Environment Assessment Report

PROPOSAL TO CONSTRUCT AND OPERATE A SATELLITE LAUNCHING FACILITY ON CHRISTMAS ISLAND

Environment Assessment Branch 2

May 2000

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 3

Table of Contents

1 INTRODUCTION...... 6 1.1 GENERAL ...... 6 1.2 ENVIRONMENT ASSESSMENT...... 7 1.3 THE ASSESSMENT PROCESS ...... 7 1.4 MAJOR ISSUES RAISED DURING THE PUBLIC COMMENT PERIOD ON THE DRAFT EIS ...... 9 1.4.1 Socio-economic...... 10 1.4.2 Biodiversity...... 10 1.4.3 Roads and infrastructure ...... 11 1.4.4 Other...... 12 2 NEED FOR THE PROJECT AND KEY ALTERNATIVES ...... 14 2.1 NEED FOR THE PROJECT ...... 14 2.2 KEY ALTERNATIVES ...... 17 2.2.1 Alternative Launch Vehicles and Technologies...... 17 2.2.2 Alternative Space Fuels ...... 18 2.2.3 Alternative Orbits...... 18 2.2.4 Alternative Launch Sites...... 18 2.2.5 Alternative of Not Proceeding with the Proposal ...... 19 3 DESCRIPTION OF THE PROPOSAL...... 20 3.1.1 General ...... 20 3.2 TECHNICAL AND LAUNCH COMPLEX ...... 20 3.2.1 Mission Control...... 25 3.2.2 Administration and Residential Complex, Irvine Hill...... 25 3.2.3 Roll-on Roll-off Facility...... 26 3.2.4 Facilities at Christmas Island Airport...... 30 3.2.5 Infrastructure Corridors...... 30 3.2.6 Roadworks...... 30 3.2.7 Launch Vehicles...... 31 3.2.8 Fuel ...... 33 3.2.9 Flight Termination System...... 34 3.3 PROJECT CONSTRUCTION...... 34 3.4 PROJECT OPERATION ...... 35 3.4.1 Employment...... 35 3.4.2 Launch Operations ...... 36 3.4.3 Drop Zones...... 36 3.4.4 Security...... 38 3.4.5 Transport...... 38 4 EXISTING NATURAL ENVIRONMENT ...... 40 4.1 GENERAL ...... 40 4.2 FLORA...... 41 4.3 FAUNA...... 42 4.4 ISLAND ECOLOGY – FAUNA & FLORA INTERACTIONS ...... 43 4.5 THREATS TO FAUNA AND FLORA ...... 44

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 4

4.6 PROJECT SITES ...... 45 4.6.1 Flora...... 45 4.6.2 Fauna ...... 46 4.6.3 Karst Habitats...... 50 5 OVERVIEW OF SOCIAL AND ECONOMIC ENVIRONMENT ...... 53 5.1 HISTORY ...... 53 5.2 ADMINISTRATION ...... 53 5.3 POPULATION AND CULTURAL DIVERSITY...... 54 5.4 INFRASTRUCTURE...... 55 5.4.1 Education...... 55 5.4.2 Health ...... 55 5.4.3 Social Services ...... 56 5.4.4 Housing...... 56 5.4.5 Electricity ...... 56 5.4.6 Water...... 57 5.4.7 Sewage...... 57 5.4.8 Waste Management...... 57 5.4.9 Policing...... 57 5.4.10 Road...... 57 5.4.11 Off-Island Transport...... 57 5.5 BUSINESS AND INDUSTRY...... 58 5.6 SOCIAL FACTORS AND LIFESTYLE...... 59 5.7 CULTURAL HERITAGE...... 60 6 POSSIBLE IMPACTS UPON THE NATURAL ENVIRONMENT AND IMPACT AVOIDANCE AND REMEDIATION...... 61 6.1 CONSTRUCTION HABITAT DISTURBANCE AND CLEARING ...... 61 6.2 TRANSPORTATION IMPACTS ...... 64 6.2.1 Quarantine ...... 64 6.2.2 Roadkills ...... 65 6.2.3 Transportation of Hazardous Substances...... 66 6.2.4 Use of Helicopters on South Point ...... 73 6.3 IMPACT OF LIGHTING AND HIGH STRUCTURES ...... 74 6.4 LAUNCH ACTIVITY IMPACTS ...... 75 6.4.1 Vehicle and payload fuelling...... 75 6.4.2 Impacts on Christmas Island of a Normal Launch – Launch Plume 77 6.4.3 Impacts on Christmas Island of a Normal Launch – Launch Noise 79 6.4.4 Impacts of a launch vehicle accident on or near the launch pad...90 6.4.5 Impacts of launch vehicle in flight...... 92 6.4.6 Drop Zone Impacts...... 94 6.4.7 Launch Impacts Upon Aircraft ...... 100 6.5 CREATION OF ORBITAL DEBRIS...... 101 6.6 IMPACTS ON CAVE SYSTEMS AND CLIFFS ...... 103 6.7 IMPACT OF SPILL AND WASTE WATER ON SOUTH POINT: ...... 104

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 5

7 POSSIBLE IMPACTS UPON THE SOCIAL AND ECONOMIC ENVIRONMENT AND IMPACT AVOIDANCE AND REMEDIATION.107 7.1 ACCESS TO SOUTH POINT AND CHINESE TEMPLE ...... 107 7.2 ROLL-ON ROLL-OFF FACILITY...... 109 7.3 IRVINE HILL RESIDENTIAL AND ADMINISTRATION COMPLEX ...... 113 7.4 WASTE GENERATION AND HAZARDOUS MATERIALS...... 116 7.5 IMPACTS UPON INFRASTRUCTURE...... 117 7.5.1 Power Supply & Sewage Treatment...... 118 7.5.2 Road use...... 118 7.5.3 Water Supply...... 119 7.5.4 Education...... 119 7.5.5 Recreational Facilities...... 120 7.5.6 Hospital...... 120 7.6 EMERGENCY PROCEDURES...... 121 7.7 SOCIAL IMPACTS...... 121 7.7.1 Employee Education...... 123 7.7.2 Community Consultation...... 123 8 ENVIRONMENTAL MANAGEMENT...... 125 8.1 ENVIRONMENT MANAGEMENT PLANS ...... 125 8.2 REHABILITATION...... 127 9 CONCLUSION...... 130 10 REFERENCES...... 132 11 GLOSSARY...... 136

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 6

1 INTRODUCTION

1.1 GENERAL

This report assesses the environmental impact of a proposal by Asia Pacific Space Centre Pty Ltd (APSC) to construct and operate a satellite launching facility on Christmas Island, an Australian External Territory in the Indian Ocean (Figure 1). In accordance with the Environment Protection (Impact of Proposals) Act 1974 (EPIP Act) the Minister for Regional Development, Territories and Local Government designated APSC as proponent in relation to his consideration of the environmental significance of decisions and approvals to be made in relation to the construction of a satellite launching facility and ancillary operations on Christmas Island.

Figure 1. Location of Christmas Island

from Draft EIS

A second key nexus for government approvals is expected to be the requirements of the Space Activities Act 1998, under which a satellite launch facility requires a space licence and each launch or series of launches requires a launch permit. This legislation is administered by the Department of Industry, Science and Resources.

This assessment report reviews the draft Environmental Impact Statement (draft EIS), and the Supplement to the draft EIS which includes the proponent's responses to public comments on the draft EIS (the draft EIS plus the Supplement constitutes the final EIS). In addition the assessment report takes into consideration the additional information provided by APSC on 23 March 2000. It also relies on information, comments and advice provided by Groups within Environment Australia, other relevant Commonwealth agencies, Western Australian Government Departments which may be service providers and/or administrators of relevant legislation in association with the Territories Office, and previous studies undertaken on Christmas Island.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 7

1.2 ENVIRONMENT ASSESSMENT

Environmental impact assessment is predicated on defining adequately those elements of the environment that may be affected by a proposed development, and on identifying the significance, risks and consequences of the potential impacts of the proposal at a local, regional and national level.

The final EIS provides a description of the existing environment in the area and the proposed operations and evaluates the environmental impacts and proposed mitigating measures to minimise the expected impacts.

This report will assess the adequacy of the final EIS in achieving the above objectives, and will evaluate the undertakings and environmental safeguards proposed by the proponent to mitigate the potential impacts. Further safeguards may be recommended as appropriate.

The contents of this report form the basis of advice to the Minister for the Environment on the environmental issues associated with the project.

1.3 THE ASSESSMENT PROCESS

Environmental assessment was conducted by the Environment Assessment Branch of the Commonwealth Department of Environment and Heritage.

The launch facility proposal requires a range of decisions by the Minister for Regional Development, Territories and Local Government in relation to the transfer of land and other matters. On this basis, and in view of the project’s environmental significance, the proposal comes within the provisions of the Commonwealth’s EPIP Act.

The proposal was also potentially subject to impact assessment under applied legislation in the Indian Ocean Territories - the Environmental Protection Act (WA) (CI) (CKI) 1986 (EP Act). The Minister for Regional Development, Territories and Local Government issued a notice under Section 6 of the EP Act so that the project was not liable for assessment under that Act, but that the assessment should be carried out under the EPIP Act as the appropriate Commonwealth instrument.

In accordance with the provisions of the EPIP Act, APSC was directed to prepare a draft EIS by the Minister for the Environment on 15 May 1998. Guidelines for the preparation of the EIS were compiled by Environment Australia in consultation with the proponent, key Christmas Island organisations, and a number of individuals and groups with expertise concerning various aspects of the Christmas Island environment. The Final

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 8

Guidelines were agreed to between APSC and Environment Australia in August 1998.

The draft EIS and Supplement to the draft EIS were prepared for APSC by the consultants, Sinclair Knight Merz Pty Ltd of Queensland.

In accordance with the EPIP Act and Administrative Procedures, the draft EIS was made available for public review between 25 August and 6 October 1999. This period was extended until 15 October due to delays in the availability of the EIS. During this period more than ten meetings were held on Christmas Island with community groups and individuals. These meetings were held by the Environment Assessment Branch to provide an alternative to written submissions on the draft EIS. Over sixty people attended these meetings. A report of notes on the issues raised in the public meetings were prepared and submitted to APSC for consideration in the revision of the draft EIS. This assessment report also notes some of the issues raised.

Thirty-one (31) submissions (including submissions from a number of WA agencies) as well as comments from Environment Australia were forwarded to APSC. APSC provided summaries of points raised in submissions at Attachment II of the Supplement.

In addition, Environment Australia commissioned ICF Consulting to provide an independent technical peer review of the Draft EIS. ICF consulting has extensive expertise and experience in reviewing environmental impacts of launch facilities, and has done so a number of times for the Commercial Space Transportation Branch of the Federal Aviation Agency of the USA. Their report was not available until some time after the close of the public review period and APSC chose to only consider ICF comments where they related to the major issues addressed in the body of the supplement.

The supplement to the EIS was submitted to Environment Australia on 31 January 2000. The Environment Assessment Branch of Environment Australia commenced preparation of this Assessment Report in consultation with other areas of the Environment Portfolio on 1 February 2000. ICF Consulting was also commissioned to review how the document addressed point raised in their earlier report.

In examining the document it became apparent that on a number of issues further information was required that was necessary for proper consideration of environmental impacts and a report being prepared for the consideration of the Minister for the Environment. With the authorisation of the Minister for the Environment and Heritage, the Head of the Environment Protection Group wrote to APSC on 21 February 2000 seeking additional information as provided by Paragraph 9.2 of the Administrative procedures of the EPIP Act. This action halted the 42 day assessment process, which was recommenced on

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 9

24 March 2000 with the receipt of further information from APSC in response to the request.

This Assessment Report and its recommendations has been prepared to satisfy section 9.1.1 of the Administrative Procedures of the EPIP Act. The report is primarily for the consideration of the Minister for the Environment. After considering the Assessment Report, Section 9.3.1 of the Administrative Procedures requires the Minister for the Environment to:

“.... make any comments, suggestions or recommendations to the action Minister and other relevant Ministers concerning the proposed action, whether or not contained in the report prepared by the Department under paragraph 9.1.1., including suggestions or recommendations concerning conditions to which the proposed action should be subject, that the Minister thinks necessary or desirable for the protection of the environment ...”

The Minister for Regional Development, Territories and Local Government, as the action Minister, is required to give all such directions and do all such things as can be given or done by that Minister for ensuring that the final EIS and the suggestions or recommendations made by the Minister for the Environment are taken into account in matters to which they relate.

Similarly it is recommended that a number of issues and recommendations raised in this report should be referred for the attention of the Minister for Industry, Science and Resources in his capacity as the Minister responsible for the Space Activities Act 1998.

1.4 MAJOR ISSUES RAISED DURING THE PUBLIC COMMENT PERIOD ON THE DRAFT EIS

Many stakeholders were critical of what they perceived to be a lack of detail and hard data regarding many aspects of the proposal. They said the draft EIS provided insufficient information on the potential for environmental impacts and contained many unsupported assertions rather than facts. Some pointed to the lack of public meetings during the public comment period.

There was widespread feeling that the rocket launch facility would effect the island’s reputation as a peaceful haven and degrade the eco-tourism experience. Of particular concern were noise levels associated with increased air traffic and rocket launches. Some submissions suggested locating the launch site on an island with lower conservation value than Christmas Island.

A number of submissions were concerned about the potential impact of spills. The launch facility is located over cavernous karst. If a spill were to occur, fuel and other toxic substances could contaminate ground water and enter the

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 10 cave system, and either be rapidly transported along the limestone/basalt interface to the ocean, or alternatively be trapped in the anchialine system with severe environmental impacts.

Dr W.F. Humphreys of the Western Australian Museum submitted that the anchialine system on Christmas Island is barely known and no assessment of the subterranean fauna has been undertaken. For example, it is believed Procaris spp. (aytid shrimps) are confined globally to anchialine systems on only a few islands.

1.4.1 Socio-economic

A number of stakeholders questioned the viability of the project and in turn the estimated economic benefits to the island, citing a potential world oversupply of rocket launch facilities. One stakeholder thought the project might be bankrupted leaving unpaid debts to island businesses. Others said that if the project proved to financially viable a percentage of APSC’s profits should be allocated to a Community Benefit Fund.

In contrast, some island and mainland businesses supported the facility, citing employment and economic benefits arising from the project.

Some residents were concerned about the impact of a large number of construction workers on their lifestyle and on the island’s infrastructure and fragile ecosystems (some thought foreign workers would have little respect for the island’s natural environment). Others opposed accommodating workers at tourist facilities and questioned restrictions on access to the Chinese temple on South Point.

A few submissions suggested the potential impacts of the project on the Cocos Islands (APSC staff using the Islands for recreation and increased air traffic) warranted further examination.

1.4.2 Biodiversity

A major concern was the potential impact of the facility on endangered species such as Abbott’s Booby. Abbott’s Booby is highly vulnerable to disturbance and phosphate mining was curtailed to protect the species. Some submissions claimed fauna and threatened species sections in the draft EIS were inaccurate and not comprehensive. For example, information on the Christmas Island Pipistrelle was said to be outdated and no concerted attempt was made to sample for it. Researchers said the proposed wildlife monitoring programs is inadequate but supported Parks Australia’s future involvement in monitoring programs.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 11

Questions were raised about the impact of construction and operational activities (including noise and burnt and unburnt fuel) on sea bird colonies, and increased traffic and security lighting on Christmas Island Hawk-Owls and red crab migration and mortality. One stakeholder said that if security lighting (which attracts birds) was essential, then any structures into which birds are likely to crash should be well illuminated.

Other concerns included; the impact of fire on rainforest and terrace forest; vegetation clearance associated with the facility resulting in a reduction in the number of nesting hollows and roosting sites for Hawk-Owls and Goshawks, and; long term effects on bird breeding;

Some stakeholders advocated more stringent quarantine activities to reduce the chance of pests being imported with materials for the project. Others supported APSC’s appointment of an environment officer and suggested the company should be required to pay a substantial environmental bond and to employ a wildlife officer.

1.4.3 Roads and infrastructure

A major concern was the ability of the Shire of Christmas Island to meet the demand for additional infrastructure, public facilities and services. Questions were raised as to the ability of the consortium to fund road construction and maintenance costs.

The proposed roll-on roll-off port facility is located near the main recreational beach and residential and commercial areas on the island and residents and tourism operators are concerned it would dominate the coastline, impacting on the tourism industry through increased traffic, parking problems and the presence of ships and trucks for extended period of time. They claim that unloading toxic chemicals at the site, which is prone to significant wave action, shows a lack of understanding of local conditions by the company. Residents suggested investigating alternative sites for a port, imposing truck curfews and constructing overtaking lanes. Thirty-one local residents signed a petition opposing the proposed port facility.

Stakeholders also expressed concern about: transport and storage of hazardous and dangerous goods; the lack of commitment by APSC to minimise energy usage or to use alternative energy sources; insufficient information on water sourcing, water use and recycling, and; the need for detailed water management, waste management and environmental management plans (including a soil and water management plan for building activities).

Some residents said transportation of construction materials, fuel and rocket sections may interfere with local traffic. Whilst others were concerned that

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 12 the facility may be used for military purposes or may become a military target.

1.4.4 Other

Some submissions mentioned the potential for contamination of the marine environment and cited the lack of data to support the contention that spills will dissipate and move out to sea. Others suggested discarded rocket stages should be recovered rather than be allowed to sink in the ocean.

The petroleum industry raised concerns about potential damage to its facilities on the North West Shelf and in the Timor Sea by spent rocket stages and subsequent contamination of the marine environment. The open sea drop zones proposed in the Draft EIS pass very close to offshore petroleum production facilities. The industry also sought clarification regarding any limitations the proposal may place on future petroleum exploration and green-field development.

Some stakeholders said the EIS lacked discussion on the spent rocket stages drop zones and the effect on air traffic in the areas along the flight paths. Planes may have to be diverted several hundred kilometres during launch operations, adding to fuel costs for the airlines involved. It was suggested that further discussions were required with Indonesia on this matter.

Other issues included: the potential for accidents through failure of second hand missile parts; no discussion of the environmental impacts of building, operating and maintaining of the 12 MW power station or the possibility of having to extend the existing airport runway, and; the need for further consideration of fire and emergency service requirements. One stakeholder supported Parks Australia’s involvement as a monitoring agent.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 13

Figure 2. Project Location at South Point

from Draft EIS

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 14

2 NEED FOR THE PROJECT AND KEY ALTERNATIVES

2.1 NEED FOR THE PROJECT

The Guidelines for the preparation of the EIS specifically required the need for the project to be specifically examined. Information was provided in Chapter 3 of the DEIS and supplemented by further information in Chapter 3 of the Supplement. The para 9.2 request for further information included a request for further detail on training opportunities to be provided on the island.

APSC’s key argument for the need for the project is that such a project will meet the growing demand for telecommunications, navigational and remote sensing satellites. The DEIS refers to studies that indicate that existing launch facilities could not meet the growing demands of the commercial satellite telecommunication market, although the Supplement makes reference to the recent decline in prospects for the low earth orbit market (for example, the recent financial failure of the Iridium satellite telecommunications network leading to the potential de-orbiting of the network).

