trigger values higher than the aquaculture guideline of favoured by abalone as food (Shepherd 1973). Indeed, this is acknowledged by the Cheshire (2018) (Appendix <10m/L. ANZECC (2000) states that Guideline trigger values are concentrations that, if exceeded, will indicate a H, page 47): These finer sediments are also representative of the fraction that would be transported from the potential environmental problem, and so ‘trigger’ further investigation. The investigation aims to both assess

Page 6 of 17 Page 7 of 17 Global Marine Resource Management Pty Ltd Global Marine Resource Management Pty Ltd whether exceedance of a trigger value will result in environmental harm and refine a guideline value, by LACK OF ECOTOXICOLOGICAL TESTS 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 The likely consequences of dredging activities in Smith Bay are captured in Page 51 of Appendix H: These reduce both costs for industry and confrontation. This invalidates the risk assessment relating to potential estimates of suspended sediment loads do not provide specific predictions on the likely composition of the dredge impacts on abalone (Appendix H, Table H-12, Page 71) which assumes a threshold suspended solids suspended material in relation to the particle size distribution (PSD). Ambient sediment loads are likely to show concentration of 25 mg/l. ANZECC (2000) explicitly states that thorough assessments are required that are site changes through time in PSD with coarser particles being found during and immediately after storm induced specific and that consider all environmental factors. 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 Table H-7 is reproduced below with comments added. It purports to present acute impacts of suspended solids fine sediment particles but as the suspended material moves further away from the dredging site the coarser on abalone and other marine fauna. Additional tests by Springer (2018b) are also added to the Table originally particles will settle more rapidly and hence, at a greater distance, the material remaining in suspension will be published in Appendix H (KIPT 2019). dominated by the finer size classes of sediment (consistent with those tested in the ecotoxicology studies).

Species Treatments Period Finding Source Comment 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 Haliotis discus TSS at: 0, 96 h No effect on Lee 2008 Unrepresentative hannai 1000,1500 and mortality. Decrease impact as does not mortality (Springer 2018b). However, as the short-term tests revealed no mortalities (after 24 h exposure and 2000 mg/l in glycogen content examine fine sediment 48 h recovery), these results do not constitute an ecotoxicological assessment. Acute and chronic impacts were over 1500 mg/l effects not observed (e.g. feeding rates, respiration). Furthermore, abalone cultivated at Yumbah Kangaroo Island have H. diversicolor TSS at: 100, 200, 96 h No effect on Wang et Unrepresentative been selectively bred for Yumbah’s farming conditions from brood stock that have been genetically selected for 300, 400 mg/l mortality, weaker al. 2007 impact as does not optimal farming conditions. Juvenile abalone exposed to sediment in the laboratory test described by Springer motility at higher examine fine sediment (2018b) were sourced from wild populations and their behaviour cannot be directly compared to farmed concentrations effects abalone due to the genetic optimisation of Yumbah’s farmed stock. Springer (2018b) notes that only a limited H. discus TSS (silt and clay): 48 h No effect on Chung et Provides evidence of number of juvenile abalone were able to be obtained from the wild. 50 mg/l mortality al. 1993 mortality effects for longer exposure (see Despite the obvious limitations presented above and a demonstrably inadequate ecotoxicological assessment, below) 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 H. discus TSS (silt and clay): 72 h 0-1.25% mortality Chung et Evidence of chronic effects. This provides a water quality guideline of 25 mg/l at which neither chronic nor acute effects 50 mg/l 96 h 0-7.5% mortality al. 1993 exposure/concentration 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 H. discus TSS (silt and clay): 96 h Up to 82.5% Chung et Evidence of 1000 mg/l mortality al. 1993 concentration effects abalone to a given concentration for a limited duration that is unrelated to the actual exposure that will result from dredging. H. discus TSS at: 250, 500, 7 d LOEC = 500 mg/l Yoon and No information hannai 1000, 2000, and Park provided on particle LC50 = 1888 mg/l 4000 mg/l 2011 size distribution FINE SEDIMENT EFFECTS ON ABALONE Tigriopus TSS at: 250, 500, 7 d LOEC = 31 mg/l Yoon and Evidence of There are several lines of evidence that support harmful consequences of exposure of abalone to fine japonicas 1000, 2000, and Park exposure/concentration LC50 = 61 mg/l sediments. Abalone are primitive gastropods retaining a bipectinate gill structure which is relatively inefficient (copepod) 4000 mg/l 2011 effects. at extracting oxygen from seawater compared with more advanced molluscs (Wanichanon et al. 2004, Ragg and Unrelated species. Taylor 2006, Morash and Alter 2016). Abalone have weak capacity to actively ventilate their gills and, instead, Paralichthys TSS at: 250, 500, 7 d LOEC = 125 mg/l Yoon and Evidence of rely on passive water movement in their natural habitat (Tissot 1992, Ragg and Taylor 2006). Water movement olivaceus 1000, 2000, and Park exposure/concentration across the perforated shell of abalone drives water into the brachial chambers and to the mantle cavity (Ragg LC50 = 157 mg/l (flounder fry) 4000 mg/l 2011 effects. Unrelated and Taylor 2006, Morash and Alter 2016). Thus, abalone typically inhabit high energy sublittoral environments species. where water movement generated by waves and tide provide for the necessary gill ventilation. The shells of H. iris Synthetic particles No significant effect Allen et Unrepresentative abalone are adapted to reduce drag (and therefore shear forces which could remove them from reef substrata) 100 mg/l on mortality al. 2006 impact as does not and to provide for gill/mantle ventilation (Tissot 1992). examine fine sediment effects Associated with the gills of abalone is a hypobranchial gland which functions to produce mucus to keep the gills H. laevigata TSS (< 63 µm) 250 24 h No effect on Springer Short term exposure and the mantle cavity clean (Wanichanon et al. 2004). When foreign particles from turbid water enter the mg/l mortality 2018b only. No examination mantle cavity, the mucus cells bind particles that can be expelled through the ciliary action of the epithelial cells. of sublethal impacts. Abalone have limited capacity to clear fine sediment and associated mucus. Exposure to fine sediment can Not representative therefore have an adverse impact on abalone health (Ragg 2014), as has been demonstrated for farmed H. ecotoxicity test laevigata at Yumbah KI (see below). Similar adverse effects of fine sediments have been found in other shellfish

Page 8 of 17 Page 9 of 17 Global Marine Resource Management Pty Ltd Global Marine Resource Management Pty Ltd whether exceedance of a trigger value will result in environmental harm and refine a guideline value, by LACK OF ECOTOXICOLOGICAL TESTS 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 The likely consequences of dredging activities in Smith Bay are captured in Page 51 of Appendix H: These reduce both costs for industry and confrontation. This invalidates the risk assessment relating to potential estimates of suspended sediment loads do not provide specific predictions on the likely composition of the dredge impacts on abalone (Appendix H, Table H-12, Page 71) which assumes a threshold suspended solids suspended material in relation to the particle size distribution (PSD). Ambient sediment loads are likely to show concentration of 25 mg/l. ANZECC (2000) explicitly states that thorough assessments are required that are site changes through time in PSD with coarser particles being found during and immediately after storm induced specific and that consider all environmental factors. 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 Table H-7 is reproduced below with comments added. It purports to present acute impacts of suspended solids fine sediment particles but as the suspended material moves further away from the dredging site the coarser on abalone and other marine fauna. Additional tests by Springer (2018b) are also added to the Table originally particles will settle more rapidly and hence, at a greater distance, the material remaining in suspension will be published in Appendix H (KIPT 2019). dominated by the finer size classes of sediment (consistent with those tested in the ecotoxicology studies).

Page 8 of 17 Page 9 of 17 Global Marine Resource Management Pty Ltd Global Marine Resource Management Pty Ltd e.g. scallops (Stevens 1987). Pumping rates of the gills of bivalves is reduced by more than 90% in the presence ADVERSE TEMPERATURE EFFECTS ON ABALONE: LIKELY CONSEQUENCES OF REDUCED of fine sediment (80 mg/l). Lateral cilia in bivalves lack the capacity to clear particles which accumulate at the LOCAL CURRENTS 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, Proposed construction of a 250 m causeway will substantially affect nearshore water movement in Smith Bay. when present in aquaria, abalone avoid fine sediment: fine sediment adversely affects the righting response The draft EIS indicates that reduction in current speed at Yumbah’s westerly seawater intake will be about 30- (Chew et al. 2013). 40% (Appendix H, page 65): this will coincide with an increase in ambient seawater temperature (Appendix G, page 23). 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 The adverse consequences of increased water temperature on abalone are acknowledged by Cheshire (2018): impacts were observed following a less intense storm during October of the same year (David Connell Yumbah, Likely increases in water temperature accentuated by recirculation of Yumbah effluent water will also have a personal communication). Abalone appeared moribund 2 days after the storm and mortality occurred over 6 harmful effect on abalone. Data collected for the EIS throughout 2017, using moored data buoys that were weeks following initial impact (storm suspension of fine sediment). Histopathological analysis by Dr Richmond equipped with a suite of water quality and hydrodynamic sensors (detailed in Chapter 10), show that mean Loh, an aquatic animal health specialist, revealed the following (Letter to David Connell 28th March 2017): seawater temperature during the monitoring period at Smith Bay within 300 m of shore during summer was Mortalities were worst in 3 to 4-year old group (harvest class), though 1-year olds were also affected. Clinical around 21-22o C but there were spikes up to 25 o C recorded during heatwaves (see Chapter 9) (Appendix H, Page signs reported in abalone include swollen head, swollen foot, and difficulty holding onto substrate, and death 27). As Cheshire (2018) further notes: many farms across South Australia have reported substantial mortality within 2 days of showing clinical signs. Storms and abalone deaths coincided with higher frequency of clogging events at much lower temperatures (22-23o C; Vandepeer 2006). of their 1 µm water filters (in their hatchery). SEDIMENT IMPACTS ON DIATOMS AND RISK OF HARMFUL ALGAL BLOOMS Microscopic examination of 20 abalone showed consistent lesions, the most significant being gill damage. Diatoms are unicellular non-motile phytoplankton important in the diet of abalone farmed at Yumbah (McShane Changes in the surface mucus layer observed in H. laevigata may be caused by changes in: 2017). Dredge spoil presents a risk to the viability of diatoms in the subtidal environment of Smith Bay by • Viscosity of the mucus (dilution) 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): • Reduced production of mucus • Degradation by enzymes, or • Diatoms are only important in diet of early stages of abalone; • Increased loss of mucus. • Algae exhibit a high level of plasticity in their adaptation to ambient light environments allowing We suspect that the breakdown of their mucus barrier and damage to the epithelium of the gills and skin, may adjustments to adverse light climate; lead to electrolyte disturbances and dehydration – and death ensues. • Changes in turbidity at shallow depths are small and will not have an adverse effect on diatom production; The sick abalone all had inflammation and oedema, varying from moderate to marked, varying between organs • Conditions that would promote harmful algal blooms (red tides) are not likely to occur in Smith Bay. in its severity. I did not see any clear evidence of bacteria such as vibrio or flavobacteria. In fact, advice from Yumbah KI’s hatchery manager reveals that diatoms are important dietary supplements Similar observations were recorded by Dr Celia Hooper (letter to David Connell 17th November 2016): 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, Normal gills were apparent from specimens sampled for histopathological examination 5 months after the selectively absorb blue light negatively impacting on diatom growth (Prieur and Sathyendranath 1981). storm event (February 2017): I examined abalone from KIAB sent to Gribbles Veterinary Pathology on 6th Although diatoms have accessory pigments that can harvest other spectral components e.g. green light (Vesk September, following severe storm weather. 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 Following the poor weather, abalone from this property became ill with puffy heads, swollen feet, difficulty al. 2019). 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. 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 Upon examination, these affected abalone had inflammation throughout, but more severe in the muscle of the such as dinoflagellates including red tide species, may be favoured over diatoms in suboptimal light regimes foot and head regions. The inflammation in the head probably reflects increased silt in the environment of these (low- or poor-quality light) (Ault 2000; Park et al. 2001; Smayda and Reynolds 2001; Peperzak 2003, Shikata et animals, including increased silt in the mouth. 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 Further disturbance of the sea bed in the vicinity of this farm is likely to have a deleterious effect on the abalone maintenance dredging activities will have a deleterious effect on those benthic diatoms favoured in the diet of and oyster farms in this location. abalone farmed at Yumbah. Further to this, changes to light climate in Smith Bay coupled with the potential Dr Hooper and Dr Loh are both experts on the pathology of abalone (Hooper et al. 2007). The evidence introduction of exotic dinoflagellates (via ballast water) increases the risk harmful algal blooms (e.g. Park et al. presented in the two histopathological reports indicate conclusively sediment is significantly detrimental to 2001, see also Dowsett et al. 2011 for H. laevigata). abalone.

Page 10 of 17 Page 11 of 17 Global Marine Resource Management Pty Ltd Global Marine Resource Management Pty Ltd e.g. scallops (Stevens 1987). Pumping rates of the gills of bivalves is reduced by more than 90% in the presence ADVERSE TEMPERATURE EFFECTS ON ABALONE: LIKELY CONSEQUENCES OF REDUCED of fine sediment (80 mg/l). Lateral cilia in bivalves lack the capacity to clear particles which accumulate at the LOCAL CURRENTS 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, Proposed construction of a 250 m causeway will substantially affect nearshore water movement in Smith Bay. when present in aquaria, abalone avoid fine sediment: fine sediment adversely affects the righting response The draft EIS indicates that reduction in current speed at Yumbah’s westerly seawater intake will be about 30- (Chew et al. 2013). 40% (Appendix H, page 65): this will coincide with an increase in ambient seawater temperature (Appendix G, page 23). 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 The adverse consequences of increased water temperature on abalone are acknowledged by Cheshire (2018): impacts were observed following a less intense storm during October of the same year (David Connell Yumbah, Likely increases in water temperature accentuated by recirculation of Yumbah effluent water will also have a personal communication). Abalone appeared moribund 2 days after the storm and mortality occurred over 6 harmful effect on abalone. Data collected for the EIS throughout 2017, using moored data buoys that were weeks following initial impact (storm suspension of fine sediment). Histopathological analysis by Dr Richmond equipped with a suite of water quality and hydrodynamic sensors (detailed in Chapter 10), show that mean Loh, an aquatic animal health specialist, revealed the following (Letter to David Connell 28th March 2017): seawater temperature during the monitoring period at Smith Bay within 300 m of shore during summer was Mortalities were worst in 3 to 4-year old group (harvest class), though 1-year olds were also affected. Clinical around 21-22o C but there were spikes up to 25 o C recorded during heatwaves (see Chapter 9) (Appendix H, Page signs reported in abalone include swollen head, swollen foot, and difficulty holding onto substrate, and death 27). As Cheshire (2018) further notes: many farms across South Australia have reported substantial mortality within 2 days of showing clinical signs. Storms and abalone deaths coincided with higher frequency of clogging events at much lower temperatures (22-23o C; Vandepeer 2006). of their 1 µm water filters (in their hatchery). SEDIMENT IMPACTS ON DIATOMS AND RISK OF HARMFUL ALGAL BLOOMS Microscopic examination of 20 abalone showed consistent lesions, the most significant being gill damage. Diatoms are unicellular non-motile phytoplankton important in the diet of abalone farmed at Yumbah (McShane Changes in the surface mucus layer observed in H. laevigata may be caused by changes in: 2017). Dredge spoil presents a risk to the viability of diatoms in the subtidal environment of Smith Bay by • Viscosity of the mucus (dilution) 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): • Reduced production of mucus • Degradation by enzymes, or • Diatoms are only important in diet of early stages of abalone; • Increased loss of mucus. • Algae exhibit a high level of plasticity in their adaptation to ambient light environments allowing We suspect that the breakdown of their mucus barrier and damage to the epithelium of the gills and skin, may adjustments to adverse light climate; lead to electrolyte disturbances and dehydration – and death ensues. • Changes in turbidity at shallow depths are small and will not have an adverse effect on diatom production; The sick abalone all had inflammation and oedema, varying from moderate to marked, varying between organs • Conditions that would promote harmful algal blooms (red tides) are not likely to occur in Smith Bay. in its severity. I did not see any clear evidence of bacteria such as vibrio or flavobacteria. In fact, advice from Yumbah KI’s hatchery manager reveals that diatoms are important dietary supplements Similar observations were recorded by Dr Celia Hooper (letter to David Connell 17th November 2016): 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, Normal gills were apparent from specimens sampled for histopathological examination 5 months after the selectively absorb blue light negatively impacting on diatom growth (Prieur and Sathyendranath 1981). storm event (February 2017): I examined abalone from KIAB sent to Gribbles Veterinary Pathology on 6th Although diatoms have accessory pigments that can harvest other spectral components e.g. green light (Vesk September, following severe storm weather. 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 Following the poor weather, abalone from this property became ill with puffy heads, swollen feet, difficulty al. 2019). 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. 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 Upon examination, these affected abalone had inflammation throughout, but more severe in the muscle of the such as dinoflagellates including red tide species, may be favoured over diatoms in suboptimal light regimes foot and head regions. The inflammation in the head probably reflects increased silt in the environment of these (low- or poor-quality light) (Ault 2000; Park et al. 2001; Smayda and Reynolds 2001; Peperzak 2003, Shikata et animals, including increased silt in the mouth. 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 Further disturbance of the sea bed in the vicinity of this farm is likely to have a deleterious effect on the abalone maintenance dredging activities will have a deleterious effect on those benthic diatoms favoured in the diet of and oyster farms in this location. abalone farmed at Yumbah. Further to this, changes to light climate in Smith Bay coupled with the potential Dr Hooper and Dr Loh are both experts on the pathology of abalone (Hooper et al. 2007). The evidence introduction of exotic dinoflagellates (via ballast water) increases the risk harmful algal blooms (e.g. Park et al. presented in the two histopathological reports indicate conclusively sediment is significantly detrimental to 2001, see also Dowsett et al. 2011 for H. laevigata). abalone.

