Scott Chidgey: Response to Expert Witness Statements and IAC RFI

CEE Pty Ltd Environmental scientists and engineers

Gas Import Jetty and Pipeline Project Environment Effects Statement (The EES)

Inquiry Advisory Committee

Scott S Chidgey

Expert Witness Response to Marine Biodiversity to

Expert Witness Statement Submissions & IAC Request for Information

Prepared for: Ashurst and Hall&Wilcox Lawyers

September 2020

CEE Pty Ltd Unit 4 150 Chesterville Road Cheltenham VIC 3192 03 9553 4787 cee.com.au

Scott Chidgey Response to Expert Witness Statements and IAC RFI Marine Biodiversity Impact Assessment

CONTENTS

Response to Expert Witness Statement 1. Prof Perran Cook 3 Response to Expert Witness Statement 2. Cardno Australia Pty Ltd 8 Response to Expert Witness Statement 3. Dr Matt Edmunds 14 Response to Expert Witness Statement 4. Mr Frank Hanson 19 Response to IAC Request for Further Information 21 Declaration 29 Appendix to Item 6 30

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 2 of 41 Scott Chidgey: Response to Expert Witness Statements and IAC RFI

CEE Pty Ltd Environmental scientists and engineers

Response to Expert Witness Statement 1. Prof Perran Cook Professor Cook is a Professor of Chemistry at Monash University and provides a balanced discussion of matters presented in EES Technical Appendix A and its Annexure A, related to chlorine toxicity and the formation of halogenated organic compounds. My responses to his discussion are listed with reference to the Item numbers used in Prof Cook’s Statement.

1. In Item2, 3 and 4, Prof Cook discusses the derivation and acceptability of the guideline value for chlorine established by CSIRO. a. He appears to agree with CSIRO’s recommended guideline value for chlorine as an acute value, but in Section 4 expresses reservations on its applicability as a chronic value. b. I would add that the CSIRO the values include important conservative considerations including: i. the laboratory results were chosen from flow-through laboratory tests that did not allow for degradation of the key toxicants (Chlorine produced Oxidants or CPOs) to less toxic forms (halogenated organocarbons or HOCs) over the duration of the test. Hence, they overestimate the toxicity expected for the exposure experienced in the field ii. Our modelling of the chlorine contours is based on the CSIRO conservative value based on dilution only, with no allowance for degradation of the more toxic CPOs to HOCs. Hence a further level of conservatism to the extent of CPO and HOC toxicity to the marine ecosystem was added in the modelled outputs presented in out reports. 2. In item 7, Prof Cook notes that brominated compounds are naturally produced by algae through natural processes. a. I would add that bromoform, dibromoacetic acid (DBAA), tribromophenol (TBP) are produced also by marine algae (Jenner and Wither 2011, Gribble 2015, Mata et al 2013), such as the red alga Asparagopsis, which is present as a natural epiphyte of seagrass in Western Port (Figure 1).

Figure 1. Asparagopsis in North Arm Western Port

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 3 of 41

Scott Chidgey Response to Expert Witness Statements and IAC RFI Marine Biodiversity Impact Assessment

3. In Item 8, Prof Cook notes that “A wide range of brominated organic compounds are found in seawater after treatment with chlorine. Bromoform is typically dominant (93- 97% of THMs) with dibromoacetic acid (DBAA), dibromoacetonitrile (DBAN) and tribromophenol (TBP) comprising the majority of other identified brominated compounds.” a. As noted previously, marine biota produce these chemicals naturally. b. Prof Cook concludes that “the risk of these compounds is low compared to primary CPOs such as bromate and hypobromite” (the latter two compounds are oxidants). a. This is consistent with CSIRO’s explanation of the conservative nature of their guideline values for chlorine which is conservative in its estimate of the acute toxicity of CPOs by selecting predominantly flow-through bioassays (Annexure A, EES Technical Appendix A). 2. Prof Cook identifies the key HOCs produced compounds found in seawater after treatment with chlorine as bromoform, dibromoacetic acid (DBAA), dibromoacetonitrile (DBAN) and tribromophenol (TBP). a. These are consistent with Allonier et al 1999 (see my response to EPA submission). b. Allonier et al provide the concentrations of chlorine, bromoform, DBAN, TBP and DBAA in chlorinated effluents from three nuclear power stations on the English Channel. Allonier et al present concentrations for chlorine in mg/L and concentrations for the HOCs in μg/L. I provide Allonier et al’s data all expressed in μg/L. Table 1. Halogenated compounds in chlorinated seawater effluent, μg/L (From Allonier et al 1999) 1 Cl Bromoform DBAN TBP DBAA 2 μg/L μg/L μg/L μg/L μg/L 3 Gravelines 770 26.75 3.61 0.37 9.5 4 Penly 570 7.37 0.94 0.1 7.25 5 Paluel 200 26.8 2.83 0.14 10.19 6 Average 513 20.31 2.46 0.20 8.98 13 % of chlorine 0.55% 0.084% 0.003% 0.281% Line 13, my calculation c. Allonier et al state that the concentration of the HOCs is approximately proportional to the amount of chlorine. Hence, I consider that i. The concentrations of these HOCs in effluent from the FSRU (100 μg/L chlorine) would be less than half the average shown in Table 1 (513 μg/L chlorine); ii. the concentrations of these HOCs would be less one than 30th of their values shown in the Table 1 at the CSIRO chlorine concentration guideline vale of 6 μg/L. iii. Allowance for further reduction due to natural decay during mixing (see Table 2 would further reduce their concentration in ambient seawater.

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 4 of 41 Scott Chidgey Response to Expert Witness Statements and IAC RFI Marine Biodiversity Impact Assessment Table 2. Natural decay constants for bromoform, and other HOCs (From Jenner and Wither 2011)

3. In Section 9, Prof Cook refers to toxicity tests of bromoform, TBP and TBAA (haloacetic acid) on sea urchin embryos (Lebaron et al 2019). a. I have read Lebaron et al and provide the following comments and analyses. b. The endpoints for the 48 hour embryo exposure tests were provided as micromolar, µM (Lebaron et al 2019). c. The LOEC results reported by Lebaron et al, together with corresponding power station discharge concentrations (Allonier et al) and expected concentrations at the CSIRO Chlorine Guideline Value of 6 ug/L (= 0.17 µM) are shown in Table 3. Table 3. Comparison of HOC LOEC toxicity test results with chlorine values Toxicity tests Lebaron, et al 1 TBP Bromoform TBAA 2 LOEC, µM 3.02E+00 1.98E+02 3.37E+2 3 LOEC, µM 3.02 198 337 4 Average in PS, µM 0.005 0.08 0.041 5 Expected at GV 0.17 µM Cl 5.30E-06 9.39E-04 4.81E-04 Line 2. As reported by Lebaron Line 3. Lebaron converted to decimal form Line 4. Average concentrations in power station (PS) discharges, from Allonier et al 1999 Line 5. Expected concentration at CSIRO Chlorine Guideline value of 6 ug/L = 0.17 µM

d. Table 3 shows that the Lowest Observed Effects Concentrations (LOEC) of HOCs used in the tests were more than 500 times higher than the concentrations measured in power station discharges, and 1000s of times higher than could be expected at the at the CSIRO Chlorine Guideline Value of 6 ug/L (= 0.17 µM). e. Lebaron et al further tested composite mixtures of the HOCs at their respective NOEC, LOEC and twice the LOEC, to determine potential genotoxicity. i. They found that only the composite mixture at twice the LOEC showed evidence of potential genotoxicity. These concentrations are more than 1,000 times higher than the concentrations measured in power station discharges would be required to induce potential genotoxicity and many more thousand times higher than could be expected at the at the CSIRO Chlorine Guideline Value of 6 ug/L (= 0.17 µM). f. Lebaron et al noted that test biota from a “bromo-DBP-polluted area produced more resistant progenies, as if they were locally adapted”. In other words, marine biota adapt to exposure.