While the low earth orbit component of the market may not grow to the extent expected, APSC points out that the Christmas Island project is the only one of the current four proposed Australian launch facilities that will cater for both the geostationary orbit and low earth orbit markets. This is due to the benefits of Christmas Island’s location – enabling trajectories to the South and South East (Low Earth Orbits), while its proximity to the equator leads to benefits for geostationary equatorial satellites (close proximity to the equator enables maximisation of payload size).

On the basis of a twenty year period of operation with a capacity for 12 launches a year (from year 6), the APSC estimates that company tax payable will be of the order of $2 billion, while the Australian content of the capital expenditure for the project would be more than $300 million.

It is estimated that construction of the launch facility will employ an average of 150-170 people, peaking at over 300 employees for approximately 8 months. Operation of the facility would require about 290 staff directly employed, along with an estimated 150 people in support industries (on island). A significant proportion of the operational staff would be employed on a fly-in fly-out basis and the majority would be likely to be foreign trained experts, with about 40% able to be recruited from mainland Australia or Christmas Island.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 15

A key issue of interest to Christmas Island residents was what job opportunities and contracting and service provision opportunities would there be for islanders, and whether APSC would be providing training opportunities for themselves and their children. APSC has not made a specific commitment on these three issues. The additional information notes that jobs of a more technical nature associated with launch vehicles and satellites will naturally require people with many years of specialist training, but that “to the extent possible, APSC would wish to see Christmas Island residents fill as many positions as is practical”. The Socioeconomic impact Matrix states that APSC will seek to employ island residents where appropriate (March 2000 additional information, Attachment 1, p36)

Training opportunities would be dependent upon the degree to which services and support activities were to be contracted out to local companies. The additional information states that APSC anticipates that it would be able to provide apprenticeships or on-the-job training in vocational areas such as electricians, plumbers, environmental management , auto mechanics etc.

The Christmas Island Tourism Association suggested that APSC consider sponsoring a tourism officer trainee position for the visitor centre. APSC’s response (Supplement pII-17) was that it was anticipated that the increase in tourism generated by APSC will also generate additional income to the business community and flow through to the tourism industry overall. “APSC is keen to investigate the promotion and generation of tourism by any practical manner”.

Some submissions and comments at community meetings expressed concern that benefits may not flow to the Christmas Island community – citing negative experiences with the casino resort (in terms of, employment and contracting going to mainland Australians and debts left owing). In responding to this in the Supplement, APSC stated that “in a commercial project there can be no guarantees of a certain level of benefit flowing to any particular section of the community, whether it be Christmas Island or mainland Australia. On this occasion, APSC Pty Ltd believes that the isolation of the Island could well act in favour of local cost structures and the company would be very surprised if significant economic benefits did not flow directly to the Island community. Already many Christmas Island companies have approached APSC Pty Ltd with cost effective proposals for the provision of goods and services”.

It is not necessarily correct that a commercial basis for a project restricts active direction of benefits. A project may include the direction of specific benefits to the community, and some public submissions raised that the Casino Resort did include the creation of a community benefit fund. Responding to this in the Supplement, APSC stated: “With regard to the transfer of profits from the Casino operations to a community benefit fund, APSC Pty Ltd does not

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 16 support this approach and sees little commercial justification for such a scheme to be put in place. The range of benefits applying to Christmas Island as a result of the casino or satellite facility will be substantial and will occur in a rational context rather than as a result of a bureaucratic decision” (Supplement PII-37). This is discussed further in Chapter 7.

In the Supplement (Ch 14, p84), APSC committed to the establishment of an independent “Christmas Island Environment Foundation” to support environmental research on the island. One million would be contributed by APSC over 10 years, along with additional effort to seek other contributions (further discussed Chapter 8).

The supplement states that APSC considers that the overall benefits of the launch facility to Australia and Christmas Island far outweigh the overall costs, but qualify this by noting that “naturally there will be some costs which fall more heavily on some sections of the community than others”.

There is no doubt that economic and employment benefits will be derived within Australia if the proposal proceeds. The level of these and in particular, where benefits will be directed is more open to uncertainty, and it should be noted that APSC has to date declined to reduce this uncertainty for the Christmas Island community in particular.

The EIS outlines other benefits as including:

Ø Spill-over benefits in technology based industry and related academic fields; Ø The addition of another tourist attraction for the island (while launch facilities such as the Kennedy Space Centre in Florida are significant tourist attractions, it is difficult to be certain to what extent a launch facility on a relatively isolated island will attract tourists); Ø APSC workers adding their spending power to the local economy; Ø Improvements to island infrastructure such as transport and communications.

Acknowledged costs include:

Ø Precluding alternative development of South Point (it should be noted that as a mining lease, Christmas Island Phosphates would be required to rehabilitate the area with endemic plants at the end of the lease); Ø Denial of access to the South Point area for a 24 hour period for each launch; Ø Audible (but brief and infrequent) launch noise for the community on the island; Ø Traffic disruption associated with transportation of large or hazardous loads;

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 17

Ø Establishment of the roll-on roll-of facility may have specific disadvantages for nearby residents;

There may also be other costs not covered in the EIS. In the social sphere these might relate to the disruption of a unique community with the arrival of the new workforce, particularly if integration is only a partial success.

In terms of cumulative impacts, the establishment of the launch facility on the island may require that new water resources need to be found and accessed.

In terms of resource use conflict, the establishment of certain drop zones may curtail future oil and gas exploration or production off the Western Australian Coastline.

In terms of natural impacts, while the EIS process has answered many of the questions relating to such projects, we are still faced with the unknown level of impact upon the South Point Sea Bird colonies as a result of launches and the potential for a launch vehicle explosion over the island. There are also some other uncertainties relating to impacts upon land based fauna, and the water table. Further approval under the National Parks and Wildlife Conservation Act 1975 will be required for the proposal to place the proposed water pipeline from Jedda Cave to South Point through the national park.

These issues are all examined further in relevant sections of this report.

In finalising this assessment, the Department notes that the option of using solid fuel rockets, the specific nature of payloads, runway extensions and the use of nuclear materials have not been assessed. If these matters are likely to have a significant impact upon the environment, they would have to be subject to further environmental impact assessment if they were to be implemented.

2.2 KEY ALTERNATIVES

Discussion of key alternatives can be found on P5-38 to 5-39 of the Draft EIS and PII-30 to PII-31 of the Supplement.

2.2.1 Alternative Launch Vehicles and Technologies

APSC states that they are restricted in their consideration of access to other launch vehicles due to reasons of national sovereignty and existing marketing rights. APSC notes that launch vehicle technologies are constantly improving and states that APSC would wish to be at the forefront of their usage for both commercial and environmental reasons.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 18

In comparison to other known launch vehicles, the liquid oxygen/kerosene fuel used by APSC launch vehicles compares favourably to other vehicles which use UDMH for launch stages, while in comparison to launch vehicles which use solid fuel for all or some stages, there would be pluses and minuses environmentally. In relation to the expendable nature of the proposed rockets, there is no indication that the manufacturers of the ARS-3K vehicle are in the forefront of efforts to develop recyclable or reusable vehicles. APSC states that as new techniques become proven, these can be incorporated into the APSC operations. Given that APSC is primarily a purchaser of pre- designed rockets, this objective would be reliant upon the supplier’s ability and willingness to comply with the objective.

2.2.2 Alternative Space Fuels

APSC states that there are currently no alternatives to the use of UDMH and NTO as storable space fuels for satellites, but that emerging technologies such as electric thrusters have the potential to replace some of the fuel used.

2.2.3 Alternative Orbits

The launch trajectories proposed by APSC service the current major orbit markets for satellite launches. APSC does note that “doglegs” can be used to avoid areas such as operational oil production facilities if necessary.

2.2.4 Alternative Launch Sites

APSC argues that as an Australian company it is interested in developing the launch industry for Australia, but that Christmas Island compares very favourably with other potential and existing launch sites around the world.

In terms of alternatives within Australia, APSC notes that the criteria for launch sites capable of meeting market demands for geostationary and Low Earth Orbits are:

Ø proximity to the equator (within 15o), for efficient launch into geostationary and low-inclination orbits; Ø safe over-ocean flight paths for the major orbit segments; Ø existing infrastructure; Ø a benign climate, without extreme temperatures or winds; and Ø a local geography and environment compatible with the launch activities.

APSC has concluded that in comparison to other potential sites considered over the past 14 years in Australia (including Woomera (SA), Temple Bay and Weipa (Cape York), and Gunn Point and Melville Island (NT), Christmas Island is superior to the other candidates. While perhaps from the

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 19 proponents point of view this might be correct, in considering environmental impacts, the last criteria comes to the fore, and in that sense South Point and Christmas Island cannot be seen as having the environment most compatible with launch activities. The natural environment surrounding Woomera (as the other area that has been assessed under the EPIP Act) would be more compatible with launch activities. In contrast though, its overland flight paths potentially raise both safety and some environmental problems.

APSC has simply stated its view regarding the suitability of Christmas Island over other potential Australian launch sites, without providing an analysis against its own criteria. As such the conclusion reached has been presented without its basis.

2.2.5 Alternative of Not Proceeding with the Proposal

APSC argues that without the launch facility, other developments would be needed on Christmas Island to help support the existing economy as mining operations wind down over the next 10-20 years. In relation to this, the launch facility proposal itself may only last for twenty years, thus closing down around the same time as the mine.

APSC also states that Australia would lose a burgeoning high technology industry and that the satellites would be launched by other operators in other countries, potentially with rockets using more harmful fuels. Given that there are currently three other proposed launch facilities in Australia, this is not necessarily the case.

The EIS neglects to consider that by not proceeding with the proposal, there would also not be the range of potential impacts that the facility might cause to Christmas Island’s valuable natural habitat, and following on, to the Island’s nature based tourist industry. Nor does it consider that without the launch facility proposal, the South Point site would be rehabilitated at the end of the mining lease, or could be used for another activity with less potential to significantly impact upon the environment.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 20

3 DESCRIPTION OF THE PROPOSAL

3.1.1 General

The objective of APSC’s proposal is the construction of a facility that will be able to assemble launch vehicles; receive and prepare satellites (or payloads); place satellites on launch vehicles and launch the assembly so that the satellite can be placed in a geostationary or low earth orbit. The satellite payloads will be owned by customers of APSC and will be designed to carry out commercial functions including telecommunications and remote sensing.

The proposal would require the construction of a number of facilities at various locations on Christmas Island:

Ø Technical Complex, South Point; Ø Launch Complex, South Point; Ø Mission Control, South Point; Ø Temporary accommodation compound, South Point; Ø Residential and Administration Complex, Irvine Hill; Ø Roll-on Roll-off seaport Facility, Gaze Rd, Settlement; Ø Facilities at Christmas Island Airport; Ø Infrastructure corridors for communication, power, and water supply; and, Ø Possible alterations to roads forming the transportation route from Dogs Head to South Point.

3.2 TECHNICAL AND LAUNCH COMPLEX

These two adjoining complexes on South Point form the main focus of the proposal (Figure 3). Both would be located on a 85ha area of land currently part of Mining Lease 100 (ML100). In the Supplement (PII-3) APSC reports that at that time negotiations were taking place between APSC and the Government on the tenure arrangements for the APSC site. APSC expects to be granted a 99 year lease over the site, with the lease converting to freehold possession once construction was finished and the space centre ready for operations.

Launch site development and operations would be carried out in partnership with Moscow based “Design Bureau of General Machine Building” (KBOM) and “Design Bureau of Transport Machinery” (KBTM). The extent to which the technology, and expertise will remain with the Russian organisations is unclear.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 21

Figure 3. Project Components on South Point from Draft EIS

The Draft EIS (S5.3) provides information on the construction materials to be used, the size and function of each of the buildings in the technical complex. The largest building in the complex, the Launch Vehicle Assembly (LV) Building, measures 110m x 50m x 25m high and as with other buildings on site, construction would be similar to large industrial warehouse structures with concrete footings and floor slabs, steel frames, and prefabricated wall panels. The LV building would be used for unpacking, fitting out and testing the launch vehicle components, assembling the components and joining them up with the satellite. This involves the use of overhead cranes, and floor rails to move components. The LV building would also support two five metre high receiving antenna systems to provide direct radio visibility of the launch vehicle.

Adjoining the LV building, the nose cone processing building is used to ready the adaptor that fits the payload to the launch vehicle, as well as the fairing halves that encapsulate the payload, and for preparing the kick stage, if one is to be used (a kick stage is a rocket stage used to move the payload to its final orbit).

The Payload processing building is probably one of the more complex structures and is used for the assembly, preparation, testing and fuelling of

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 22 the payload. The building would contain three high bays which would allow for the simultaneous preparation of two payloads, and an airlock entry. Due to the hazardous nature of the fuels used, the building would be designed with drains and traps built into floor slabs in order to control spills. The payload fuelling area is physically isolated from the rest of the building, has ventilation and decontamination systems, gas detectors, escape exits and a non-water fire suppression system (discussed further in S3.4).

Operation of the facility requires a number of different types of fuels and therefore fuel stores. Kerosene is required to fuel the types of rockets to be used, and would be stored in the containers approved by the International Standards Organisation (ISO containers) that it would be shipped to the island in. The additional information clarifies that the bunded volume for this and other fuel storage facilities will at least equal that of the largest tank plus the heaviest daily rainfall on a 20 year recurrence interval. The storage facility would contain five tanks each holding 110, 000 litres of kerosene. The ISO containers would be transported to the launch complex when required for fuelling.

Two separate storage facilities would be used for nitrogen tetroxide (NTO) and dimethyl hydrazine which are used to fuel satellites. Both storage facilities are steel framed with a roof and open sides (for ventilation). The fuels would be stored in the ISO containers they were transported in, which would be placed in storage racks. The facility would be bunded and the area drain into a collection tank that would collect waste in the event of a leak. The stores would also have a gas detection system, a fire detection system and a manually operated misting sprinkler system. Due to the dangerous nature of these materials, the storage facilities must be positioned a specific distance from each other and from other dangerous materials as determined by WA regulations and Standards Australia so that an accident in one facility does not propagate an accident in another facility. The Draft EIS provides information on the safety and emergency facilities provided at each store (DEIS P 5-34).

The project also requires a diesel supply – both for the diesel fuelled power station, and the on site petrol station (which would only supply diesel). The fuel farm will store 710,000 litres of fuel in three 200,000 litre and two 55,000 litre tanks stored in an impervious compound. The petrol station is the only fuel facility proposed to involve below ground storage tanks.

A hazardous store would also be required to house and prepare pyrotechnic items used for launch vehicles. These include small explosive devices for activating mechanisms; explosive ribbon for separating components; and, small solid fuel rocket motors. These motors weigh up to 20 kg. They are used to separate stages during the flight of the launch vehicle. One launch vehicle may carry about 100kg of solid fuel rockets.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 23

The storage of fuels considered dangerous goods would be required to be in accordance with Western Australian regulations and would need to be covered in inspection programs conducted by the Explosives and Dangerous Goods Division of the WA Department of Minerals and Energy (as advised in their comments on the Draft EIS).

The on-site diesel power station would have a maximum capacity of 12 Mega Watts, although this level of power would only be required for a period of three days surrounding a launch. APSC also proposes to have the capacity to access an additional 3 Mega Watts of power from the existing Christmas Island power station when required. This would require the establishment of a 20km cable connection that would be trenched alongside existing roads and service routes. The existing CI power station is diesel powered with a capacity of 12.5 MW, although current usage quoted in the draft EIS was 4.5 MW.

The proposed launch vehicles also require liquid oxygen and a liquid oxygen plant is proposed to be located in the Technical Complex. The prefabricated plant would include an electricity driven refrigeration system for liquefying air, a distillation column, storage tank, pumps and control system. The plant would be designed to run continuously and the liquid oxygen would be transported by truck to the Launch Complex for storage. Smaller quantities of liquid nitrogen would also be produced for use on site.

The assembled launch vehicle is designed to be moved horizontally on a rail vehicle. A rail system would link the Technical Complex with the Launch Complex and would require a storage building for rail vehicles and related equipment.

It is estimated that within the Technical Complex, 20,000 m2 of roofed areas will be available to harvest rainfall. A water storage area of tanks would be established with a volume of 38,000,000 litres. The reservoir would be below ground level with the surface area covered by a lightweight material to provide protection from airborne pollutants and deter birds. When required, additional water would be sourced from Jedda Cave (a freshwater spring already used as a water supply resource for the township), via a new pipeline to South Point.

Additional facilities that would be required as part of the Technical Complex include:

Ø Fire station, to house two fire tenders, two spill clean-up trucks, portable fire fighting equipment and associated facilities; Ø Vehicle maintenance and wash-down facilities; Ø Staff facilities;

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 24

Ø Sealed roads; Ø Water, waste water, and power services;

The space separating the Technical Complex from the Launch Complex would be largely vacant, but would be crossed by a corridor of road, rail, power and water services, and would also contain the tertiary sewage treatment plant.

The Launch Complex would require an area of 30 hectares focusing on two launch pads. Launch pads are constructed of reinforced concrete and support the launch vehicle over a flame trench. The launch vehicle sits in a steel cradle system. Built into the launch pad are piping systems that transfer the fuel and refrigerants, and cabling and control systems. Below the adaptor is a deluge system, which at the moment of launch, emits up to 0.13 Megalitres of water which is designed to reduce the impact of noise upon the delicate satellite payload, and also reduces general launch noise levels and helps protect the launch pad. Each pad will contain a large storage facility for the deluge water, although this has not been made entirely clear. This assessment report is based on the assumption that a water deluge system would be used and a decision not to use deluge water would have implications for the noise impacts of a launch.

The flame trench design directs gases upwards at 45° to the ground line to the south east. Atop each launch pad would be a service tower for staff access to launch vehicles, and an umbilical tower for connection to power and control lines (37m tall). Each launch pad would have two adjacent lightning towers, and three towers for high intensity lighting required for night launches, all about 70 m high.

The rail system leads to each of the launch pads, as does the sealed road system, which also links to the technical plants which would be positioned between the two launch pads. The technical plants provide the propellants, gases and other services to the launch pads. The area will be bunded to contain liquid spills. Pipelines connect the technical plants to the launch pads (these pipelines are not bunded). The following liquids and gases are stored:

Kerosene – up to 250 t in three tanks (one reserved to assist in the case of a rocket requiring de-fuelling) and associated pumps and valves. The tanks would be nearly empty at the time of launch.

Liquid Oxygen – up to 750 t. Storage vessels are vacuum insulated and would be nearly empty at the time of launch.

Nitrogen (250 t), Helium (5 t), and compressed air (42 t) would be contained in the compressed gas facilities – with compressors, valves and reservoirs.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 25

A refrigeration system would also be located in the technical plant area to provide chilled water and gases for cooling parts of the launch vehicle and payload prior to launch.

Staff facilities would be provided in a building that would also contain computers and automatic control equipment for operating all launch systems. This would be unmanned during launch.