Page 10 of 17 Page 11 of 17 Global Marine Resource Management Pty Ltd Global Marine Resource Management Pty Ltd There is a significant risk of introduction of harmful marine dinoflagellates from ballast water of vessels using There is also potential for ongoing loss of seagrass through erosion of the seafloor adjacent to the dredged basin the proposed seaport (Hewitt and Campbell 2019). Although high seas ballast water exchange (as required (Appendix I1, page 23). under existing biosecurity protocols) can reduce numbers of toxic dinoflagellates, it is generally ineffective at These mitigation of these risks to the subtidal flora and fauna of Smith Bay have not been adequately described reducing ballast sediment which can house cysts of harmful algal species (Ruiz and Reid 2017). The risk of in the draft EIS. On the contrary as noted by Wiltshire and Brook (2018): the ecological significance of the loss of harmful algal blooms will also be enhanced by reduction of nearshore currents following construction of a 250 this habitat, and in particular the seagrass communities, would be minor as there is vast amount of similar m causeway in Smith Bay. The draft EIS indicates that reduction in current speed at Yumbah’s westerly habitat within Smith Bay, at Emu Bay and elsewhere along the north coast (Appendix I1, page 27). 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). 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 EXTRANEOUS LIGHT IMPACTS ON ABALONE this study, the overall density of pipefish within the seagrass meadows was found to be approximately one per 20 Potential impacts of extraneous light from the seaport operation on Yumbah abalone farm production are square metres (Page 25 of Appendix K). dismissed in the Draft EIS. Light has a demonstrable and adverse effect on feeding and growth of abalone. Thus, applying this information from the draft EIS, removing 10 ha of seagrass during construction of the Abalone are nocturnal feeders and feeding rates decrease in the presence of white (full spectrum) light (Garcia- seaport will potentially destroy more than 5,000 listed syngnathids. Yet this is considerably understated Esquivel et al. 2007, Gao et al. 2016, Xiaolong et al. 2016). These published findings are consistent with the (without supporting evidence) in the draft EIS: the loss of a very small amount of pipefish habitat and potentially observations of Yumbah’s hatchery manager and the practice of reducing light to optimise feeding and growth some pipefish during construction would have a negligible effect on their overall population in the Smith Bay in the farming of abalone. Thus, extraneous light from the proposed seaport will have a negative effect on area (Appendix I1, page 28). feeding and growth of abalone farmed at Yumbah. REFERENCES MARINE ECOLOGICAL IMPACTS: SEAGRASSES AND LISTED MARINE SPECIES Allen, V.J., Marsden, I.D., Ragg, N.L.C., and Gieseg, S. (2006). The effects of tactile stimulants on feeding, The proposed seaport construction will have a substantial impact on the ecology of the nearshore sublittoral growth, behaviour, and meat quality of cultured Blackfoot abalone, Haliotis iris. Aquaculture. 257, 294-308. 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 ANZECC (2000). Australian and New Zealand Guidelines for Fresh and Marine Water Quality. Volume 1 (the the most obvious impact. Similarly, construction and operation of the proposed seaport will increase turbidity Guidelines). National Water Quality Management Strategy Paper No. 4. Australian and New Zealand and sedimentation in Smith Bay and this will have a detrimental effect on adjacent seagrass communities Environment and Conservation Council, Agriculture and Resource Management Council of Australia and New (Westphalen et al. 2004). Zealand. From the Summary of Appendix I1 (Wiltshire and Brooks 2018): The marine listed Stipecampus cristatus (ring- Ault, T. R. (2000). Vertical migration by the marine dinoflagellate Prorocentrum triestinum maximises backed pipefish) was found in Posidonia habitat in the area that would be dredged and is therefore at credible photosynthetic yield. Oecologica 125, 466-457. 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 Baldisserotto, C., Sabia, A., Ferroni, L., and Pancaldi, S. (2019). Biological aspects and biotechnological potential in the area. The ring-backed pipefish was the only syngnathid observed in visual surveys of Smith Bay but the of marine diatoms in relation to different light regimes. World Journal of Microbiology and Biotechnology 35, 1- draft EIS lists another 15 species that may be found in Smith Bay (Appendix I1 pp 21,22). 9. Dredging of the wharf pocket and approaches would result in the loss of some seagrass habitat and the potential Blott, S. J. and Pye K. (2012). Particle size scales and classification of sediment types based on particle size loss of some pipefish. Although pipefish have limited mobility, some are likely to be able to move a short distributions: review and recommended procedures. Sedimentology 59, 2071-2096. 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 Bolam, S. G. and Rees, H. L. (2003). Minimising impacts of maintenance dredged material disposal in the coastal similar density of pipefish (Appendix I1 page 26). environment: a habitat approach. Environmental Management 32, 171-188. 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 Bray, R. N. (2008). Environmental aspects of dredging. Taylor and Francis, London. through direct physical disturbance of biota inhabiting the sea floor, but also through the effects of the dispersed Cao, S., Wang, J., and Chen, D. (2013). Settlement and cell division of diatom Navicula can be influenced by light sediment plume generated during dredging. These effects can include smothering of surrounding biota, light of various qualities and intensities. Journal of Basic Microbiology 53, 884-894. 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). Charles, F., Lantoine, F., Brugel, S., Chretiennot-Dinet, M., Quiroga, I., and Riviere, B. (2005). Seasonal survey of Similar secondary impacts on marine communities may occur during construction of the causeway, from re- the phytoplankton biomass, composition and production in a littoral NW Mediterranean site, with special suspension of exposed sediments during storms, from winnowing of sediments during shipping operations and emphasis on the picoplanktonic contribution. Estuarine, Coastal and Shelf Science 65, 199-212. from sediment run-off from the on-shore construction site.

Page 12 of 17 Page 13 of 17 Global Marine Resource Management Pty Ltd Global Marine Resource Management Pty Ltd There is a significant risk of introduction of harmful marine dinoflagellates from ballast water of vessels using There is also potential for ongoing loss of seagrass through erosion of the seafloor adjacent to the dredged basin the proposed seaport (Hewitt and Campbell 2019). Although high seas ballast water exchange (as required (Appendix I1, page 23). under existing biosecurity protocols) can reduce numbers of toxic dinoflagellates, it is generally ineffective at These mitigation of these risks to the subtidal flora and fauna of Smith Bay have not been adequately described reducing ballast sediment which can house cysts of harmful algal species (Ruiz and Reid 2017). The risk of in the draft EIS. On the contrary as noted by Wiltshire and Brook (2018): the ecological significance of the loss of harmful algal blooms will also be enhanced by reduction of nearshore currents following construction of a 250 this habitat, and in particular the seagrass communities, would be minor as there is vast amount of similar m causeway in Smith Bay. The draft EIS indicates that reduction in current speed at Yumbah’s westerly habitat within Smith Bay, at Emu Bay and elsewhere along the north coast (Appendix I1, page 27). 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). 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 EXTRANEOUS LIGHT IMPACTS ON ABALONE this study, the overall density of pipefish within the seagrass meadows was found to be approximately one per 20 Potential impacts of extraneous light from the seaport operation on Yumbah abalone farm production are square metres (Page 25 of Appendix K). dismissed in the Draft EIS. Light has a demonstrable and adverse effect on feeding and growth of abalone. Thus, applying this information from the draft EIS, removing 10 ha of seagrass during construction of the Abalone are nocturnal feeders and feeding rates decrease in the presence of white (full spectrum) light (Garcia- seaport will potentially destroy more than 5,000 listed syngnathids. Yet this is considerably understated Esquivel et al. 2007, Gao et al. 2016, Xiaolong et al. 2016). These published findings are consistent with the (without supporting evidence) in the draft EIS: the loss of a very small amount of pipefish habitat and potentially observations of Yumbah’s hatchery manager and the practice of reducing light to optimise feeding and growth some pipefish during construction would have a negligible effect on their overall population in the Smith Bay in the farming of abalone. Thus, extraneous light from the proposed seaport will have a negative effect on area (Appendix I1, page 28). feeding and growth of abalone farmed at Yumbah. REFERENCES MARINE ECOLOGICAL IMPACTS: SEAGRASSES AND LISTED MARINE SPECIES Allen, V.J., Marsden, I.D., Ragg, N.L.C., and Gieseg, S. (2006). The effects of tactile stimulants on feeding, The proposed seaport construction will have a substantial impact on the ecology of the nearshore sublittoral growth, behaviour, and meat quality of cultured Blackfoot abalone, Haliotis iris. Aquaculture. 257, 294-308. 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 ANZECC (2000). Australian and New Zealand Guidelines for Fresh and Marine Water Quality. Volume 1 (the the most obvious impact. Similarly, construction and operation of the proposed seaport will increase turbidity Guidelines). National Water Quality Management Strategy Paper No. 4. Australian and New Zealand and sedimentation in Smith Bay and this will have a detrimental effect on adjacent seagrass communities Environment and Conservation Council, Agriculture and Resource Management Council of Australia and New (Westphalen et al. 2004). Zealand. From the Summary of Appendix I1 (Wiltshire and Brooks 2018): The marine listed Stipecampus cristatus (ring- Ault, T. R. (2000). Vertical migration by the marine dinoflagellate Prorocentrum triestinum maximises backed pipefish) was found in Posidonia habitat in the area that would be dredged and is therefore at credible photosynthetic yield. Oecologica 125, 466-457. 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 Baldisserotto, C., Sabia, A., Ferroni, L., and Pancaldi, S. (2019). Biological aspects and biotechnological potential in the area. The ring-backed pipefish was the only syngnathid observed in visual surveys of Smith Bay but the of marine diatoms in relation to different light regimes. World Journal of Microbiology and Biotechnology 35, 1- draft EIS lists another 15 species that may be found in Smith Bay (Appendix I1 pp 21,22). 9. Dredging of the wharf pocket and approaches would result in the loss of some seagrass habitat and the potential Blott, S. J. and Pye K. (2012). Particle size scales and classification of sediment types based on particle size loss of some pipefish. Although pipefish have limited mobility, some are likely to be able to move a short distributions: review and recommended procedures. Sedimentology 59, 2071-2096. 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 Bolam, S. G. and Rees, H. L. (2003). Minimising impacts of maintenance dredged material disposal in the coastal similar density of pipefish (Appendix I1 page 26). environment: a habitat approach. Environmental Management 32, 171-188. 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 Bray, R. N. (2008). Environmental aspects of dredging. Taylor and Francis, London. through direct physical disturbance of biota inhabiting the sea floor, but also through the effects of the dispersed Cao, S., Wang, J., and Chen, D. (2013). Settlement and cell division of diatom Navicula can be influenced by light sediment plume generated during dredging. These effects can include smothering of surrounding biota, light of various qualities and intensities. Journal of Basic Microbiology 53, 884-894. 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). Charles, F., Lantoine, F., Brugel, S., Chretiennot-Dinet, M., Quiroga, I., and Riviere, B. (2005). Seasonal survey of Similar secondary impacts on marine communities may occur during construction of the causeway, from re- the phytoplankton biomass, composition and production in a littoral NW Mediterranean site, with special suspension of exposed sediments during storms, from winnowing of sediments during shipping operations and emphasis on the picoplanktonic contribution. Estuarine, Coastal and Shelf Science 65, 199-212. from sediment run-off from the on-shore construction site.

Page 12 of 17 Page 13 of 17 Global Marine Resource Management Pty Ltd Global Marine Resource Management Pty Ltd Cheshire, A. (2018). Assessment of risks and mitigation strategies to the Yumbah Aquaculture Facility from the KIPT (2019). Smith Bay Wharf Draft Environmental Impact Statements. Prepared for Kangaroo Island Plantation Construction and Operation of the proposed KI Seaport. Prepared for Kangaroo Island Plantation Timber Pty Timbers by Environmental Projects January 2019. Ltd. 24 September 2018. Lawrenz, E., and Richardson, T.L. (2017). Differential effects of changes in spectral irradiance on Cheshire, A.C. and Miller, D.J. (1999). The impact of sand dredging on Benthic Community Structure at Port photoacclimation, primary productivity and growth in Rhodomonas salina (Cryptophyceae) and Skeletonema Stanvac Dredge Site: Final report on the results of surveys 1992 to 1999. Report to the Coast Protection Board, costatum (Bacillariophyceae) in simulated blackwater environments. Journal of Phycology 53, 1241-1254. South Australian Department of Environment and Natural Resources (as cited in Appendix I1 of KIPT (2019)). Lee, K.S. (2008). The effects of suspended solids on the mortality and the glycogen content of abalone Haliotis Chew, C.A., Hepburn, C.D., and Stephenson, W. (2013). Low-level sedimentation modifies behaviour in juvenile discus hannai. Journal of the Korean Society of Marine Environment and Safety 14, 183-187. English abstract Haliotis iris and may affect their vulnerability to predation. Marine Biology 160, 1213-1221. and data tables only.

Chung, E.Y., Shin, Y.K., and Lee J.H. (1993). Effects of silt and clay on respiration and mortality of the abalone, Lockhart, J. (2013). Blue light checkpoint: how blue light controls the onset of cell division in diatoms. The Plant Nordotis discus. Korean Journal of Malacology 9, 23-29. Cell 25, 1.

DAC (2017). Guidelines for the preparation of an Environmental Impact Statement: Deep water port facility at McShane P.E. (2017). Impacts of a proposed wharf development on the marine environment and an existing Smith Bay, Kangaroo Island. Proposal by Kangaroo Island Plantation Timbers Ltd. Published by the South abalone aquaculture facility, Smith Bay, Kangaroo Island, South Australia. Global Marine Resource Management Australian Development Assessment Commission (DAC) June 2017. 36pp. Pty Ltd. 19 pp.

Department of Planning, Transport and Infrastructure (2015). Development Plan Kangaroo Island Council. McShane, P.E., Gorfine, H., and Knuckey, I.A. (1994). Factors influencing food selection in the abalone Haliotis Government of South Australia rubra (Mollusca: Gastropoda). Journal of Experimental Marine Biology and Ecology 176, 27-37. http://www.dpti.sa.gov.au/__data/assets/pdf_file/0009/249975/Kangaroo_Island_Council_Development_Plan. pdf 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. 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 Mercado, J.M., Sanchez-Saavedra, M.P., Correa-Reyes, G., Lubian, L., Montero, O., Figueroa, F.L. (2004). Blue Alexandrium minutum in Australian greenlip abalone, Haliotis laevigata. Toxicon 58, 101-111, light effect on growth, light absorption characteristics and photosynthesis of five benthic diatom strains. Aquatic Botany 78, 265-277. Essink, K. (1999). Ecological effects of dumping of dredged sediments: options for management. Journal of Coastal Conservation 5, 69-80. 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. 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. Moore, P.G. (1977). Inorganic particulate suspensions in the sea and their effects on marine animals. Oceanography Marine Biology Annual Review 15, 225-363. 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 Mutshinda, C.M., Finkel, Z.V., and Irwin, A.J. (2013). Which environmental factors control phytoplankton balanced diet. Aquaculture 262, 129-141. populations? A Bayesian variable selection approach. Ecological Modelling 269, 1-8.

Gibbs, R. J. (1977). Clay mineral segregation in the marine environment. Journal of Sedimentary Petrology 47, Naylor, J.R. and McShane, P.E. (1997). Post settlement survival of abalone (Haliotis iris, H. australis) in turbulent 237-243. flows. Molluscan Research 18, 227-232.

Hewitt, C.L. and Campbell, M.L. (2019). Smith Bay Wharf Draft Environmental Impact Statement. Marine Park, J.G., Jeong, M.K., Lee, J.A., Cho, K-J, Kwon, O-S. (2001). Diurnal vertical migration of a harmful Biosecurity Review. Report for Yumbah Aquaculture. Harry Butler Institute, Murdoch University dinoflagellate, Cochlodinium polykrikoides (Dinophyceae) during a red tide in coastal waters of Namhae Island, Korea. Phycologia 40, 292-297. 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 Peperzak, L., (2003). Climate change and harmful algal blooms in the North Sea. Acta Oecologica 24, S139-S144. Immunology 22, 363-379. Phillips, N. E. and Shima, J. S. (2006). Differential effects of suspended sediments on larval survival and Humphrey, G. F. (1977). The effect of the spectral composition of light on the growth, pigments, and settlement of New Zealand urchins Evechinus chloroticus and abalone Haliotis iris. Marine Ecology Progress photosynthetic rate of unicellular marine algae. Journal of Experimental Marine Biology and Ecology. 66, 69-67. Series 314, 149-158.