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 5 of 41 Scott Chidgey Response to Expert Witness Statements and IAC RFI Marine Biodiversity Impact Assessment g. Prof Cook cites tests toxicity tests of TBP on Daphnia magna (Howe et al 2005). This is a freshwater species and could be expected to have a low tolerance to TBP compared to any marine species. h. From this, I conclude that CSIRO’s Chlorine Guideline Value of 6 ug/L is an appropriately conservative for ecosystem protection from CPOs and associated HOCs. 4. Prof Cook cites two case studies from the Gulf of Fos in France: Boudjellaba et al 2016 (cited in EES Technical Appendix A) and; Manasafi et al 2019. a. I note that HOC concentrations in the Gulf of Fos should be considered in the following context from Boudjellaba et al 2016: • The industrial zone of the Gulf of Fos is the largest in Southern Europe • The Gulf is a “semi-enclosed bay favouring water confinement in some of its more restricted inlets and docks” • “Average tidal range is 0.4 m” • Facilities discharging chlorinated seawater to the Bay of Fos listed by Boudjellaba et 2016 include: • Two LNG terminals • Three power stations • Steel industry • An oil refinery • The discharges to “several millions m3 day” of chlorinated seawater • The area of the Bay of Fos is km2 compared to the area of North Arm in Western Port. b. These conditions are recognised by Prof Cook in a more general manner. c. The HOC concentrations of “1 - 5 μg/L” cited are within the ballpark of the concentrations from the three power stations discussed above (Allonier et al), and substantially below the toxicity levels LOECs as discussed above. d. Cross referencing these concentrations with Table 3 indicates that the concentrations of HOCs in the Gulf of Fos were considerably hundreds of times higher than the HOC concentrations corresponding to the CSIRO Guideline Value of 6 μg/L. 5. Prof Cook cites Khalanski and Jenner 2012: “…are persistent substances and their chronic toxicity constitutes a key question in the impact assessment of these substances. There is lack of sufficient experimental data to precisely assess the chronic toxicity levels of these substances.” a. On the same page, I note that Jenner and Khalanski state: “The annual production of CBPs by the chlorinated cooling waters of all the French coastal power plants in 2000 was estimated to be approximately 210 tons. This value pales in comparison with the natural production of bromoform by seaweeds and planktonic micro-algae in The Channel (estimated to be a few hundreds to a few thousands of tons) and with the production of bromoform in the world ocean (one to two million tons)”. b. Also note that Chlorine Guideline values have not been used (or quoted) in any of the above situations.

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 6 of 41 Scott Chidgey Response to Expert Witness Statements and IAC RFI Marine Biodiversity Impact Assessment 6. Prof Cook’s concludes that “an adverse ecological effect cannot be ruled out with a high degree of certainty (95%-99%) within the context of the Western Port marine environment”. a. However, on the basis of the above discussion, I consider the information in EES Technical Report A, its Appendix A and the additional information here provides a suitable background to support our conclusion of low to very low risk of chlorine toxicity (acute or chronic) in waters beyond the CSIRO Guideline Value of 6 μg/L for chlorine and that there will be “low risk of bioaccumulation of halogenated by-products given the hydrodynamic environment at Crib Point”. 7. In either case, Prof Cook and I would appear to agree that monitoring HPBs would be an important and interesting component of a monitoring program. Professor Cook’s contribution has added value to EPA’s submission item that halogenated by-product related “issues should be assessed in more detail in the IAC hearing”.

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 7 of 41 Scott Chidgey Response to Expert Witness Statements and IAC RFI Marine Biodiversity Impact Assessment Response to Expert Witness Statement 2. Cardno Australia Pty Ltd Cardno Australia Pty Ltd’s Witness Statement was prepared jointly by Dr Craig Blount and Dr Marcus Lincoln-Smith, both Senior Principals of Cardno Australian Pty Ltd (Cardno).

Cardno quotes the EES Scoping document: “descriptions of the existing environment to the extent relevant to the assessment of potential impacts” and states “We do not consider that the EES satisfies this requirement” I reject Cardo’s assertion with respect to EES Technical Appendix A and associated Annexures. Our approach to the EES is described previously in my Witness statement. We reviewed the project description and used available information and our own previous experience in Western Port to identify potential critical pathways of impact from the project to marine environmental habitats. We recognised that the project is located in an operating port. We used this information and initial hydrodynamic and dispersion modelling to provide integrated spatial boundaries for the descriptions of the existing environment to the extent relevant to the assessment of potential impacts. We progressively developed models to quantify the spatial and temporal extent of impacts on marine habitats. We initiated marine ecological investigations to provide further information on the nature of ecological communities and key species in the areas identified by the initial models that were most at risk. We further developed predictive tracer and particle dispersion models and ecosystem protection guideline values for the key stressors to determine the spatial and temporal extent of impact from the operation of the FSRU as a facility. The outcomes of marine ecological investigations provided contemporary information on the nature of the marine communities in the potentially impacted and adjacent areas. I consider that EES Appendix A and annexures provide the evidence that the EES requirements have been met, and I reject Cardno’s statement.

Poor sampling design…flawed for the purposes of environmental impact assessment (EIA) We adopted a sampling approach that was appropriate to describing “the existing environment to the extent relevant to the assessment of potential impacts” in the EES. Cardno’s criticism appears to be based on their approach to impact assessments using the “hypothesis testing” family of statistical analyses (Section 3.1.1.2 of their report) for detecting impacts “following approval”. This process tests for potential differences between potentially impacted and non-impacted sites. 1 Hence, I reject Cardno’s assertion that our sampling design was poor or that our work is flawed. Cardno’s approach would require at least an understanding of (1) the nature of the stressors (2) the extent of the predicted impacts, (3) the nature and distribution of marine community receptors that the decision-makers need to consider (4) agreement on the individual receptors that would be monitored for impact detection, and (5) an operating facility to create an impact. None of these were known prior to the EES and, even now, items 4 and 5 have not occurred.

1 Note that we used nMDS to compare infauna communities at the previously-dredged Berths 1 and 2 with undredged, natural reference sites in EES Technical Appendix Annexure D

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 8 of 41 Scott Chidgey Response to Expert Witness Statements and IAC RFI Marine Biodiversity Impact Assessment The plankton sampling program was based on procedures that were used to previously establish spatial and temporal patterns in zooplankton populations in Western Port and Port Phillip, and to estimate water body flushing times in East Arm of Western Port (Kimmerer and McKinnon, who are cited extensively in EES Technical Appendix A). Kimmerer and McKinnon (1985) explained the strategy for sampling numerous sites over numerous replicates at individual sites based on their ANOVAR analyses of initial results, and concluded “we were justified in spreading our effort over many stations instead of counting replicates”. They similarly explained the use of vertical trawls in terms of the tested vertical mixing of plankton in the strong tidal regime of Western Port. We adopted this previously tested strategy. In addition to zooplankton, our plankton program separately sampled three separate multispecies community components (phytoplankton, zooplankton and ichthyoplankton) comprising separate trophic levels (primary, primary and secondary consumers). Hence, the results for these three ecological units were part of an integrated program to assess risks of impact pathways as discussed previously in my Witness Statement. The inclusion of separate plankton components increases the ecological meaning of spatial and temporal patterns. We developed the plankton sampling program in consultation with specialist subconsultants who understood the purpose to describe plankton communities in lower North Arm, their variation over a twelve-month period and obvious spatial patterns and to inform interpretation of the particle entrainment model. They are all familiar with the work of Kimmerer and McKinnon in Port Phillip and Western Port and have worked with them in past research. Specialist independent subconsultants and experts in their fields provided valuable explanations of plankton ecology and interpretations on the seasonal and spatial patterns in abundance on planktonic communities of the phytoplankton, zooplankton and ichthyoplankton data. Their reports are provided as Annexures to EES Technical Appendix. Cardo makes no reference to Kimmerer and McKinnon, or the interpretation of the data by independent specialists in phytoplankton, zooplankton and ichthyoplankton ecology. We developed and used a purpose-build and validated integrated hydrodynamic, tracer and particle dispersion model as our primary tool to assess the spatial and temporal extent of impact from the operation of the FSRU. This, in combination with the results of the three- tiered plankton sampling program, was used to spatially quantify natural losses of plankton from Lower North Arm to Bass Strait, which was crucial to the assessment of entrainment losses as a proportion of natural losses. Particle models as a tool in describing plankton are now widely used in combination with sampling programs to explain planktonic spatial distributions and natural losses (Kimmerer et al 20142, Black et al 20153). Cardno makes no reference anywhere in their document to the particle model a fundamental, integrating tool to inform the prediction impacts on plankton from different parts of Western Port in the EES. As discussed previously in my Witness Statement, the entrainment model zones were informed by topographic, ecological habitat and hydrodynamic factors that may influence plankton characteristics. The integrated hydrodynamic particle dispersion model provides the hydrodynamic description of the physical mixing, dispersion and flushing factors that are crucial to understanding plankton characteristics and distribution in Western Port. Our program fulfilled its primary role and provides valuable information on the nature of the plankton community in Western Port that is useful in proving context to the impacts subsequently predicted by the project dispersion and entrainment models.

2 Kimmerer et al (2014): “Tidal migration and retention of estuarine zooplankton investigated using a particle tracking model” Limnol and Oceanogr 59(3) 901-916 3 Black et al (2015): “Bubbles -The nutrient, phytoplankton, zooplankton and fish recruitment (NPZ-F) numerical model.” Technical Report 2015-1 School of Biological Sciences University of Melbourne, Sanctuary Beach Pte Ltd

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 9 of 41 Scott Chidgey Response to Expert Witness Statements and IAC RFI Marine Biodiversity Impact Assessment The aim of presentation of information that I have contributed to EES process is to inform a wide range of interested parties including public stakeholders, agencies, regulators and professional decision-makers with a range of backgrounds and interests. I consider that the EES Appendix A and annexures provides all information relevant to the assessment of potential marine environmental impacts of this project in an accessible format for a wide range of readers. I therefore strongly reject Cardo’s assertion that the plankton work or any other work presented by CEE is “flawed”.