3.2.1 Mission Control

The Mission Control building would be located about 2.5 km to the north of the Launch Complex, within mining lease 101 adjacent to South Point Road. The complex would be single level buildings with an area of approximately 1000m2. All antenna and tracking systems would be operated from Mission Control. Tracking of launched vehicles would be carried out from here during the early stages of the flight. Later stages may require relays from other tracking stations. Power would be supplied from a trenched line following South Point Road from the power station at the Technical complex. Water supply would also connect from the road, while a small “packet plant” would provide sewage treatment services.

3.2.2 Administration and Residential Complex, Irvine Hill

The Irvine Hill area is to the west of the airport and the Draft EIS notes that the Island Strategy Plan highlights the suitability of Irvine Hill for residential and light industrial development. It is intended that accommodation be provided for up to 300 personnel during the operational stage of the project. On the expectation that personnel would be predominantly transient (fly-in fly-out, many foreign technical experts), the accommodation would be in the form of two person self contained serviced apartments. The complex would also contain a communal dining facility and communal passive and active recreational facilities (the active facilities would be available to other island residents). The Irvine hill area is sixty hectares in size, and it is expected that 10 hectares would be required for the complex. Design information has not been provided for the residential and administrative complexes. The additional information (P53) states that the design and planning of the complex would be in complete cooperation compliance with the local and state planning authority’s requirements and guidelines. APSC further states that design will be undertaken with due consideration and attention to the existing prevailing site conditions (terrain, landscaping, orientation, climate) and that the use of energy efficient systems such as solar heating and recyclable materials will also be considered where possible. Due to the proximity of this proposed complex to existing township areas, we understand that there would be minimal effort involved in connecting to existing power, water and sewage disposal services.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 26

APSC also proposes to provide approximately ten individual residences for the more permanent operational personnel (senior managers). These houses would be located within existing residential areas and would be subject to normal design and construction approvals.

3.2.3 Roll-on Roll-off Facility

Sea freight would be used for the delivery of most construction materials, kerosene, and space fuels, and launch vehicle stages. Diesel would also arrive by sea, but it is intended that it would be delivered via the current fuel facilities at Smith Point.

The Draft EIS presented two options for the provision of offloading facilities for project freight transported by sea. These were: the use of the existing Seaport at Flying Fish Cove with some upgrading; and the construction of a Roll-on Roll-off (RO-RO) facility on the shoreline opposite Gaze Rd, just to the west of Temple Court (Figure 4).

The RO-RO facility would be designed for transport ships that allow freight to be retained on trailers whilst on the ship and are thus able to be offloaded without the need for cranes. As with most of Christmas Island’s shoreline, the shore along Gaze Road is bordered by sea cliffs (7m high at the original proposed RO-RO). The proposal would involve cutting into the cliff to reduce the height to about 2m above sea level, and linking this point to Gaze road by a sloping ramp.

The Supplement states that on further review of the alternative of utilisation of the existing port, APCS decided that because of reasons concerning shared usage, strict and limited availability and the physical constraints of the site, use of the port for the project’s sea freight was not a viable option (although on occasion APSC might use the existing port for general freight of goods).

While deciding to proceed with the RO-RO facility, the Supplement describes an alternative location for the facility. This alternative location was proposed in response to public concerns relating to the proximity of the original facility to the Temple Court commercial and residential area. Submission 3 was a letter of objection specifically directed only at that aspect of the proposal and carried signatures of 30 residents of the Temple Court area.

The preferred site identified by APSC is located between the southern side of the Police Station and the Gaseng Tanks (See Fig 5). This is on the Gaze Road foreshore and in effect relocates the Gaze Road entrance to the RO-RO facility approximately 125m to the north. The major difference is that due to the fact that the cliff face is higher at this point, the concrete ramp/road cutting would be angled at 45 degrees to Gaze Road in order to allow for a suitable grade.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 27

The loading platform is therefore further to the east – approximately 60 m from the Police Station. A horizontal platform 30m long by 20m wide would create a wharf area at the base of the ramp for unloading and loading operations. The platform would be lit at night and berthing dolphins (mooring devices) would be required to absorb the berthing energy of the vessel. The supplement states that a level area for short term storage of unloaded goods can be accommodated at the head of the ramp to Gaze Rd. Run-off would be diverted into a storm water drain.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 28

Figure 4. Location of Roll-on Roll-off facility as proposed in the Draft EIS

from Draft EIS

Figure 5. Location of Roll-on Roll-off facility as proposed in the Supplement

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 29

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 30

3.2.4 Facilities at Christmas Island Airport

Air transport will be used for transportation of personnel, visiting officials and satellites. The draft EIS listed a range of possible additions or alterations that might be required at the airport (P5-21). The supplement narrowed this down to the need for the addition of a new aircraft apron and taxiway on the south end of the existing runway. Plans were not provided. The Draft EIS also mentioned the possibility of using Cocos Island as a staging point for the transport of satellites to Christmas Island (due to limitations of the Christmas Island runway). The additional information states that APSC does not intend to pursue that option.

3.2.5 Infrastructure Corridors

The South Point components of the proposal would require provision of communication, water and power infrastructure that are not currently present at that end of the island.

While a power station would be constructed as part of the Technical Complex at South Point, APSC wishes to also be able to draw power from the existing Christmas Island Power Authority (up to 3 MW) as a contingency measure in the event of a generator failure at the South Point power station during the 3 day launch cycle when a full 12 MW will be required. A 20km power cable would be trenched along existing roads and service routes. An optical fibre communications link would also be established between the township and South Point. APSC has stated that it would endeavour to install all services along access corridors at the same time.

Additional water requirements would be sourced from Jedda Cave – a freshwater source in the central area of the island, that is already used as part of the town water supply. The Draft EIS proposed that the pipeline would be constructed on low level concrete trestles above the ground, however the additional information states that it is quite possible that the pipeline could be placed below ground. This water supply would be used to supplement the rainwater harvested at the technical complex and also serve as the water source for the construction phase of the project.

3.2.6 Roadworks

Sealed roads would be constructed to service the South Point facilities. APSC is confident that the transport route across the island (made of crushed chalk) is of a sufficient standard for access and safety requirements and has committed to contributing to the upkeep of the road network due to expected extra wear and tear. There may need to be alterations made at several points, including the roundabout near the wharf, the intersection of Murray road and

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 31

Irvine Hill Road to accommodate the long haul vehicles required to move the longest launch vehicle stages. 3.2.7 Launch Vehicles

APSC propose to use Russian designed and manufactured launch vehicles. The vehicles would be transported to the island via sea. Transported across the island by road and assembled at the Technical Complex.

The main launch vehicle that APSC proposes to use is the ARS-3K, designed by the Russian company, TsSKB Progress in Samara. The Progress plant is responsible for the manufacture of the Soyuz family of launch vehicles. Soyuz vehicles are used for manned flights by the Russian Government.

The EIS notes that APSC is still negotiating to use other Russian launch vehicles. The most likely candidate is the new Angara range of rockets being developed by the Krunichev State Research and Space Production Centre (manufacturers of Proton Rockets) and being marketed by the Lockheed Martin Corporation (USA). The supplement states that for the purposes of environment assessment, the largest of the vehicles has been used as the basis for impact assessment (Supplement p6).

The extent to which the technology, and expertise will remain with the Russian organisations is unclear at this time.

The ARS-3K launcher is a three stage launch vehicle with the following basic features(See Fig 6):

3.2.7.1 First Stage

Four Strap-on “boosters are fixed around the central vehicle. These are fired on the ground and burn until fuel is exhausted (150-200 seconds, by which the rocket has reach about 100 km). Each propulsion stage consists of a fuel tank, oxidiser tank, pressurisation system, rocket motor(s), steering system and other subsytems. At the end of stage 1 flight, the strap-ons are separated from the rest of the vehicle by explosive devices and fall to earth.

3.2.7.2 Second Stage

In the case of the ARS-3K, the second stage also ignites on the ground, but continues to burn after separation of the first stage. Once the fuel of this central module is exhausted, it also separates from the remainder of the launch vehicle and falls to earth.

3.2.7.3 Third Stage

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 32

The third stage of the launch vehicle takes the payload up into orbit. Launch vehicle flight computer and guidance systems are usually located in this stage. APSC proposes to leave third stages in orbit on the basis that this is current industry practice.

3.2.7.4 Kick Stage

A kick stage is sometimes used to manoeuvre payloads into a specific orbit. Kick-stages remain in orbit after disconnecting from the payload.

3.2.7.5 Payload

This is the satellite carried into orbit for APSC’s customer. The satellite is attached to the launch vehicle by a launch adaptor. APSC expects to launch the following types of payloads:

Geosynchronous telecommunications satellites (main market); Low earth orbit communication satellites; Earth observation satellites; Scientific missions; and, Government sponsored payloads.

APSC has no plans for launching manned missions from Christmas Island.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 33

Figure 6. Typical Rocket Components (from APSC Draft EIS)

3.2.7.6 Payload Fairing

The visible nose of a rocket is actually a hollow casing which protects the payload during flight. The fairing is explosively separated into two or three parts once the rocket reaches heights where the air is thin enough and frictional heating no longer poses a threat to the payload. The fairing components fall to earth.

3.2.8 Fuel

Options for fuelling launch vehicles include solid fuels, hydrazine, kerosene and oxygen, and hydrogen and oxygen. APSC states that all launch vehicles proposed to be used at the Christmas Island Launch Facility would be fuelled by kerosene and liquid oxygen. The Draft EIS indicates that both Kick stages and payloads would be fuelled by di-methyl hydrazine and nitrogen tetroxide (P5-10 & 5-31). However recent advice from APSC indicates that APSC will now use a kick stage fuelled with liquid oxygen and kerosene. The satellite

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 34 fuels would be about 0.5%of the volume of launch vehicle fuels (APSC April 2000). APSC does not propose to launch payloads that utilise nuclear fuel to produce heat and electricity. This assessment is therefore set within those parameters.

3.2.9 Flight Termination System

APSC has not provided detailed information on all of the systems contained within a launch vehicle, nor would there appear to be any need for such detailed information to be provided for the purpose of environmental impact assessment. The flight termination system is of interest however, as it is instrumental in determining how a malfunctioning launch vehicle is dealt with. The flight termination system is located in the third stage of the launch vehicle. This is connected to components in each stage so as to enable destruction of the rocket in the case of launch malfunctions such as deviation from the intended trajectory.

3.3 PROJECT CONSTRUCTION

APSC expects that construction would take eighteen months, and provided an indicative timetable of the construction program in Appendix E of the Draft EIS. APSC commits to full compliance with Australian standards in terms of design and construction parameters and materials and equipment. Generally the proposal will be subject to building approvals under Western Australian legislation – through WA state regulatory authorities under service agreements with the Commonwealth Territories Office or by the Shire of Christmas Island Council.

Construction would be a staged process, commencing with infrastructure upgrades (Roll-on Roll off facility, water pipeline, power supply and road works) prior to construction of the main South Point facilities.

Where possible, building components would be prefabricated prior to shipping to the island. Early shipments of materials would be delivered via the current port facilities at Flying Fish Cove. Once the RO-RO facility is in operation, shipments would switch to that facility, although the EIS also identifies the option of transporting material directly to South Point using an offshore barge and helicopter.

The EIS commits to the avoidance of unnecessary vegetation clearance and to no clearance of rainforest (there is a moratorium on the clearance of primary rainforest on Christmas Island). It is estimated that construction at South Point and Irvine Hill will require the disturbance of about 65 ha of land (the condition of this land is discussed in the impacts section). The Draft EIS (p5-28) also states that about 20km of infrastructure corridors (along road

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 35 borders) would be disturbed. With the power cable alone 20 km long, this may be an underestimate.

As noted previously, the South Point facilities would be constructed on previously mined land. A feature of the earlier mining by hand of phosphate is that an odd landscape of sizeable limestone pinnacles has been left behind. This landscape can be found in some areas that would form part of the Technical Complex and would have to be levelled and crushed and compacted so that building platforms can be created. The Draft EIS states that investigations to date have indicated that blasting would not be required for the removal of limestone pinnacles (P9-1). Blasting impacts were therefore not examined in the EIS, and have not been considered in this assessment.

It is expected that the construction workforce would be 150-170 people on average with a peak of 300 for about 7-8 months. The workforce would be sourced from the Island where possible, with the bulk from the Australian construction industry. A number of Russian supervisors would also be required. Some of the workforce would operate on a fly-in fly-out basis.

A temporary accommodation compound of demountable buildings would be established in the area between the proposed Technical and Launch Complexes, and would be dismantled after use with the site rehabilitated. The compound would be fairly self contained – providing accommodation, dining and food preparation facilities for employees as well as fuel storage, maintenance workshop, vehicle and machinery parking and storage. Some of the support facilities such as catering, laundering, transport, cleaning and waste disposal would be out-sourced to local businesses.

3.4 PROJECT OPERATION

3.4.1 Employment

APSC estimates that approximately 300 direct employees would be required for the operational stage of the project. Of these about 50% would be technical, 30% management and 20% support staff.

The specialist technical nature of much of the work (and possibly limitations on technology transfer) leads APSC to estimate that 60% of staff would be foreign trained experts, while the remaining 40 % could be recruited from mainland Australia and Christmas Island.

Satellite assembly and preparation would be handled by the satellite owners, and staff would visit the island for this purpose.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 36

The cyclical nature of the launch process would lead to variations in employment levels, with some staff on the island for specific periods associated with a launch. While the normal operation of the facility would involve 12 launches a year, this will not occur until about the sixth year of operation, and there would be a corresponding rise in staff over that period.

3.4.2 Launch Operations

Launch vehicle assembly would begin 30 days prior to a scheduled launch. This involved unpacking stages, equipment installation, electrical and pressure testing, and installation of pyrotechnic (explosive) devices. The rocket stages are then joined together.

Satellite preparation can take up to 8 weeks. Once delivered by air, the satellite undergoes a series of tests prior to fuelling. It is then transferred to the hazardous processing bay for fuelling and the addition of pyrotechnic devices and small solid rockets as required. Further tests are then conducted.

The satellite is joined to the adaptor and kick stage (if used) and is then moved across to the Launch Vehicle Assembly Building for assembly with the launch vehicle and fairing. The completed vehicle is then lifted onto a specialised rail vehicle for transport to the launch pad.

The launch pad is prepared by checking all plumbing and connections. The launch vehicle is taken slowly by rail (by remote control) from the Technical Complex to the Launch Complex. The launch vehicle is brought to an upright position and attached to the adaptor. The vehicle is then attached to the service tower and umbilical tower.

The Draft EIS (P5-12) specifies weather conditions which may prevent a launch. Prior to fuelling, the exclusion zone is evacuated. The fuelling is carried our automatically and monitored from the Mission Control. Launch approval is given by the launch safety officer subject to all conditions being met. These include the condition of the rocket, payload, and tracking facilities, as well as weather conditions, clearance of local exclusion zones, and drop zones and flight path declared and cleared.

The ascent to a low earth orbit takes about ten minutes. During this time the launch vehicle is remotely monitored and the data is used to monitor the safe flight of the vehicle. Tracking will be carried out via satellite systems, existing down range terrestrial stations, or by a down range ship.

3.4.3 Drop Zones

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 37

APSC intends launching to the east, south-east and south (see figure 7). In the case of south-east path, the exact direction may vary between 42 and 52 degrees. Each launch will require the declaration of three drop zones for the return to earth of the first and second stages and the fairings. If the third stage was to be de-orbited, it too would require a drop zone.

The exact location of drop zones along the flight path will vary between launches depending on the payload size and model of launch vehicle. Drop zones can also be altered to avoid certain areas, although this may require a larger rocket for a given payload, or restrict the amount of fuel that can be carried by a payload. Drop zone ellipses are set at the 95 percent probability limit (ie, 95% probability of the stage landing within the ellipse) .

The EIS provides information on the various notification procedures to inform shipping and aircraft of intended launches, flight paths and drop zones. During final launch preparation (3hrs before a launch and half an hour after) aircraft using Christmas Island Airport will have to avoid a 5km restricted zone around the launch pad, while generally aircraft will be banned from a 15km radius area around the launch site and extending 35 km downrange. From 30 minutes before a launch to 30 minutes after a launch all aircraft will be banned from drop zones. Sea exclusion zones will operate for 4 hours before the launch until the all clear signal and will include the first 50 km of the flight path as well as drop zones. These parameters may vary slightly, depending on the final decisions of the Space Licence and Safety Office.

Figure 7. Launch Directions from Christmas Island (note, some drop zones have been revised in the Supplement)

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 38

from APSC Draft EIS

3.4.4 Security

The Technical Complex and the Launch Complex would both be surrounded by security fences and a security check point would be located at the road entrance to the Technical Complex.

APSC proposes that for a period of up to 24 hours before a launch, people would be excluded from a land and sea exclusion zone in a 2 km radius from the launch pad. Viewing areas outside this radius would be established in consultation with the Shire Council. The area would be secured by road checkpoints, patrols and light aircraft surveillance of the marine component.

Local notification of timing would include public notices (community noticeboards, boat ramps and roads crossing exclusion zone), radio announcements, and newspaper advertisements. Local notices would be in all three Christmas Island languages.

3.4.5 Transport

Most transport associated with the proposal would be cross island – between various areas of the Dogs Head Settlement area and the South Point facilities. APSC anticipate that during the construction period, about 15 trips a month

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 39 would be required to transport freight and construction materials across the island. Personnel would be located at South Point during the construction period, although they could be expected to visit the township. About 41 trips per month would be required for rocket components and fuel during the operational phase, as well as about 22 bus trips a day to transport personnel to and from the site.

Safety procedures for transportation of hazardous materials are discussed in the Impacts Chapter.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 40

4 EXISTING NATURAL ENVIRONMENT

4.1 GENERAL

Christmas Island is located in the Indian Ocean, approximately 2,600 km west of Darwin , 2,600 km north-west of Perth, and 360 km south of Java. The island covers approximately 135 square km. The island has a typical tropical, equatorial climate with a wet season from December to April. The mean annual rainfall is 2109 mm.

The island is thought to have formed as a result of an undersea volcano that rose to the surface, resulting in the formation of a coral atoll. The atoll later subsided and then about 10 million years ago began to rise again – the terraced effect seen on the island today is a result of staged fringing reef development and erosion of sea cliffs prior to the next uplift. Soils are derived from either limestone sources, or in some areas basaltic extrusive rocks. The phosphate deposits found on the island are thought to be a combination of guano deposits and lagoon marine sediments.

Christmas Island can be viewed as a series of concentric terraces around an irregular plateau with lower terrace cliffs steeper and higher than the upper terraces. Deeper soils occur on the upper plateau and inland sides of terraces.

The immediate coastal zone is generally saline with thin soils. The zone directly behind that is also a harsh habitat for most plants, with Pandanus and salt bush occurring in areas exposed to salt spray. Further inland, the environment becomes more sheltered and rainforest develops with structure and floristics determined by depth and type of soil. Coastal terrace forests are generally more open and drier than those on higher terraces (also dependant on the aspect, with SE coastal terraces being moist and closed), while the plateau rainforests possess a tall closed canopy with emergent trees to 45 metres.