Kinloch, M.A., Brock, D.J., Kirkman, H., and Laperousaz, T. (2007). Seagrass Biodiversity on Kangaroo Island. KI Prieur, L., and Sathyendranath, S. (1981). An optical classification of coastal and oceanic waters based on the NRM Board Coast and Marine Program Report No. CMP07/004. specific spectral absorption curves of phytoplankton pigments, dissolved organic matter and other particulate materials. Limnology and Oceanography 26, 671-689.

Page 14 of 17 Page 15 of 17 Global Marine Resource Management Pty Ltd Global Marine Resource Management Pty Ltd Cheshire, A. (2018). Assessment of risks and mitigation strategies to the Yumbah Aquaculture Facility from the KIPT (2019). Smith Bay Wharf Draft Environmental Impact Statements. Prepared for Kangaroo Island Plantation Construction and Operation of the proposed KI Seaport. Prepared for Kangaroo Island Plantation Timber Pty Timbers by Environmental Projects January 2019. Ltd. 24 September 2018. Lawrenz, E., and Richardson, T.L. (2017). Differential effects of changes in spectral irradiance on Cheshire, A.C. and Miller, D.J. (1999). The impact of sand dredging on Benthic Community Structure at Port photoacclimation, primary productivity and growth in Rhodomonas salina (Cryptophyceae) and Skeletonema Stanvac Dredge Site: Final report on the results of surveys 1992 to 1999. Report to the Coast Protection Board, costatum (Bacillariophyceae) in simulated blackwater environments. Journal of Phycology 53, 1241-1254. South Australian Department of Environment and Natural Resources (as cited in Appendix I1 of KIPT (2019)). Lee, K.S. (2008). The effects of suspended solids on the mortality and the glycogen content of abalone Haliotis Chew, C.A., Hepburn, C.D., and Stephenson, W. (2013). Low-level sedimentation modifies behaviour in juvenile discus hannai. Journal of the Korean Society of Marine Environment and Safety 14, 183-187. English abstract Haliotis iris and may affect their vulnerability to predation. Marine Biology 160, 1213-1221. and data tables only.

Page 14 of 17 Page 15 of 17 Global Marine Resource Management Pty Ltd Global Marine Resource Management Pty Ltd Ragg, N.L.C., and H.H. Taylor (2006). Oxygen uptake, diffusion limitation, and diffusing capacity of the Wanichanon, C., Laimek, P., Linthong, V., Sretarugsa, P., Kruatrachue, M., Upatham, E.S., Poomtong, T., and bipectinate gills of the abalone, Haliotis iris (Mollusca: prosobranchia). Comparative Biochemistry and Sobhon, P. (2004). Histology of hypobrachial gland and gill of Haliotis asinina Linnaeus. Journal of Shellfish Physiology Part A. 143, 299-306. Research 23, 1107-1112.

Ragg, N.L.C. (2014). Fighting for breath: how does oxygen exchange limit abalone performance in a changing Wang, G.J, Xie, J., De-guang, Y.U., Lan, W.U., and Zhao-ying, H.U. (2007). Physiological responses of abalone coastal environment? In Proceedings of the 6th National Trans Tasman Abalone Convention. Queenstown, New Haliotis diversicolor to suspended sediment stress. Journal of Dalian Ocean University 22, 352-356. Zealand 6th-8th August 2014. Westphalen, G., Collings, G., Wear, R., Fernandes, M., Bryars, S., and Cheshire, A. (2004). A review of seagrass Ruiz, G.M. and Reid, D.F. (2007). Current state of understanding about the effectiveness of ballast water loss on the Adelaide metropolitan coastline. ACWS Technical Report No. 2. Prepared for the Adelaide Coastal exchange (BWE) in reducing aquatic nonindigenous species (ANS) introductions t the Great Lakes basin and Waters Study Steering Committee. South Australian Research and Development Institute (Aquatic Sciences) Chesapeake Bay, USA: Synthesis and analysis of existing information. NOAA Technical Memorandum Publication No. RD04/0073. GLERL0142. GL:ERL, Ann Arbor, USA. 127 pp. Wilber, D.H. and Clarke, D.G. (2001). Biological effects of suspended sediments: A review of suspended Schellenberger Costa, B., Jungandreas, A., Jakob, T., Weisheit, W., Mittag, M. and Wilhelm, C. (2013). Blue light sediment impacts on fish and shellfish with relation to dredging activities in estuaries. North American Journal is essential for high light acclimation and photoprotection in the diatom Phaeodactylum tricornutum. Journal of of Fisheries Management 21, 855-875. Experimental Botany 64, 483-493. Wiltshire, D. and Brook, J. (2018). Smith Bay Marine Ecological Assessment. Report to Kangaroo Island Plantation Shepherd, S. A. (1973). Studies on southern Australian abalone (genus Haliotis). I. The ecology of five sympatric Timbers Pty Ltd., SEA Pty Ltd. 6th September 2018. species. Australian Journal of Marine and Freshwater Research 24, 217-257. Xiaolong, G., Mo, Z., Xian, L. Ce, S., Changbin, S. and Ying, L. (2016). Effects of LED light quality on the growth, Shikata, T., Matsunaga, S., Iseki, M., Nishide, H. Higashi, S., Kamei, Y., Yamaguchi, M., Jenkinson, I.R., and metabolism, and energy budgets of Haliotis discus discus. Aquaculture, 453, 31-39. 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. 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. 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 Yoon, S.J., and Park, G.S. (2011). Ecotoxicological effects of the increased suspended solids on marine benthic and Oceanography 60, 1251-1264. organisms. Journal of the Environmental Sciences 1383-1394.

Shikata, T., Onitsuka, G., Abe, K., Kitatsuji, S., Yufu, K., Yoshikawa, Y., Honjo, T., and Miyamura, K. 2017). Zhou, Z., Yu, R., Zhou, M. (2017). Seasonal succession of microalgal blooms from diatoms to dinoflagellates in Relationships between light environment and subsurface accumulation during the daytime in the red-tide the East China Sea: A numerical simulation study. Ecological Modelling 360, 150- 162. 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 16 of 17 Page 17 of 17 Global Marine Resource Management Pty Ltd Global Marine Resource Management Pty Ltd Ragg, N.L.C., and H.H. Taylor (2006). Oxygen uptake, diffusion limitation, and diffusing capacity of the Wanichanon, C., Laimek, P., Linthong, V., Sretarugsa, P., Kruatrachue, M., Upatham, E.S., Poomtong, T., and bipectinate gills of the abalone, Haliotis iris (Mollusca: prosobranchia). Comparative Biochemistry and Sobhon, P. (2004). Histology of hypobrachial gland and gill of Haliotis asinina Linnaeus. Journal of Shellfish Physiology Part A. 143, 299-306. Research 23, 1107-1112.

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.

Thomas, S. and Ridd, P. (2004). Review of methods to measure short time scale sediment accumulation. Marine Geology 207, 95-114.

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 16 of 17 Page 17 of 17 Global Marine Resource Management Pty Ltd Global Marine Resource Management Pty Ltd APPENDIX 3 – AUSTRALIAN ABALONE GROWERS ASSOCIATION (AAGA) SUBMISSION 2019

172 Smith Bay Wharf Environmental Impact Statement Yumbah Response 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 Minister for Planning C/- Robert Kleeman GROWERS ASSOCIATION Unit Manager Policy and Strategic Assessment Department of Planning, Transport and Infrastructure (AAGA) SUBMISSION GPO Box 1815 ADELAIDE SA 5000 2019 [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

| Page 1 of 4 to denigrate our industry. he report fails to recognie that seaports of this scale and auaculture in such immediate proimity cannot successfully coeist. or eample, Southood ibre recently abandoned its proposed oodchip eport facility near oer in asmania due to an impasse ith salmon groer assal. Should the Sea ort proposal be approed it ill set a precedent for similar emerging incompatible encroachments to auaculture around the country. AAGA’s opposition to the proposal is entirely based on proimity, it is simply too close. Australian abalone is highly regarded in both our domestic and eport marets as a clean, green and healthy product. Our production relies on pumping clean seaater of oceanic uality. his is a hard fought reputation and one that could be easily lost. Yumbah Kangaroo Island farm YKI relies on the South Australia nironment rotection ater uality olicy SA guidelines as set out in Australian and e ealand nironment and onseration ouncil A Agriculture and esource anagement ouncil of Australia and e ealand AA, to protect the precious marine resource that abalone farms depend on. states “On the basis of these findings it is concluded that the construction and operation of the he proposed seaport poses an etreme ris to Yumbah Kangaroo Island farm YKI due to its immediate proimity, raising threats to biosecurity, pollution, eleation of fine settlement loading the performance of the Yumbah Smith Bay abalone farm.” beyond the SA and A standards, airborne pollution, sadust and dust, artificial lighting and interruptions to the eisting coastal processes ithin Smiths Bay. • • essel born Biohaards and ollution. • he potential biosecurity threats to the marine enironment and auaculture from cargo hold ballast ater, hullclinging or hullfouling) and ships’ bilge water is understated in the EIS. Ballast water may • contain oil, bacteria, iruses, algae and other marine organisms including the oftenmicroscopic egg, embryo or immature laral stage of marine inertebrates. Ballast ater taen from one ecological one then discharged it into another can introduce inasie species and eotic diseases. ullclinging can also transport marine organisms and pathogens beteen locations. Bioinasion is one of greatest threats facing the world’s oceans today, once established these pests are almost impossible to eradicate in the marine enironment ith catastrophic conseuences. he Smiths Bay Seaport ould place the Yumbah KI farm directly in the firing line of these threats greatly increasing the biosecurity ris to the farm. Ship’s bilge water can contain oil, detergents, chemicals and more. he AAGA shares YKI’s further concerns regarding dust, noise and light. IS does not refer to any riss from bilge ater and is oid of any reference to its management. It • should be noted also that YKI lie most abalone farm has approal and intentions of culturing other species under a multitrophic auaculture model. o consideration has been applied to ris the report • poses to any other species the farm may gro in the future. • otal Suspended Solids SS. he K IS report neglects to properly describe the impacts of eleated SS and sediment resuspension that ould be created during construction, maintenance dredging and operation of the seaport. he report attempts euate sand particles ith silt. hereas abalone are ell adapted to the rigors of high energy marine enironments and the sand present there they are much less tolerant of fine silts and clays and the high bacteria loads typically associated ith such sediments. cShane

| Page 2 of 4 | Page 3 of 4 to denigrate our industry. he report fails to recognie that seaports of this scale and auaculture in such immediate proimity cannot successfully coeist. or eample, Southood ibre recently abandoned its proposed oodchip eport facility near oer in asmania due to an impasse ith salmon groer assal. Should the Sea ort proposal be approed it ill set a precedent for similar emerging incompatible encroachments to auaculture around the country. AAGA’s opposition to the proposal is entirely based on proimity, it is simply too close. Australian abalone is highly regarded in both our domestic and eport marets as a clean, green and healthy product. Our production relies on pumping clean seaater of oceanic uality. his is a hard fought reputation and one that could be easily lost. Yumbah Kangaroo Island farm YKI relies on the South Australia nironment rotection ater uality olicy SA guidelines as set out in Australian and e ealand nironment and onseration ouncil A Agriculture and esource anagement ouncil of Australia and e ealand AA, to protect the precious marine resource that abalone farms depend on. states “On the basis of these findings it is concluded that the construction and operation of the he proposed seaport poses an etreme ris to Yumbah Kangaroo Island farm YKI due to its immediate proimity, raising threats to biosecurity, pollution, eleation of fine settlement loading the performance of the Yumbah Smith Bay abalone farm.” beyond the SA and A standards, airborne pollution, sadust and dust, artificial lighting and interruptions to the eisting coastal processes ithin Smiths Bay. • • essel born Biohaards and ollution. • he potential biosecurity threats to the marine enironment and auaculture from cargo hold ballast ater, hullclinging or hullfouling) and ships’ bilge water is understated in the EIS. Ballast water may • contain oil, bacteria, iruses, algae and other marine organisms including the oftenmicroscopic egg, embryo or immature laral stage of marine inertebrates. Ballast ater taen from one ecological one then discharged it into another can introduce inasie species and eotic diseases. ullclinging can also transport marine organisms and pathogens beteen locations. Bioinasion is one of greatest threats facing the world’s oceans today, once established these pests are almost impossible to eradicate in the marine enironment ith catastrophic conseuences. he Smiths Bay Seaport ould place the Yumbah KI farm directly in the firing line of these threats greatly increasing the biosecurity ris to the farm. Ship’s bilge water can contain oil, detergents, chemicals and more. he AAGA shares YKI’s further concerns regarding dust, noise and light. IS does not refer to any riss from bilge ater and is oid of any reference to its management. It • should be noted also that YKI lie most abalone farm has approal and intentions of culturing other species under a multitrophic auaculture model. o consideration has been applied to ris the report • poses to any other species the farm may gro in the future. • otal Suspended Solids SS. he K IS report neglects to properly describe the impacts of eleated SS and sediment resuspension that ould be created during construction, maintenance dredging and operation of the seaport. he report attempts euate sand particles ith silt. hereas abalone are ell adapted to the rigors of high energy marine enironments and the sand present there they are much less tolerant of fine silts and clays and the high bacteria loads typically associated ith such sediments. cShane

| Page 2 of 4 | Page 3 of 4 epanding or actiely seeing epansion opportunities. he I site has aailable land and licenses to epand to more than double its current capacity, creating significantly more obs and inestment to Kangaroo Island. I am advised that this expansion would be already underway if there wasn’t a proposed seaport threatening its ongoing eistence.

AAGA appreciates the effort hae undertaen to gain approals for their proect. It is most unfortunate that they chose such an inappropriate site and failed to consult properly with their APPENDIX 4 – immediate neighbor. YKI should not be forced to bear the cost of KPT’s poor decision making. MARINE BIOSECURITY REVIEW ours sincerely Hewitt & Campbell 2019

icholas Saa

Eecutie fficer

eferences

heshire, A. ). Assessment of riss and mitigation strategies to the umbah Auaculture acility from the onstruction and peration of the proposed I Seaport. repared for angaroo Island lantation imber ty td. September .

cShane, . ). Smith Bay harf. esponse to raft Enironmental Impact Statement. angaroo Island lantation imbers.

| Page 4 of 4 APPENDIX 4 – MARINE BIOSECURITY REVIEW Hewitt & Campbell 2019

Smith Bay Wharf Environmental Impact Statement Yumbah Response 177 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 Smith Bay Wharf Draft Environmental Impact 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 Statement in Appendix A and the information provided in Appendix I, but also including information provided in other locations in the SBW Draft EIS (2019).

Marine Biosecurity Review 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 Prepared by: 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 Professor Chad L Hewitt and Professor Marnie L Campbell determine a priority list of invasive marine species (DAWR 2015). Additionally they note that “[a]ll Harry Butler Institute, Murdoch University, Murdoch, Western Australia 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 Page | 1

178 Smith Bay Wharf Environmental Impact Statement Yumbah Response REVIEW OF MARINE BIOSECURITY ASPECTS OF SMITH BAY WHARF

The mitigation measures as stated are unlikely to be adequate to mitigate risk during the construction phase.

Smith Bay Wharf Environmental Impact Statement Yumbah Response 179 load (eg Ruiz and Reid 2007). Additionally it is unlikely that domestic movements will be able Ballast water exchange is a risk minimisation strategy, and does not provide a zero risk to undertake ballast exchange in the “high seas” and indeed are not required to under scenario. For this reason International Convention for the Control and Management of Ships' international or Commonwealth legislation. Therefore this mitigation is unlikely to be Ballast Water and Sediments (aka BWM; IMO 2004) explicitly highlighted that ballast applied unless explicit agreements and requirements are made. exchange was an interim measure, with a focus on developing ballast water treatment • Biofouling on domestic vessels, particularly in niche areas or on slow moving vessels (such as technologies that would achieve much more rigorous standards as highlighted in the dumb barges and dredges) can transfer mature communities resulting in the spawning or Convention, and now in the Biosecurity Act. 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.

Page | 2 Page | 3

load (eg Ruiz and Reid 2007). Additionally it is unlikely that domestic movements will be able Ballast water exchange is a risk minimisation strategy, and does not provide a zero risk to undertake ballast exchange in the “high seas” and indeed are not required to under scenario. For this reason International Convention for the Control and Management of Ships' international or Commonwealth legislation. Therefore this mitigation is unlikely to be Ballast Water and Sediments (aka BWM; IMO 2004) explicitly highlighted that ballast applied unless explicit agreements and requirements are made. exchange was an interim measure, with a focus on developing ballast water treatment • Biofouling on domestic vessels, particularly in niche areas or on slow moving vessels (such as technologies that would achieve much more rigorous standards as highlighted in the dumb barges and dredges) can transfer mature communities resulting in the spawning or Convention, and now in the Biosecurity Act. 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 mitigation measures as stated are unlikely to be adequate to mitigate risk during the operation phase.

Page | 2 Page | 3

Table 1: Introduced marine species relevant to Smith Bay from Smith Bay Wharf Draft EIS (2019), emended to include those species known from the Northwest Pacific bioregion. Note highlighted sections in yellow represent mis-alignment to phyla in the original table.