Inspection of the many of the references relied upon in the EES indicates that much of that information is old and does not apply specifically to Crib Point. We did not rely on old references. As stated above, we developed new predictive tracer and particle dispersion models and ecosystem protection guideline values for the key stressors for this project. We initiated specific ecosystem investigations to provide contemporary information specific to Crib Point and Lower North Arm, including a 13-month study of the plankton community. We mapped benthic habitats in and adjacent to areas of predicted impact at and around Crib Point. We spent at least one day every two weeks on the waters of Western Port for 13 months in the region of Crib Point during EES. Hence, I reject Cardno’s assertion that we relied in old information and spatially irrelevant information.

Given the predicted impacts of Climate Change and natural variability in aquatic systems through time though, it is possible that comparisons among sites in Western Port would be confounded with temporal change As stated above, we initiated specific ecosystem investigations to provide contemporary information specific to Crib Point and Lower North Arm where relevant to the assessment of potential impacts. We have stated on numerous occasions in Appendix A and Annexures that our plankton monitoring program followed the methods and approach used by Kimmerer and McKinnon in their benchmark studies of zooplankton of Port Phillip and Western Port Bays in the 1980s. We applied their approach to sampling in the East Arm of Western Port in the early 1980s to our zooplankton, phytoplankton and ichthyoplankton sampling program in Lower North Arm in 2019. As a consequence, we were able to validly compare the seasonality and abundance of the key zooplankton species Acartia spp between sampling programs 35 years apart.

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 10 of 41 Scott Chidgey Response to Expert Witness Statements and IAC RFI Marine Biodiversity Impact Assessment There is no correct sample replication, that is, one sample is taken at each location and time and the EES combines sites when comparing times of sampling eg Figures 5-63 and 5- 64. This statement provides a misleading intent of the sampling program and the figures cited. The figures provide monthly abundances (using mean and standard error bars) for various zooplankton groups in Lower North Arm channel based on seven samples collected at positions dispersed along and across the channel. Hence there is no intent to show relationships among sites in these two figures. I consider that the figures presented in the EES are a reasonable representation of the monthly variation in zooplankton abundance and variation over the 13-month period December 2018 to December 2019. Comparison of the data from Lower North Arm over this period with data from East Arm in 1982-83 using the same method shows remarkable similarities in monthly variation. Hence, I consider that sampling replication is appropriate to the purpose of establishing the pattern of monthly variation in abundance over the 13-month period.

Figure 5-63 Figure 5-64 Figure 5-68 has no error bars…because only one sample was taken at each site and time. This limitation renders meaningless any comparison of plankton adjacent to Crib Point with the other sites sampled. This information is crucial for the EIA, but is lacking. Figure 5-68 includes four individual plots of site, date and abundance data for four zooplankton species. It clearly shows the spread of spatial data for each survey. No error bars are provided because all raw data are presented deliberately to show the spread of data points that represented as error bars in the subsequent plots (see below). Following Cardno’s reference to lack of error bars in Figure 5-68, Cardno have omitted to mention that the raw data were used immediately following Figure 5-68 in the ten figures of zooplankton showing means and error bars (Figures 5-69 to Figure 5-74), and a further ten figures of ichthyoplankton seasonal abundances (means and error bars) at sampling sites (5-78 to 5-87). Figures 5-70 and 5-71 are provided as examples.

Figures 5-70 and 5-71 showing seasonal Acartia abundance All these figures provide seasonal abundances (mean and standard error) for a range of species that show the seasonal relationship among the eight sample sites, including along the main axis of the channel and across the channel at Crib Point. They are accompanied by clear and transparent interpretations of the figures based on the generally understood concepts of means and standard errors.

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 11 of 41 Scott Chidgey Response to Expert Witness Statements and IAC RFI Marine Biodiversity Impact Assessment Overall, therefore, Cardno appears to have missed the crucial information that was present in EES Technical Appendix A but that they considered was lacking. Hence, I consider their comments in this matter are not valid. Vertical sampling Vertical sampling was adopted based on project operating characteristics of the FSRU, which will result in seawater being entrained over most of 14 m (average) water column below 2 m from the surface and 2 m above the seabed. Integrated vertical samples from approximately 2 m above the seabed to the surface were collected for phytoplankton, which are considered to be fully vertically mixed, and from 2 m above the seabed to 2 m below the sea surface for ichthyoplankton. Hence, the vertically integrated plankton samples were representative of the plankton that would be entrained by the FSRU.

Lack of inferential statistics As stated above, Cardno’s references to the use of inferential statistics in environmental impact assessment may be relevant to detecting impacts “following approval” and after commencement of operations when a stressor may be expected to show and effect on an ecological receptor. The statistical example provided by Cardno is one of many statistical approaches to impact detection. I have stated previously that, in my recent experience, environmental approvals are usually conditional on an approved monitoring and management plan. The scope and detail of any monitoring and mitigation programs would be determined in consultation with relevant environmental regulators. This has been the case for the Victorian Desalination Project (State) and Darwin’s Ludmilla Wastewater Treatment Plant discharge at East Point Outfall (Territory and Commonwealth). My approach to this matter is consistent with EPA’s submission to this EES: “EPA recommends Mitigation Measure ME16 stipulate that the proponent will consult with EPA about the exact nature of the monitoring programs, as part of the discharge licencing conditions”.

Crib Point Jetty as an aquatic habitat We provided reference to our previous published studies of the Crib Point Jetty, BlueScope Jetty and Long Island Point jetty as marine habitats in Section 5.7.1 of EES Technical Appendix A (and see Figure 5-29). These studies included 12 surveys sampling encrusting marine invertebrates at parts of BlueScope, Long Island Point and Crib Point Jetties from 2010 to 2017, as well seagrass and water quality sampling closer to Long Island Point Jetty. These studies were dealt with relatively briefly in the EES, but stated “strong similarities between the jetties in terms of community composition” over the period of the program. We noted that various other biota including small fish and pipefish were seen on the structures, but were “not abundant in the water column”. Similarly, fish and pipefish and other semi- mobile invertebrates were sparse on the jetty piles and seldom seen in the hundreds of photoquadrats taken during the program and for that reason were not included in the 17 biotic groups monitored. I have not observed that Crib Point jetty piles or the adjacent water column as particularly different from other jetty structures in Western Port.

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CEE biologist at Long Island Point Jetty, photoquadrat Crib Point Jetty may act as an artificial reef, but its primary role is as a functional port facility associated with the SEPP Beneficial Use “Navigation and Shipping”. In this respect, the jetty piles are subject to maintenance activities and access may be limited by shipping activity. On the basis of the above, I have not recommended monitoring of the jetty piles at Crib Point for this project.

Where do penguins go? See my response to IAC.

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 13 of 41 Scott Chidgey Response to Expert Witness Statements and IAC RFI Marine Biodiversity Impact Assessment Response to Expert Witness Statement 3. Dr Matt Edmunds Australian Marine Ecology Pty Ltd

Dr Edmunds provide a lengthy alternative approach to an EES, with different input and output requirements. In my experience, I consider the approach we have taken and that the information we have collected, interpreted and presented is more suitable and achievable that that proposed by Dr Edmunds. I therefore reject Dr Edmunds’ assertion that our contribution to the EES was not best practise and was therefore flawed or subjective. In my response below, I describe the framework, processes, science and assessment that have shaped the contents of our EES Technical Appendix A and associated annexures and subconsultant reports in a form that, I hope, is accessible to most stakeholders. I believe this is approach is clearly justified. I acknowledge that there are individual matters raised by Dr Edmunds in his Statement. I will be pleased to address these matters as appropriate to marine biodiversity during the Hearing. As discussed in my Witness Statement and my response to Cardno, our approach to the assessment of potential effects on the marine environment involved a series of steps that provide informed project and environmental context to the assessment of this particular project (GIJPP) in this particular environment (Western Port). This is our usual practise for risk-based assessment and fits within the legal framework for various levels of legal requirements for environmental approvals including the Commonwealth Environment Protection and Biodiversity Conservation Act, and the State Environment Protection Act, Environment Effects Act and, specific to the marine ecosystem, State Environment Protection Policy ‘Waters’ and the Flora and Fauna Guarantee Act to name the main items guiding our approach to specific proposal in specific environmental situations. I provide some details of the steps below with respect to CEE’s involvement in AGL’s Gas Import Jetty and Pipeline EES.

Stage 1. Referral of project This stage generally involves the following steps 1. Review the project description and identify potential impact pathways a. Analyse pathways of immediate concern to establish preliminary potential level of risk i. Model pathways at level appropriate to initial assessment 2. Review available information on marine ecosystem to identify key receptors of identified risks a. Identify habitats or community within direct impact pathways 3. Compare with regulatory requirements from appropriate government agencies 4. Provide initial assessment to regulators to advise on requirements for subsequent assessments a. Referral In this stage of the AGL EES, CEE assisted in the identification of impact pathways to the marine environment from the description of the project provided by the client. • We assembled existing information on the Western Port and specifically Lower North Arm marine environment including hydrodynamic, chemical, marine ecological and regulatory matters including Commonwealth Matters of National Environmental Significance, State Flora and Fauna Guarantee listed species and Victorian Fisheries Act species. • We examined environmental legislation for regulatory environmental quality objectives relevant to the project.