Other habitats include:

Ø limestone scree slopes, inland cliffs and pinnacles; Ø perennial springs and surface water (in areas where basalt comes to the surface); Ø sea cliffs (average 10-20 m rising to 60 m); Ø karst formations (cave systems, overhangs, rock crevices and sinkholes); Ø Mangrove forest (50 m above sea level at Hosnie’s Springs – a Ramsar site); Ø Minefields – often limestone pinnacles left after the removal of topsoil; Ø Beaches – coral and shell with a few sand beaches – Dolly and Greta beaches providing turtle nesting habitat;

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 41

Ø Shoreline rock platforms; and Ø Marine – the shallow water area supporting corals and sand areas extends 50-100m out from land before the sea floor plunges deeper towards the Java trench.

Table 1. The following table lists threatened species listed under the Endangered Species Protection Act 1992 and species of migratory wader which occur on Christmas Island, that are listed under Japanese and Australian Migratory Bird Agreement (JAMBA) and the China and Australia Migratory Bird Agreement (CAMBA),:

Type Scientific name Common name Listing* MB** RP† Mammal Crocidura attenuata trichura Christmas Island Shrew Endangered A Pipistrellus murrayi Christmas Island Pipistrelle * Bat Bird Parasula abbotti (Sula abbotti) Abbott’s Booby Endangered J A Accipiter fasciatus natalis Christmas Island Goshawk Endangered F Fregata andrewsi Christmas Island Frigatebird Vulnerable C F Ninox squamipila natalis Christmas Island Hawk Owl Vulnerable F Anous stolidus pileatus Common Noddy C, J Fregata minor minor Greater Frigatebird C, J Phaethon lepturus fulvus White-tailed Tropic Bird C, J Sula leucogaster plotus Brown Booby C, J Sula sula rubripes Red-footed Booby C, J Reptile Chelonia mydas Green Turtle Vulnerable F Eretmochelys imbricata Hawksbill Turtle Vulnerable F Lepidodactylus listeri Tree Gecko Vulnerable Rhamphotphylops exocoeti Christmas Island Blind Snake Vulnerable Plant Muellerargia timorensis Endangered Tectaria devexa Endangered Huperzia phlegmarioides Vulnerable * = potential candidate for listing under the ESP Act. ** ‘MB’ Migratory Birds: ‘J’ = JAMBA; ‘C’ = CAMBA † ‘RP’ Recovery Plan Status: ‘A’ = Approved by the Minister; ‘F’ = Final Recovery Plan prepared. Note: In August 1999 the status of the Christmas Island Goshawk was upgraded from Vulnerable to Endangered.

4.2 FLORA

There are 412 documented plant species on the island, with 17 endemic to the island. Many of the plant species on Christmas Island can be found on the island in a form and in habitat different to that with which they are usually associated. Elsewhere they are found in open coastal habitats, whereas on Christmas Island, they can be found in elevated dense closed forests, forming part of the canopy. There are also several plants which occur with very limited distribution on Christmas Island.

The island has twenty five species of rare plants (Briggs and Leigh 1995), and, and two species are listed as endangered and one as vulnerable under the Endangered Species Protection Act 1992. The Draft EIS provides maps of known

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 42 distributions for these species and short descriptions of the species and known habitat. Table 1 shows endangered and vulnerable species.

4.3 FAUNA

The geographic isolation of Christmas Island has led to a high number of endemic species and the development of unique natural history features of the native fauna. Of the 31 native vertebrate species that occur on Christmas Island, 20 species are endemic: five mammals, seven land and shore birds, three seabirds, and five reptiles.

Of the mammals, two rat species have become extinct since settlement, while the Christmas Island Shrew is listed as endangered and has not been sighted since 1985. The Christmas Island Pipistrelle – a small insectivorous bat – has declined markedly in the last decade for reasons not fully understood. The main text of the Draft EIS (P6-26) fails to consider the most recent surveys and incorrectly states that the Pipistrelle “ … is well distributed over the island and is also common”. The endemic Christmas Island Flying Fox is widespread across the island.

Five of the six reptile species are endemic, and there has been a marked decline of several species over the last decade. Opportunistic observations carried out at various points on the island by Newsome and Bamford, while conducting surveys for the EIS, noted this absence of native reptile fauna in areas where anecdotal accounts had them as common (Supplement Att V, P15).

Of the 11 native land birds (7 endemic) the Christmas Island Goshawk is listed as endangered, while the Christmas Island Hawk Owl is listed as vulnerable. The Island has been listed by the Birdlife International as a key area of bird endemicity.

Christmas Island is a world class seabird breeding colony. Three of the eight seabirds present are endemic to the island. The forest on Christmas Island is the only remaining habitat for the endangered Abbott’s Booby; while the endemic and endangered Christmas Island Frigatebird is restricted to nesting in three areas in the north-east of the island. In discussing the third endemic bird – the Golden Bosun – Phaethon lepturus fulvus – the Supplement (p20) notes scientific debate concerning whether this bird is simply a colour morph of the more widely distributed White Tailed Tropic Bird, or actually a sub species. While this has yet to be settled, it would be appropriate for the purpose of this assessment to assume until proven otherwise that the Golden Bosun is a distinct subspecies restricted to Christmas Island. Six of the seabirds are listed under the Japan Australia Migratory Birds Agreement and six are also listed under the China Australia Migratory Birds Agreement (see Table 1).

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 43

The most striking feature of the invertebrate fauna are the 11 species of land crabs including the numerous red land crab, the blue crab and the once widespread large robber crab which no longer occurs in most of its range elsewhere (due to deforestation and over-consumption). The Island’s land crabs migrate to the ocean once a year to reproduce.

Less obvious is the internationally significant terrestrial and aquatic subterranean fauna that occurs in the caves, crevices and groundwater systems on the island and of which little is known. Fauna has been found in anchialine systems on the island. Anchialine habitats consist of bodies of haline waters, usually with a restricted exposure to open air, always with more or less extensive subterranean connections to the sea, and showing noticeable marine as well as terrestrial influences. They typically occur in volcanic or limestone bedrock (Humphreys in press), and are vulnerable to disturbance. The Procaris species found on the island is one of only three species known from this genus – the other two are known from Hawaii and from Ascension Island in the south Atlantic. Information on the subterranean fauna was provided in a submission by Dr W F Humphreys, a senior curator at the Western Australian Museum. Apart from an acknowledgment of comments on this issue in the supplement, the EIS did not provide any details regarding subterranean fauna.

4.4 ISLAND ECOLOGY – FAUNA & FLORA INTERACTIONS

The EIS notes that the forest communities of Christmas Island are unusual in species composition because of the sparse vegetation cover in the understorey and the occurrence in the closed forest of trees found elsewhere in open coastal forests. These characteristics may be due in part to the presence of the red land crab found in abundance throughout the forest. Studies have shown that the red crabs are a ‘keystone’ determinant of forest structure and processes (Green et al 1997 1998 1999), largely determining rates of seedling recruitment and litter decomposition.

The resulting forest provides important nesting habitat for a number of seabirds including the Abbott’s Booby in the plateau forests. The terrace rainforest supports the Christmas Island Frigatebird, while the shore Terrace forests are the breeding grounds for the Red Footed Booby.

The Christmas Island Fruit Bat, and a number of the land birds are important for pollination and seed distribution, while the land crabs may also be important for seed distribution.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 44

4.5 THREATS TO FAUNA AND FLORA

Historically island ecosystems around the world have been particularly vulnerable to damage and degradation as a result of human settlement. Most other islands in the Indian Ocean and the South-East Asia region are losing habitat to expanding human populations and associated habitat destruction and degradation. Christmas Island possesses a relatively intact ecosystem, but, as indicated by the list of endangered and vulnerable species, it has and still does experience a range of threats.

Phosphate mining operations have resulted in about 70 clearings in the plateau rainforest, adding up to a total of 32 km2 out of the 137 km2 island (25% of the island and 30% of the plateau area). The removal of soil has deterred regrowth, enabling the establishment of weed species. Gaps in the rainforest canopy has also increased wind turbulence in adjacent areas important for the returning Abbot’s Boobies. Weed species have been accidentally introduced as hitchhikers on sea and air transport and freight, as well as being deliberately introduced as food or garden plants. To date most weed invasions have occurred in mined, disturbed or marginal rainforest areas. While generally this clearance has reduced habitat for species, some of the areas cleared and mined at the turn of the century have become valuable habitat in itself, and some introduced species such as the Japanese Cherry are important food sources for the Imperial Pigeon and the Christmas Island Fruit Bat. There is currently a moratorium on the clearing of primary rainforest on the island and the Christmas Island Rainforest Rehabilitation program is working to rehabilitate mined areas.

Of the introduced vertebrates, the Black Rat may have been responsible for the extinction of the native rats (via disease), while feral cats are numerous and widespread. There are five introduced reptiles – the South-East Asian Wolf snake being of particular concern as it may possibly be having a negative impact upon the endemic Pipistrelle bat and native reptiles.

The introduced animal of most concern is the Yellow Crazy Ant, Anoplolepsi gracilipes, which was accidentally introduced early this century. Recently the population has exploded and formed multi-queened “supercolonies” at several locations. The ant sustains very high densities and systematically wipes out red crabs, robber crabs, blue crabs and reptiles where supercolonies have become established. Drs Green and O’Dowd and Professor Lake, have been studying this problem, and in their submission noted that the ant is also associated with a sap-sucking scale insect and causing extensive canopy dieback. The submission by Birds Australia notes that a forthcoming review of the status of Australian birds by S.Garnett will recommend that all endemic Christmas Island birds be listed as critically threatened as a consequence of the threat posed by Yellow Crazy Ants.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 45

The removal of land crabs already appears to have led to an increase in understorey vegetation in supercolony areas, while canopy dieback could have a direct impact upon seabird nesting areas. These are profound changes in the island’s ecology with unknown long term consequences. A three year ant Action Plan has been developed to better understand the ecology of the ants and to trial and implement suitable control techniques to manage their populations.

4.6 PROJECT SITES

4.6.1 Flora

The site of the proposed Technical and Launch Complexes at South Point is on a higher terrace separated from the surrounding coastal terrace by steep slopes and cliffs which are broken by an intermediate narrow terrace in some areas. The site itself is within the boundaries of a mining lease – ML100 – and has been subject to mining for phosphate. Some areas have also been previously used for phosphate processing, and for tailings ponds from processing. The resulting landscape includes the dried tailings pond surfaces, high areas of limestone pinnacles in the northern section, and more recently and currently mined areas in the southern section. Apart from the current and recently mined areas, the site is covered by a combination of regrowth and weed species. The north and north west border is fringed by primary rainforest and adjacent regrowth, while to the north-east, a fragment of primary rainforest remains within the ML100 lease (adjacent to the proposed Technical Complex). The southern area is adjacent to cliff-side vegetation.

The survey conducted for the EIS did not find any threatened or endangered species within this area, although five of the island’s endemic species were found within or adjacent to the area. Of the 96 plant species recorded on the APSC site, 54 are known to have been introduced. The flora survey focused on identifying the presence of rare and endangered flora and in our view did not extend to a thorough examination of the habitat value of regrowth on the sites that may be cleared as a result of construction of the Technical and Launch Complexes.

Based on current information, we do not support the conclusion in the Draft EIS that “This regrowth vegetation generally consists of colonising species and weeds, and is therefore of limited conservation value” (DEIS p9-8). APSC also is of the view that current vegetation on the site is likely to be removed through proposed future mining activities prior to construction of APSC facilities (DEIS p9-9). Christmas Island Phosphates (CIP) Environmental Coordinator has informed us that:

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 46

“CIP does not intend to clear any areas within ML100 that would involve clearing secondary regrowth or mature rainforest trees. We are currently conducting secondary mining in this area which consists of mining between pinnacles that were mined in previous years. To gain access to some area we have cleared vegetation, but only of the weed species Leucena” (Lynch, pers com 1999).

Similar concerns apply to the level of information available on vegetation coverage of the proposed Irvine Hill Residential and Administrative area (which is covered by secondary regrowth and patches of primary rainforest) and any areas that may need to be cleared for additional airport facilities (the flora survey noted that some secondary regrowth in that area was gradually being replaced by trees associated with primary rainforest).

Recommendation 1: APSC, in consultation with the Christmas Island Conservator, should establish a comprehensive baseline by identifying areas of vegetation on the proposed Launch and Technical Complex that are of important habitat value.

Recommendation 2: APSC, in consultation with the Christmas Island Conservator, should establish a comprehensive baseline by conducting flora and fauna surveys of the Administration and Residential Complex, and any areas to be disturbed during construction of additional airport facilities.

4.6.2 Fauna

Fauna Surveys of South Point were carried out for the EIS in April 1999 (DEIS App l) and July 1999 (Supplement Att V). Fauna surveys were not conducted for the Irvine Hill site. The surveys included systematic observations for birds and reptiles, but only opportunistic observations for mammals. Fourteen sites spread across South Point were the focus of the original survey, with an additional four sites to the NW of the proposed South Point facilities added in the second survey. Survey techniques used were:

Ø Opportunistic observations; Ø Fixed point census for Seabirds from points on the coastal terrace, and cliffs overlooking the coastal terrace; Ø Area search for land birds. Searches were over an area of about 20 ha for 20 minutes and were located in each of the main vegetation types; Ø Hand searching for reptiles. Searches at three sites during daylight and two sites at night. The report noted that conditions were not good for observing reptiles with heavy cloud and frequent rain.

We believe that there are a number of issues that restrict the reliability of the surveys conducted for the EIS:

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 47

The survey found no Pipistrelle bats “despite driving at night just after sunset, when the species is reported to be most active”. The submission on the Draft EIS by Dr Lindy Lumsden (one of the authors of a report on 1998 survey results) stated that the level of survey conducted for the EIS was inadequate and that ultrasonic detectors should have been used. The 1998 survey, which made use of ultrasonic detectors, detected 44 bat passes at a site very close to the proposed Technical and Launch Complexes on South Point. In other correspondence Dr Lumsden has stated “While population densities are lower in the South Point area than they are in the west of the island, as the species is currently in decline and classified as Endangered, it is important to consider all populations of the species. To comprehensively investigate the distribution and abundance of the pipistrelle in this area further survey work would be required, using ultrasonic detectors so that the data was comparable to our results. To determine how the species is using the area and the likely impact of the space station, it would be necessary to locate roost sites and foraging areas by radiotracking” (Lumsden pers com, March 1999). It should be noted that in discussing APSC’s proposals for conducting surveys for the EIS, Environment Australia did advise that ultrasonic detectors should be used to detect Pipistrelles.

The final version of the Natural Impact Matrix (P30) submitted as part of the March 2000 additional information concludes that no commitment is required by APSC in relation to the Pipistrelle, as no bats were found in the fauna surveys.

Recommendation 3: APSC should establish a comprehensive baseline for the Christmas Island Pipistrelle Bat by conducting surveys of its distribution using ultrasonic detectors, and where appropriate, radio tracking, in order to establish the distribution and abundance of the bat on South Point. The survey should be completed prior to the commencement of any construction activity on South Point by APSC and the survey design should be approved by the Environment Australia.

The survey for reptiles was very limited, and none of the survey sites identified occur on the area to be disturbed by the proposal. The additional information provided in March 2000 responded to a request for additional information on this issue and explained that although none of the survey points shown on the map are within the project area, the map points are only indicative and that surveys at the points nearest the project area did indeed cover the site itself. While accepting this, we still view the level of effort in searching for reptiles on or near the project area as inadequate. The site searched that probably included parts of the Technical Complex was searched for 40 minutes on one evening by torchlight. The site searched closest to the Launch complex was searched for one hour on one day. As noted in the general discussion on fauna, there has been a marked decline of several species of endemic reptiles over the last decade. The report for the April 1999 survey by Newsome and Bamford (DEIS App l) noted that the Blue Tailed

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 48

Skink, which was not found at all during a 1998 reptile survey of the island, has been reported from the artificial environment of pinnacle fields elsewhere on the island, and that it is therefore possible that it may be found in the pinnacle fields on South Point.

Recommendation 4: APSC should establish a comprehensive baseline, by undertaking a survey of the occurrence of endemic reptile species should be carried out in the areas that would be disturbed during the construction and operation of the Technical and Launch Complexes on South Point. The survey should be completed prior to the commencement of any construction activity on South Point by APSC and the survey design should be approved by Environment Australia.

Some aspects of the approach used to survey seabirds were questionable (for example, there were no surveys from the ground on the eastern coastal terrace), although, the surveys were sufficient to confirm previously documented seabird distribution. Substantial improvements in the survey design will need to be made if a credible baseline is to be established for monitoring purposes. This is discussed further in the Natural Impacts Chapter.

Apart from these issues, the EIS provides a general picture of the occurrence of fauna on South point, based on both the surveys and previous information. As with most other parts of the island, red land crabs were found in most environments, other than in areas along the western coastal terrace where crazy ants were found. The Draft EIS assumes that on available data, all native reptile species would be present in their preferred habitat on South Point, but that activities on the areas proposed for the Technical and Launch Complexes would be unlikely to directly affect any species other than possibly the Blue Tailed Skink. Two introduced reptile species were found during the surveys.

Christmas Island Fruit Bats were observed at several points along the Western Coastal Terrace (note that ground surveys were not conducted on the Eastern Terrace). A male, female and juvenile Christmas Island Goshawk were sighted on the eastern terrace less than 1km from the proposed Launch Complex, as were relatively large flocks of the Christmas Island Imperial Pigeon. A Christmas Island Hawk Owl was heard calling during a night survey of the western terrace, and the surveyors conclude that given a total island population of 600 pairs, it is likely that a “reasonable” population occupies the south point area

Nine species of land bird and six species of seabird were recorded during the initial survey. Of these, the Christmas Island Goshawk is endangered, the Christmas Island Hawk Owl is vulnerable, as is the Christmas Island Frigatebird (although these were only seen in flight and are unlikely to nest on South Point). During the second survey one Abbott’s Booby (endangered)

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 49 was sighted in flight at a new survey site to the NNW of the project area. The survey report noted that this may indicate that a pair nests in the area, although it may also have been a bird from the nearest Abbott’s Booby colonies which are about 5 km from the South Point project area.

While the seabirds known to nest at South Point are not endangered or vulnerable, the seabird colonies on South Point are some of the most important on an island that is itself recognised as an important seabird breeding site. In response to comments that the draft EIS did not fully consider this aspect, the Supplement provided further information on this issue (P20).

The Supplement notes that while the actual proposed South Point site for the project may represent less than 1% of the island, the development is on a peninsula and within a few kilometres of roughly 5% of the island’s terrace rainforest. This may be an underestimate given that South point incorporates approximately 16% of the island’s coastline. The actual number of seabirds estimated to nest on the coastal terraces of South Point are much higher than either 5% or 16% of the Island’s population.

Based on evidence from previous surveys, the 6000 pairs of Red Footed Boobies that nest on South Point make up 50% of the total Christmas Island population, while there are estimated to be a further 1,400 to 5000 pairs in the rest of Australia. The Draft EIS recognises that the Christmas Island population is one of the largest in an estimated global population of one million.

In addition, South Point is a breeding area for 20% of the island’s Brown Boobies, 20% of the Red Tailed Tropic Birds, 25% of Golden Bosuns (subspecies endemic to Island), 40% of Common Noddys and 40% of Greater Frigatebirds. In relation to the significance of the Red Footed Booby and Greater Frigatebird populations, the supplement notes that while these may be significant in the Australian regional context, “The widespread distribution of these birds, however, and their occurrence in many protected areas, is reflected in their secure and stable global populations” (Supplement p19).