Group Species Common name National PIRSA Declared Recorded Known priority concern noxious on from NW Kangaroo Pacific Island Bioregion Ascidians Ascidiella aspersa European sea squirt Y Ascidians Botrylloides leachi Y Y Ascidians Botryllus schlosseri Y Y Ascidians Ciona intestinalis Vase tunicate M Y Y Ascidians Didemnum spp (exotic strains only) Y Ascidians Styela clava M Y Ascidians Styela plicata Y Y Macroalgae Bryopsis plumosa Y Y Bryozoans Bugulla flabellata M Y Bryozoans Bugula neritina M Y Y Bryozoans Schizoporella errata M Bryozoans Tricellaria occidentalis M Y Bryozoans Watersipora arcuata M Y Bryozoans Watersipora subtorquata M Y Crustaceans Balanus eburneus M Y Crustaceans Balanus reticulatus M Y Crustaceans Balanus improvisus M Y Y Crustaceans Megabalanus rosa M Y Crustaceans Megabalanus tintinnabulum M Y Ctenophore Mnemiopsis leidyi comb jelly Y Polychaetes Sabella spallanzanii European fan worm M Y Y Y Crustaceans Carcinus maenas European shore crab M Y Y Y Crustaceans Charybdis japonica lady crab M Y Y Crustaceans Eriocheir sinensis Chinese mitten crab M Y Y Y Crustaceans Hemigrapsus sanguineus Japanese shore crab M Y Y Crustaceans Hemigrapsus takanoi/penicillatus Pacific crab Y Y Page | 4

Crustaceans Pseudodiaptomus marinus (a copepod) M Y Echinoderms Asterias amurensis Northern Pacific sea star M Y Y Y Fish Neogobius melanostomus round goby M Fish Siganus rivulatus rabbit fish Y Fish Tridentiger bifasciatus shimofuri goby M Y Macroalgae Caulerpa cylindracea (green macroalga) Y Macroalgae Caulerpa taxifolia (green macroalga) Y Y Y Macroalgae Cladophora prolifera (green macroalga) Y Y Macroalgae Codium fragile ssp tomentosoides (green macroalga) Y Y Macroalgae Grateloupia turuturu (red macroalga) Y Y Macroalgae Hincksia sandriana (brown filamentous macroalga) Y Y Macroalgae Polysiphonia brodiei (red macroalga) M Y Y Macroalgae Sargassum muticum Asian seaweed Y Y Macroalgae Ulva lactuca Y Y Macroalgae Ulva taeniata Y Y Macroalgae Undaria pinnatifida Japanese seaweed M Y Y Y Microalgae Alexandrium catenella Y Y Microalgae Alexandrium minutum H Y Y Microalgae Alexandrium tamarense Y Y Microalgae Gymnodinium catenatum H Y Y Microalgae Heterosigma akashiwo Y Y Molluscs Corbula amurensis Asian clam M Y Y Molluscs Crassostrea gigas Pacific oyster M Y Y Y Molluscs Crepidula fornicata American slipper limpet Y Molluscs Ensis directus jack-knife clam Y Molluscs Limnoperna fortunei golden clam M Y Molluscs Maoricolpus roseus New Zealand screwshell M Y Y Molluscs Musculista senhousia Asian date mussel M Y Y Molluscs Mya arenaria soft shell clam Y Molluscs Mytilopsis sallei black-striped mussel M Y Y Molluscs Perna perna brown mussel Y Molluscs Perna viridis Asian green mussel H Y Y Y Molluscs Pinctada albina sugillata pearl oyster Y Page | 5

Molluscs Rapana venosa rapa whelk Y Y Molluscs Varicorbula gibba European clam Y Polychaetes Hydroides ezoensis M Y Polychaetes Hydroides sanctaecrucis M Y Polychaetes Marenselleria spp. red-gilled mudworm Y

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Kangaroo Island) Kangaroo to (specifically a Australi in arriving of likelihood higher a have now would species These globally. introduced been have Korea) Japan, (China, Pacific Northwest the to native species numerous that noted be also It should invasibility of the already established pests. Of particular concern to abalone farming farming abalone to concern particular Of pests. established already the of invasibility the enhance may material genetic novel potentially and additional of influx the Island, Kangaroo on detected been already have PIRSA) by or Commonwealth the by (ie either concern of species several that noted is While it There is some concern with the exclusion of species considered “[e] considered species of exclusion the with concern some is There vessels. of hulls the on present in species Additional risks associated with mature biofouling communities incl communities biofouling mature with associated risks Additional hic environment at Smith Bay Smith at environment hic oceanograp the in establish to unlikely considered

to fails EIS the that find We environment and to Yumbah Yumbah to and environment • • • • • • • • •

Undaria pinnatifida, pinnatifida, Undaria include fo include for aspectdominance abalone’s with native algal sources. food distribution at Kangaroo Island. Kangaroo at distribution and population the enhance may Adelaide Port with linked activity Increased facilities. aquaculture Codium fragile ssp fragile Codium worm, fan European The Asterias amurensis, amurensis, Asterias shellfish. the of feeding and movement the hindering and drag enhanced to leading the shells be become concentrated as a consequence of the causeway. The causeway. the of consequence a as concentrated become be microalga forming bloom for conditions optimal create will temperature water increasing with coupled formation bloom and establishment of likelihood the enhance may development, port with associated conditions environmental changing the with combined material, new of addition The River. American and Cove Western Cove, , which is already known already is which , catenatum Gymnodinium microalga, forming bloom toxic, The overseas. and Australia in problem oyster ‘feral’ the to contributed has and documented well is been through intentional movements for aquaculture, the transport by commercial and recreational ves recreational and commercial by transport the aquaculture, for movements intentional through been has transfer global of mechanism primary its While thrusters. and shaft, propeller propeller, the including Crassostrea gigas Crassostrea oyster, Pacific The

focused recreational on vessels and High Value Areas. primarily measures, independent undertaken have Territories and States several and risks, biofouling inter only are there present At material. of dislodgment accidental or spawning the in resulting communities mature transfer can docking), dry previous the during repainted not represent threatscoastal to waters, particularly Alexandrium environment. Bay Smith the in establishment particularly harbours, estuaries and (GISD lagoons 2017) Toxic dinoflagellates in the genus Alexandrium genus the in dinoflagellates Toxic Biofouling o Biofouling ballast sediments, particularly for the cysts of toxic dinoflagellates. dinoflagellates. toxic of cysts the for particularly sediments, ballast with associated risks the reducing at poor is exchange water ballast phase, Operational the in noted As

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f commercial f tomentosoides the Northern Pacific Seastar, which c which Seastar, Pacific Northern the sufficiently sufficiently the Japanese kelp, which could settle on shells and enhance drag, as well as compete compete as well as drag, enhance and shells on settle could which kelp, Japanese the

in Smith Bay KI ’s interests.

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national guidelines mitigate to guidelines national ” : be would ]

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from Eastern Page

sels sels | 7

Page | 6

Kangaroo Island) Kangaroo to (specifically a Australi in arriving of likelihood higher a have now would species These globally. introduced been have Korea) Japan, (China, Pacific Northwest the to native species numerous that noted be also It should invasibility of the already established pests. Of particular concern to abalone farming farming abalone to concern particular Of pests. established already the of invasibility the enhance may material genetic novel potentially and additional of influx the Island, Kangaroo on detected been already have PIRSA) by or Commonwealth the by (ie either concern of species several that noted is While it There is some concern with the exclusion of species considered “[e] considered species of exclusion the with concern some is There vessels. of hulls the on present in species incl communities biofouling mature with associated risks Additional hic environment at Smith Bay Smith at environment hic oceanograp the in establish to unlikely considered Yumbah to and environment fails to to fails EIS the that find We • • • • • • • • •

include fo include for aspectdominance abalone’s with native algal sources. food pinnatifida, Undaria distribution at Kangaroo Island. Kangaroo at distribution and population the enhance may Adelaide Port with linked activity Increased facilities. aquaculture worm, fan European The shellfish. the of feeding and movement the hindering and drag enhanced to leading the shells ssp fragile Codium Asterias amurensis, amurensis, Asterias microalga forming bloom for conditions optimal create will temperature water increasing with coupled The causeway. the of consequence a as concentrated become be formation bloom and establishment of likelihood the enhance may development, port with associated conditions environmental changing the with combined material, new of addition The River. American and Cove Western Cove, , which is already known already is which , catenatum Gymnodinium microalga, forming bloom toxic, The overseas. and Australia in problem oyster ‘feral’ the to contributed has and documented well is ves recreational and commercial by transport the aquaculture, for movements intentional through been has transfer global of mechanism primary its While thrusters. and shaft, propeller propeller, the including focused recreational on vessels and High Value Areas. primarily measures, independent undertaken have Territories and States several and risks, biofouling inter only are there present At material. of dislodgment accidental or spawning the in resulting communities mature transfer can docking), dry previous the during repainted not Crassostrea gigas Crassostrea oyster, Pacific The represent threatscoastal to waters, particularly Alexandrium environment. Bay Smith the in establishment particularly harbours, estuaries and (GISD lagoons 2017) Alexandrium genus the in dinoflagellates Toxic o Biofouling ballast sediments, particularly for the cysts of toxic dinoflagellates. dinoflagellates. toxic of cysts the for particularly sediments, ballast with associated risks the reducing at poor is exchange water ballast phase, Operational the in noted As

via residual ballast water and sediments, biofouling and e. uling intake screens and pipes and growing in tanks. in growing and pipes and screens intake uling

in Smith Bay KI ’s interests.

consider

is known to interfere with shellfish aquaculture through attachment onto onto attachment through aquaculture shellfish with interfere to known is . T

known biofouling biofouling -known well a is , 40% and drift algae will algae drift will 30-40%and may by currents reduce that ports re EIS he

the domestic and international introduction risks to the to the risks introduction international and domestic the

are stated to be “r be to stated are

to harbours, to estuarieslagoons. and restricted not but

” and therefore not represent a threat of of threat a represent not therefore and ” ould cause direct predatory mortality predatory direct cause ould

spp are widely distributed and continue to to continue and distributed widely are spp udetransfer the disease of agents parasites and xceptions that meet [those meet that xceptions

Direct effects to Yumbah KI could also also could KI Yumbah to effects Direct species particularly in niche areas of the hull the of areas inniche particularly species .

enriched sites, sites, -enriched nutrient coastal, to estricted reduced turnover and mixing of the water, water, the of mixing and turnover reduced

national guidelines mitigate to guidelines national ” : be would ]

to occur to criteria but are are but criteria toxic

from Eastern Page

sels sels | 7

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 DISEASES source for future infection. The proponents have identified two “most significant diseases” of concern, however no methodology is presented • The risk of transfer of salmonid diseases, including Anaphomyces invadans, from other locations within that suggests a rigorous process was employed to determine either the significance or the likelihood of these two Australia has not been assessed. 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). We find that the EIS fails to sufficiently consider the domestic disease and pathogen risks to Yumbah Table 2: Permitted culture species for Yumbah KI at the Smith Bay lease Aquaculture’s current and licensed interests.

Phylum Common name Genus Species Channels Tanks Lobster, Southern International movements Crustaceans Rock Jasus Edwardsii x An examination of listed Office International des Epizootics (OIE) species identifies nine notifiable diseases of marine Echinoderms Sea Urchin Heliocidaris erythrogramma x species that are known to be present in Japan or China that affect species, or congeners of species, on the Yumbah Fish Bream, Black Acanthopagrus butcheri x KI permitted species list. These include two abalone diseases; and one oyster disease; and six fish diseases (Table 3). Fish Mullaway Argyrosomus Japonicas x Additionally, a cursory examination of the literature for disease agents and mortality events in aquaculture facilities, Fish Seahorse, Potbellied Hippocampus abdominalis x including abalone hatcheries or farms, in China and Japan provides an additional nine non-OIE species of concern Fish Trout, Rainbow Oncorhynchus Mykiss x (Table 3). Fish Snapper Pagrus auratus x Fish Flounder, Greenback Rhombosolea Taparina x x The full extent to which these disease agents pose a risk to Australian native species has not been investigated, Fish Trout, Brown Salmo Trutta x however consideration of transfer through ballast water (including retention after ballast water exchange), or via Fish Kingfish, Yellowtail Seriola lalandi x x infected biofouling is warranted as these represent an ignored yet significant suite of biosecurity hazards to Yumbah Fish Whiting, King George Sillaginodes Punctate x KI. Note that many are water-borne, or have unknown (eg un-researched) horizontal transfer mechanisms (not Molluscs Oyster, Pacific Crassostrea Gigas x inherited disease spread between individuals). Molluscs Scallops, Queen Equichlamys Bifrons x Molluscs Abalone Haliotis conicopora x x Molluscs Abalone Haliotis Laevigata x x We find that the EIS fails to sufficiently consider the international disease and pathogen risks to Yumbah KI’s Molluscs Abalone Haliotis Roei x x current and licensed interests. 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, Page | 8 Page | 9

The unexamined domestic risks to Yumbah KI’s licensed species (Table 2) is considerable.

Table 3: Diseases and etiological agents affecting permitted aquaculture species under Yumbah KI lease arrangements in Smith Bay. NOTE bolded disease agents are reportable and listed in OIE 2018.

Affected Etiological Disease name Survival Horizontal Vectors Japan China Korea AUS Target Reference Phylum Agent outside transmission Aquaculture host Genera affected

Mollusc Abalone Abalone Viral Unknown water borne unknown x x Haliotis OIE 2018 Herpes Virus Ganglio-neuritis (abalone) (AbHV)

Fish Infectious 1 month contact invetebrate X x Oncorhynchus; OIE 2018 Haematopoietic vectors Salmo Necrosis (IHN)

Fish Viral yes - water borne birds, x x Seriola OIE 2018 Encephalopathy "long invertebrat and time" es Retinopathy (VER) Mollusc Xenohaliotis Withering yes – water borne colonial x x Haliotis Kiryu et al 2013; californiensis Syndrome (WS) unknown ascidians (abalone) OIE 2018 Fish Aphanomyces Epizootic encysting water borne unknown x x Acanthopagrus; OIE 2018 invadans Ulcerative stage Oncorhynchus Syndrome

Fish Oncorhyncus 7-14 days water borne unknown x Oncorhynchus OIE 2018 masou virus disease (OMVD)

Fish Red Sea Bream Unknown water borne unknown x Acanthopagrus; OIE 2018 Iridoviral Seriola Disease (RSIV)

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Affected Etiological Disease name Survival Horizontal Vectors Japan China Korea AUS Target Reference Phylum Agent outside transmission Aquaculture host Genera affected Fish Viral yes - water borne fish x Oncorhynchus; OIE 2018 haemorrhagic 40hours Salmo septicaemia (VHSV)

Mollusc Ostreid Pacific Oyster Unknown contact; oysters x x Crassostrea; OIE 2018 Herpesvirus 1 Mortality possibly Ostrea microvariant Syndrome water borne (OsHV-1) (POMS)

Fish Viral Epidermal Unknown unknown unknown x Acanthopagrus Miyazaki et al Necrosis (VEN) 1989 Fish Yellowtail Unknown unknown unknown x Seriola Sorimachi and Ascites Virus Hara 1985 (YTAV) Mollusc Peronosporom Unknown unknown unknown x Haliotis Hatai 2012 ycetes fungus Mollusc Francisella sp. Unknown unknown unknown x Haliotis Kamaishi et al 2010 Mollusc Marteilioides Yes – water-borne unknown x Crassostrea Tun et al 2007 chungmuensis unknown Mollusc Vibrio Unknown unknown unknown x Sulculus Nishimori et al. carchariaeis (abalone) 1998 Mollusc Vibrio fluvialis Unknown unknown unknown x Haliotis Li et al. 1998 Mollusc Vibrio harveyi Unknown unknown unknown x Haliotis Sawabe et al. 2007 Mollusc Viral Unknown unknown unknown x Nordotis Nakatsugawa et amyotrophia (abalone) al. 1999

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Table 3: Diseases and etiological agents affecting permitted aquaculture species under Yumbah KI lease arrangements in Smith Bay. NOTE bolded disease agents are reportable and listed in OIE 2018.