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 14 of 41 Scott Chidgey Response to Expert Witness Statements and IAC RFI Marine Biodiversity Impact Assessment

• We initiated conservative modelling exercises to provide spatial scale of impact pathways identified in the project description. • We further refined our understanding of impact pathways and ecosystem relationships. • We identified gaps in knowledge of processes, regulatory objectives and ecosystem processes that would be needed to further assess the project impacts. • We attended public and agency meetings to discuss the project and gauge concerns. • We prepared six specialist reports describing our Stage 1 investigation outcomes Our reports were appended to the Project Referral Submission to State and Commonwealth environmental regulators. The State and Commonwealth regulators reviewed the information provided and determined the required next stage of the environmental approvals. In this case the regulators determined that the project should be assessed as an EES under state and commonwealth legislation. Many of the impacts and required marine studies were those listed and identified in our referral documents.

Stage 2. EES As a part of the EES team, we reviewed the scoping documents issued by the Ministers to plan the next series of tasks. In relation to the marine environmental assessment, we recognised that key physical features and processes shape the Western Port environment and ecosystem. Impact pathways We also recognised the key impact pathways could be divided into three categories: 1. Ship related operations: a. The FSRU: Arriving from an international origin and mooring at Berth 2 b. LNG carriers: 12 to 40 carriers entering the port from an international origin, mooring alongside FSRU, unloading LNG and departing port c. Noise, light, visibility 2. Port operation and facility improvements at Crib Point Jetty a. Various refurbishments and upgrades 3. Operation of a floating storage and regasification facility (FSRU) as a scheduled premise at Crib Point Jetty a. Entrainment of biota by intake of seawater; b. Cooler seawater discharge; c. Warmer seawater discharge; and d. Chlorinated seawater discharge. Shipping and port operations We recognized that “navigation and shipping” are listed Beneficial Uses of Western Port in State Environment Protection Policy Waters 2018. Impact Pathway Groups 1 and 2 above were therefore identified as stressors consistent with the current and future operation, maintenance and management of the Port of Hastings as an operating port with four separate active shipping hubs within North Arm including Crib Point. The Port of Hastings Development Authority is responsible for managing and mitigating these impact pathways using existing environmental programs and guidelines. We considered that the proposed shipping and port related pathways of the project did not increase the consequence of any of the existing risks (other than catastrophic events related to LNG storage and regasification). Hence, our assessment was based on incremental increase in consequence and incremental increase in likelihood.

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 15 of 41 Scott Chidgey Response to Expert Witness Statements and IAC RFI Marine Biodiversity Impact Assessment

Operation of the FSRU The group of impact pathways related to the intake and discharge effects from the operating FSRU to ecosystem receptors were based on hydrodynamic processes of transport and dispersion. We also recognized the key marine ecosystem receptors and trophic interrelationships from our understanding of the Western Port ecosystem as represented in our ecosystem conceptual models provided Technical Report A.

EQOs as regulatory guidelines of consequence We further recognized that State Environment Protection Policy Waters 2018 provides “environment quality objectives” for protection of ecosystem values specific to various segments of Victoria’s aquatic environment, including “The Entrances and North Arm Subsegments of Western Port”. Since the Policy provides the legal framework for managing aquatic ecosystems, we followed the policy guidance using ambient environmental data (12 months of 15-minute water temperature records) and hydrodynamic information (measured currents and purpose-built hydrodynamic model) specific to the Crib Point area of Lower North to develop temperature and entrainment guideline values for this project. The guideline values would provide the initial negligible consequence limit for ecosystem effect for the respective stressor. The derivation and application of these guideline values is described in detail in EES Technical Appendix A and technical annexures. The discharge from the FSRU comprises seawater with chlorine oxidant residuals from electrolysis of the seawater taken into the FSRU heat exchangers. We recognized during the referral stage that a Policy requirement for 99% ecosystem protection Guideline Value for chlorine in the marine environment was not available in the ANZECC guidelines at that time. Hence, we commissioned CSIRO to establish a Guideline Value for 99% ecosystem protection for chlorine in the marine environment. CSIRO’s report is provided in Annexure A of CEE’s Technical Appendix A. The report describes the iterative process they used to select toxicity data to establish a very conservative 99% protection Guideline value for chlorine, which also included allowance for the toxicity and rate of formation of halogenated byproducts likely in discharges to the marine environment. CSIRO provided 99 percent guideline values for continuous and pulsed or intermittent exposure as is the case for the proposed discharge in Western Port. (See my responses to EPA and Prof Cook).

Hydrodynamic, tracer and particle model We recognised that the topographic and hydrodynamic features of Western Port are fundamental to shaping the marine ecosystem character of Western Port. They are also key to determining the magnitude, temporal variability and spatial extent of FSRU discharge and entrainment stressors. We sought access to the existing hydrodynamic model of Western Port developed by EPA and Melbourne Water for identifying and quantifying catchment related stressors on the Western Port Ecosystem. We specifically calibrated for the Crib Point area of Lower North Arm and augmented with tracer and particle dispersion and nearfield dispersion modules to simulate mixing and dispersion of discharges, rates of natural loss of plankton due to physical processes and proportional entrainment for different FSRU operating modes.

Entrainment of plankton comprising primary producers (phytoplankton), primary and secondary consumers (zooplankton) and fish eggs and larvae was recognised as the key risk linkage to other marine ecosystem components of Western Port. General discussions between ecologists and modelers optimized ecologically relevant outputs for Western Port characteristics:

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• Neutrally buoyant particles were determined to best simulate the natural movement of most plankton occurring in the entrainment zone of the FSRU located in the strong tidal currents of the deep central channel of Lower North Arm. • Range of time steps that may represent duration of typical larval periods of fish species typical of Western Port and benthic invertebrates and fish, and turnover rates of key zooplankton species found in Western Port (Acartia spp) and phytoplankton typical of Western Port of marine biota – based on cited scientific literature and knowledge and advice of specialist subconsultants; • Ecological spatial units (zones) for particle transport, natural flushing and entrainment outputs were provided based on Crib Point jetty as the point of extraction. The boundaries of the zones were based on tidal excursion distance, topography, water depth and known benthic habitat character.

EES Targeted ecosystem investigations Our approach to risk-based studies is to focus particular attention on key pathways and corresponding environmental component that may me critical to potential flow-on effects in the marine ecosystem.

Plankton Community As discussed previously, entrainment of plankton comprising primary producers (phytoplankton), primary and secondary consumers (zooplankton) and fish eggs and larvae representing key plankton trophic levels was recognised as the key direct risk to recruitment and community trophic link to other marine ecosystem components of Western Port. Information on the plankton community of Western Port was recognised during our referral review as a major information gap in available information. Hence, we assembled a team subconsultants from a range of agencies comprising phytoplankton, zooplankton and ichthyoplankton specialist. Their experience provided key input to the design of a 13-month, monthly plankton sampling program. Their ecological description of the plankton community components and identification of population interaction factors was a major factor in the integrated ecosystem picture and assessment presented in EES Technical Appendix A and annexures. The specialists’ reports are appended to the relevant annexures. The hydrodynamic model, particle dispersion module outputs and the documentation of phytoplankton, zooplankton and ichthyoplankton composition, seasonality and spatial variability provides the first truly integrated hydro-ecological of the plankton community of North Arm. The predicted levels of effect of entrainment on this community, which is central to the Bay’s trophic pathway structure as indicated in our ecosystem figure, were fundamental to our assessment of risks to the broader community.

Seabed community The nature of the seabed in North Arm was broadly described as comprising unconsolidated sandy sediments, with more detail in some parts of Western Port such as the reefs in the north of Lower North Arm. We recognised the likely extent of effect the FSRU discharge from early model runs during the referral stage and more refined model runs during the EES. From our previous investigations in Lower North Arm, we knew that there were more features to the unconsolidated sediments than indicated in the available general descriptions or remote grabs. A better understanding of the diversity of the soft seabed character was needed, particularly in the area likely to be affected by the seawater discharge constituents. and could be achieved by mapping seabed character and associated visible epibiota using towed underwater video. Hence, we initiated a program to map seabed character and associated visible epibiota on underwater video tow-tracks in the vicinity of Crib Point Jetty and at other locations to the north and south.

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 17 of 41 Scott Chidgey Response to Expert Witness Statements and IAC RFI Marine Biodiversity Impact Assessment The nature of these seabed characteristics, habitat and associated biota was previously undocumented in Lower North Arm. The results of these investigations provided the basis for further understanding potential effects of the discharge on the observed and inferred sessile invertebrate community and as habitat for mobile demersal and pelagic species of fish and molluscs. The data are available for additional analysis and incorporation to publicly available agency GIS platforms.

Threatened species Two species of ghost shrimp are listed on the Victorian Flora and Fauna Guarantee Act threatened species list as occurring in the Crib Point area. We consulted with the world expert on ghost shrimps to develop a sampling strategy to determine the potential presence of threatened ghost shrimps in the Crib Point area. Dr Poore accompanied us on the investigations that are described in detail in Technical Appendix A and Annexure F. We did not find either of the two listed ghost shrimp species, but many common ghost shrimps were found and released. Dr Poore provided a thoughtful discussion in his report on the rareness of crustaceans and particularly the species Michelea microphylla in relation to its once-only record near Crib Point in the 1960s. The plankton sampling program included a comprehensive fish larval sampling component, which among many hundreds of small fish larvae collected included one small early post- hatch fish larva which was cautiously considered to be the larva of an Australian Grayling. Subsequent closer examination of the larvae by a fish larval expert from the Australian Museum revealed the larva to belong to a common Galaxid group, rather than Grayling. Nevertheless, Australian grayling are discussed in some detail in my response to the Department of Agriculture, Water and the Environment’s submission.