Apart from the estimates of global population numbers, no evidence is provided to support this assertion. Contrary to this are reports of evidence that across the globe “ … many seabird populations have become endangered owing to the rapid acceleration of certain activities by man in marine areas …” (Nettleship et al 1994). In the case of Indonesia “Records from before 1960 and the results of surveys carried out in 1981, 1987 and 1989 reveal that Indonesian seabird populations are declining rapidly” (De Korte, 1991). Whilst these seabird species may be widespread, so are the effects of human exploitation. Unless documentation is provided showing otherwise, it must be assumed that the seabird colonies on Christmas Island, and that on South

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 50

Point are highly significant regionally, if not globally, and are currently comparatively secure from negative human impacts.

4.6.3 Karst Habitats

No attempt was made to determine whether subterranean fauna occurred in cave systems or groundwater systems under South Point. The Supplement (p82) notes that reports and studies on Christmas Island cave systems have focused on accessible caves in the north and central part of the island. No obvious cave systems are known to exist on South Point. Cave systems have often been found on Christmas island through detection of sea cave openings. The remoteness of the South Point area and the commonly rough conditions on that side of the island have discouraged this practice.

Figure 8. Upper level chamber in Daniel Roux Cave, Christmas Island (this cave is not on South Point)

Photo courtesy of Rauleigh Webb

APSC notes that drilling work carried out as part of geotechnical investigations for the project did not reveal any large cave systems beneath the proposed facility. APSC’s position is that “At this time, APSC considers that there is a possibility that cave systems do exist beneath South Point and has structured its impact response accordingly”. APSC commits to discussing with Parks North “ … the possibility of carrying out investigations over the next several years into the presence or otherwise of cave systems beneath

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 51

South Point and whether these are stable or contain valuable flora and fauna” (Supplement P83). Prior to this, during early launches, monitoring locations would be set up within the nearest known cave systems.

The report on Geotechnical Investigations by ARUP Geotechnics for APSC (May 1999) was not provided to Environment Australia until after the request for additional information was made in March 2000. The document reports that investigations found that narrow, near vertical, open joints were encountered in a number of boreholes including some in the area proposed for the launch pads, while two larger cavities were encountered in boreholes in the vicinity of the proposed technical complex. The maximum amount of free space encountered in each borehole was around 10m, at the base of which was a loose bed of sandy gravelly debris up to a depth of 6m. The cavities began at 10 and 12 metres depth. The Geotechnical report concluded with recommendations including that:

“ … further investigation must be carried out once the final design layout of the Space Base has been determined. The purpose of the investigations will be to confirm that there are no large cavities, cave networks or adverse structural features in the rock … In particular, further investigation should aim to resolve the following issues: Whether the location of sinkholes between BH108 and BH109 and the occurrence of deep open cavities in both of these boreholes represents a possible cave network in this area.”

While the focus of the geotechnical survey was on determining whether appropriate bearing stratum existed for the proposed structures, the results indicate that there may be a potential cave system in the area, thus posing a question as to the occurrence of subterranean fauna. We are of the view that APSC’s commitment to consider further investigations in a few years time is inadequate given that insufficient data is currently available to gauge the importance of the area to subterranean fauna, and that the geotechnical survey clearly indicates that it is possible to obtain further information on any cave systems.

Recommendation 5: APSC must develop a proposal to conduct a survey for possible cave systems and subterranean fauna on South Point focusing on the proposed site of the Technical and Launch Complexes and using non damaging techniques such as ground probing radar. This plan is to be approved by Environment Australia prior to the survey taking place. A report on the survey results must be provided to Environment Australia and should be taken into account in the development of the Environmental Management Plan for the project.

A final point in relation to the environmental value of the project areas on South Point relates to a comment made by Newsome and Bamford in the April survey report (Appendix l p14) of the Draft EIS: “It is difficult to

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 52 establish the significance of the South Point area to the endemic land birds that occur there because much of the original habitat has already been lost”. It should also be noted that a condition of mining leases on Christmas island is that rehabilitation must occur prior to the end of the lease. Actions and commitments by the proponents need to be contrasted not just against the current environment, but also against what future improvement in the natural environment may be forgone.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 53

5 OVERVIEW OF SOCIAL AND ECONOMIC ENVIRONMENT

5.1 HISTORY

Christmas Island was originally sighted and named by a British East Indies Company Captain William Mynors on Christmas Day 1643. The first recorded landing was by William Dampier in 1688 (Adams 1993), however the island was not settled until 1888 following the discovery of indications of rich phosphate deposits by the Challenger Oceanographic expedition. Most of the workforce were indentured labourers recruited from China, Malaysia, the Cocos-Keeling Islands, Singapore and India. These workers suffered isolation, low wages, difficult and dangerous working conditions, social segregation and inequality of rights in contrast to the Europeans on the island.

The island was occupied by Japanese forces from March 1942 to August 1945, after which the island was administered as part of the Colony of Singapore. In 1958 sovereignty was transferred to Australia. It was not until 1981 that Australian residents status was available to residents of Christmas Island, and Western Australian law only replaced Singaporean law in 1992.

Continuing poor conditions for labourers led to the formation of the Union of Christmas Island Workers in 1975, and hunger strikes in Canberra in 1979 which finally led to pay and conditions equivalent to those on the mainland (Curl 1997). The government operated mine closed in 1987, and attempts were made between 1976 and 1989 to depopulate the island through a series of redundancy schemes for mine workers and government employees - causing many people to leave the island. The mine was reopened after two years with the workforce as majority shareholders.

The island economy diversified into tourism with the opening of the Christmas Island Resort Casino in 1993, but has suffered since the casino closed in 1998 with debts of almost two million Australian dollars. It was recently announced that the casino and hotel buildings are to be sold to APSC.

5.2 ADMINISTRATION

Christmas Island is an Australian External Territory, with the responsibility for service coordination and delivery resting with the Commonwealth

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 54

Department of Transport and Regional Services through the Territories Office. Services are provided by either:

Ø Christmas Island Administration (the on-island component of Territories Office); Ø Christmas Island Shire Council (established in 1992 and operating under the Local Government Act 1995); Ø Via Service Delivery Agreements with Western Australian Government Departments; or, Ø Through other Commonwealth departments and agencies.

The EIS provides details of the allocated responsibilities, and a range of relevant Commonwealth and Commonwealth/Western Australian legislation.

A town plan was developed in 1994 in an environment of optimism regarding the economy of the island, and earmarked several areas for expansion of the township. The decline in the economic outlook has since led to a revision of the plan. The submission from officers of the WA Ministry for Planning in October 1999 noted that the Shire of Christmas Island Town Planning Scheme No.1 has previously been advertised for public comment and is soon to be presented to the Minister for Territories for final approval. “The Scheme is currently being held in abeyance pending discussions between the Council and the Commonwealth Island Administration regarding, among other things, the proposed release of sites for residential development”.

5.3 POPULATION AND CULTURAL DIVERSITY

There have been significant fluctuations in the island population over the past decade. The 1991 census recorded 1272 persons, in 1994 the population was estimated at 2100 persons, while the 1996 census recorded a residential population of and estimated 1793 persons. The Draft EIS estimated the current population at approximately 1700, while population projections in the March 2000 additional information worked from an existing population base of 1400. Much of the change has been due to the changing fortunes of the resort and casino.

By ethnic groups, the community make-up is about 65% Chinese, many of whom are Buddhist, 20% Malay, most of whom are Islamic, the remainder Caucasian (Johnson, 1988(a)). In 1996, 60% of the population were classified as speaking languages other than English compared with 13% Australia-wide. Chinese languages were recorded as being spoken by 40% of the population while 10% of the population listed Malay as the language spoken in the home. The diversity in languages creates a need for organisations such as the Shire Council and Christmas Island Administration to use interpreters.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 55

The strong cultural diversity of the island is visible through over a dozen Taoist and Buddhist shrines and temples located around the island. The Muslim community focuses around the Kampong area where the Mosque is located. The ethnic communities are also recognised through community organisations such as the Chinese Literary Association, the Islamic Council, the Buddhist Society and temple committees.

In 1996 only 5% of the population were aged over 55 years, while 32% were under the age of 15 years. The lack of educational opportunities past grade ten at the school results in low numbers of people in the 15-24 age group, with a lack of employment opportunities on the island discouraging people from returning after completing their education.

5.4 INFRASTRUCTURE

5.4.1 Education

The Christmas Island District High School caters for students from preschool to year ten. Children are expected to board on the mainland for their final two years of education at a subsidised cost. About 80% of the school children are from non-English speaking backgrounds. Chinese and Malay reading and writing classes are offered on a voluntary basis and Mandarin is formally taught at the school from year three. A Muslim primary school is located in the Kampong.

There are no technical and further educational facilities currently available on the island. Vocational training is provided by Indian Ocean Group Training which provides employment opportunities through traineeships and apprenticeships, short courses, Skillshare services, and by providing a coordination point for employers and potential trainers on Christmas and Cocos Islands.

5.4.2 Health

Christmas Island has a well appointed, 9 bed hospital staffed by trained medical personnel. The island has two general practitioners. Residents have access to the Patients Assisted Travel Scheme if they require specialist treatment in Perth, and medivac facilities are also available in emergencies.

While the medical services are regarded as being of a high standard compared to similar areas on the mainland, it should be noted that the community does not have access to services in a nearby centre, or even a

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 56 centre which could be reached by car. Medical evacuations have a turn- around time of twelve hours. Some inadequacies noted by the island’s social worker (Johnston, L. 1998(a)) were:

Ø The need for one general practitioner position to be designated for a female doctor; Ø Absence of an overall health promotion and awareness strategy; and, Ø Lack of structures to address social health factors of the community.

5.4.3 Social Services

The island has a full time social worker and a welfare assistant (one day a week). Centrelink provides a part time agency service, while the WA Legal Aid Commission provides a paralegal service two days a week and a visiting solicitor every few weeks. Johnson (1998(a)) notes that NGO social services normally expected in Australia such as disability services, meals on wheels, living skills, mental health services, youth services, emergency foster care, respite care, carer supports, community legal services, drug and alcohol services etc are not present on Christmas Island. This is attributed to the island’s ineligibility for traditional sources of NGO funding through State government and Commonwealth sources, and Lotteries Commission funds.

The Christmas Island Women’s Association has an unstaffed safe house which is used by an average of one family a month.

5.4.4 Housing

The population of Christmas Island is concentrated in the north eastern part of the island known as Dog’s Head. Five main residential areas make up the township – located on the coastal terrace and several higher terraces. There is a total stock of residences of about 750 units. The majority of these are flats, units or apartments. The standard of housing has been criticised as inadequate, and there has been efforts to upgrade the standard in the past decade. The Christmas Island Administration has commenced a program of upgrading the existing stock of housing and building new public housing units. Excluding the Island Resort staff accommodation, the current occupancy rate is over 95%. Housing costs are high, with rents ranging from $180 to over $500 a week. There is no equivalent of a state housing authority and home loans tend to be more expensive due to bank’s concerns with the fragility of the island’s economy (Johnson 1998(a)).

5.4.5 Electricity

The diesel power station at Drumsite has a capacity of 12.5 MW, with current usage of about 4.5 MW.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 57

5.4.6 Water

Because of the porosity of the soil, the presence of surface water is restricted to a number of springs emerging where basalt flows intersect with the surface. Drinking water is pumped and treated from a number of springs and underground streams. Flow rates vary according to levels of rainfall. Short term storage is provided by above ground tanks with a capacity of 4.5 ML. In 1995 water usage was four to five times higher than metropolitan Australia – possibly due to losses due to a degraded system.

5.4.7 Sewage

The town sewage treatment plant has a capacity of 4000 equivalent persons. The casino resort has an independent plant.

5.4.8 Waste Management

The island has one landfill site on the plateau with an adjacent second site under development. Difficulties with waste management on the island include the high cost of removal of waste from the island, the need to protect the groundwater, difficulty in disposing of oil wastes and the limited supply of topsoil available to cover the landfill.

5.4.9 Policing

Police services are provided by the Australian Federal Police. At the time of the Draft EIS, there were eight permanent police officers, seven special constables and two administrative personnel. The AFP is also responsible for customs and immigration, while there is one full time officer from the Australian Quarantine and Inspection Service on the island.

5.4.10 Road

There are about 140 km of road on the island. Urban roads are generally sealed with bitumen, while the main roads outside the urban area are surfaced with chalk. Five organisations have responsibility for roads on the island, with the Shire Council acting as a central road authority. The island has a limited bus service for the school, while cycling is limited by the steep hills and distances between the sections of the township. There is a high level of vehicle ownership.

5.4.11 Off-Island Transport

The seaport at Flying Fish Cove has facilities for bulk handling and container ships. A separate handling facility for diesel fuel shipments is at Smith Point.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 58

The port can be closed for several days at a time during an annual period of heavy swells. The draft EIS refers to the longest closure having been 54 days, however the March 2000 additional information states that the maximum period is 10 days. Phosphate shipments are now 700,000 tonnes a year with about 130 ships a year using the facilities (McGovern pers com 1999). Air flights are on a weekly (or more frequent in school holidays) basis from Perth (also servicing Cocos Island), and on a weekly basis to and from Jakarta via a community charter organised by local businesses. The airport is a 24 hour, sealed, all weather runway, capable of taking heavy aircraft.

5.5 BUSINESS AND INDUSTRY

Phosphate mining has been the basis of the Christmas Island economy for much of its history, although its importance has declined recently to some extent. In 1997 the mining lease held by Christmas Island Phosphates covered about 20 square kilometres, at which time Christmas Island Phosphates negotiated with the Commonwealth to extend the mining lease for a further 21 years from February 1998. The mine employs about 140 people.

During the period when the casino resort was operational (1993-98), tourism became an important component of the island economy. The resort itself employed about 325 people, of whom 110 were locally recruited. Some attendees at the community meetings held for this assessment commented that the actual number of people locally employed and contracting opportunities offered to local businesses was less than had originally been expected. In 1995 the resort attracted 30,000 visitors. The injection of wages and business opportunities associated with the resort and increased tourist numbers was a significant boost to the island economy. In addition, an agreement between the resort owners and the Commonwealth required the owners to pay 1% of gross casino profits to a Community Benefit Fund every quarter. The fund was administered by an advisory committee on behalf of the Minister for Transport and Regional Services. The funds were used for projects such as building upgrades and sport and recreational facilities, with some money also directed to identified at-risk groups (Johnson 1998(a)).

The close of the resort casino had a significant impact upon the community and the economy. Apart from the direct reduction in employment, there was also a significant reduction in the population; higher cost and very reduced air services; businesses affected by the decline in tourists and population (leading to more unemployment); and the loss of community assets such as a childcare centre closed due to a reduction in the number of working parents.

The unique natural features of Christmas Island still attract a number of tourists who are catered for by several small accommodation establishments.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 59

The island also has a range of small businesses including supermarkets, cafes and restaurants, diving and fishing charters, and speciality shops.

Christmas Island Administration, the Department of Education and the Shire Council are also major employers on the island.

5.6 SOCIAL FACTORS AND LIFESTYLE

Johnson (1998(a)) describes Christmas Island as a safe, open and genuinely multicultural, welcoming, community. There are numerous and active and diverse community organisations with events open to all. The active and vibrant nature of the community is reflected in the contents (often multilingual) of the Christmas Island Newsletter, and the events notice blackboard at the roundabout. The range of active faiths on the island is quite visible and brings an added dimension to the community probably unique in Australia.

The official crime rate is quite low given the risk factors such as isolation, cheap alcohol, unemployment, and racial mix present. Residents regularly leave their houses and cars unlocked as part of the relaxed lifestyle on the island. A small increase in minor property offences was noted while the casino was operating (Spence pers com 1999). The isolated nature of the island discourages large property offences.

Johnson (1998(a)) suggests that the official crime rate might conceal a much higher rate of unofficial or unreported crime that may be dealt with internally within sectors of the community. Issues such as domestic and family violence and alcohol and drug abuse may be regarded as internal problems.

A number of attendees at the community consultation meetings stressed the value of the lifestyle on the island and were cautious of anything that might threaten this.

Johnson is of the view that some features of the resort casino and its closure had negative impacts upon the community. Apart from the economic impacts, other impacts included:

Ø Damage to some important community alliances; Ø An increased sense of insecurity and some loss of belief in the future of the island; and, Ø An increased sense of isolation and conflict , pointing to a shift toward social dysfunction.

“The impact of the Resort’s closing has been dramatic for several reasons. First, the Resort did not integrate well with the island community, and it did

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 60 not sufficiently consider local perspectives in its decision making. As a result, when it closed and the operators left the island owing money, it was experienced by the community as a betrayal.

Secondly, there is a sense that the Resort owners came to the island promising employment, training and a better quality of life, then left the people and the community worse off.”

5.7 CULTURAL HERITAGE

The Draft EIS provides an overview of Christmas Island’s built cultural heritage. Most of the island is listed on the Register of the National Estate as a Natural Area, while there are a number of items listed for historic values including building groups and precincts representing different aspects of colonial, industrial and Asian architecture, in some cases very different from anything found on mainland Australia.

Of particular interest to this proposal is the listing of the South Point Settlement Remains – the settlement on South Point was used to house many of the labourers working on the mine between 1914 and 1974. The residential area was demolished in 1977 to allow for mining beneath the location of the buildings. Apart from ruins of the railway station and other structural remains, the key feature of the area today are the Chinese South Point Temple and two small shrines, still in active use and important to the Chinese community on the island.

The second particularly relevant listing is the Settlement Services Precinct. The buildings and streetscapes in this area are representative of architecture derived from the British experience in Singapore and Malaya, as well as Chinese terrace houses, all with historical significance. The proposed Roll-on Roll-off facility would be located within the Settlement Services Precinct, which has now become a key commercial area on the island (and also has some residential areas ).

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 61

6 POSSIBLE IMPACTS UPON THE NATURAL ENVIRONMENT AND IMPACT AVOIDANCE AND REMEDIATION.

6.1 CONSTRUCTION HABITAT DISTURBANCE AND CLEARING

As noted in the project description, APSC estimates that about 65 ha of land of varying condition would be directly disturbed during the construction of the proposal. Information regarding the extent of proposed clearing in the Draft EIS was at times inconsistent. In response to a request for clarification, a summary of measures relating to clearing, rehabilitation and revegetation was set out in the additional information provided in March 2000. In relation to construction activities, the proponent included undertakings to:

Ø Locate and describe significant species and their populations and habitat – map and estimate extent of significant species on site for baseline and monitoring; Ø Avoid all unnecessary vegetation clearance; Ø Mark and protect all threatened flora species during construction and operation – install protective fencing around identified threatened species; Ø Monitor significant species on site and avoid disruption to any environments deemed to be significant habitat.

As noted in the existing environment section, further work needs to be completed on vegetation surveys and habitat identification. The loss of large areas of vegetation due to the negative impacts of past activities on the island has meant that degraded habitats and secondary regrowth may currently be important for the survival and recovery of populations of some species (such as the Imperial Pigeon and Blue Tailed Skink, Christmas Island Glossy Swiftlet and Christmas Island Goshawk). It may therefore be necessary for the layout of buildings and infrastructure to accommodate the retention of important disturbed habitat and secondary regrowth.