Affected Etiological Disease name Survival Horizontal Vectors Japan China Korea AUS Target Reference Phylum Agent outside transmission Aquaculture host Genera affected

Mollusc Abalone Abalone Viral Unknown water borne unknown x x Haliotis OIE 2018 Herpes Virus Ganglio-neuritis (abalone) (AbHV)

Fish Infectious 1 month contact invetebrate X x Oncorhynchus; OIE 2018 Haematopoietic vectors Salmo Necrosis (IHN)

Fish Oncorhyncus 7-14 days water borne unknown x Oncorhynchus OIE 2018 masou virus disease (OMVD)

Fish Red Sea Bream Unknown water borne unknown x Acanthopagrus; OIE 2018 Iridoviral Seriola Disease (RSIV)

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Mollusc Ostreid Pacific Oyster Unknown contact; oysters x x Crassostrea; OIE 2018 Herpesvirus 1 Mortality possibly Ostrea microvariant Syndrome water borne (OsHV-1) (POMS)

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• 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 MANAGEMENT AND MITIGATION MEASURES al 2016). It should be noted that preventative management of potential invasion transport vectors does not, and cannot, • Biofouling on slow moving vessels (such as dumb barges and dredges) can transfer mature communities result in zero risk, but is intended to provide risk minimisation. 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 It should also be acknowledged that risk species can potentially be transported to a new location by a number of permitted at Smith Bay” will limit the intentional discharge of biofouling species. This will not mitigate the means (Hewitt and Campbell 2010). For example, many species can be transported during a planktonic phase in accidental dislodgement of biofouling organisms or spawning of biofouling species on ship’s hulls and ballast water, and as benthic adults in biofouling (Hewitt and Campbell 2010; Davidson et al. 2016). protected areas while in port. As a consequence, it is difficult to determine if a species’ arrival following ballast exchange was due a “failure” of • Disease agents and parasites may be transmitted within biofouling species, including primary and secondary ballast water exchange or if the species arrived by other means. There is, however, evidence that species are hosts. retained in ballast tanks following open ocean exchange (eg Murphy et al 2002; Ruiz and Reid 2007; Bailey et al. 2011). SUMMARY The proposed marine biosecurity management and mitigation measures provided in the SBW Draft EIS (2019) are 1. The methodology for determining marine biosecurity risk activities, vectors and species is unclear and, based on insufficiently defined to determine the level of biosecurity protection. Management and mitigation measures have the material presented, inadequate. been provided for two elements: Discharges and Ballast Water Management, and for Biofouling. Each are further a. The species assessments do not appropriately consider either the domestic or international source addressed below with consideration of how these might be improved: locations to determine the species (and disease agents and parasites) likely to be transported into Smith Discharges and Ballast Water Management Bay waters. The proponents state that the primary risk mitigation and management strategy will be to comply with international b. The assessment of disease agents (pathogens and parasites) does not adequately consider the suite of and Commonwealth law. This is a mandated (and expected) mitigation and does not adequately and explicitly licensed aquaculture species permitted to Yumbah KI. address the additional risks created by this activity. c. Nine OIE listed diseases or etiological agents present in Japan or China are known to affect Genera licensed to Yumbah KI. As indicated above, there are additional risks associated with the construction and operational phases that would d. An additional nine diseases or etiological agents species from Japan or China are known to affect Genera not be adequately addressed through simple compliance with international and Commonwealth law. licensed to Yumbah KI, and known to have caused mass mortalities of aquaculture species in China or • Dredges and associated supporting barges are exposed to sediments in previous ports of operation and have Japan. been explicitly linked to the transfer and spread of non-native marine species, particularly biofouling species 2. The risk mitigation measures proposed are generic and meet the letter, rather than the intent, of international, such as Sabella spallanzanii, and dinoflagellate cysts in retained sediments from the last port of operations. Commonwealth and State requirements. • Ballast water exchange on the “high seas” is only moderately successful at reducing the planktonic 3. The measures for discharges and ballast water management focus explicitly on the operational phase using component of the assemblage, although this varies significantly by taxa, and by the method and location of commercial trading vessels and are insufficiently detailed to address the construction phase, particularly for the ballast exchange (Molina and Drake 2016; Bailey et al. 2011). risks associated with slow moving vessels including dredges and barges. • Ballast water exchange on the “high seas” is very poor at reducing the ballast sediment load and will not 4. The lack of mitigation measures that consider sediment transfer risk either in the dredges and barges, or in the adequately mitigate the risk of toxic dinoflagellate cyst introductions (Molina and Drake 2016). 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” • Vessel trading routes between the Northwest Pacific bioregion and Australia are largely in nearshore and and therefore will not be able to undertake adequate protections. shallow waters which may restrict the opportunities for these vessels to undertake ballast water exchange in 6. Biofouling species hazards associated with both construction and operational phases will continue to pose water of sufficient depth and distance offshore. How these situations will be managed by the unmitigated risks. The restriction on “in water or dry dock cleaning” at Smith Bay will not prevent mature species Commonwealth remains unclear (ie will the vessel still be allowed to enter and discharge). from spawning or being dislodged into Smith Bay waters. • Under international and Commonwealth law there are clear protections to vessels to not undertake ballast 7. Additionally, mature biofouling assemblages are likely to pose the additional risk of transferring disease agents exchange if they consider it to be a risk to the vessel (Endresen et al. 2004). How these situations will be and parasites into Smith Bay waters. 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. REFERENCES Bailey SA, Deneau MG, Jean L, Wiley CJ, Leung B, MacIsaac HJ. 2011. Evaluating efficacy of an environmental policy Biofouling to prevent biological invasions. Environ. Sci. Technol 45: 2554–2561 • Biofouling is currently unregulated. International guidelines have been developed and adopted by the Davidson I, Scianni C, Hewitt CL, Everett R, Holm E, Tamburri M, Ruiz G. 2016. Assessing drivers of ship biofouling International Maritime Organization (IMO) Marine Environmental Protection Committee (MEPC) in management: aligning industry and biosecurity goals. Biofouling 32:411-428. Resolution MEPC.207. The Commonwealth further developed biofouling guidelines in 2015 (DAWR 2015).

Page | 12 Page | 13

DAWR 2015, Review of national marine pest biosecurity, Department of Agriculture and Water Resources, Australian Nishimori E, Hasegawa O, Numata T, Wakabayashi H. 1998. Vibrio carchariae causes mass mortalities in Japanese Government, Canberra abalone, Sulculus diversicolor supratexta. Fish Pathology 33: 495–502. DAWR. 2015. Anti-fouling and in-water cleaning guidelines. OIE. 2018. Manual of Diagnostic Tests for Aquatic Animals. http://www.agriculture.gov.au/biosecurity/avm/vessels/biofouling/anti-fouling-and-inwater-cleaning- http://www.oie.int/index.php?id=2439&L=0&htmfile=sommaire.htm, accessed 17 April 2019. guidelines. accessed 2 April 2019 PIRSA. 2015. Noxious fish list, Primary Industries and Regions South Australia, Government of South Australia, Deagle BE, Bax N, Hewitt CL, Patil JG. 2003. Development and evaluation of a PCR based test for detection of Asterias Adelaide, viewed 24 July 2017, http://pir.sa.gov.au/biosecurity/aquatics/aquatic_pests/noxious_fish_list>. (Echinodermata: Asteroidea) larvae in plankton samples from ballast water. Marine and Freshwater Ruiz GM, Reid DF. 2007. Current State of Understanding about the Effectiveness of Ballast Water Exchange (BWE) in Research 54: 709-719. Reducing Aquatic Nonindigenous Species (ANS) Introductions to the Great Lakes Basin and Chesapeake Bay, Endresen Ø, Lee Behrens H, Brynestad S, Bjørn Andersen A, Skjong R. 2004. Challenges in global ballast water USA: Synthesis and Analysis of Existing Information. NOAA Technical Memorandum GLERL-142. GL:ERL, Ann management. Marine Pollution Bulletin 48: 615–623. Arbor, USA. 127 pp. GISD 2017, Global Invasive Species Database, accessed 2 April 2019, . 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. 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. 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 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. , 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. Page | 14 Page | 15

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 APPENDIX 5 – 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 ECONOMIC IMPACT STATEMENT 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 Dench McLean Carlson $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 2019 represents a growth of $9.59 million in Value Added within the local economy Stage 2 – Expansion of Yumbah’s Kangaroo Island operation The Stage 2 expansion of Yumbah’s current Kangaroo Island operation is forecast to generate $50M in sales (or output) This increase in output is estimated to:

• 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 5 FTE jobs directly and 2 FTE jobs indirectly within Kangaroo Island’s local economy • 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.

194 Smith Bay Wharf Environmental Impact Statement Yumbah Response

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

• 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 Stage 2 – Expansion of Yumbah’s Kangaroo Island operation The Stage 2 expansion of Yumbah’s current Kangaroo Island operation is forecast to generate $50M in sales (or output) This increase in output is estimated to:

Using ABS datasets and an input / output methodology industrial economic data estimates for defined geographic regions are generated.

Summary of Estimated Economic Impacts of Yumbah’s Kangaroo Island Operation Estimated FTE Employment Kangaroo Island on the Kangaroo Island Local Economy Sectors FTE Jobs % of FTE Jobs Supply-Chain Consumption Impact Summary Direct Effect Total Effect Sheep, Grains, Beef & Dairy Cattle 366 19.50% Effect Effect Poultry & Other Livestock 51 2.70% Output ($M) $6.00 $1.60 $1.00 $8.59 Other Agriculture 29 1.60% Agriculture, Fishing, Hunting & Trapping 29 1.60% Employment (Jobs FTE) 25 4 3 32 Forestry & Fishing Current KI Operation Forestry & Logging 6 0.30% Wages and Salaries ($M) $1.08 $0.41 $0.22 $1.70 Agriculture, Forestry & Fishing Support Services 29 1.60% Value-added ($M) $2.80 $0.71 $0.60 $4.11 Aquaculture 25 1.30%

Output ($M) $20.00 $5.32 $3.32 $28.64 Accommodation & Food Services 199 10.60% Construction 173 9.20% Employment (Jobs FTE) Stage 1 – Proposed 60 15 10 85 Education & Training 142 7.50% Growth of KI Operation Wages and Salaries ($M) $3.59 $1.35 $0.72 $5.66 Transport, Postal & Warehousing 131 7.00% Value-added ($M) $9.33 $2.37 $2.00 $13.70 Health Care & Social Assistance 125 6.60%

Retail Trade 119 6.30% Output ($M) $14.00 $3.73 $2.32 $20.05 Public Administration & Safety 105 5.60% Change Employment (Jobs FTE) 35 11 7 53 Administrative & Support Services 64 3.40% Current to Stage 1 Wages and Salaries ($M) $2.51 $0.95 $0.50 $3.96 Other Services 61 3.20%

Value-added ($M) $6.53 $1.66 $1.40 $9.59 Manufacturing 60 3.20% Professional, Scientific & Technical Services 47 2.50% Output ($M) $50.00 $13.30 $8.29 $71.59 Wholesale Trade 40 2.10% Employment (Jobs FTE) Arts & Recreation Services 34 1.80% Stage 2 – Proposed 140 37 24 201 Rental, Hiring & Real Estate Services 16 0.90% Growth of KI Operation Wages and Salaries ($M) $8.98 $3.38 $1.80 $14.16 Electricity, Gas, Water & Waste Services 12 0.60% Value-added ($M) $23.32 $5.92 $5.00 $34.25 Financial & Insurance Services 11 0.60%

Output ($M) $30.00 $7.98 $4.97 $42.96 Information Media & Telecommunications 5 0.30% Mining 0 0.00% Change Employment (Jobs FTE) 80 22 14 116 Total 1,880 100.00% Stage 1 to Stage 2 Wages and Salaries ($M) $5.39 $2.03 $1.08 $8.50 Value-added ($M) $13.99 $3.55 $3.00 $20.55 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 Output ($M) $44.00 $11.71 $7.29 $63.00

Change Employment (Jobs FTE) 115 33 21 169

Current to Stage 2 Wages and Salaries ($M) $7.90 $2.98 $1.58 $12.46

Value-added ($M) $20.52 $5.21 $4.40 $30.14

Output ($M) $1.77 $0.40 $0.31 $2.48

Employment (Jobs FTE) 5 1 1 7 Tourism Impact Wages and Salaries ($M) $0.36 $0.10 $0.07 $0.53

Value-added ($M) $0.77 $0.19 $0.19 $1.15

Value-added ($M) $6.53 $1.66 $1.40 $9.59 Manufacturing 60 3.20% Professional, Scientific & Technical Services 47 2.50% Output ($M) $50.00 $13.30 $8.29 $71.59 Wholesale Trade 40 2.10%

Employment (Jobs FTE) Arts & Recreation Services 34 1.80% Stage 2 – Proposed 140 37 24 201 Rental, Hiring & Real Estate Services 16 0.90% Growth of KI Operation Wages and Salaries ($M) $8.98 $3.38 $1.80 $14.16 Electricity, Gas, Water & Waste Services 12 0.60% Value-added ($M) $23.32 $5.92 $5.00 $34.25 Financial & Insurance Services 11 0.60%

current FTE jobs in the Kangaroo Island local economy Output ($M) $44.00 $11.71 $7.29 $63.00

Change Employment (Jobs FTE) 115 33 21 169

Current to Stage 2 Wages and Salaries ($M) $7.90 $2.98 $1.58 $12.46

Value-added ($M) $20.52 $5.21 $4.40 $30.14

Output ($M) $1.77 $0.40 $0.31 $2.48

Employment (Jobs FTE) 5 1 1 7 Tourism Impact Wages and Salaries ($M) $0.36 $0.10 $0.07 $0.53

Value-added ($M) $0.77 $0.19 $0.19 $1.15

27 May 2019

APPENDIX 6 – David Connell Our ref: 6137616-2601 Your ref: Manager REVIEW OF AIR Yumbah Kangaroo Island

QUALITY IMPACTS Dear David Cook Smith Bay Aquaculture Assessment Review of Air Quality Impacts 2019 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.

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.

198 Smith Bay Wharf Environmental Impact Statement Yumbah Response

27 May 2019

David Connell Our ref: 6137616-2601 Your ref: Manager Yumbah Kangaroo Island

Dear David

Smith Bay Aquaculture Assessment Review 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 Background Kangaroo 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.

2 Documents considered 4.1 EIS purpose The following documents have been considered during the peer review of the Air Quality EIS chapters, Chapter 17 of the EIS Main report (page 373) identifies the scope for the Air Quality assessment in sections and appendix: 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  Smith Bay Wharf - Draft Environmental Impact Statement Executive Summary, January 2019 any matter prescribed by regulations under the Development Act)” (EIS, p.9). The published guidelines  Smith Bay Wharf - Draft Environmental Impact Statement Main Report, January 2019 for the EIS process of 6 July 2017 specifically reference (emphasis added) the impact on Yumbah KI:

 Smith Bay Wharf - Draft Environmental Impact Statement Appendix M – Air Quality: Air Pollution  Guideline 5.2 Modelling Outputs, January 2019  “Outline the impacts of dust and/or particle generation on the existing commercial operations and  SA Environment Protection (Air Quality) Policy 2016 any other identified nearby sensitive receivers in the vicinity of the proposed development, in

 SA Guideline for Ambient air quality assessment, August 2016 particular the existing abalone farm” (EIS, p.373). Other documents and results of research pertaining to the assessment of air quality are also taken into Guideline 5.1 “includes modelling undertaken in accordance with the Environment Protection (Air Quality) account (e.g. National Environment Protection (Ambient Air Quality) Measure). 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 3 Methodology their reduction or elimination” (ibid.). In undertaking this review, consideration has been given to: 4.2 Modelling to Policy and guideline requirements  The expected character of the air quality impacts during operational and construction phases of the The author of the EIS air quality assessment has demonstrated competencies in following the SA project Environment Protection Authority’s Ambient Air Quality Assessment (2016) guidelines. The guideline, for  The relevant regulatory and technical/scientific documents referenced in section 2 example, requires an electronic copy of the output text file(s) to be provided. Appendix M provides  Australian and South Australian Environment Protection Authority (EPA SA) practices in assessing these. However, the guideline also says that “the EPA recommends that practitioners produce a the predicted air quality from projects ‘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 The review has taken a risk-based approach and has sought to identify the more important issues where within Chapter 17 – even on the figures). A number of assessment choices have been made that raise problems might arise. A summary of the key findings from the peer review is provided in section 4. The concerns about the accuracy of the modelling – these are expanded upon below. 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. 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 4 Key findings 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 The key findings of the review address the key concern of ‘dust, expressed as (Pers. Comm, Sustainable Air Policy – so NSW criterion adopted). These are not very relevant to the abalone farm although they Project Management, May 2019): are the requirement for assessing impact at the residential sensitive receptor locations (as done by the  The dust review should “consider the accumulation of dust on the abalone grow out shade cloth” consultant).

 “The accumulated dust on the grow out shade cloth may be an issue, particularly if rains washes the The guideline (p.10) identifies “Important stages for assessment using air quality modelling” as: accumulated dust into the abalone tanks” 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

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 SA Guideline for Ambient air quality assessment, August 2016 particular the existing abalone farm” (EIS, p.373). Other documents and results of research pertaining to the assessment of air quality are also taken into Guideline 5.1 “includes modelling undertaken in accordance with the Environment Protection (Air Quality) account (e.g. National Environment Protection (Ambient Air Quality) Measure). 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 3 Methodology their reduction or elimination” (ibid.). In undertaking this review, consideration has been given to: 4.2 Modelling to Policy and guideline requirements  The expected character of the air quality impacts during operational and construction phases of the project 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  The relevant regulatory and technical/scientific documents referenced in section 2 example, requires an electronic copy of the output text file(s) to be provided. Appendix M provides  Australian and South Australian Environment Protection Authority (EPA SA) practices in assessing these. However, the guideline also says that “the EPA recommends that practitioners produce a the predicted air quality from projects ‘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 The review has taken a risk-based approach and has sought to identify the more important issues where within Chapter 17 – even on the figures). A number of assessment choices have been made that raise problems might arise. A summary of the key findings from the peer review is provided in section 4. The concerns about the accuracy of the modelling – these are expanded upon below. 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. 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 4 Key findings 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 The key findings of the review address the key concern of ‘dust, expressed as (Pers. Comm, Sustainable Air Policy – so NSW criterion adopted). These are not very relevant to the abalone farm although they Project Management, May 2019): are the requirement for assessing impact at the residential sensitive receptor locations (as done by the  The dust review should “consider the accumulation of dust on the abalone grow out shade cloth” consultant).