Integrated mitigation and assessment Having developed models and assembled all the necessary information to assess the risks of the quantitatively modelled impact pathways of the project on key environmental components, we undertook a detailed assessment of the risk to the key receptors by integrating the results of the model predictions of environmental quality frequency contours and zone and the interaction with marine ecosystem components within and beyond the contours, which were clearly presented and explained the EES Technical Appendix A and Annexures. Having established the key risks, we discussed and assessed the potential for flow-on risks to other components of the ecosystem that were not directly affected.

Monitoring, Mitigation and Management I recognise that Monitoring, Mitigation and Management of environmental risks is a most important component of any project that poses risks to the environment. Careful measured consideration must be given to an integrated monitoring, mitigation response and management program that is a mandatory component of any approval to proceed. It must be proportionate to the level of risks identified and uncertainties involved. The program must be designed to measure the key risk sources, the behaviour of the stressor along the potential impact path and the key environmental risk receptors and other indicators and environmental values. This requires consideration of the outcomes of the initial assessment consultation between specialists, environmental managers and regulators. As stated previously, in my experience the best outcome may be achieved by rational agreement of program conditions in a suitable forum when or if the project is given conditional approval.

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 18 of 41 Scott Chidgey Response to Expert Witness Statements and IAC RFI Marine Biodiversity Impact Assessment Response to Expert Witness Statement 4. Mr Frank Hanson Frank Hanson Urban Design

Mr Hansen’s Witness Statement brief included “Determine the availability of tools to address shadowing on oceans with night impacts”. Mr Hansen acknowledged that he was unable to determine the availability of tools to address shadowing on oceans with night impacts and other elements outside his scope of expertise. Mr Hanson modelled the potential impact pathway of shading from the FSRU, with models of the shadow cast by the FSRU for the winter solstice and autumn equinox. Ecosystem context I provide the following analysis and assessment of the effect of shadow from the FSRU from a marine ecosystem perspective. The FSRU will be oriented in a north south direction. • Hence Mr Hanson’s figures show that the shadow moves from the west of the vessel in the morning to the east in the afternoon. • The only location permanently shaded will be the area directly beneath the FSRU and the eastern side of the jetty berthing head and short distance at the stern of the FSRU. The seabed that may be exposed to during shadow during other parts of the annual cycle (eg, 9 am to 3 pm autumn equinox and winter solstice) are in depths greater than 10 m deep. These sediments and the jetty piles and seabed adjacent to and beneath the position of the FSRU and LNG carrier are predominantly characterised by invertebrates that do not require light. The waters of North Arm are turbid and light is rapidly reduced through the water column. The seabed in the area of temporary shadow (ie, seabed depth > 10 m) is unconsolidated sediments with no permanent marine macrophytes due to the naturaly low light conditions and the absence of natural hard substratum for the establishment of permanent macroalgae. Using Mr Hanson’s plots of the shadow cast by the FSRU and my knowledge of the extent of seagrasses at Crib Point (green dashed line), the nearest seagrass beds are more than 400 m inshore of the 9 am winter solstice shadow from the FSRU, and more than 500 m inshore of the 9 am autmn solstice (see below).

>500 m

>400 m

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 19 of 41 Scott Chidgey Response to Expert Witness Statements and IAC RFI Marine Biodiversity Impact Assessment My assessment of shading The reduction of ambient light resulting from the shadow cast by the FSRU will not impinge on natural permanent benthic macrophytes including seabed seaweeds and seagrasses. Phytoplankton may pass through the shadow in a matter of minutes with no effect on net photosynthesis. I conclude that the shadow of the FSRU would have negligible effect on marine ecosystem systems of the Crib Point Jetty area.

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 20 of 41 Scott Chidgey Response to Expert Witness Statements and IAC RFI Marine Biodiversity Impact Assessment Response to IAC Request for Further Information

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2 Marine Biodiversity

The IAC considers Chapter 6(Marine Biodiversity), Technical Report A (Marine Biodiversity Impact Assessment), Attachment VIII (Works Approval Application) and Annexure A-A to Annexure A-H of the EES require further information to be provided by the proponent as follows.

2.2 Tidal movement

Reference: Technical Report A, section 6.3.4

6. Explain the effects of the operation of the Floating Please see my detailed Storage and Regasification Unit (FSRU) on inter- response in row below tidal communities such as mangroves, seagrasses and mud flats and associated listed species, such as the Pale Mangrove Goby, with flood and ebb tidal movement. This request relates to (1) the potential effects of chlorine and temperature in the FSRU discharge on this area, (2) the effects of entrainment on the communities in this area and (3) the combined impact of the operation of the FSRU on this area.

The potential exposure of the listed communities to the wastewater discharged from the FSRU is very low due to the high degree of mixing of the wastewater with ambient water and the indirect pathway that the discharge takes between the discharge point and the nearest distribution boundary of these communities, which is determined by seabed elevation: the deepest extent of seagrasses near Crib Point is less than about –3.5 m AHD the upper limit of seagrasses is about -1 m, the lower limit of mangroves is just above mean sea level (>0 m ) and the upper limit of the mangroves and start of the saltmarsh is about 1 m above AHD.

The frequency of contours of temperature and chlorine Guideline values for various operational scenarios are provided in Section 6.

The contours demonstrate the net exposure of the communities taking into account variation in duration, tides and dilution due to mixing. The contours do not include decay of chlorine oxidants to less toxic chlorinated by products (CPBs or Halogenated Organo- Carbons, HOCs– see my response to Prof Cook’s submission) or the decay of CPBs and HOCs during the time the discharge constituents reached the contour boundaries. Hence, the exposures demonstrated in the contours represent a very conservative indication of the risks of exposure.

The contours demonstrate that the discharge is predominantly carried up and down the channel from the discharge points with the tidal currents, but onshore travel is very small. Even at peak production in open loop with an LNG carrier (Figure 6-42, worst case dilution/dispersion) the 2 µg/L concentration for chlorine on the seabed was more than 400 m offshore from the nearest subtidal seagrasses and the Guideline Value (6.0 µg/L) was more than 550 m offshore. These concentrations occur on the seabed at greater than 10 m depth (see figure 6-16). Concentrations at shallower depth would be considerably smaller.

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Predicted exposure of shallow subtidal and intertidal communities to the various temperature anomalies from the discharge are similarly well-below the guideline value contours.

Dr Wallis’ response to this request includes greater detail of contours of lower chlorine concentrations and temperature anomalies.

Overall, I concluded that exposure of the intertidal marine communities near Crib Point to chlorine and temperature anomaly from the FSRU discharge was very low and the associated risks to the mangrove, seagrass and mud flat communities and associated listed species, such as the Pale Mangrove (or “flatback”) Goby was very low.

Entrainment of free drifting propagules from the intertidal and shallow subtidal habitats is discussed in Sections 7.6.9, 7.6.10, 7.6.11 and 7.6.12 of EES Technical Appendix A. Tables 7-4 and 7-5 show the proportion of propagules entrained from various zones including Zone 7 (the Crib Point/Hastings intertidal and shallow subtidal area -Figure 7-7) for various FSRU operational modes. The effects of entrainment are discussed based on ecological and biological understanding of planktonic dispersion of propagules from the intertidal area, and the modelled proportion of these propagules that would be entrained from the Crib Point intertidal and shallow subtidal area compared with natural mortality (Table 7-8) and natural losses from the area due natural tidal current transport and flushing. Table 7-4 shows that the maximum loss of propagules from Zone 7 to entrainment would be 0.21%, compared to a natural loss to flushing of 46% and transport to other parts of Western Port of 46%. Hence, the loss to entrainment represented 0.23% of total losses from the zone. Over this period a substantial proportion of propagules would have transported into the zone from other Zones. Hence, I considered risks to the intertidal and shallow subtidal area of Crib Point due losses of propagules or free drifting living ‘food’ due to entrainment to be Very Low.

Combined risk: In considering the combination of these very low likelihood and consequences of the impact pathways, I conclude that there is insufficient justification to elevate the risk rating above very low risk for the combined effect.

Dr Wallis provides further technical information on this matter in his response Cardno’s Submission.

2.3 Re-gasification when Liquefied Natural Gas (LNG) tanker is present

Reference: Technical Report A, section 6.6.2.