The Draft EIS explained that cleared vegetation would be burnt. Both Parks Australia and Christmas Island Administration suggested that cleared vegetation could be mulched rather than burnt. In response, APSC committed to assess the options for mulching lighter vegetation as part of site clearing and explained that large logs and trunks would be scattered over the site to provide habitat where not a safety hazard (Supplement PII-52). Mulching of vegetation already occurs on the island (eg, by Parks Australia North) and obviously produces a more desirable product.

Layout plans have not been provided for the proposed residential and administrative facilities at Irvine Hill. The additional information states that

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 62 the Irvine Hill area is 60 ha in size, or which 10 ha will be required. APSC proposes to wait until the location of the 10 ha development has been decided before a fauna survey is undertaken. This approach bypasses consideration of environmental considerations in deciding which area to develop.

Construction of the Roll-on Roll-off facility will most likely cause some disturbance to the immediate sea floor. The EIS notes however that the sea floor adjacent to that area of cliffs has already suffered degradation due to the presence of a number of stormwater outfalls in the area. The condition of the sea floor communities past the “drop-off”, where the level falls away quickly, is less certain and no information on surveys is provided.

While power and communications infrastructure would be placed underground, it is proposed that the water pipeline be placed above ground on low trestles. An underground pipeline would generally have less of an impact upon areas it passed through in terms of appearance and lower maintenance requirements. The towns main water pipeline from Jedda cave to Drumsite tank is currently being put underground. The route for the water pipeline from Jedda Cave to South Point passes through an area of national park, which would require specific approval under the National Parks and Wildlife Conservation Act 1975.

The EIS commits APSC to rehabilitation of areas as soon as possible after construction activity has ceased in a given area. The Flora and Fauna Management Plan indicates that revegetation would be with native, low growing shrubs in conjunction with native grasses where low vegetation is required. While it is appreciated that areas immediately adjacent to buildings, and within areas required to be empty for safety purposes may require any vegetation to be low growing, other areas such as the large empty area between the Technical and Launch Complexes should be able to be revegetated with the object of creating habitat as close as possible to the area’s natural state. Rather than simply discussing rehabilitation and landscaping programs with Parks Australia North (as stated p44 of Additional Information), it would be appropriate for these plans to be approved by Environment Australia as part of the overall Environment Management Plan.

Recommendation 6: The layout of buildings and infrastructure in all areas of the proposal must be designed as far as possible (without compromising safety requirements) to avoid necessitating the clearance of important regrowth habitat during construction. Project layout and construction must not involve the clearance or damage of primary rainforest. Buffer zones at least 20m in width, consisting of regrowth vegetation or rehabilitated areas must be left between primary rainforest and project areas. Cleared vegetation must not be burnt and should be mulched where possible. APSC must obtain the approval from Environment Australia for vegetation clearance prior to construction commencing.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 63

Recommendation 7: Rehabilitation and landscaping plans must be developed as part of the Environment Management Plans to be approved by Environment Australia.

Recommendation 8: The water pipeline from Jedda Cave to South Point must be placed underground. Placement of the pipeline through a section of national park will require separate consideration under the National Parks and Wildlife Conservation Act 1975 or Environment Protection and Biodiversity Conservation Act 1999.

Clearance and construction activity may result in the spread of weeds, edge effects (such as increased levels of predation by native or introduced predators), and the spread and/or dislocation of feral animals. APSC has committed to the monitoring of weed infiltration, eradication of weeds and the design of road and infrastructure corridors to prevent weed infiltration. In relation to the potential dispersal of exotic fauna, the Natural Impact Matrix (p22) states that APSC will cooperate in any eradication programs proposed by Parks Australia North, while the Flora and Fauna Management Plan states that the responsibility for eradication of feral animals from the site would be the responsibility of APSC Environmental Officer in conjunction with Parks Australia North.

Earthmoving equipment could be a transport vector assisting the proliferation across the island of the Yellow Crazy Ant. This is particularly significant with the construction of water pipelines and underground infrastructure requiring the excavation and transportation of soil. The EIS does not consider the need for sterilisation or decontamination of earth moving equipment for either crazy ants or harmful soil micro-organisms.

Recommendation 9: The cost for control of feral animals on project sites and feral animals dispersed to adjacent areas as a result of construction activity must be met by APSC. Control techniques must be approved by Parks Australia.

Recommendation 10: A strategy for the prevention of transportation of the Yellow Crazy Ant and soil micro-organisms through the movement of earthmoving and construction vehicles must be developed and implemented as part of the Environment Management Plan.

In planning the construction activities, APSC will also need to be mindful of the requirements of Part 3 of the Regulations of the National Parks and Wildlife Conservation Act 1975, which makes it an offence to injure, kill or interfere with wildlife unless the wildlife is unprotected. Similar regulations are anticipated for the Environment Protection and Biodiversity Conservation Act 1999.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 64

6.2 TRANSPORTATION IMPACTS

6.2.1 Quarantine

The proposal involves the creation of at least two if not three new entry points to Christmas Island:

Ø Roll-on Roll-off Facility, settlement; Ø South Point landing of construction materials by helicopter (temporary 2-3 months); Ø Additional offloading area at airport (uncertain).

Both the construction and operational components would involve periods of significant increases in traffic onto the island. As noted in the description of the existing environment, introduced plants and animals have had and continue to have a significant impact upon the environment of Christmas Island. The Draft EIS (P9-8) notes that construction materials will be derived from existing quarry sources on the island, or imported from mainland Australia. Although this narrows down the range of possible introductions, the possibility of, for example, phytopthera being introduced to the island with a load of sand is a good reason for strong enforcement of quarantine controls. The Draft EIS also notes that a mosquito vector for Dengue Fever – Aedes albopictus – is present on the island, although the disease itself is not. Increases in the number of visitors to and from Asia (for example, project workforce travelling on leave) could increase the chances of establishment of dengue fever on the island.

In relation to comments on the new entry points, the Supplement (PII-59) states that this issue will be discussed with the Australian Quarantine Service. In relation to the possible increased risk of disease introduction, the Natural Impacts Matrix (P31) concludes that no commitment is required by APSC as although there may be potential, severe, long term impacts on the health of the island population, this risk is no higher than that associated with increasing tourism. A more active approach by APSC would involve inclusion of awareness of quarantine procedures and requirements in introductory training for all employees and contractors.

The submission on the draft EIS by the Manager of Operations of the Western Australian Region of the Australian Quarantine and Inspection Service explained that a Quarantine Officer was supplied on Christmas Island on a 100% cost recovery basis arrangement with the Department of Territories and Regional Services, although this arrangement was under review with the possibility of quarantine services being supplied by trained and audited resident(s) of the island. The submission observed that “Provided that suitable facilities are available to undertake inspections and treatments of imported cargo, containers and adequate suitably trained inspection staff are

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 65 available, it is not anticipated on the information available that there would be any significant environmental impact on the island”.

Recommendation 11: APSC must include awareness of quarantine procedures and requirements in introductory training for all employees and contractors.

Recommendation 12: APSC, in consultation with the Australian Quarantine and Inspection Service, must construct appropriate quarantine facilities at all new points of entry to Christmas Island that are established as part of the proposal.

Recommendation 13: Territories Office must ensure that adequate levels of suitably trained inspection staff are available to undertake quarantine inspections and treatments of the expected increased levels of cargo and containers arriving on the island as a result of the proposal.

6.2.2 Roadkills

The annual migration of land crabs to the sea gives the issue of roadkills a particular significance on Christmas Island. However, even at other times of the year vehicle collision with animals have an impact upon land crabs and other animals such as the Christmas Island Hawk-Owl. The submission from Birds Australia notes that road-killed owls are regularly found in areas of higher traffic density and suggests that a marked increase in the island’s human population might limit the population density of owls in settled areas where traffic density was highest. Safety requirements involving separation of facilities can increase the use of motorised transport within a launch facility. Wildlife studies at Kennedy Space Centre in Florida have noted the impact of road mortality and the potential for measures such as culverts and underpasses to provide corridors for movement (Breininger et al 1994).

The possible increase in red crab road mortality was an issue raised by several public and government agency submissions.

Measures APSC proposes to take that may decrease the level of impact include:

Ø Design of the security fencing at the Technical and Launch Complexes to exclude all crabs (including young crabs); Ø Bus transport for staff to reduce cross-island road use; Ø Cooperation with Parks Australia North during the period of crab migration to minimise impacts to ensure that sections of the roads experiencing high crab migration numbers are avoided or traffic minimised; Ø Making use of flexibility in bringing fuels and components to the island and flexibility in timing of transportation across the island;

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 66

Ø Use of the most appropriate roads between Settlement and South Point; Ø Driver education program for all employees; Ø Use of low growing shrubs to break up large grassed areas that may attract birds.

The Fauna and Flora Management Plan (Supplement Att IV ) states that APSC will “support installation of crab tunnels along newly constructed roads” and will audit the effectiveness through “estimates of crab migration numbers in areas with and without crab tunnels”. However the Supplement itself (PII-53) is less certain about this, stating that “There appears to be little information about the cost effectiveness of existing crab crossings as a means to reduce crab mortality during peak migration periods”, and going on to list measures that APSC consider more appropriate (see above).

The Christmas Island National Park Draft Plan of Management (p74) lists the provision of crab tunnels under roads to have proved effective, although more cost effective designs need to be found .

Recommendation 14: In addition to APSC’s commitments in the EIS, APSC should record instances of significant avifauna road mortality, both on the South Point project area and during cross-island transportation and report instances to the Conservator (monthly). Modification of transport activity may have to be made if Environment Australia determines that levels of road mortality may endanger or further endanger native species. APSC should install crab tunnels under new and existing roads at points to be determined by the Conservator, and should contribute to the maintenance of existing crab tunnels.

6.2.3 Transportation of Hazardous Substances

APSC estimates that the following fuel delivery trips will occur between port facilities and South Point each month:

Ø Kerosene: 15 trips over five days; Ø Diesel fuel: 16 trips over eight days; Ø Unsymmetric di-methyl hydrazine (UDMH) and Nitrogen Tetroxide (NTO): One trip (one UDMH trip every three months, two NTO trips every three months).

The Draft EIS provides details of vessels in which Kerosene, UDMH and NTO are transported in, properties of the fuels, methods of road transport and associated safety procedures. Further information on transport routes and analysis of impacts arising from the transportation of fuels (including spills) was provided in the Supplement (P40-47).

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 67

In response to requests for information regarding transport of diesel fuel, the Supplement (PII-23 & II-13) explained that diesel fuel would be delivered as it is currently on the Island via the facility at Smith Point, pumped to the fuel depot adjacent to the existing power station from where it would be transferred to a road tanker (carrying 12.5 kL) for delivery to South Point. Consideration of the risks and impacts associated with the transportation and storage of diesel fuel has not been supplied by APSC.

The EIS explains that rocket propellant kerosene is similar to aviation turbine fuel, used commonly by jet aircraft. The fuel will be offloaded at the Roll-on Roll-off facility in large ISO approved containers, similar to those currently used to transport jet fuel to the airport. The possible environmental impacts of kerosene have not been effectively discussed in the EIS. In response to a request for additional information on this, APSC responded in the March 2000 additional information report (P41) by referring back to chapter 8.4.1 of the Supplement. While the supplement describes how an uncontained spill could, in a worst case scenario of a large spill (1000+ litres), pass through the porous soil and enter the groundwater supply where many of the toxic compounds tend to persist and recovery “will be virtually impossible”, there is no description of how the presence of kerosene in soils and groundwater may impact upon flora, fauna and the human population. Without this information, we must assume that in such a worst case scenario, there will be a significant negative impact.

The supplement does provide information on how a surface spill might be contained, contaminated soil treated, and how contaminated groundwater might be pumped to the surface and treated.

The Draft EIS provides an outline of the hazardous nature of NTO and UDMH (P5-31 and P5-36) and Appendix B contains the “Statement of Hazardous Nature: Hazardous According to Worksafe Criteria”. Further information regarding the persistence of the chemicals in the environment and the likely environmental impacts was provided in Chapter 8 of the supplement. Environment Assessment Branch sought further information from the Hazardous Substances Unit of the National Occupational Health and Safety Commission (Mazurski pers com Feb 2000).

UDMH is a highly toxic substance classified as a dangerous good under the “Australian Code for the Transport of Dangerous Goods by Road and Rail”. Classification by the National Occupational Health and Safety Commission describes UDMH as a substance that is highly flammable, may cause cancer, is toxic by inhalation and if swallowed, and causes burns. Dr Mazurski sums up its hazardous nature as follows:

“As such UDMH would be classified as hazardous because of its carcinogenicity at concentrations of 0.1% or more. In the Exposure Standards for Atmospheric Contaminants in the Occupational Environment [NOHSC:1003 (1995).UDMH is listed

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 68

with an atmospheric exposure standard of 0.01ppm with a carcinogen and skin notation. Since only a handful of chemicals have lower exposure standards in this list, it may be considered a highly hazardous chemical, particularly in terms of chronic atmospheric exposure.

Patty's Industrial Hygiene and Toxicology (1998) report several incidents of human inhalation exposure to UDMH have occurred. Symptoms of exposure included respiratory effects, nausea, vomiting, neurological effects, pulmonary edema, and increased serum glutamic pyruvic transaminase (indicates liver damage).

The NAERG (North American Emergency Response Group) classifies UDMH as follows: TOXIC; · May be fatal if inhaled, ingested or absorbed through skin. · Inhalation or contact with some of these materials will irritate or burn skin and eyes. · Fire will produce irritating, corrosive and/or toxic gases. · Vapors may cause dizziness or suffocation. · Runoff from fire control or dilution water may cause pollution.

With respect to fire safety concerns NAERG (North American Emergency Response Group) classifies UDMH as follows: HIGHLY FLAMMABLE: · Will be easily ignited by heat, sparks or flames. · Vapors may form explosive mixtures with air. · Vapors may travel to source of ignition and flash back. · Most vapors are heavier than air. They will spread along ground and collect in low or confined areas (sewers, basements, tanks). · Vapor explosion and poison hazard indoors, outdoors or in sewers. Some may polymerize explosively when heated or involved in a fire. · Runoff to sewer may create fire or explosion hazard. · Containers may explode when heated

NAERG (North American Emergency Response Group) recommends for UDMH, when a spill or leak occurs the area is to be immediately isolated for at least 100 to 200 meters in all directions on public safety grounds. If a tank is involved in a fire, isolate for 800 meters in all directions; also, consider initial evacuation for 800 meters in all directions.”

Nitrogen tetroxide is an extremely poisonous, oxidising and corrosive gas classified as a dangerous good under the “Australian Code for Transport of Dangerous Goods by Road and Rail”. NTO exposed to air rapidly forms nitrogen dioxide (a noxious and toxic gas). Reaction with water will produce highly corrosive nitric and nitrous acids, which are sever irritants to skin, lungs and eyes. This may later produce nitrates. Dr Mazurski sums up its hazardous nature as follows:

“NTO is classified in the List of Designated Hazardous Substances as follows

Classification Very Toxic (T+) R26 Very toxic by inhalation. Corrosive (C) R34 Causes burns. .

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 69

As such NTO would be classified as hazardous because of its inhalation toxicity at concentrations of 0.1% or more. With respect to its industrial use NTO (or NDO, see below) are used in the manufacture of other chemicals (e.g., nitric acid and ammonia fertiliser), as chemical manufacturing intermediates, nitrating agents, oxidising agents, as polymerisation inhibitors for acrylates, and as catalysts. In air, nitrogen tetroxide liquid vaporises and dissociates to form gaseous phases of nitrogen tetroxide, nitrogen dioxide (NDO), and nitric acid (mist). NTO is a thick, heavy, greenish liquid that is very volatile (its vapor pressure is about 50 times that of water and 5 times that of acetone). Its yellowish to reddish brown vapor, which is due to the nitrogen dioxide (NO2) resulting from the N2O4--NO2 equilibrium mixture, has a pungent odour similar to bleach. Because of the rapid formation of NDO from NTO in air the atmospheric exposure standard for NDO is relevant to NTO use. In the Exposure Standards for Atmospheric Contaminants in the Occupational Environment [NOHSC:1003 (1995)]. NDO is listed with an exposure standard of 3ppm.

Patty's Industrial Hygiene and Toxicology (1998) report that mild exposure intoxication may induce transient nonspecific symptoms, including cough, dyspnea, headache, nausea, vertigo, fatigue and somnolence, which typically dissipate over the following hours to days, but may persist up to 2 weeks without pulmonary abnormalities detectable by clinical examination. More commonly described in the industrial medical literature is a multiphasic course of disease that can be fatal if untreated. An individual may experience a variety of acute symptoms, including cough, dyspnea, wheeze, chest pain, heart palpitations, weakness, sweating, nausea, vomiting, headache, and eye irritation during or shortly after exposure.

The NAERG (North American Emergency Response Group) classifies NTO as follows:

TOXIC · May be fatal if inhaled or absorbed through skin. · Fire will produce irritating, corrosive and/or toxic gases. · Contact with gas or liquefied gas may cause burns, severe injury and/or frostbite. · Runoff from fire control may cause pollution.

With respect to fire safety concerns NAERG (North American Emergency Response Group) classifies NTO as follows: · Substance does not burn but will support combustion. · Vapors from liquefied gas are initially heavier than air and spread along ground. · These are strong oxidizers and will react vigorously or explosively with many materials including fuels. · May ignite combustibles (wood, paper, oil, clothing, etc.). · Some will react violently with air, moist air and/or water. · Containers may explode when heated. · Ruptured cylinders may rocket.

NAERG (North American Emergency Response Group) recommends for NTO, when a spill or leak occurs the area is to be immediately isolated for at least 100 to 200 meters in all directions on public safety grounds. If a tank is involved in a fire, ISOLATE for 800 meters in all directions; also, consider initial evacuation for 800 meters in all directions.

By bringing these fuels to the island and transporting them across the island, the proposal will create a number of possible scenarios which could cause harm to the environment and/or human health:

6.2.3.1 Spillage into marine environment

Spillage could occur while containers are offloaded onto the island. The Supplement (P45) states that kerosene is moderately to highly toxic to aquatic life (dependent upon the type of kerosene). A kerosene spill would float on the surface and would evaporate and disperse within 24 hours. Spills of UDMH or NTO could have a locally severe impact resulting in the death of

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 70 marine organisms in the immediate vicinity. The Draft EIS (p9-4) states that “No long term ecosystem damage occurs as no harmful residual materials remain in the environment”. While there may be no residual chemicals, any death of coral could be considered an impact in the medium term.