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4.2.1 Emissions inventory development Some rigor has been applied to partition the data into size fractions - but these assume soil Two emission inventories are required – for construction and operation. In the absence of site-specific characteristics and not fibrous/cellulous material. Wind erosion from the woodchip stockpile has data, it is standard procedure to use default NPI emission factors. Such factors are usually based on assumed the same default NPI emission factor as that used for mine-site overburden. Further, the emission factor estimates for mining operations, and are acceptable for construction activity and vehicle deposition modelling assumes a particle density that needs to be different from the other sources - this is related fugitive dust sources due to operational traffic. However, NPI emission factors are not available not discussed and may have to be re-modelled correctly. Both of these assumptions have the potential to for woodchips, otherwise the assumptions made are all on the conservative side. For example, a cause an error in the accuracy of the predictions. 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 4.2.2 Consideration of meteorological and terrain effects inventory for wind erosion to being a function of wind speed (rather than just the threshold, and binary, It is stated that for Kingscote PO and Kingscote Airport the meteorological "data are generally consistent" wind speed cut-off) – further compounded by the meteorological modelling by the TAPM model under (EIS, p.378). However, there are differences between the sites, somewhat related to the measurement predicting the wind speed (see also section 4.2.2). method (wind) and exposure (temperature and rain). Wind erosion emissions only occur when the winds are high enough and then at the NPI default emission Because of the distance the airport is inland the "Kingscote Aero is generally warmer during the day and factors. Since the TAPM model has under predicted winds, which is considered overly conservative. colder at night than the Kingscote" Post Office (EIS, p.378). This questions the assumption that wind The default emission factors (EF's) are wind speed independent. If winds are light, then the particles will data at the Airport are representative of the coastal location. However, differences between the sites are not disperse as far. The model is better to be used to have the emission inventory at the default EF's all critical as the comparison is done to justify using a slightly inland site at the airport as being the time (and allowing the model to disperse accordingly) or adjusting the hour-by-hour EF's according to representative of a site with a beachhead. It can be assumed that the coastal sites of Smith Bay are the emission rate varying as a function of the wind speed. 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 Dust-generating activities and assumptions for both construction and operations used NPI default representativeness of the modelled winds. 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 A standard procedure, when site-specific data are not available, is to initialise the CALMET (wind) model the expected tonnage of loaded and unloaded log/woodchip trucks. 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 A 75% emission reduction is assumed for vehicle dust emissions on unsealed haul roads. This is due to CALMET fields. This diminishes the accuracy of the modelling as the comparison done shows that (mine site) standard level 2 watering of >2 L/m2/hr. This is not stated in the main text but is contained in TAPM under predicts the winds (at the reference site of the Airport and by analogy at the subject site), a a table. Such a mitigation measure assumes that this is applied during all hours of operation where known artefact of the model. No model settings for the TAPM or CALMET models are provided. It would vehicles are on unsealed roads. Such a water cart, or even a source of water, may not be available at all also have been useful to compare the TAPM predicted winds to the Airport annual wind climate. The times. methodology of including measured winds, and varying the wind erosion with wind speed, will lead to A very brave assumption has been made that the handling of woodchips produces the same emissions higher predicted dust impacts. as 'Log debarking' (USEPA emission factor from the late 1970s). It is further assumed that the PM10 to 4.2.3 Modelling using suitable dispersion models 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. “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, As woodchip material handling is assumed to occur four times (Table 17-6), the accuracy of this CALPUFF is preferred when "for conditions such as coastal fumigation, cold-air drainage or a location assumption is very important. The total of the assumed emissions of woodchip handling (0.32 g/s of with complex terrain" (SA EPA, 2016, p.12). None of these apply here. 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 "It is important that the complex mechanisms that affect air movements are incorporated into dispersion be woodchips). 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.

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4.2.4 Airshed approach (if considering cumulative impacts) The only monitoring proposed is “A series of gauges would be established on the site boundaries to “Kangaroo Island has no air quality monitoring stations” (EIS, p.381). It is the incremental change that is monitor dust deposition rates before and during construction and during operation” (EIS, p.396). It is critical to the assessment of impacts so it is best to treat the estimated baseline values as indicative only. standard procedure to undertake audit monitoring of impacts (just deposition as PM monitoring not a PM10 and PM2.5 can be used to assess human health exposure. However, as we are concerned with health issue at Yumbah) along the common boundary so as to enable adjustments to the dust 'ecological-like' impacts of dust deposition into water bodies or the shade-cloth areas of the abalone management plan if levels are experienced to be too high. However, this will be too late (as it takes a tanks, the use of these indicators can be ignored. 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 For the important dust deposition criterion, a background of 2 g/m2/month is assumed as a baseline (not detected to cross the boundary, either visually or measured, construction activity should cease. seasonally varying). While this is based on Eyre Peninsula benchmarking, it is consistent with the Downtime is only required due to drying conditions involving stronger winds and are likely to be rare assumed background/natural deposition rate in the NSW Approved Methods (albeit an overestimation for enough that activity curtailment does not delay the construction program significantly. a coastal site on an island off the mainland).

4.2.5 Validation of air pollution modelling output Yours sincerely This 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 Barry Cook boundaries to residential areas is likely to be more accurate than a modelling approach. For example, Technical Director - Air Quality and Meteorology the residential areas of Portland are just 150 m from the site boundary and within a 1,500 m threshold +61 3 8687 8649 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.

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6137616/6137616-LET-0_Review of KIPT EIS Air Quality Impacts.docx 6 6137616/6137616-LET-0_Review of KIPT EIS Air Quality Impacts.docx 7 APPENDIX 7 – EASEMENTS - CERTIFICATES OF TITLE

206 Smith Bay Wharf Environmental Impact Statement Yumbah Response

Product Register Search (CT 6127/273) Date/Time 07/02/2018 03:40PM Customer Reference pmed Order ID 20180207010162 Cost $28.25

The Registrar-General certifies that this Title Register Search displays the records maintained in the Register Book and other notations at the time of searching.

Certificate of Title - Volume 6127 Folio 273 Parent Title(s) CT 5870/746

Creating Dealing(s) RTC 12040789

Title Issued 17/12/2013 Edition 2 Edition Issued 24/04/2014 Estate Type FEE SIMPLE Registered Proprietor CINEREA PTY. LTD. (ACN: 167 774 058) OF SE 816 AURORA HOUSE 147 PIRIE STREET ADELAIDE SA 5000 Description of Land ALLOTMENT COMPRISING PIECES 51 AND 52 DEPOSITED PLAN 92343 IN THE AREA NAMED WISANGER HUNDRED OF MENZIES Easements SUBJECT TO EASEMENT(S) OVER THE LAND MARKED A ON DP 92343 TO DISTRIBUTION LESSOR CORPORATION (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 OF ELECTRICITY BY UNDERGROUND CABLE (RTC 12040789) Schedule of Dealings Dealing Number Description 12719258 MORTGAGE TO COMMONWEALTH BANK OF AUSTRALIA (ACN: 123 123 124) Notations Dealings Affecting Title NIL Priority Notices NIL Notations on Plan NIL Registrar-General's Notes NIL Administrative Interests NIL

Land Services Page 1 of 1 Copyright Privacy Disclaimer: www.sailis.sa.gov.au/home/showCopyright www.sailis.sa.gov.au/home/showPrivacyStatement www.sailis.sa.gov.au/home/showDisclaimer

20 May 2019

APPENDIX 8 – David Connell Our ref: 6137616-87921 Your ref: Manager REVIEW OF NOISE Yumbah Kangaroo Island

AND VIBRATION Dear David Lenchine Smith Bay Aquaculture Assessment Noise & Vibration Review 2019 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).

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.

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 operational and construction noise and vibration assessments.

2 Documents considered The following documents have been considered during the peer review of the Background Noise Monitoring Report:

 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 N- Noise and Vibration: Environmental Noise Impact Assessment, Resonate 17 Dec. 2018

216 Smith Bay Wharf Environmental Impact Statement Yumbah Response

20 May 2019

David Connell Our ref: 6137616-87921 Your ref: Manager Yumbah Kangaroo Island

Dear David

Smith Bay Aquaculture Assessment Noise & 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).

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 operational and construction noise and vibration assessments.

2 Documents considered The following documents have been considered during the peer review of the Background Noise Monitoring Report:

 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 N- Noise and Vibration: Environmental Noise Impact Assessment, Resonate 17 Dec. 2018

 SA Environment Protection (Noise) Policy 2007  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  SA Guidelines for the Use of the Environment Protection (Noise) Policy 2007 expected to comply with limits in the policy, as is the case with the proposed development.  SA DPTI Underwater Piling Noise Guidelines 2012 Therefore, it is desirable to expand the acoustic report to show that meeting applicable noise limits at  SA DPTI Road Traffic Noise Guidelines 2016 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 Other documents and results of research pertaining to the assessment of airborne underwater noise and analysis does not form a part of the current report. vibration are also taken into account.  SA Noise EPP and Guidelines contain procedures for noise acquisition that require removal of 3 Methodology 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 In undertaking this review, consideration has been given to: separate section on the weather data used in the assessment should be included in the report and  The expected character of the noise and vibration impacts during operational and construction further clarification on the data filtering that has been undertaken should be included. It should be phases of the project. noted that under SA Noise EPP the criteria does not depend on the pre-existing background level but

 The relevant regulatory and technical/scientific documents referenced in the previous section. rather on the zoning of the noise source and the relevant receivers.

 Australian and international practices in assessing onshore and offshore noise and vibration. 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 The review has taken a risk-based approach and has sought to identify the more important issues where and high wind speeds. The acoustic report should have a weather analysis section for this. 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  A traffic noise assessment is a relatively complex task. Summaries of the study are included in the reviewed and relevant standards. 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 4 Key findings 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 The key findings of the review are: inputs relevant to predicting noise impact are not provided in the considered documents. Method of  The SA Environment Protection (Noise) Policy 2007 (SA Noise EPP) contains procedures to derive the traffic noise predictions, locations of affected receivers, predicted traffic noise levels and other permissible noise levels for operational noise from developments and during construction. Applicable relevant information should be included as a part of the acoustic report or in other submission noise limits for the development have been derived correctly and the approach used in the main documents. report and other documents is in line with the SA Noise EPP and other relevant regulatory documents. Yours sincerely

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 Val Lenchine period, a more in-depth assessment should be performed and included into the submitted Technical Director- Noise & Vibration documents. +61 3 8687 8710

 The main report contains a shorter version of the findings of the noise assessment report (Appendix Attachment: Tabulated comments – EIS Tracker Acoutics.xlsx 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.

6137616/6137616 LET-Smith Bay Noise Vibration Review May 2019.docx 2 6137616/6137616 LET-Smith Bay Noise Vibration Review May 2019.docx 3

 The relevant regulatory and technical/scientific documents referenced in the previous section. rather on the zoning of the noise source and the relevant receivers.

6137616/6137616 LET-Smith Bay Noise Vibration Review May 2019.docx 2 6137616/6137616 LET-Smith Bay Noise Vibration Review May 2019.docx 3 APPENDIX 9 – AUSOCEAN MARINE ECOLOGY REPORT 2019 Australian Ocean Lab (AusOcean)

SMITH BAY MARINE ECOLOGY REPORT

220 Smith Bay Wharf Environmental Impact Statement Yumbah Response Australian Ocean Lab (AusOcean)

SMITH BAY MARINE ECOLOGY REPORT

Copyright © The Australian Ocean Laboratory Limited (AusOcean) 2019. The information contained herein is licensed under a Creative Commons Attribution 3.0 SMITH BAY Australia License (http://creativecommons.org/licences/by/3.0/au).

MARINE ECOLOGY REPORT

A report prepared for AusOcean

by Ms Catherine Larkin Marine Biologist

Smith Bay Marine Ecology Report 3

MARINE ECOLOGY REPORT

A report prepared for AusOcean by Ms Catherine Larkin Marine Biologist

Smith Bay Marine Ecology Report 3

Acknowledgements Contents Copyright ...... 3 A big thanks to the AusOcean expedition crew for both enjoyable and productive expeditions. Acknowledgements ...... 4 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 Tables and Figures ...... 6 joining two expeditions. Your marine expertise, your insight and knowledge of marine species Foreword ...... 7 and marine ecology helped immensely. Introduction ...... 9

We would also like to thank molecular biologist and on-board syngnathid expert Graham Methods ...... 11 Short from the California Academy of Sciences for joining our third expedition. Your Results ...... 14 knowledge and expertise all things syngnathid was invaluable. Finally, thanks also to Species of Conservation Significance ...... 19 AusOcean intern Trek Hopton for his wonderful underwater photos. Discussion...... 23

Limitations...... 26

Conclusions and Future Research ...... 27

References ...... 28

Appendices ...... 32

Smith Bay Marine Ecology Report 4 Smith Bay Marine Ecology Report 5

Limitations...... 26

Conclusions and Future Research ...... 27

References ...... 28

Appendices ...... 32

Smith Bay Marine Ecology Report 4 Smith Bay Marine Ecology Report 5

Tables and Figures Foreword

Tale ocal species of anaroo sland...... I learned to dive in the cold, clear waters of the Monterey Bay, California, and for that I am Tale umer of transects at sites ...... Tale Area ecoloy of each site ...... very grateful. Had I learned in warmer waters, I might never have donned a 7mm-thick Tale reuency of ccurrence of the most commonly sihted species...... wetsuit. Many divers never experience the wonders of temperate waters, eschewing them

Tale ost aundant fish and inerterate species...... 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

iure ap of surey locations and imae of mith ay facin east...... Australia, increasingly referred to as the Great Southern Reef (GSR). Unlike tropical reefs in

iure reuency of ccurrence of fish and inerterate species ...... which species are distributed globally, 90% of species found in the Great Southern Reef are iure Total species at each site ...... endemic to southern Australia, and what marvellous creatures they are; from the colony- iure ish and inerterate species occurrin in each site ...... forming bryozoans that rival corals in their fantastic shapes and colours, to those masters of iure Total numer of fish and inerterates recorded at each site ...... 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 late iers preparin to surey...... Philippines. These are marine species that are native to Australia and geographical isolation late iers conductin reef life sureys ...... has confined them to our waters. They are as much a part of the Australia’s wonderful natural late enator wrasse Pictilabrus laticlavius ...... heritage as our unique terrestrial wildlife. late estern slatepencil urchin Phyllacanthus irregularis ...... late eedy seadraon Phyllopteryx taeniolatus ...... Kangaroo Island's marine environment is particularly significant as it encompasses semi- late other of pearl pipefish – Vanacampus margaritifer ...... late estern lue roper Achoerodus gouldii ...... protected Gulf waters, unprotected Southern Ocean waters and areas of confluence between late onsnout oarfish – Pentaceropsis recurvirostris ...... the two. While several marine studies have been conducted over the years, generally these late outhern lue deil – Paraplesiops meleagris...... have been quite sparse in their geographical coverage. During the summer of 2018-2019

late oral Plesiastrea versipora ...... AusOcean therefore embarked upon a series of expeditions to intensively study Smith Bay on late ier sureyin coral ...... 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.

mith ay arine coloy eport Smith Bay Marine Ecology Report 7

Tables and Figures Foreword

Tale ost aundant fish and inerterate species...... 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

iure ap of surey locations and imae of mith ay facin east...... Australia, increasingly referred to as the Great Southern Reef (GSR). Unlike tropical reefs in

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.

mith ay arine coloy eport Smith Bay Marine Ecology Report 7

Introduction

As such, it would represent a microcosm of the marine environment of Kangaroo Island’s Kangaroo Island KI is uniuel situated at the confluence of several oceanographic sstems Kinloch, his uniue positioning and, the effects of the warm waters of the eeuwin current have a profound influence on marine assemlages iddleton e he northern coastline comprises a mixture of macroalgal (“seaweeds” such as elp dominated

roc reef sstems and dense seagrass communities hese sstems form part of the wider reat outhern eef spanning the entire southern coastline of the Australian continent ennett et al. In addition to the man significant economic and social enefits, these sstems provide e ecological services such as nutrient ccling, sediment stailisation, enhanced iodiversit, trophic transfers and caron seuestration rth et al. male et al. B.Eng. (Hons) (Adelaide), M.S. (A.I.) (Stanford), Fellow, Engineers Australia KI’s marine environment exhibits high species richness and endemism supporting an aundance of emlematic and threatened species with high conservation value such as the eaf sea dragon (Phycodurus eques), the estern lue groper (Achoerodus gouldii), lue devil (Paraplesiops meleagris) and arleuin fish (Othos dentex) cArdle et al. , einhold et al ) KI’s coastline provides uniue haitat that is paramount for the eistence and longevit of these species, whose numers have declined significantl elsewhere Additionall, valuale commercial fisheries such as umah auaculture the world’s largest exporter of Greenlip abalone and the Rock lobster industry rely heavily on the local environment for ualit production

leven species of fish and one invertebrate are listed as ‘in peril’ by the SA conservation ouncil eef atch, hese species are nown to freuent outh Australian waters and have een previousl noted on KI cArdle et al , einhold et al , hepherd et al. ) he estern lue groper is listed as Vulnerable on the I red list of threatened species hoat et al., and the giant cuttlefish is listed as Near threatened with populations declining drasticall since the turn of the centur rowse et al. tale All memers of the ngnathidae famil seahorses, seadragons and pipefish are listed as protected species under the Australian Commonwealth’s Environmental Protection and Biodiversity Conservation (EPBC) Act (1999)

mith a arine colog eport

Introduction

mith a arine colog eport

able ocal species of Kangaroo Island Methods

Conservation Value Commercial Value en surey ocations itin it ay on te nortern coast of Kanaroo Isand ere seected estern blue groper Southern rock lobster for arine ife sureys fiure . ites ere strateicay seected to encopass ot te Southern blue devil Greenlip abalone eastern and estern sides of te ay and deeper aters ocated ore centray tae . arleuin fish lacklip abalone urey data as coected on to die trips in eceer of and one in eruary of . ueen snapper A dies ere off a oat and undertaen durin dayit ours. ongsnout boarfish

eafy sea dragon tandardised eef ife urey etods ere adapted to ater sustrate fis and eedy sea dragon inerterate species coposition and aundance data at eac site eef ife urey Spotted wobbegong oundation . e standard etod inoes ayin out on transects aon