7. Explain the discharge and water quality implications Dr Ian Wallis of re-gasification operations (and the discharge ports) when an LNG tanker is moored beside the FSRU. 2.4 Ramsar values Reference: Chapter 6, Technical Report A and Annexure A-B and Annexure A-C. 8. Provide details on the information collected or relied on during EES compilation to inform baseline condition of seabirds, fish, migratory waders, marine mammals, and the extent of mangroves, seagrasses and saltmarsh communities (refer to Table 15 Technical Report B). List of information appended on Page 12 (end of this table)

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9. Provide detail on the ongoing monitoring to assess Please refer to Section potential impacts from the FSRU. Explain the 9 of my Witness triggers and mitigation actions if impact to Ramsar Statement and my values is established. responses to EPA and Cardno submissions. Monitoring programs will be developed in consultation with regulators (EPA, DWLWP, DAWE). Tiered monitoring, management trigger and response proposed as basis for programs.

10. Explain the potential for long term effects of I am not an expert on entrainment on plankton abundance and diversity of waders and migratory food supply for waders and migratory birds. bird diets, but I understand that these birds feed on a range of surface and burrowing invertebrates in the intertidal areas. Hence, I can offer the following in relation to their prey. As discussed in my response to Item 6 above, the direct risks of entrainment to intertidal biota including food supply or recruitment of burrowing invertebrates are very low. Any indirect or long-term effects of entrainment on food supply to birds feeding across Western Port are likely to be very low considering the large area of Western Port compared to the modelled effect sizes of entrainment and the natural flushing and exchange processes.

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11. Review the plankton sampling techniques and results Please Section 5.8 of collected for the EES in comparison to other data Technical Appendix A collected in Western Port Bay. and Annexures B, C and G of Technical Appendix A and my response to Cardo’s submission. As stated in Appendix A and Annexures, our plankton monitoring program followed the methods and approach used by Kimmerer and McKinnon in their benchmark studies of zooplankton of Port Phillip and Western Port Bays in the 1980s. We applied their approach to sampling in the East Arm of Western Port in the early 1980s to our zooplankton, phytoplankton and ichthyoplankton sampling program in Lower North Arm in 2019. As a consequence, we were able to validly compare the seasonality and abundance of the key zooplankton species Acartia spp between sampling programs 35 years apart. The figure inset shows the remarkable similarities in the key plankton species Acartia in East Arm in the 1980s and 35 years later in Lower North Arm. Interannual variations are apparent in the first and last records for each program. The response of the populations 35 years apart to seasonal factors is remarkably similar. This species is adapted to the high suspended solids concentrations of upper and eastern Western Port, is a key biological factor in regulating phytoplankton abundance and abundance of its key copepod competitor Paracalanus. Acartia’s high abundance in Western Port is starkly contrasted by its low abundance in the clearer waters of Bass Strait and Port Phillip, as described in EES Technical Report A and Annexures, with frequent reference to the work of Kimmerer and McKinnon in the 1980s.

2.5 Chlorine and temperature discharge conditions Reference: Technical Report A, Attachment VIII, Appendix C and Annexure A-A. 20. Provide details regarding any possible sublethal and See my responses to chronic affects to biota exposed to chlorine. Outline if Item 6 above and EPA exposure times of chlorine will be based on pulsed or and Professor Cook’s continuous dosing, and relevance of Guideline Value submissions. Note that CSIRO chose continuous dose

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(GV) results that are based on acute toxicity of test bioassays to inform the species. Guideline value and modelled exposure times do not include decay factors. Hence both provide additively conservative outputs for continuous dosing. CSIRO’s provide Guideline values for continuous exposure (2 μg/L Cl) and for variable (or pulse) exposure (6 μg/L Cl) in situations such as Western Port. We used the 6 μg/L Cl Guideline Value. 22. Explain any relevance halogenated by-products of Please see detailed chlorine have to the receiving environs of Western response below Port Bay, particularly in response to ammonia and dissolved organic matter. Please see my Witness Statement and responses to EPA and Prof Cook. Allonier et al 1999 explain that the formation of chloramines is unlikely to occur in the marine environment due to the relatively low concentration of ammonia (as it is in Western Port) and due to the presence of bromide, which preferentially reacts with free chlorine ahead of ammonia. Instead “thus the bromine and chlorine species are therefore in competition to react with the organic matter either as an oxidising agent or as substituting agents. As a consequence, brominated compounds may be formed” (Allonier et al 1999). The concentration of brominated compounds (HOCs) is substantially lower than the concentration of the initial oxidants. The main brominated compound is bromoform or tribromomethane or TBM or THM. Bromoform is substantially less toxic than the chlorination produced oxidising agents, which rapidly decay to harmless salts. Bromoform is also produced naturally by marine plants. Bromoform decays or volatises to the atmosphere. Bromoform also slowly creates smaller quantities of other HOCs, which are also created by marine biota. These HOCs are even less toxic than bromoform. Further detailed discussion is provided in my response to Prof Cook’s submission. 2.8 Marine biota Reference: Technical Report A, section 5 and section 6.3.7. 25. Section 5.10.1 relies on numbers of Australian fur We reference our own seal recorded from 1995 to 2004. Explain what data observations “(CEE has been relied on to confirm the presence of seals observations)” as well in the Project area. as published literature in Section 5.10.1. Our unrecorded observations during work on various projects in the Entrance and North Arm of Western Port over the past 10 years,

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including more than 40 days on the waters Lower North Arm over the 13 months period of field works for this project. During this time, we have seen seals swimming or feeding in the channel on only a few occasions. A single young seal seen consistently at the southern end of Crib Point jetty as shown on the cover of EES Technical Report A. Our observations are consistent with previous data cited in 5.10.1. 26. There is no reference to the penguin colony on See detailed response Barralier Island. Explain the likely foraging and below migratory patterns of the individuals that form the colony north of French Island.

I am from aware that various small colonies of penguins occur in the Western Port area that are not generally publicised. I am aware there is a small penguin colony near French Island. On inspection of the EES, I see that the Barralier Island population is not mentioned. As discussed above, we have worked on various projects in the Entrance and North Arm of Western Port over the past 10 years, including more than 40 days on the waters Lower North Arm over the 13 months period of field works for this project. During this time, we have seen or heard few penguins swimming or feeding in the North Arm channel. This contrasts with relatively frequent sightings and more often ‘hearings’ of penguins offshore from Wonthaggi and in Port Phillip Bay. By way of comparison with the Barralier Island colony and their interaction with Port of Hastings shipping related operations, I am aware of the growing breeding colony of approximately 1,500 penguins located St Kilda harbour breakwater in Port Phillip. This population of penguins together with over-wintering penguins from Phillip Island feed in Port Phillip. The St Kilda penguins spend their entire lives at St Kilda feeding in the busy shipping and boating channel adjacent to the Port of Melbourne and Hobsons Bay. Newport power station and Altona refinery are nearby. The St Kilda penguins’ favoured feeding ground is the dredged shipping channel and approach to the Port of Melbourne between Altona/Williamstown and St Kilda. The St Kilda colony is centrally situated among the movements of thousands of ships, and thousands of recreational yachts, fishing boats, jet-skis and other water craft annually. Our risk assessment for penguins in North Arm of Western Port was prepared the context above, including our own observations of conditions in Lower North Arm during the 40+ days on the waters during EES studies. Mitigation measures for entrainment of a range of large biota specifically including penguins are described in Section 7.5.1. Mitigation include fitting screens over intakes (as a deterrent) and a water intake velocity limit of 0.15 m/s (9 metres per minute) at the screens. • We stated that the risk of penguins in Western Port being entrained or impinged in the screen is “Very low risk”.

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• In Section 7.7.8 we stated the risk on penguins in Western Port of temperature differential was no impact.

• In Section 7.8.4 we stated the risk on penguins in Western Port of chlorine was no impact.

I have no reason to change these ratings.

27. Explain the characteristics of the dredged seabed See detailed response conditions around Crib Point Jetty that are favourable below for invertebrate epibiota species. Invertebrate epibiota are the invertebrate animals that live on the seabed. These are different from the invertebrate infauna that burrow in the seabed. Natural invertebrate epibiota and infauna communities are strongly influenced by the physical nature of the seabed (rock, gravel, sand, mud, dead shell, shell grit and so on), water depth, turbulence and seabed stability. Strong waves and currents may disturb the seabed and create an environment unsuitable for some biota, but suitable for others. In recognition of the importance of seabed character in determining epibiota and infauna characteristics, our major effort in documenting seabed epibiota and infauna in Lower North Arm focussed on mapping habitat in representative areas using towed video. (Technical Report A Section 5.7.3 and Technical Annexure D). Figures 5-32 shows that the dredged area appeared to be more homogeneous and flatter for its size than other areas (Figure 5-32), probably because it is relatively flat following dredging in the 1960s. From our direct observations (including ghost shrimp surveys), the unconsolidated sediments in the dredged area appears to be a relatively shallow layer of fine and medium sand, with a relatively high proportion of shell over a stiff clay base. Lumps of clay are visible at the surface in some places. It is possible that the fine sand and shell resettled to the seabed from the dredge hopper “overflow” in this area during dredging. The tidal currents on the seabed are relatively strong, so epibiota need to attach to something solid on the seabed or ‘take root’ in the seabed (ascidians and tube worms). It appears that the relatively consistent fine sand, shell and shellgrit over the provides a consistent bed for some epibiota and infauna. Figure 5-38 shows that infauna were more abundant at Berth 2 compared with Berth 1 and reference sites (Figure 5-37, and see nMDS plots in Annexure D). This may be due to a combination of more homogeneous and finer sediments than reference sites and lack of seabed disturbance due to shipping at Berth 2 compared with Berth 1, The presence of large, long-dead shell (relict mud oyster) and scattered coble sized rock also affected grab return efficiency between sites. Annexure D demonstrates that, while the seabed of North Arm is predominantly unconsolidated sediments as previously described, there is considerable variation in nature of the seabed between locations in the deeper channels, banks and shoals. These variations will result in differences in the composition of the infauna and epibiota found at those locations. However, the natural dispersion of biota and propagules by the tidal currents in Western Port ensures that there is continuity of species in similar habitat. Overall, we consider that the mapped seabed habitat and associated distributions provide a wider and more useful representation of seabed biota distributional pattern in Lower Arm Western Port and the Crib Point area than the infauna grab results indicated.