6.2.3.2 Spillage in the vicinity of the township

Fuel will be landed and transported through a number of areas of the township where residences line the road to be used. In the case of NTO and UDMH the roads will be temporarily closed for about 10 minutes and the goods will be accompanied by a spill clean-up truck (the Draft EIS does not mention the use of a spill clean-up truck for kerosene transport, however the March 2000 additional information (p41) in discussing kerosene spills, mentions that an emergency spill team will be present). Householders would be advised of shipments in advance. A spillage in these areas could pose a danger to human health and necessitate evacuation of an area surrounding the shipment. The Supplement (p46) lists potential impacts of a spill of UDMH or NTO in a populated area as follows:

Ø Severe burns to eyes, skin, and lungs of people that come into contact with the compounds; Ø Noxious fumes are blown into dwellings; Ø Severe damage to fauna and/or fauna that come into contact with the compounds; and Ø Temporary contamination and closure of spill area.

The supplement notes that in the USA these chemicals are transported along public highways using a security escort. APSC states that NTO is banned from transport in the USA without a permit (March 2000 additional information p54) while advice from ICF consulting is that NTO is prohibited from highway transport in the USA and that a specific exemption is required (ICF Dec 1999).

There is some confusion in the Supplement regarding possible transport route alternatives. PII-7 states that APSC has already investigated the possibility of alternative road routes to transport goods from the offloading facilities to South Point, but that the only practical route is that which has been proposed. However, P46 states that in responding to an event involving the release of UDMH or NTO during transport through a populated area, APSC would investigate alternative transport route options through less populated areas and goes on to list three options. In responding to this discrepancy, APSC states in the March 2000 additional information (p19), that it has investigated alternative road routes and that the only practical option is that which is proposed and in addition “APSC is willing to investigate the viability of

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 71 alternative routes on a commercial basis where benefits to the community and the Spaceport can result from a combination of resources from APSC, PRL and the Commonwealth”. It is uncertain whether the benefit to the community referred to would include improved road infrastructure or only be the removal of a hazardous substance transport route from their front door. The March 2000 additional information also notes that no detailed routing analysis has been undertaken (p54).

6.2.3.3 Spillage in areas of natural habitat/ areas allowing groundwater access

Kerosene exposed on the surface (including in a marine environment) readily evaporates and is broken down by sunlight. Of particular concern is the possibility of a kerosene spill entering an anchialine groundwater system where the light fuel may become trapped and not disperse to the marine environment.

As noted in the human impact section, direct exposure of fauna and flora in the immediate vicinity of a spill of NTO or UDMH would result in severe damage and death, as would exposure to the resulting nitrogen dioxide cloud from a NTO spill. The occurrence of rain, or the use of misting with water as a spill containment mechanism for an NTO spill could create nitrates that could enter the water table. The March 2000 additional information (P22) provides information on current nitrates levels in island groundwater (very low) and concludes that the quantities of nitrates that could be formed as a result of a spill would be insignificant in contributing to nitrate levels in groundwater. No reasoning as to why a small increase in nitrates levels would be insignificant is given. The Supplement (p44) does however note that APSC’s response to such a spill would include determination of whether sampling of groundwater is warranted. While UDMH is not a persistent contaminant, the Supplement notes that movement through some soils can slow decomposition but concludes that available data suggests a spill of UDMH onto open ground would not readily migrate to groundwater. UDMH can also remain in water for up to 9 days depending on water purity. The Supplement states that “If UDMH did make it to the groundwater, then it will continue to mix and dilute, adsorb to soils and breakdown” (P43).

Apart from the possibility of immediate death or injury to humans, flora and fauna, the key potential impact is the release of hazardous substances into the groundwater system. This is because of the central role groundwater plays on Christmas Island as the only human water supply, a source for fresh water springs, and a habitat in itself. The nature of the groundwater system is not fully understood. The Draft EIS (P9-3) explains that groundwater is thought to flow in a radial direction from the centre of the island. Comments by Environment Australia noted that if this was the case, then it was of some concern that the hazardous material transport route would appear to be on

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 72 the landward side of groundwater flow to areas that included the Hosnie's Spring Ramsar site, a number of town water pumping sources and natural springs that formed habitat essential to the survival of species such as the grey crab. The March 2000 additional information (P40) states “from discussions with Tony Falkland it would appear that it is highly improbable that a spillage from a road accident could effect Hosnie's Spring. This is because it would require the spill to occur in such a way that it happened near access to a currently unknown fissure which also had a connection with Hosnie’s Spring, a highly improbable set of circumstances” (Tony Falkland of Ecowise Environmental Ltd has 15 years experience in relation to Christmas Island water supply issues and recently prepared the draft Water Management Plan for the Island). These comments could be seen to emphasise the unknown characteristics of the groundwater system.

While the results of such an accident could be highly significant, APSC has outlined a range of safety measures to both minimise the chance of a spill and to enable rapid detection, clean-up and isolation of a spill in many cases. The measures proposed for the transport of these goods will also require approval in accordance with relevant Western Australian regulations. The Draft EIS (P11-3) provided the following Road accident probabilities:

Ø Kerosene – one in 33069 years; Ø UDMH – one in 595239 years; Ø NTO – one in 283447 years.

These probabilities are derived by applying a UK study on hazardous materials transport. The Supplement (p40) also refers to US Department of Transport 1996 statistics which showed that the probability of oil shipment accidents was one in 244,000. ICF Consulting (April 2000) concluded that the studies appeared to provide reasonable point estimates of accident probability, but noted that there had been no detailed modelling of the probability of releases in the event of an accident, the consequences of release, or damages associated with releases of UDMH or NTO. ICF suggests that “At a minimum, it would be desirable to model the impacts of worst case releases of NTO and UDMH in inhabited and ecologically sensitive areas of the island. This would at least demonstrate if such releases exceed a threshold of concern and would also help in the formation of spill response strategies.”

Recommendation 15: APSC must present the results of a routing analysis (including the landing of materials onto the island) describing and evaluating all options for the transportation of Kerosene, Diesel fuel, Unsymmetric di- methyl hydrazine and Nitrogen Tetroxide, so that the Minister for the Environment and Heritage can provide additional advice on the preferred route in relation to his responsibilities under the Environment Protection (Impact of Proposals) Act 1974.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 73

Recommendation 16: APSC must produce a report modelling the impacts of worst case releases of Unsymmetric di-methyl hydrazine and Nitrogen Tetroxide in inhabited and ecologically sensitive areas of the island and provide it to the Minister for Environment and Heritage no later than the provision of the routing analysis.

6.2.4 Use of Helicopters on South Point

APSC proposes that during the construction period, larger goods and prefabricated components would be transported to South Point via large seagoing barges and heavy lift helicopters on a monthly basis for the first 2-3 months, then once every 2 months for the duration of the construction period (Supplement pII-27). Each unloading period would take 5-7 days depending on weather conditions.

Chapter 6 of the Supplement documents a range of past research on noise and aircraft impacts upon birds. In relation to helicopter flights it states: “Considerable uncertainty surrounds the prediction of helicopter flights, lights and noise impact on birds. If prediction by analogy is used as a guide, then depending on species, location and situation, there are impacts in some cases and no discernible impact in others” (P23). Table 6.3 refers for the need for monitoring and a management strategy, although there is no reference to this in the draft environmental management plans. The Supplement also refers to a 1997 review of impacts of aircraft on seabirds by GBRMPA that concluded that the response of birds to aircraft will depend on the species, location, history of experience, aircraft type and aircraft activity. Because of the uncertainty surrounding aircraft impacts on different species GBMPA recommended that helicopters should not be permitted to land near surface or tree nesting seabirds.

North Keeling Island, which is another Australian external territory with a large Red Footed Booby colony, has a Notice To Airmen that no aircraft approach within one nautical mile of the island and must maintain at least 2,000ft in altitude above the island. This is in response to an instance where a navy aircraft was observed by Parks Australia staff to pass over the island at 500ft, causing thousands to rise in the air, and possibly some deaths.

The proposal is questionable both in terms of the potential negative impact upon the seabird colonies, and possibly in terms of aircraft safety.

Recommendation 17: APSC should not use helicopters as a means of transporting construction material to South Point. If APSC believes that it has no alternative to the use of helicopters, then a trial should be carefully designed and approved by Environment Australia (and other relevant authorities). After approval, the trial should be carried out with appropriate monitoring to determine the reaction of seabird colonies to helicopter

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 74 disturbance. After considering the outcomes of the trial, the Minister for the Environment may provide further recommendations.

6.3 IMPACT OF LIGHTING AND HIGH STRUCTURES

The South Point facilities would possess low level security lighting at night. In the 24 hours leading up to a launch, and during a night launch (an infrequent event), high intensity lighting will be used The Draft EIS (p9-12) and the March 2000 additional information (p32) note that the Red Footed Booby may be attracted to lights when returning from feeding at night, while the Greater Frigatebird is known to be active at night. The Christmas Island Hawk Owl is known to be attracted to street lights in the Township area and the Birds Australia submission states that lighting would be very likely to attract the Hawk Owl. Lighting might also attract the Pipistrelle bat.

Lighting can be a problem for birds when combined with tall structures. The Birds Australia submission gives the example of migrating shorebirds which are regularly attracted to lighthouses and then killed in collisions with unlit structures such as cables or walls. Kennedy Space Centre also experiences bird strikes as a result of tall structures. There will be a number of high structures around each launch pad: a 37m service tower, two 70 m lightning towers, and three 70 m lighting towers. The additional information states that lighting design will include the use of downlights rather than upward pointing lights and that APSC will provide shielded lighting to minimise the glare and visibility from outside the facility area. Efforts will be made to design or mark high, but less visible, structures such as powerlines so as to reduce the likelihood of bird collisions.

Another approach would be to minimise the number of tall structures by, for example, combining the lighting with lightning towers (at Kennedy Space Centre the lightning rod is actually on top of the service tower, however the design of Soyuz launch pads would most likely not allow this).

Some submissions on the Draft EIS also raised concerns about the possible impact of lighting upon red crabs and sea turtles. The red land crab is known to be attracted to existing light sources on the island (potentially interrupting foraging). APSC states that the use of shielding to minimise light throw will reduce this effect. The intention to make security fencing crab proof will also help.

Greta and Dolly Beaches are known nesting sites for Green and Hawksbill turtles (both vulnerable). The nearest beach is about five kilometres from the launch site. Newly hatched turtles head towards the nearest lights (generally the light sky over the sea) and can be severely impacted by artificial lighting. If the intensity of lighting is such that a glow in the sky at South Point can be

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 75 seen at Greta and Dolly Beaches, then this would be likely to impact on the hatching turtles. The Draft EIS dismisses this due to the elevation and distance between the lights and the nesting areas. The Natural Impacts Matrix (p30) states that lighting will be designed to not be an attractor from the sea, ie by the use of appropriate shielding.

Kennedy Space Centre and Cape Canaveral have both experienced problems with launch pad lighting disorienting hatching marine turtles (Breininger et al 1994), and have worked in consultation with the US Fish and Wildlife Service to address the problem (for example, through the use of low pressure sodium vapour lights). Launch facilities at these bases do however occur much closer to nesting areas than the South Point complex would.

Recommendation 18: Lighting facilities must be designed in such a manner that light from the South Point facilities must not be visible in the sky over Greta or Dolly Beaches.

Recommendation 19: Strategies for lighting design and the minimisation of lighting and tall structure impacts and for the monitoring of impacts and subsequent management responses must be approved by Environment Australia as part of the Environmental Management Plan.

6.4 LAUNCH ACTIVITY IMPACTS

The launch cycle has a number of potential impacts upon the environment associated with various stages within the launch cycle:

Ø Vehicle and payload fuelling; Ø Impacts on Christmas Island of a normal launch – noise and launch plume; Ø Impacts of a launch vehicle accident on or near the launch pad – shockwave, fireball, plume, debris; Ø Impacts of launch vehicle in flight – drop zone impacts and sonic boom footprint; Ø Impacts of launch vehicle failure in flight.

6.4.1 Vehicle and payload fuelling

Fuelling processes and fuelling facilities for the payload and launch vehicle are outlined in the project description chapter and described in more detail in the EIS (DEIS p5-35, 8-12).

In relation to the fuelling of the launch vehicle, ICF Consulting remains dissatisfied with the level of discussion of the hazards associated with the production, storage and use of liquid oxygen. Liquid oxygen is dangerously explosive in fires and in contact with materials that can be oxidised.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 76

Refrigerated oxygen can also cause frostbite on contact with skin. ICF recommended that the management of hazardous substances should include consideration of liquid oxygen and discuss safety systems for refrigeration. A quantity distance analysis would also need to be conducted for all propellants to see whether catastrophic failure at storage areas or a launch failure on the pad would create conditions that damage more flammable/toxic vessels, creating even more catastrophic conditions.

Recommendation 20: The management of liquid oxygen must be addressed in the Hazardous Material Contingency Plan.

The Draft EIS estimated that up to 10 tonnes pa of UDMH and 20 tonnes pa of NTO would be required by the facility. This may now be an overestimate given that we have recently been informed by APSC that they now intend to use kick-stages fuelled by kerosene and liquid oxygen.

The DEIS states that fuelling activities would be carried out by Astrotech, described as the leading commercial satellite contractor in the USA. The DEIS states that an experienced team of US engineers from Astrotech would fuel the satellites. If a release of UDMH or NTO occurred, the situation is dealt with by staff in full suits with self contained breathing apparatus. Positive ventilation would remove the fumes via special filters and floor drains would direct liquid to a waste container in a sump. Any waste liquid would be transported to a hazardous materials treatment facility on the Australian mainland. Normal fuelling operations could produce a small amount of fuel diluted in water to a safe level. The transportation of hazardous wastes will need to be considered in the Waste Management Plan.

The Draft EIS (p11-2) states that the risk of spillage of space fuels is highest during satellite pre-processing, but concluded that the risk of a spillage was very small and accidents and consequences would be confined to the fuelling facility and its personnel. The Draft EIS concluded that there was insignificant risk to the public. The Supplement (pII-28) outlined the results of a safety analysis of Astrotech’s facilities in Florida, which included an analysis of fires. The analysis concluded that for realistic toxic gas concentrations and durations, there would be minimal risk to humans located at the facility boundary 60 metres away.

It should be noted that the 1990 safety evaluation of Astrotech’s Florida facility by the US Environment Protection Agency and Office of Commercial Space Transportation states that the payload customer is responsible for and performs all hands-on work related the assembly, processing and fuelling of the spacecraft, while all hazardous operations performed at Astrotech are directly supervised by the Astrotech safety officer. The report notes that Astrotech safety requirements include such things as training and certification of propellant handling teams.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 77

In the request for additional information, APSC was asked whether the payload fuel tanks would be required to satisfy at least the same containment standards as the ISO cylinders that the space fuels were transported and stored in. APSC’s response in the March 2000 additional information (p38) was that the fuel tanks would be designed differently to satisfy their handling, filling and usage requirements. The tanks a designed to be light, but are inherently rugged, as they are designed to withstand high pressures once in space, and so on the ground have a high strength reserve. The payload and launch vehicle would be accompanied by an emergency response unit on its rail journey to the launch pad.

As noted in the proposal description, fuelling of the launch vehicle in the launch pad is an automatic process, and is carried out after the launch pad area has been cleared of personnel. Payload and launch vehicle telemetry systems will be in operation, providing information on the status of fuel tanks. If at any stage a launch is aborted while the vehicle is still on the launch pad, the launch vehicle fuel tanks are able to be drained, and the launch vehicle returned to the assembly building.

Recommendation 21: All UDMH and NTO storage and transport containers (including payload fuel tanks) must be approved as safe for use under the relevant Western Australian legislation. The payload processing facility, its safety features and certification of fuel handling teams must also be approved under relevant Western Australian legislation. Where such regulation does not currently exist, it must be developed to match or exceed world’s best practice prior to any operation involving these fuels proceeding.

6.4.2 Impacts on Christmas Island of a Normal Launch – Launch Plume

The proposed launch facility would conduct launches up to twelve times a year. As the launch vehicle ascends, it remains over Christmas Island for the first 25 seconds of flight. After that time it passes over the shoreline and the fringing reef and out to sea.

The launch plume from combustion of kerosene and liquid oxygen in the rocket engines produces water, carbon dioxide, carbon monoxide, smaller amounts of hydrogen, nitrogen and oxygen, as well as some ions (at rocket exhaust and in the upper atmosphere). In addition approximately 500 tonnes of deluge water is combined with the exhaust either as steam or cloud droplets. This combination passes through the ground cloud and is added to for the first approximately 460 metres of flight (15 seconds).

APSC based their conclusions regarding emissions from a combination of Russian data, measurements from other launches and theoretical adjustments. The 33 tonne ground cloud produced in the first 15 seconds begins to mix with surrounding ambient air (thereby diffusing), and also rises due to

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 78 buoyancy. The Supplement (P60) concludes that humans and animals will be safe from the effects of the launch exhaust plume at a distance of 30 metres downwind, but notes that the impact of heat and noise will be greater.

The March 2000 additional information provides information on the ground cloud temperature (p43). APSC’s estimated impacts are shown in the following table:

Distance Downwind Dilution Cloud Effect on Flora and From Pad Ratio Temperature Fauna (estimated) 15 m 28 240°C Severe 45 m 36 195°C Severe 85 m 100 91°C Severe 150 m 420 45°C Mild or nil 180 m 600 40°C Nil

This would indicate that flora and fauna beyond the fenced security area would be at risk of harm from the heat impacts of the ground cloud, as both launch pads are closer than 180 m to the security fence in some directions. The western launch pad is about 50 m from the nearest perimeter of the Launch Complex and areas beyond the mining lease to the south and south- east that may be of habitat value (Figure 5.3 of the Draft EIS identifies this area as rainforest). The eastern launch pad is about 75 m from the nearest perimeter fence to the north. The nearest area of National Park is 770 m from the nearest launch pad, with the required wind direction only occurring 12% of the time. The prevailing SE wind (67%) would blow the cloud over the zone between the Technical and Launch Complexes (presumably rehabilitated) and beyond to other mined areas of mining lease 100. The flame trenches would be designed to direct the gas and steam to the south- east, although upward at forty-five degrees (Supplement pII-13). Given the prevailing winds, the ground cloud has more of a potential impact upon the land birds such as the Christmas Island Goshawk, and Imperial Pigeon, and the land crabs and reptiles than for harming sea birds, although the March 2000 additional information (P4) notes that during the 1999 surveys a cluster of about 20 red-footed Booby nests were noted approximately 300m from the site of the proposed launch facility.

Apart from redesigning the launch pad area to create a wider buffer zone, it is difficult to envisage how this potential impact could be reduced. In contrast to the short distance from the launch pads to natural habitat and the 770m to the nearest area of national park, it should be noted that the Technical Complex (which would be evacuated during launch, thus only leaving property in danger) is separated from the Launch Complex by a distance of 1.4km.

Recommendation 22: APSC must monitor the impact of the ground cloud in the first five launches. Monitoring reports must include measurements on the

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 79 cloud composition, temperature, dispersal and area of harmful impact. Surveys for impacts on fauna and flora must be conducted at a number of sites spaced downwind of the launch pad concerned (100m, 300m, 600m, 1km, 2km). Reporting arrangements and possible management responses will be specified in the Environmental Management Plan.

Recommendation 23: APSC must investigate and report on alternative configurations which would allow for a wider buffer zone between the launch pads and areas of natural habitat. Comment should be sought from the Minister for Environment and Heritage on the alternatives prior to the final siting decision being made.