Gulf wobbegong continuous dept contours to assess reef iodiersity. A copete surey consists of te Cobbler wobbegong fooin coponents lack cowrie

Giant cuttlefish  oto uadrats taen at . interas aon te transect ine per transect.  is sureyed in to ide y i ands parae it te transect ine. Southern Australia’s marine macroalgal flora has the highest levels of species richness and  ryptic fis and are .c acroinerterate ousc ecinoder and crustacean searces in ide y i ands eiter side of te transect ine. endemism of any regional macroalgal flora in the world (hillips owever despite their ac surey ocation as ocated apart. utipe transects itin a surey ocation intrinsic and economic value temperate reef systems are often overlooked by their tropical ere ocated itin of eac oter. e ony sites in ic transects ere not undertaen reef counterparts A defining feature of these reef systems is the kelp (Ecklonia Radiata as it ay ort and ort entra as tey did not adere to te reuireents which is largely supported by neighbouring seagrass systems that facilitate both reef of the RLS methods. However, location species was noted via an area ‘swim around’. interconnectivity (eck et al. Ricart et al. and provide important ‘nursery’ areas erefore tese sites ae een excuded fro te ain data anaysis ut are incuded in for fishes (enkins and heatley cevittIrwin et al. In South Australia Appendix . pecies identifications ere supported y Fishes of Australia’s Southern Coast seagrass habitats are protected under the Native Vegetation Act ( oon et al., . Current levels of both scientific and public engagement threaten the health and longevity of ae uer of transects at sites. these significant systems (ennett et al. . As part of AusOcean’s first expedition to KI’s Smith Bay No of transects north coast Smith ay was selected as an appropriate site for a comprehensive marine life ast ocs survey due to both its high diversity of flora and fauna and uniue variety of habitats ast ast ore Although a number of both scientific and communitybased programs have conducted ort entra A ort A surveys along the north coast of KI collecting baseline data on fish invertebrate and algae ree anne est entra et al et al communities for long term reef health monitoring (cArdle Reinhold est ore

Scorseby aker Smith ay remains relatively lightly studied est est ocs

Smith ay arine cology Report it ay arine cooy eport

able ocal species of Kangaroo Island Methods

Gulf wobbegong continuous dept contours to assess reef iodiersity. A copete surey consists of te Cobbler wobbegong fooin coponents lack cowrie

Giant cuttlefish  oto uadrats taen at . interas aon te transect ine per transect.  is sureyed in to ide y i ands parae it te transect ine. Southern Australia’s marine macroalgal flora has the highest levels of species richness and  ryptic fis and are .c acroinerterate ousc ecinoder and crustacean searces in ide y i ands eiter side of te transect ine. endemism of any regional macroalgal flora in the world (hillips owever despite their intrinsic and economic value temperate reef systems are often overlooked by their tropical ac surey ocation as ocated apart. utipe transects itin a surey ocation reef counterparts A defining feature of these reef systems is the kelp (Ecklonia Radiata ere ocated itin of eac oter. e ony sites in ic transects ere not undertaen which is largely supported by neighbouring seagrass systems that facilitate both reef as it ay ort and ort entra as tey did not adere to te reuireents of the RLS methods. However, location species was noted via an area ‘swim around’. interconnectivity (eck et al. Ricart et al. and provide important ‘nursery’ areas erefore tese sites ae een excuded fro te ain data anaysis ut are incuded in for fishes (enkins and heatley cevittIrwin et al. In South Australia Appendix . pecies identifications ere supported y Fishes of Australia’s Southern Coast seagrass habitats are protected under the Native Vegetation Act ( oon et al., . Current levels of both scientific and public engagement threaten the health and longevity of ae uer of transects at sites. these significant systems (ennett et al. . As part of AusOcean’s first expedition to KI’s Smith Bay No of transects north coast Smith ay was selected as an appropriate site for a comprehensive marine life ast ocs survey due to both its high diversity of flora and fauna and uniue variety of habitats ast ast ore Although a number of both scientific and communitybased programs have conducted ort entra A ort A surveys along the north coast of KI collecting baseline data on fish invertebrate and algae ree anne est entra et al et al communities for long term reef health monitoring (cArdle Reinhold est ore

Scorseby aker Smith ay remains relatively lightly studied est est ocs

Smith ay arine cology Report it ay arine cooy eport

late ivers preparin to surve.

N NC

E E WR ER C WC WS W Smith a E

ES E

late ivers conductin reef life surves. Fiure ap of surve locations and imae of Smith a facin east.

Smith a arine colo Report Smith a arine colo Report

late ivers preparin to surve.

N NC

E E WR ER C WC WS W Smith a E

ES E

late ivers conductin reef life surves. Fiure ap of surve locations and imae of Smith a facin east.

Smith a arine colo Report Smith a arine colo Report

Results West ied Creek Channel sponesearass Smith a is comprised of mied roc reef, dense searass and spone haitat. Roc reefs West Central and patches of macroalae covered were dominated macroalal assemlaes comprisin Cystophora spp., Sargassum spp., roc reef. and Ecklonia radiata with interstitial patches of Posidonia spp., Amphibolis spp. and Zostera nigricaulis searasses. Roc reef haitat sites were often covered in the rown ala Lobophora variegate. Surve locations have een rouped toether in relation to their area North Rule and shell ecolo tale . ast Rocs, ast shore and est Shore had much hiher macroalal cover North Central framents with in comparison to other sites which consisted of mied searass, roc reef and spone with mied searassspone areas of are sand. he northern sites sustrate comprised of are sand, shell framents and and patches of rhodoliths Sporolithon durum with interspersed patches of searass, roc reef and spone. roc reef. t is worth notin that althouh the haitat at these deeperwater sites was somewhat framented, supportin less dense canopies, a numer of macroalae species includin

Scaberia aghardii and several species of Cystophora and Sargassum were noted tale . Across all surveed sites within Smith a, species of fish and species of inverterates ale Area ecolo of each site. Site Area Ecology Image were noted, comprisin individuals fish and inverterates. f these, fish East Rocks ense macroalae and inverterates were noted within transects. here multiple transects were East Shore covered roc reef. West Shore undertaen, data has een collated to assess each site. t should e noted that the scallop count from the oth orth and orth Central has een ecluded due to their occurrence in lare aundances and lac of formal transects.

he Senator wrasse was the most commonl occurrin species appearin at all sites followed the lue throat wrasse at sites and the lacspotted wrasse at sites tale . he most East ied macroalae West Rocks covered roc reef freuentl occurrin inverterates were the estern slatepencil urchin at sites and oth and searass. the ainted lad mollusc and the iscuit star noted at sites tale .

ale Freuenc of ccurrence F of the most commonl sihted species. Fish Species (FOO) Invertebrate Species (FOO) Senator rasse estern slate pencil urchin lue throat rasse ainted lad

lacspotted rasse iscuit Star Castelnau’s wrasse ( us orwon, encil weed whitin, apie perch, ellowheaded hula fish, oadfish

Smith a arine colo Report Smith a arine colo Report

ale Freuenc of ccurrence F of the most commonl sihted species. Fish Species (FOO) Invertebrate Species (FOO) Senator rasse estern slate pencil urchin lue throat rasse ainted lad

lacspotted rasse iscuit Star Castelnau’s wrasse ( us orwon, encil weed whitin, apie perch, ellowheaded hula fish, oadfish

Smith a arine colo Report Smith a arine colo Report

lst s sees were rere at ne ste nl er nerterate sees e ste wt te est nuer sees (t s an nerterate suree was est urre n tree r less stes (ure Central llwe ast re an est re (ure

ees ees sees reuen urene (nuer stes ast s ast ast re Cree est est est est s nerterates Cannel Central re s te (ast t est ure reuen urrene s an nerterate sees

ure tal sees at ea ste

t est an est s ete te est nuer nerterate sees an stes

ast re est Central an est re a te est nuer s sees (ure

tes wt te est nuer nerterate sees ete te lwest nuer s sees

late enatr wrasse (Pictilabrus laticlavius

sees

ast ast ast Cree est est est est s re Cannel Central re s

te (ast t est

s nerterates late estern slateenl urn (Phyllacanthus irregularis ure s an nerterate sees urrn n ea ste

t a arne l ert t a arne l ert

lst s sees were rere at ne ste nl er nerterate sees e ste wt te est nuer sees (t s an nerterate suree was est urre n tree r less stes (ure Central llwe ast re an est re (ure

ees ees sees reuen urene (nuer stes ast s ast ast re Cree est est est est s nerterates Cannel Central re s te (ast t est ure reuen urrene s an nerterate sees

ure tal sees at ea ste

t est an est s ete te est nuer nerterate sees an stes

ast re est Central an est re a te est nuer s sees (ure

tes wt te est nuer nerterate sees ete te lwest nuer s sees

late enatr wrasse (Pictilabrus laticlavius

sees

ast ast ast Cree est est est est s re Cannel Central re s

te (ast t est

s nerterates late estern slateenl urn (Phyllacanthus irregularis ure s an nerterate sees urrn n ea ste

t a arne l ert t a arne l ert

e st aunant s (est nuer nuals was te lastte wrasse Species of Conservation Significance llwe te ellweae ula s an te luetrat wrasse e st aunant eeral sees nseratn snane were nte e estern lue rer was ste nerterate was te estern slate enl urn llwe te ante la llus an at ast s te nsnut ars was ste at Cree Cannel est Central an rt te sut star (tale an t te utern lue el an ee searans at rt Central ale st aunant s an nerterate sees ( entes sln sees Fish Species Invertebrate Species Syngnathids la stte wrasse ( estern slate enl urn ( ree sees nnatae were nte at rt Central n te eeer waters te a ellweae ula s ( ante la ( at et rsn tw es Stigmatopora nigra an Vanacampus margaritifer, luetrat wrasse ( sut star ( eras ( erlln sut star ( an s ee searans Phyllopteryx taeniolatus. lerell ( utern r lster ( Cetaceans tes ast re an est Central ete te est nuer nuals rsn ree ttlense lns were ste at est rs utse te suree transet t sul stl s ese nuers were ue n art t te resene an aunane sln e nte n transt tru t a Cn ttlense lns were resent at ea sees (tale ast s an Cree Cannel ete te lwest nuer nuals ste utse suren urs (ure weer ts a e n art ue t te la relate transets tes est an est s n te western se te a were te nl latns were re nerterates Coral Plesiastrea versipora Coscinaraea mcneilli tan s were suree w ln rn rals were ste an ne lare teerate ral P.versipora nearn tall an n ruerene an a saller

ral aratel n ruerene was late n lse rt t ast rs nalss

nate tat te larer ral surte at least s sees sle n llete tae ln C.mcneilli was ste at rt Central

Commercially Valuable Species

utern r lsters were ste at est s ast re an est re an alne

at est

nuals

Other species of interest

e nl tus ste was late at Cree Cannel utse a transet ast s ast ast re Cree est est est est Cannel Central re s

te (ast t est

s nerterates

ure tal nuer s an nerterates rere at ea ste

t a arne l ert t a arne l ert

ral aratel n ruerene was late n lse rt t ast rs nalss

nate tat te larer ral surte at least s sees sle n llete tae ln C.mcneilli was ste at rt Central

Commercially Valuable Species

utern r lsters were ste at est s ast re an est re an alne

at est

nuals

Other species of interest

e nl tus ste was late at Cree Cannel utse a transet ast s ast ast re Cree est est est est Cannel Central re s

te (ast t est

s nerterates

ure tal nuer s an nerterates rere at ea ste

t a arne l ert t a arne l ert

late Cn ttlense ln (Tursiops spp. trae at est late estern lue rer (Achoerodus gouldii trae at ast s

late ee searan (Phyllopteryx taeniolatus trae at rt Central

late nsnut ars (Pentaceropsis recurvirostris trae at Cree Cannel

late ter earl es (Vanacampus margaritifer trae at rt Central late utern lue el (Paraplesiops meleagris) trae at rt Central

t a arne l ert t a arne l ert

late Cn ttlense ln (Tursiops spp. trae at est late estern lue rer (Achoerodus gouldii trae at ast s

late ee searan (Phyllopteryx taeniolatus trae at rt Central

late nsnut ars (Pentaceropsis recurvirostris trae at Cree Cannel

late ter earl es (Vanacampus margaritifer trae at rt Central late utern lue el (Paraplesiops meleagris) trae at rt Central

t a arne l ert t a arne l ert

Discussion

e el wtn t a s l etereneus rn le atat r a ra

sees nlun ses an nerterates e aunane ses n rees s nluene a aret sal an t atrs (res aer lls ( nates

tat aralal seatn rates n utern ustrala are nluene lutuatn enrnental ntns aunane sutale r ree sustrate atat eterenet an te war waters te eeuwn urrent ese eatures a n antann aurale

ntns e eeuwn urrent lws ut aln te estern ustrala ast rnn

warer water east tru te reat ustralan t (letn an e an a run eet n atat ntns

t a s art a l nnete arne enrnent te east are u a an

n a an t te west s asw a e latter s artularl ntewrt as a

latn reuente lns w were sere n reat nuers urn ur sen

eetn ln resene n te nrt ast s surte new eene tat

late Cral (Plesiastrea versipora suests ulatn nnett ttlense lns etween anar slan an ut ustralan anlan waters (Cr et al. . The bay’s diverse assemblage of organisms a e nluene n art ue t ts unue latn eall stuate etween tw arne

ars te east les te nunter arne ar an te sutern ener ul arne ar

t te west (atural esures anar slan arne ars are nwn t nluene adjacent marine environments via the ‘spillover’ effect, invln te eent nuals arss resere unares (wle an ertatn larae an reruts (Clanaan

an an weer te satal etent tese eets ar nseral (areln

et al. et al. en a la

ttal sees s an nerterates were suree nlun seeral sees listed as ‘In peril” by the conservation council (Reef Watch, 2019). e st nl

urrn sees rsn te wrasses were als te st aunant aearn at sure latns n t ses te a s ete strn atat assatn wt alst

rere as snle ste assate sees ue n art t te unue el stes arss

t a ese elal aratns are nluene sal letes su as

sustrate stn an tra an resene an aunane aralal an late er suren ral

t a arne l ert t a arne l ert

Discussion

e el wtn t a s l etereneus rn le atat r a ra

sees nlun ses an nerterates e aunane ses n rees s nluene a aret sal an t atrs (res aer lls ( nates

tat aralal seatn rates n utern ustrala are nluene lutuatn enrnental ntns aunane sutale r ree sustrate atat eterenet an te war waters te eeuwn urrent ese eatures a n antann aurale

ntns e eeuwn urrent lws ut aln te estern ustrala ast rnn

warer water east tru te reat ustralan t (letn an e an a run eet n atat ntns

t a s art a l nnete arne enrnent te east are u a an

n a an t te west s asw a e latter s artularl ntewrt as a

latn reuente lns w were sere n reat nuers urn ur sen

eetn ln resene n te nrt ast s surte new eene tat

late Cral (Plesiastrea versipora suests ulatn nnett ttlense lns etween anar slan an ut ustralan anlan waters (Cr et al. . The bay’s diverse assemblage of organisms

a e nluene n art ue t ts unue latn eall stuate etween tw arne ars te east les te nunter arne ar an te sutern ener ul arne ar

an an weer te satal etent tese eets ar nseral (areln

et al. et al. en a la

ttal sees s an nerterates were suree nlun seeral sees listed as ‘In peril” by the conservation council (Reef Watch, 2019). e st nl

urrn sees rsn te wrasses were als te st aunant aearn at sure latns n t ses te a s ete strn atat assatn wt alst

rere as snle ste assate sees ue n art t te unue el stes arss

t a ese elal aratns are nluene sal letes su as

sustrate stn an tra an resene an aunane aralal an late er suren ral

t a arne l ert t a arne l ert

seagrass communities. any species surveyed in this study appear in earlier documents large teperate oral Plesiastrea versipora as loated in lose proiity to surveyed site pertaining to fish and invertebrate biodiversity assessments (crdle et al. 201, Reinhold et ast ros ith a saller oral noted less than aay he larger oral as al. 201, coresby aer, 200). approiately in iruerene and supported at least speies o ish he saller oral as approiately in iruerene arge olonies o this oral ere irst ites dominated by dense macroalgae cover, supported species such as the ebra fish and disovered in outh ustralia over years ago ohin ard orals suh as these ilver drummer, hich ere not noted anyhere else in the ay. These species freuent high are very slo groing in teperate aters ith varying rates o less than per year algal biomass areas due to their herbivorous diets consisting of a variety of green, bron and urgess et al. ue to the rarity o longlived speiens in teperate aters there red algae (lements hoat, 199). nvironments ith high macroalgal cover also provide have been e studies o environental reords urgess et al. roth o these orals habitat compleity and protection from predation maing them ideal refuges for a variety of is dependent on upon a ultitude o environental ators inluding teperature nutrient fishes (ayton 19). ast hore, characterised by dense macroalgae cover supported both availability turbidity depth and light availability urgess et al. istorially any o the highest abundance of individuals and number of fish species. these larger olonies ere dredged up by tralers dyvane and ipated through ites consisting of a mied spongeseagrassrocy reef habitat often neighboured patches of eologial odiiations suh as breaater onstrution he egister high density seagrasses. pecies such as the ongtail eed hiting, harpnose eed hiting peies o interest suh as the ong snout boarish estern blue groper outhern blue devil and lender eed hiting ere surveyed only at these sites. Research indicates eed hiting and eedy seadragon ere noted in the bay and are listed as speies o onservation species sho strong habitat association to seagrass near reef edges (hepherd et al. 2009). onern n ddition to ore speies ro the yngnathidae aily proteted under the This is consistent ith the area ecology ehibited at sites here these species ere noted. t ere also noted yngnathids ehibit lie histories and behaviours hih aes igh numbers of invertebrates ere surveyed in the estern sites of the bay including West the vulnerable to deline oster and inent hene their notable proteted status entral, West and West Rocs. This is liely due to the absence of canopyforming tudies traing Phyllopteryx taeniolatus indiate sall hoe ranges and high site idelity macroalgae, and associated habitat structure and food ebs (rutter Irving 200). In hih has aor ipliations or eetive habitat anageent and onservation o this support of this, research indicates areas of high density seagrass aid in sustaining large proteted speies anheaara and ooth macroinvertebrate communities (ttrill et al. 2000). Interstitial seagrass habitats are important ecological components ensuring reef interconnectivity (ec et al. 200) hilst providing essential ‘nursery’ habitat for a variety of fishes (enins and Wheatley 199

cevittIrin et al. 201).