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19 Matters of National Environmental Significance This section is largely in response to the submission from the Commonwealth Department of Agriculture Water and Environment submission (2871), which raised a number of issues about Matters of National Environmental Significance (MNES) which the IAC is seeking clarification. 19.3 Cetaceans Reference: Attachment I. 158. Provide further information including how vessel See below strike will be avoided or mitigated, taking into account the nature and extent of possible impacts to individual cetaceans. 159. Provide details on potential risks to Southern Right See below Whales with reference to the Commonwealth Conservation Management Plan for the Southern Right Whale 2011–2021 and the resulting impacts in the event risks are realised. We reviewed available information on the nature and distribution of environmental receptors to these ship and port related stressors in Western Port. In view of the existing widespread dispersion of these stressors (whale strike by commercial ships) and key receptors (humpback and Southern Right Whales, we decided that it was appropriate to address risks to these receptors due to the project (1) using available information on key receptors and (2) the proportional increase of existing risks due to project related increased in likelihood of existing consequences occurring. In stating this approach, I am aware that some of these stressors at a regional or national scale are significant to some populations or species. This is particularly relevant to migratory threatened species, such as the Southern Right whale, that have very diminished populations and migration paths that correspond with major national and international shipping routes. The loss of an individual from these populations due to strike by any form of vessel anywhere is truly unfortunate. It is ineffectual to consider this risk in the context of an additional 40 vessels per year, to and from a single port, for a single project. The risk of these stressors to diminished populations and individual animals is at a larger geographic scale and must be addressed at a state or national scale. In the case of Southern Right Whales, it may be appropriate to develop a joint Tasmania, Victoria and New South Wales (and perhaps South Australia) strategy to address ship-strike risks to the remaining individuals of the seriously diminished southeastern population of this large, docile, endangered whale that is so valued by many Australians.

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 28 of 41 Scott Chidgey Response to Expert Witness Statements and IAC RFI Marine Biodiversity Impact Assessment Declaration I have made all the inquiries that I believe are desirable and appropriate and that no matters of significance which I regard as relevant have to my knowledge been withheld from the Panel.

Dated 9 October 2020

Scott S Chidgey

Scott Selwyn Chidgey

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CEE Pty Ltd Environmental scientists and engineers

Appendix to Item 6 2.4 Ramsar values Reference: Chapter 6, Technical Report A and Annexure A-B and Annexure A-C. Appendix to Item 6 Geographic Title Scope/Abstract Taxa covered Coverage/Relevance The horizontal and vertical distribution of fish eggs and larvae in relation to the Bass Strait Eastern proposed desalination plant for Victoria Multi-species Western Port

Acevedo, S., Jenkins, G., and Kent, J. (2010). National Recovery Plan detailing the National Recovery Plan for the Australian species’ distribution and biology, Grayling Prototroctes maraena. conservation status, threats, and recovery South eastern Australian grayling objectives and actions necessary to ensure Australia Backhouse, G., Jackson, J. and O’Connor, J. the long-term survival of the Australian (2008a). Grayling. Victorian Marine Habitat Database: Maps the distribution of seagrass in Seagrass. Mapping of Western Port. Western Port using aerial photography, and Western Port Seagrass compares the present distribution with Blake, S. and Ball, D. (2001). previous studies. Mangroves and Coastal Saltmarsh of Describes ecological vegetation classes on Victoria. Distribution, Condition, Threats the basis of a new structural and floristic Victoria, including and Management. Saltmarsh, mangroves classification for coastal saltmarshes in Western Port

Victoria. Boon et al (2011). Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 30 of 41

Scott Chidgey Response to Expert Witness Statements and IAC RFI Marine Biodiversity Impact Assessment

Evaluation of effects of targeting breeding elephant fish by recreational fishers in Impact assessment of elephant fish catch on Western Port. its stocks and future catches, to inform Western Port Elephant fish management of the potential need for a Braccini, J. M., Walker, T. I., Conron, S. D. response to ensure sustainable stocks. (2008). Loss of seagrass in Western Port – Program E06 First Review, May 1984.

Bulthuis DA (1984) Seamap Australia [Version 1.0] the development of a national benthic marine Spatial database that collates all national Benthic habitats: classification scheme for the Australian benthic habitat mapping data into one Australian continental saltmarsh, mangrove, continental shelf. location on the Australian Ocean Data shelf, including seagrass, biogenic Network (AODN) complete with metadata Western Port. reef. Butler C., Lucieer V., Walsh P., Flukes E., records. Johnson C. (2017) Population genetic structure of the Burrunan dolphin (Tursiops australis) in coastal waters of south-eastern Australia: Describes the existence of small, localised South Australia, conservation implications. and genetically distinct dolphin populations Burrunan dolphin Victoria, Tasmania in south eastern Victoria. Charlton-Robb K., Taylor A. C, McKechnie S.W. (2015).

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A quantitative survey of the macrobenthos Reports the invertebrate assemblage of of Western Port, Victoria. Coleman, N., Western Port where the fauna is dominated Western Port Marine invertebrates Cuff, W., Drummond, M. and Kudenov, J.D. by polychaetes, crustaceans and molluscs. (1978).

King George whiting, Data compilation (1998-2014) from Western Port Fishery Assessment 2015. snapper, gummy recreational fishery monitoring programs, Western Port shark, flathead, commercial fishery catch and scientific Conron S., Hamer P., Jenkins G. (2016). southern calamari and surveys to assess stock and fishery status. elephant fish Use of otolith chemistry to examine Suggests that juveniles from rivers may patterns of diadromy in the Australian reside in a relatively homogenous chemical South eastern Victoria, grayling Prototroctes maraena. environment, such as the sea, and including Western Australian grayling populations in coastal Victorian rivers may Port Crook, D. A., Macdonald, J. I., O'Connor, J. share a common marine recruitment P., and Barry, B. (2006). source. Mangroves. In Understanding the Western Port Environment: A summary of current Description of Western Port mangrove knowledge and priorities for future habitat, including spatial and temporal Western Port Mangrove research. dynamic patterns, associated communities and major threats. Dittman, S. (2011).

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Australian National Recovery Plan for the Grey Nurse Shark (Carcharias taurus). The Recovery Plan for the Grey Nurse Shark plan considers the conservation (Carcharias taurus), Department of requirements of the species across its range Environment and Energy, Canberra. Australia Grey nurse shark and identifies the actions to be taken to

ensure the species' long-term viability in DoEE (2014). nature and the parties that will undertake those actions. Marine mammals: Two Bays Whale Project Summary 2018. Citizen science project that reports the humpback whale, recording of sightings of large cetacean Port Phillip Bay and southern right whale, Donnelly D., Mason S., Peters M., McFee J. species within Port Philip, Western Port and Western Port killer whale, minke (2018) adjacent waters since 2000. whale, blue whale. The production and trophic ecology of shallow-water fish assemblages in southern Australia I. Species richness, size-structure Describes dietary habits and associated and production of fishes in Western Port, Western Port Shallow water fish habitats of 91 fish species. Victoria.

Edgar, G.J., Shaw, C. (1995a). Investigation of population dynamics, Population characteristics of southern sea demography and spatial distribution of the garfish (Hyporhamphus melanochir, southern sea garfish in South Australia. Hemiramphidae) in South Australia. Commercial catch and effort data were Southern Australian South Australia used to indicate spatial and temporal garfish Fowler, A. J., Steer, M. A., Jackson, W. B., abundance, and it has prompted a stock and Lloyd, M. T. (2008). rebuilding program for the South Australian stock.

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High levels of spatial and temporal recruitment variability in the temperate Investigation of spatial and temporal Port Philip Bay, sparid Pagrus auratus. variation in snapper recruitment in south Western Port, Corner Snapper eastern Australia Inlet, Gippsland Lakes Hamer, P. A., and Jenkins, G. P. (2004). Chemical tags in otoliths indicate the importance of local and distant settlement areas to populations of a temperate sparid, Investigates the geographic origins of fish Port Philip Bay, West Pagrus auratus. Australasian snapper recruitment in coastal Victorian waters. Victoria

Hamer, P. A., Jenkins, G. P., and Gillanders, B. M. (2005). Connectivity of a large embayment and coastal fishery: spawning aggregations in one bay source local and broad-scale Reports on the source of local and broad- fishery replenishment. scale fishery replenishment of snapper Port Philip Bay Snapper stocks. Hamer, P. A., Acevedo, S., Jenkins, G. P., and Newman, A. (2011). Swimming ability and behaviour of post- larvae of a temperate marine fish re- Reports on vertical movement and entrained in the pelagic environment. horizontal transport of King George whiting Port Philip Bay King George whiting post-larvae in relation to local Hindell, J. S., Jenkins, G. P., Moran, S. M., hydrodynamics. and Keough, M. J. (2003).

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The decline of sand flathead stocks in Port Phillip Bay: magnitude, causes and future prospects. Recreational Fishing Grant Reports that sand flathead recruitment in Program Research Report. Port Phillip Bay is heavily influenced by Port Philip Bay Sand flathead climatic conditions. Hirst, A., Rees, C., Hamer, P., Conron, S., and Kemp, J. (2014). Diet of subadult Australian salmon, Arripis truttaceus, in Western Port, Victoria. Reports that Australian salmon diet varies Western Port Australian salmon on a seasonal basis. Hoedt, F. E., and Dimmlich, W. F. (1994). Composition, seasonality and distribution of ichthyoplankton in Port Phillip Bay, Investigates composition, seasonality and Victoria. Port Philip Bay Fish distribution of fish eggs and fish larvae.

Jenkins, G. P. (1986). Variation in settlement and larval duration of King George whiting, Sillaginodes Reports on temporal variation of larval punctata (Sillaginidae), in Swan Bay, duration and settlement in King George Port Philip Bay King George whiting Victoria, Australia. whiting.

Jenkins, G. P., and May, H. M. A. (1994).

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The role of passive transport and the influence of vertical migration on the pre- settlement distribution of a temperate, Predicts spatial variation in abundance of demersal fish: numerical model predictions King George whiting using hydrodynamic Port Philip Bay King George whiting compared with field sampling. and dispersal models.

Jenkins, G. P., Black, K. P., and Keough, M. J. (1999). Determination of spawning areas and larval advection pathways for King George whiting in south eastern Australia using Reports on King George whiting spawning Port Philip Bay, otolith microstructure and hydrodynamic sites and larval pathways in Central Victoria. Western Port, Corner King George whiting modelling. It estimates larval duration from otoliths of Inlet post larval individuals. Jenkins, G. P., Black, K. P., and Hamer, P. A. (2000). Spatial variation in the use of seagrass and unvegetated habitats by post-settlement King George whiting (Percoidei: Describes patterns of habitat use by King Sillaginidae) in relation to meiofaunal Port Philip Bay King George whiting George whiting. distribution and macrophyte

Jenkins, G. P., and Hamer, P. A. (2001).

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The swimming abilities of recently settled post- larvae of a temperate demersal fish, Reports on experiments of King George the King George whiting, Sillaginodes whiting swimming abilities and correlates it King George whiting punctata. with its dispersal and recruitment patterns.

Jenkins, G. P., and Welsford, D. C. (2002). Fisheries Adaptation to Climate Change - Marine Biophysical Assessment of King Identifies the key characteristics of seagrass George whiting. regions that are important to the Port Philip Bay King George whiting

production of juvenile King George whiting. Jenkins, G. P., Hutchinson, N., Hamer, P. A., and Kemp, J. (2012). Spawning sources, movement patterns, and nursery area replenishment of spawning populations of King George Whiting in south-eastern Australia — closing the life Investigation of population structure and Victoria, South history loop. associated spawning areas of King George King George whiting Australia whiting in South Australia and Victoria. Jenkins, G. P., Hamer, P. A., Kent, J. A., Kemp, J., Sherman, C. D. H., and Fowler, A. J. (2016). Reports spatial distribution and habitat use of relevant fish populations in Western Port. Overview of Fish, Fisheries and Aquaculture Suggests that variation in catches by in the Lower North Arm, Western Port. recreational fishers was primarily influenced Western Port Fish

by the environmental drivers of recruitment Jenkins, G. P. (2019). of young fish to the Western Port ecosystem.

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Western Port Ramsar Wetland Ecological Detailed description of the ecological Character Description. Report for character of Western Port as a Ramsar Department of Sustainability, Environment, wetland, to maintain and protect the Saltmarsh, mangrove, Water, Population and Communities, wetland values, establishing a benchmark Western Port seagrass, marine Canberra. from which change can be assessed and invertebrates, fish monitoring can be effectively planned and Kellogg Brown & Root (2010). implemented. The population dynamics of red cod, Describes the reproductive strategy of red Pseudophycis bachus. A contribution to cod being characterized by early maturity Western Port, Port understanding the trophic role of this and high fecundity, coupled with a Philip Bay, Lakes Red cod important prey species. particularly fast growth rate, suggesting that Entrance red cod populations are quite resilient to Kemp, J. (2010). increased predation pressure. Temporal and spatial patterns in ichthyoplankton assemblages in bay and Reports on spatial and temporal variations open coastal environments. Victoria 52 families of fish on the larval fish community in Victoria.

Kent, J., Jenkins, G., and Acevedo, S. (2013). Continued population recovery by Australian fur seals. Reports on fur seal population size in south eastern Australia. Three new colonies are South eastern Fur seals Kirkwood R., Pemberton, D., Gales R., reported suggesting that fur seal population Australia Hoskins A., Mitchell T., Shaughnessy P., has continued to recover. Arnould J. (2010).

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Reports basic biological parameters for sand Population dynamics and assessment of and rock flathead in Port Phillip Bay and sand and rock flathead in Victorian waters. Corner Inlet. Evidence that stock sizes of Phillip Bay and Corner Flathead both flathead species have been largely Inlet Koopman, M., Morison, A. K., and unaffected by fishing pressure under Troynikov, V. (2004). current fishery management arrangements. Downstream spawning migration by the Reports spawning and movement patterns amphidromous Australian grayling of the Australian grayling in the Bunyip (Prototroctes maraena) in a coastal river in River during the spawning period (2009- south-eastern Australia. Western Port Australian grayling 2010) showing that downstream migration

and peak egg abundance were associated Koster, W. M., Dawson, D. R., and Crook, with increased river flows. D. A. (2013). Gummy Shark Mustelus antarcticus. In 'Status of key Australian fish stocks report 2014 Description of current gummy shark Southern Australia Gummy shark biological stock structure. Marton, N., Fowler, A., Gorfine, H., Lyle, J., McAuley, R., and Peddemors, V. (2014). Suggests that the main differences between Use of ichthyoplankton ecology to evaluate 1969 and 1995 in the composition and ecosystem changes: a case study in a large, abundance of fish eggs and larvae, may be semi-enclosed Australian bay. Port Philip Bay Fish attributable to ecosystem changes,

particularly the introduction of exotic Neira, F. J., and Sporcic, M. I. (2002). marine species.

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Victorian Marine Species of Conservation Compilation of Victorian marine Concern: Molluscs, Echinoderms and invertebrate species of conservation Victorian marine Decapod Crustaceans. concern, areas that may require protective waters including Marine invertebrates management, and species that are Western Port O’Hara, T., Barmby, V. (2000). dependent on vulnerable habitats. Comprehensive guide to the identification Marine decapod crustacea of Southern of crustacean species from southern Southern Australia, Australia: A guide to identification. Australian marine waters, includes the including Western Crustacea authority, year of description, diagnosis, Port Poore, G.C.B. (2004). size, geographical distribution, and ecological and depth distribution. Ecology of juvenile King George whiting Sillaginodes punctatus (Cuvier and Valenciennes) (Pisces: Perciformes) in Reports growth rates, feeding and habitat Western Port King George whiting Western Port, Victoria. preferences of King George whiting.

Robertson, A. I. (1977). Trophic interactions among macrofauna of Reports the diets and estimated annual an eelgrass community. consumption of food by 11 fish species Western Port Shallow water fish

associated with eelgrass. Robertson, A.I. (1978). Population Dynamics and Feeding Ecology Reports the different dietary behaviour of of Juvenile Australian Salmon, (Arripis western and eastern subspecies of trutta) in Western Port, Victoria. Western Port Australian salmon Australian salmon in Western Port eelgrass

meadows. Robertson, A.I. (1982)

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Feeding habits of the southern Australian Reports distinct diurnal and nocturnal garfish Hyporhamphus melanochir: a feeding habits on the southern Australian Southern Australian diurnal herbivore and nocturnal carnivore. garfish suggesting an adaptation to diet Western Port garfish changes in food availability as well as Robertson, A. I., and Klumpp, D. W. (1983). metabolic requirements. The distribution of seagrass in Western Port, Victoria.

Stephens, A.C. (1995b). Reports few to no significant gummy shark Investigation of school and gummy shark pupping grounds in Victoria and Tasmania. nursery areas in south eastern Australia. Describes the distribution, size structure, South eastern Gummy shark residence time and movements of new- Australia Stevens, J. D., and West, G. J. (1997). born and juvenile sharks in nursery areas. Ongoing project that tracks Philip Islands' Phillip Island Nature Parks. (2018). Annual little penguin colony, including nesting, Philip Island Little penguin Report 2017-18. Melbourne. breeding and feeding habits.

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