t surveyed sites orth and orth entral reef shelfs and sponge gardens provide protection and habitat for a diverse range of species. 19 species of fish and 1 species of invertebrates present at these sites ere not noted anyhere else in the bay. lthough the environment is somehat fragmented, these uniue pocets of varied topography are integral components of the ider marine environment and provide important refuges for fishes. These sites ere not included in the main data analysis, hoever, a number of species of conservation concern such as the outhern blue devil and Weedy seadragon ere noted, as ell as to species of protected pipefish.

mith ay arine cology Report 2 ith ay arine ology eport

cevittIrin et al. 201).

mith ay arine cology Report 2 ith ay arine ology eport

Limitations Conclusions and Future Research

ultiple transets ere unable to be surveyed at every site his redued our overall data he ecoloy within mith bay is hihly heteroeneous providin comple habitat for a myriad olletion aeting speies ounts and the overall results his should be taen into of species both fishes and invertebrates. he distribution and abundance of species is onsideration hen oparing data ro ast ros and ree hannel here only one influenced by a variety of physical and biotic factors includin but not limited to substrate transet as undertaen dditionally the ore entral parts o the bay ere not surveyed composition and toporaphy and presence and abundance of macroalal and searass his as due to both eather and tie restritions that inhibited urther data olletion communities. he uniue ecoloy of sites across the bay is reflected in the hih number of sinle site associated species. ll dives ere undertaen during the day s speies behaviours vary at night it ould have been valuable to undertae surveys both during the day and at night acroalal covered reefs provide key ecoloical services habitat protection and are an important food source for many species. Interstitial searass habitats are essential ecoloical he trips onsisted o our divers three o hih ere ne to the survey ethod and components ensurin reef interconnectivity whilst providin vital ‘nursery’ habitat for a speies identification. It was evident that diver’s observational capabilities and species variety of fishes. hese systems are interal components of the wider reat outhern eef identiiation sills iproved etensively during in situ ativities hereore it is liely that ystem spannin the entire southern coastline of ustralia. lthouh outhern ustralia there are disrepanies beteen earlier and later onduted surveys ariability in loal marine macroalal flora has the hihest levels of species richness and endemism of any onditions suh as urrents andor visibility also aeted surveying apabilities hih ay reional macroalal flora in the world current levels of both scientific and public enaement have inluened the inal results threaten the health and lonevity of these sinificant systems. tilising the transet ethod is eetive in standardising data olletion ethods Much like the rest of Kangaroo Island, Smith Bay’s marine environment ehibits hih species however many ‘skittish’ species of fish were likely missed due to divers presence and transect richness and endemism supportin an abundance of emblematic and threatened species with restritions ie ide band hih conservation value. he now documented presence of numerous lare temperate corals

and a number of protected species includin those from the ynnathidae family outlines the importance of onoin marine life surveys with much left to be discovered. uscean aims to increase public awareness perception and appreciation of these manificent

temperate ecosystems that are often overlooked by their tropical reef counterparts. hese were the first of many anaroo Island epeditions hihlihtin the diversity and richness of

mith ay and the north coast. uture research will involve additional marine life surveys substantial footae collection via camera sled andor and potential analysis of the

internal compositions via coral core drilled samplin of the coral which can provide historic climate data of the area.

ith ay arine ology eport mith ay arine coloy eport

Limitations Conclusions and Future Research

temperate ecosystems that are often overlooked by their tropical reef counterparts. hese were the first of many anaroo Island epeditions hihlihtin the diversity and richness of

mith ay and the north coast. uture research will involve additional marine life surveys substantial footae collection via camera sled andor and potential analysis of the

internal compositions via coral core drilled samplin of the coral which can provide historic climate data of the area.

ith ay arine ology eport mith ay arine coloy eport

References ec, , arruthers, , uarte, , ughes, AR, endric, G, rth, R, illiams, S rohic ransfers from Seagrass eados Susidie iverse arine and ttrill, M, Strong, , oden, re macroinertebrate communities influenced by errestrial onsumers. 11, . seagrass structural comleity Ecography 23, ochin, otes on the discover of a large mass of living coral in Gulf St incent Bennett, S, ernberg, , onnell, S, obday, , ohnson, , olocanska, S he ith iliograhical references to the recent corals of South Australia. ransactions ‘Great Southern Reef’: social, ecological and economic value of Australia’s neglected of the Roal Societ South Australia 3, –. kel forests Marine and Freshwater Research 67, enins, G, heatle, he influence of haitat structure on nearshore fish Burgess, S, Mculloch, M, Mortimer, , ard, M Structure and groth rates of assemlages in a southern Australian emament: omarison of shallo seagrass, the highlatitude coral lesiastrea ersiora Coral Reefs 28, reefalgal and unvegetated sand haitats, ith emhasis on their imortance to hoat, , illanders, B, ollard, Achoerodus gouldii The IUCN Red List of recruitment. 221, . Threatened Species e, ieed anuary inloch, . A. . httddoiorgIKSen . angaroo sland atural Resources oard, lements, K, hoat, omarison of herbiory in the closelyrelated marine fish ingscote. genera Girella and Kyphosus. Marine Biology 137, cArdle, A, ashmar, , lein, iving deeer: a communit assessment of ribb, , Bartram, , Bartram, , Seuront, e idence for Bottlenose olhin Kangaroo Island’s rocky reefs. Final report, Caring for our Country Community Action ursios s oulation onnectiity beteen Kangaroo Island and South Grants o. G. ustralian Mainland aters Open Journal of Marine Science 8, clanahan, R, angi, S Sillover of eloitale fishes from a marine ar and its da Sila, IM, ill, , Shimadu, , Soares, MM, ornelas, M Silloer ffects of a effects on the adacent fisher. 10, . ommunityManaged Marine esere PLoS One 10, e cevittrin, , acarella, , aum, Reassessing the nurser role of seagrass ayton, K cology of Kel ommunities Annual Review of Ecology and Systematics haitats from temerate to troical regions: a metaanalsis. 16, 557, . oster, S, incent, ife history and ecology of seahorses imlications for iddleton, , e, A A revie of the shelfslope circulation along Australia’s conseration and management Journal of Fish Biology 65, southern shelves: ae eeuin to ortland. 75, . omon, M, Bray, , Kuiter, () ‘ishes of ustralias southern coast.’ e olland atural Resources angaroo sland arine ars, atural Resources angaroo sland, ublishers ty td Sydney vieed arch htts:.naturalresources.sa.gov.auangarooisland armeliniien, M, e irach, , BayleSemere, , harbonnel, , arcaharton, , dy, ar sandlacesmarinears. , reuafa, , eones, , Sncheere, , alle, radients of rth, R, arruthers, , ennison, , uarte, , oururean, , ec, , ughes, AR, abundance and biomass across resere boundaries in si Mediterranean marine endric, GA, enorth, , larni, S, Short, , acott, , illiams, S rotected areas idence of fish silloer Biological Conservation 141, A Gloal risis for Seagrass cosstems. 56, .

Smith Bay Marine cology eort Smith a arine colog Reort

illips, A arine macroalgal iodiersity otspots y is tere ig species Sale, A, Burrows, T, oore, P, onnor, N, Hawkins, SJ (20) Threats and knowledge ricness and endemism in soutern Australian marine entic flora gaps for ecosyste serices proided by kelp forests a northeast Atlantic 10, . perspectie. 3, 008. rose, AA, illanders, , rook, , Foler, A, all, KC, teer, A, ellin, C, Clisy, , Tanaka, H, hiba, S, usa, T, Shoi, J (208) ay–night change in fish counity structure in anner, , ard, , Fordam, A idence for a roadscale decline in a seagrass bed in subarctic waters. 84, 228. giant Australian cuttlefis iepia apamai aundance from nontargeted The Register (1909) ‘The Glenelg Corals’, 7 July, p.4, viewed 29 January 2019, surey data. 66, . httpstroe.nla.go.aunewspaperarticle2 eef ife urey Foundation tandardised urey rocedures for onitoring ocky Coral eef cological Communities, oart, asmania, Australia. eef atc Feral or in peril out Australia, ieed anuary ttpsdnaprom.cloudfront.netconserationsapagesattacmentso riginalFeralorineriluidelores.pdf icart, A, almau, A, re, , omero, ffects of landscape configuration on te ecange of materials in seagrass ecosystems. 532, . einold, , Kinloc, , asmar, K, cArdle, A rock, Community Assessment of eef iodiersity on Kangaroo Island. atural esources Kangaroo Island Coast and arine rogram eport o. C oley, arine reseres in fiseries management. 4, . anceCamara, , oot, oement, ome ange and ite Fidelity of te eedy eadragon ylloptery taeniolatus eleostei yngnatidae. 70, . 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. oyal ociety of out Australia Adelaide. eperd, A, aker , ron A, Craford, eef fises of Kangaroo Island a nursery role for astern Coe upplementary eport for Commonealt epartment of te nironment, ater, eritage and te Arts nirofund roect .

mit ay arine cology eport Sith Bay arine Ecology Report

Appendices

Appendix 1: Inventory of species Total and inludes orth Central and orth whih were eluded ro the ain data analysis.

Ros ast est orth Total ast Ros ast hore est est est hore est est Central est orth Central Transet Total Transet peies Coon nae Channel Cree ish laspotted wrasse 10 11 1 0 2 1 10 122 ellowheaded hula ish 4 0 100 0 2 9 4 19 luethroat wrasse 4 2 4 2 2 2 7 7 era ish 2 0 2 2 2 4 ilverelly 0 0 1 0 1 enator wrasse 1 4 1 4 2 2 avy gruish 1 11 12 2 17 Castlenau wrasse 1 2 1 11 1 enil weed whiting 4 1 2 2 10 4 14 usy orwong 2 1 2 1 1 9 4 12 rownspotted wrasse 1 9 9 Rainow ale 2 2 alyin 2 ea sweep 4 2 2 Goatish 2 1 7 4 4 7 1 agpie perh 1 1 1 4 9 Toadish 1 1 1 1 4 4 4 4 oonlighter 1 4 2 4 2 ilver druer 1 2 2 2 ith ay arine ology Report 2

Rough ullseye 1 1 4 2 piny tailed leatheraet 2 2 1 2 1 estern lue groper 2 2 1 2 1 lathroat threein 1 1 2 2 2 2 Hypoplectrodes nigroruber anded seaperh 2 2 1 2 1 orseshoe leatheraet 2 2 1 2 1 Twinar goy 2 2 1 2 1 Coon ullseye 2 2 1 2 1 ongsnout oarish 1 1 2 2 lender weed whiting 1 2 2 1 2 harpnosed weed whiting 2 2 1 2 1 noo 2 2 1 2 1 Gloeish 1 1 1 1 1 lue weed whiting 1 1 1 1 1 Coon weedish 1 1 1 1 1 erring ale 1 1 1 1 1 ongtail weed whiting 1 1 1 1 1 haws owish 1 0 0 1 1 rnate owish 2 0 0 2 1 ellowtail sad 0 0 0 0 1 utterly perh 1 0 0 1 1 arer perh 4 0 0 4 1 ight redish 2 0 0 2 1 estern tala 0 0 2 estern leaner lingish 1 0 0 1 1 ongin pie 100 0 0 100 1 ld wie 0 0 1 ispine leatheraet 2 0 0 2 1 ig head gunard perh 1 0 0 1 1 outhern lue devil 2 0 0 2 1 ith ay arine ology Report

Appendices

Appendix 1: Inventory of species Total and inludes orth Central and orth whih were eluded ro the ain data analysis.

longate ullseye 20 0 0 20 1 rownspotted oarish 1 0 0 1 1 rangelined ullseye 0 0 0 0 1 eedy seadragon 0 0 1 ideodied pipeish 1 0 0 1 1 otheropearl pipeish 1 0 0 1 1 Total Fish 2 1 191 42 21 2 17 20 2 9 902 Total Fish Species 9 9 17 27 9 1 14 7 7 7 55 nverterates estern slatepenil urhin 2 4 1 2 4 2 0 ainted lady 2 1 2 4 17 17 isuit star 2 1 2 4 1 14 1 outhern ro loster 4 2 11 11 erillion isuit star 2 7 1 11 1 4 nidentiied sallop 4 10 2 10 2 nidentiied herit ra 4 4 2 2 outhern sea uuer 2 1 1 2 4 4 range ree star 1 1 2 4 4 alone 4 4 1 4 1 Granular seastar 1 4 2 4 2 ale osai sea star 1 1 1 eriwinle 2 1 2 2 osai sea star 1 1 1 ottled seastar 1 2 2 1 2 leven ared seastar 1 1 2 2 2 2 outhern spindle 1 1 2 2 2 2 outhern herit ra 1 1 2 2 2 2 inna 20 17 1 1 2 2 9 4 Tulip shell 1 1 2 2 tupy penil urhin 1 1 1 1 2 2 ith ay arine ology Report 4

ulti spined seastar 1 1 1 1 1 or snail 1 0 0 1 1 asetstar 0 0 1 anyspotted sea star 1 0 0 1 1 Curviers sea uuer 10 2 0 0 12 2 ustralasian rown sea uuer 0 0 0 0 outhern asetstar 0 0 1 ea uuer 1 2 0 0 2 Gunns si ared seastar 2 0 0 2 1 nail 1 0 0 1 1 aoris seastar 2 0 0 2 1 eon lolly doris 1 0 0 1 1 Cushion seastar 1 0 0 1 1 nail 1 0 0 1 1 eastar 1 0 0 1 1 Total invertebrates 7 9 11 0 29 1 21 12 2 0 12 222 Total Invertebrate Species 4 4 1 7 11 11 29 35 Total Count of fish and invertebrates 0 40 202 402 0 44 1 4 701 1124 Total number of fish and invertebrate species 1 1 2 4 1 1 24 20 1 1 90

ith ay arine ology Report

Appendix 2: Expedition images

ate er a se trae at est etra ate sas ) trae at rt etra late 1 Ree ledge photographed at orth Central. late 14 ld ives ( ) photographed at est Central.

ate k ae ra ) ate ra ) trae at trae at rt etra rt etra late 1 Basket star’s late 1 ideody pipeish ( ) ) photographed at orth Central. photographed at orth Central.

late 17 haws owish ) late 1 eedy seadragon ) ate er a ra ) ate ra ) photographed at orth Central. rnate owish ) photographed at orth Central.

ith ay arine ology Report t Ba are ert

Appendix 2: Expedition images

ate er a se trae at est etra ate sas ) trae at rt etra late 1 Ree ledge photographed at orth Central. late 14 ld ives ( ) photographed at est Central.

ate k ae ra ) ate ra ) trae at trae at rt etra rt etra late 1 Basket star’s late 1 ideody pipeish ( ) ) photographed at orth Central. photographed at orth Central.

late 17 haws owish ) late 1 eedy seadragon ) ate er a ra ) ate ra ) photographed at orth Central. rnate owish ) photographed at orth Central.

ith ay arine ology Report t Ba are ert