The EIS stresses that some alternative rocket fuels create emissions that potentially have a greater effect than that of kerosene and liquid oxygen. For example, solid fuel rockets (such as the boosters used on the Space Shuttle) produce hydrochloric acid and aluminium oxides, while launch vehicles that use NTO and UDMH produce ammonia and oxides of nitrogen. This is worth noting in terms of the possibility that some public concern relating to the impacts of a launch facility may be based on awareness of impacts of another launch vehicle entirely.

6.4.3 Impacts on Christmas Island of a Normal Launch – Launch Noise

Launch Noise has the potential to be the launch impact of most concern in relation to successful launches. The Draft EIS provided a noise contour map of the noise levels estimated from a rocket at 50 m in height (See Fig 9). This was based on NASA and Russian data scaled to the largest rocket proposed to be launched by APSC (the Angara-5). The Draft EIS did not provide sufficient technical information with which to verify APSC’s estimates. The information was provided in the Supplement (p31), allowing ICF Consulting to verify that the acoustical analysis calculations were technically accurate and the approach was verifiable (ICF April 2000).

As the largest rocket was used for the modelling, many launches would be expected to produce lower sound levels. APSC states that the ARS-3K launch vehicle would produce noise levels 5 dB less than the Angara.

Figure 9. Noise Contour Map (rocket at 50m – worst case scenario)

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 80

from APSC Draft EIS

In relation to direct human impacts, the Draft EIS states that the Launch Complex is located a minimum of 14 km away from areas of human habitation. The March 2000 additional information acknowledges that two people reside at Grant’s Well, approximately 8 kilometres from the launch facility. The research station is located a little closer and is intermittently used as accommodation for visiting researchers. Noise levels at Grants Well are estimated to be 86 dBA (APSC compares this to a food blender), while the township area would experience 78 dBA on higher terraces (compared to a car travelling at 100 km/h at 8 metres) and 75 dBA lower down near the shoreline (living room music).

The EIS estimates that rocket noise would last for up to 45 seconds (with a gradual build-up). Launches occur up to twelve times a year. Given the infrequent occurrence and expected advance notice of the event, this would not appear to be an unacceptable impact upon the human population.

Fauna of course occurs much closer to the site. Of particular concern is the seabird nesting colonies at South Point, and possibly territorial land birds that occur on South Point – the Christmas Island Goshawk (endangered) and Christmas Island Hawk Owl (vulnerable). The area of South Point within a 1.5 km radius of the launch site(110 dBA or greater) includes sites where an adult pair and juvenile Goshawk were sighted and important seabird nesting areas along the eastern coastal terrace. Part of the western coastal terrace

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 81 seabird nesting area also occurs within this zone, while a larger portion falls within the zone subject to between 100 and 110 dBA.

The Draft EIS recognised the possibility that launch noise may have some impact on the fauna on South Point and committed to long term monitoring of the effects. The draft referred to background literature on the subject which presented varied and conflicting views and findings on the matter of noise impacts on wildlife. The Draft did not make any definite commitment as to what would be done if a significant negative impact was detected, nor did it provide sufficient detail of the proposed monitoring. In response to comments on the Draft EIS, further information on potential impacts and long term monitoring was provided in the Supplement, while information on the short term monitoring associated with each launch was provided in the March 2000 additional information.

It should be noted that the rocket launch event has some specific characteristic that can influence the noise impact: the noise will last for about 45 seconds, and will vary in level during that time; associated with the noise for some species will be the visual stimuli of the launch vehicle rising from the launch pad; and, the noise will only occur up to twelve times a year.

The noise levels given above are expressed in units (dBA, or A-weighted sound level in decibels) that are filtered to the approximate response of a human ear. It is unlikely that the various species of fauna exposed to the launch noise have hearing similar to humans. This issue was taken into account in analysing the behavioural and auditory responses of Harbor Seals to Titan IV launches from Vandenberg Air Force Base in California (Thorson et al 1998), and it was found that as amphibious mammals, harbor seals have had to compromise their in-air hearing in relation to their underwater hearing. At the frequency at which the seals can detect the faintest sound, their sensitivity is about 30 dB less sensitive than humans (at their best sensitivity). Their decreased sensitivity most likely reduces the amplitude of sound that they perceive from a rocket launch. In contrast, domestic cats can hear much better than humans. For the purposes of studying the response of the seals to rocket launches, the researchers developed a “seal” weighted sound filter to accurately represent the sound level perceived by seals and so better gauge likely impacts on them.

Recommendation 24: APSC must carry out and report on measurements of launch noise for the first launch of each model of rocket so that the predicted noise levels may be verified. Distances at which noise levels are measured should be determined in consultation with Environment Australia and appropriate noise regulation authorities under applicable Western Australian law.

Recommendation 25: APSC must develop weighted sound filters for a range of target species to be agreed with Environment Australia.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 82

6.4.3.1 Seabirds

The Draft EIS provided information on an experimental blast (measuring 138 dB) detonated in the vicinity of breeding Red Footed Boobies (P9-6). APSC concluded that there was no discernible behavioural reaction by Red Footed Boobies, however Parks Australia North staff present observed that behaviour of chicks in nests changed from generally somnolent to highly vigilant, which may have been associated with elevated heart rates and increased metabolic rates. The supplement included a statement that “APSC Pty Ltd recognises that this did not simulate a rocket launch, nor is a single experiment significant, but that it did give some indication of a possible bird response to noise”.

General effects of human disturbance according to the “Guidelines for Managing Visitation to Seabird Breeding Islands” (GBRMPA 1997) are listed below in order of their occurrence during the normal breeding cycle of nest establishment, egg laying and incubation, hatching, brooding and feeding of chicks, fledging and survival to breeding age:

· changes to ideal breeding habitat characteristics; · deterrence from settling to breed; · desertion of colony site by all or part of a breeding population; · increased destruction or predation of eggs; · increased mortality of young chicks from predation, exposure, trampling or disorientation; · reduced number of young birds fledging; and · reduced fledging weight, contributing to lower juvenile survival.

Launch activity sound could effect the seabird colonies on South Point in the following ways:

Ø Harassment as a result of flushing of the colony in response to launch noise (potentially causing increased heart and metabolic rates and decreased food search capacity,); Ø Nests left temporarily unattended – leaving chicks or eggs exposed to weather and/or predators; Ø Individual nests permanently abandoned – loss of chicks or eggs; Ø Injury or death of juveniles or adults due to startle responses (may be particularly an issue with tree nesting birds such as Abbott’s Booby and Red Footed Booby which are not adept at manoeuvring amongst trees. Individual Greater Frigatebirds or Abbott’s Boobies that fall to the ground are not able to become airborne again and generally die unless given human assistance); Ø Abandonment of nesting colony by one or more species.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 83

These responses could lead to a decline in reproductive output, reduced fledging weight, contributing to lower juvenile survival, a reduction in the number or density of birds, a reduction in the diversity of species using the South Point area, and the possibility of birds forced to nest in other less optimal nesting habitats. The infrequent nature of the event would in some ways reduce the potential magnitude of the impact, but may also prevent the seabirds from becoming habituated to the disturbance (as do some species of birds that nest near military and civilian airbases).

As noted in the supplement, the same species of birds may react differently in different situations. Reference is made to varied responses of seabird to human disturbance at different colonies. In some cases the birds appeared very sensitive, with frigatebirds and Red Footed Boobies flying at an approach within 50 m at some sites, while at another site it was reported that the Red Footed Booby could be touched while on the nest.

Seabirds are generally more sensitive to disturbance in the early parts of the breeding cycle. If complete abandonment of nests occurs, it generally happens in the early part of the breeding cycle, thus indicating that this is generally the most sensitive time for many species. Regular disturbance at this time can prevent a significant portion of a colony from establishing (GBRMPA 1997). The success of seabird nesting colonies will also fluctuate for natural reasons, thereby making it difficult to gauge the impact of human disturbance, as well as meaning that human instigated losses can combine with natural losses to produce an even greater effect.

In some situations identification of such periods of particular sensitivity may enable the avoidance of impacts by avoiding launches during that time. It is unlikely that this will be possible with South Point. Table 6.2 in the Supplement shows that the breeding seasons of species relevant to the proposal range occur in varying periods from February to June (Abbott’s Booby season extends to July). The Golden Bosun (White-tailed Tropicbird) may breed in all months. In addition, the period of incubation and parental care is particularly lengthy for some seabirds. The Red Footed Booby requires 45 days incubation, over 100 days of care to reach fledgling stage and 190 days of post fledgling care. The Greater Frigatebird requires 55 days incubation, up to 161 days to reach fledgling stage, and 15-18 months of post fledgling care.

After reviewing available data, APSC concludes that uncertainty remains as to how seabirds, such as Red-footed Boobies and Greater Frigatebirds, would react to periodic and very loud noise events (Supplement P18). APSC suggests that in attempting to predict the impacts of rocket launch events on the seabirds at South Point, the following points need to be taken into consideration:

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 84

Ø “The reaction of seabirds to disturbance varies between species and between sites for the same species; Ø A greater severity of impact has been observed when there is a consistent disturbance at the start of the breeding season; Ø Chick mortality/stress as a result of adult birds leaving the nest is likely to be highest during the hottest times of the day; Ø The scope for habituation and instances where no impact has been detectable; and, Ø There are no data to give any indication as to how seabird colonies, such as those on Christmas Island, will react to periodic rocket blast events.” (Supplement P19).

As noted previously, habituation is unlikely to be an issue with the proposal. In relation to the last point, there have been some studies of the impacts of rocket launch activity upon birds. Some public comments on the Draft EIS requested that APSC provide information on the environmental impacts of existing launch facilities, however no information was provided in response to these requests.

Kennedy Space Centre and the adjoining Cape Canaveral launch facilities are perhaps the most well known launch facilities in the world. Kennedy Space Centre covers 570 square kilometres and contains the Merrit Island Wildlife Refuge (566 square kilometres). The landscape provides habitat for more than 330 species of birds, 31 mammals, 117 fishes, 65 amphibians and reptiles and 1000 plant species. The refuge supports 21 species of wildlife listed as endangered or Threatened on either Federal or state lists, which is more than any other single wildlife refuge in the United States. At 135 square kilometres, the entire area of Christmas Island is less than one quarter of Kennedy Space Centre. Unlike seabirds, many other species are not colonial nesters, and can therefore be distributed more evenly across their preferred habitat. The endangered Florida Scrub Jay is a territorial bird, and studies of the impact areas of Titan launch pads have found that reproductive success and mortality are comparable to areas on the Centre that are not subject to launch effect (Breininger et al, 1994). A closer comparison could be made with the colony of endangered Wood Storks (colonial waterbirds; 5 to 25 pairs will often nest in a single tree) that began nesting within two kilometres of one of the space shuttle launch pads in 1988. Video observation revealed a startle response of wading birds during launches when the birds briefly took flight from their nests and returned within minutes (providing the opportunity for some loss or damage to eggs or nestlings, or predation). Pre and post launch studies suggested that no mortality of nestlings occurred from launches and the number of breeding pairs increased between 1988 and 1990. The colony was abandoned prior to the first launch in 1991 – most likely as a result of

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 85 rising water levels and degradation of the mangrove nesting trees caused by freezes (unusually cold weather).

Vandenberg Air Force Base is 398 square kilometres in area and extends along 56 kilometres of Californian coastline. It is used for ballistic missile testing, and the launch of unmanned government and commercial satellites into orbit. A colony of endangered Californian Least Terns nest within about 650 metres of one of the launch pads at Vandenberg. Because of concerns regarding possible launch impacts upon the colony, each launch that occurs during the nesting season is monitored for impacts upon the Least Terns. The US Fish and Wildlife Service has issued an Incidental Take Statement in relation to the launch activity, requiring that there be a take of only:

“1. A maximum of eight (8) adult California least terns and eight (8) adult western snowy plovers in the form of direct mortality or injury per calender year, as a result of predation or launch vehicle malfunction.

2. A maximum of ten (10) California least tern nests and ten (10) western snowy plover nests as a result of indirect launch effects per calender year. Examples of indirect effects include, but are not limited to, abandonment, predation, or exposure to weather. The annual loss of ten California least tern nests is not expected to exceed ten (20) chicks or eggs. The annual loss of ten western snowy plover nests is not expected to exceed thirty (30) chicks or eggs.

3. All nesting individuals in the project area through harassment as a result of flushing during seven (7) flushes of nesting western snowy plovers and five (5) flushes of nesting California least terns per calender year without signs of nest abandonment, death, or injury. No numerical estimate is possible because of the uncertainty regarding the number of nesting birds that may be present.

4. All non-breeding western snowy plovers, California least terns, and brown pelicans and all American peregrine falcons and southern sea otters in the project area through harassment. No numerical estimate is possible because of the uncertainty regarding the number of individuals of each species that may be present.

5. No (0) American peregrine falcons, brown pelicans, or southern sea otters are expected to die or be injured as a result of implementing the proposed project.”

A study of a launch on July 1997 found that Least Tern losses directly attributable to the launch included 4-5 nests containing 7-9 eggs and one nest that contained 2 chicks. At the time of the launch the colony had approximately 20 adult Least Terns (Schultz 1997). The study also concluded that the severe disturbance of the launch combined with predation attempts by owls were the factors likely to have affected an early seasonal departure from the site by the remaining adult least terns.

Based on the information provided in the EIS and the additional information above, it would appear to be a real possibility for launch noise at South Point to have a significant negative impact upon the nearby seabird colonies. In

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 86 addition, the breeding behaviour of some of the seabird species does not provide them with the ability to rapidly recoup losses beyond natural losses to which they have adapted. However, it cannot be certain that such negative impacts will occur, or if they will be of a magnitude to have an ongoing resulting decline in seabird populations nesting on South Point.

APSC proposes to monitor the seabird populations on South Point to determine whether there is a negative impact as a result of launch noise or other activities associated with the APSC facilities. APSC proposes to establish baseline information of bird population numbers based on data from the two existing surveys as well as three to four surveys per year until 2004. Future survey programs would also include surveys of a number of control areas elsewhere on the island, so as to provide a comparison to areas not directly exposed to APSC facilities on South Point. After the baseline had been established and interpreted in consultation with Environment Australia, APSC proposes that the surveys continue in order to monitor any impacts.

The March 2000 additional information provided details of launch specific monitoring which would measure short term responses and impacts by gathering data before, during and after launches. This would involve pre and post launch surveys of South Point baseline survey sites, monitoring of specific nest trees (including at the nearest Abbott’s Booby nest site), and direct and indirect video observations during the launch.

There are a range of uncertain aspects of the monitoring program outlined in the EIS that require further attention. These include:

Ø During the proposed baseline monitoring period, APSC proposes to conduct 11 launches. Construction activity would also occur, however this could be comparable to mining activity that already occurs on South Point.

Ø Some survey methods, such as counts from cliff-top vantage points (ie, looking down upon trees the birds are nesting in) may not be reliable means of conducting consistent surveys;

Ø Other methods such as counting piles of droppings under trees during the breeding season, to survey breeding seabirds, are based on questionable assumptions about the behaviour of the seabirds; and,

Ø The absence of any reliable approach to the monitoring of breeding success rates and distinguish launch activity induced changes from other changes.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 87

If the proposal is to proceed, a full monitoring program would need to be developed and approved as part of the Environmental Management Plan. Because of the importance of the Seabird colonies and the possibility of negative impacts, it would be appropriate for the monitoring program to be developed in consultation with scientists that have expertise in relation to both the seabirds concerned and expertise in the development of monitoring techniques.

Recommendation 26: A full seabird monitoring program be developed and tested as part of the Environment Management Plan to be approved by the Minister for Environment and Heritage. The seabird monitoring program must include the collection of baseline data for at least three years prior to the first launch. The monitoring program must be developed in consultation with Environment Australia and scientists recognised as having expertise in relation to both the seabirds concerned and expertise in the development of monitoring techniques.

In order for the monitoring program to be of value, it must be associated with a feedback mechanism whereby negative impacts detected by the monitoring can be addressed through changes to the management regime. APSC proposes the following options for alterations to the launch regime if a significant impact can be linked to launch events (Supplement p21):

Ø Minimise night launches (reducing light impacts and disturbance to nocturnal and roosting birds); Ø Avoid launches during the middle part of the day if birds are disturbed and seen to fly from their nests in response to a launch event (reducing impacts of high temperatures on unattended nests); Ø Conduct launches in a manner that minimises impacts during peak periods of courtship and egg laying (thought to be the period when birds are most susceptible to disturbance).

These responses would not be able to address all potential launch impacts. For example, while not launching in the middle of the day may avoid temperature impacts, it would not necessarily avoid predator impacts upon temporarily abandoned nests. As noted previously, some of the seabirds care for their young for over a year, making it difficult to avoid disturbance if any are found to be particularly sensitive. There is a particular concern with night launches given that it would be difficult or impossible to determine the short term responses of fauna to the launch. Environment Australia is of the view that it is possible that in some circumstances, the only means of addressing significant negative impacts upon seabirds or other fauna would be to cease launches at South Point.

APSC has proposed a regime of “adaptive environmental impact assessment” where when set indicators are reached, APSC would respond at a certain level (Supplement P24, Table 6.4). Such an approach would be necessary, however,

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 88 if the level of response to the indicators proposed by APSC is insufficient. APSC has only recognised that there may be a need to respond with a delay in the launch program, and this would only be in the case of extreme events such as “abandonment of the site” (only 10% of original baseline conditions remain at 30% or more of study sites, while control sites remain stable), or a 20-50% decline in the breeding success and numbers occupying nests sites of the nearest Abbott’s Booby nesting sites. Lesser impacts such as monitoring showing a continual reduction in population size at 60% or more of study sites would at the most result in a modification of the launch protocol. A decline in the reproductive output, or numbers of one or more species at 15- 30% of study sites would only result in increased monitoring, investigations, and an examination of the possibility of modifying the launch protocol.

Recommendation 27: The adaptive response management regime must be revised as part of the Environment Management Plan to be approved by the Minister for Environment and Heritage. The revised regime must be developed in consultation with Environment Australia and scientists recognised as having expertise in relation to the seabirds concerned and expertise in monitoring techniques. A significant impact upon the seabird colony such as a decline in reproductive output of seabirds at 15-30% or more of sites monitored on South Point (without a corresponding decline at control sites) must result in a suspension of the launch regime while the possible causes are investigated by a panel of avian experts appointed by the Minister for Environment and Heritage, until such a time that the panel has determined whether further launches are possible without bringing about further decline or preventing recovery of numbers.

Recommendation 28: For any night launches conducted, APSC must carry out the monitoring program to ensure effective monitoring of short term impacts.

6.4.3.2 Other Fauna

In addition to the presence of the endangered Christmas Island Goshawk and vulnerable Christmas Island Hawk Owl, the assessment report also noted large numbers of endemic Imperial Pigeons and Christmas Island Glossy Swiftlets in the vicinity of the project area. Further surveys will be required before the presence of vulnerable reptiles such as the Christmas Island Tree Gecko and Blind Snake can be determined, as well as other reptiles such as the declining Blue Tailed Skink. The Christmas Island Fruit Bat was noted as being present on the western Terrace (it was not searched for on the eastern side), and the presence of the Christmas Island Pipistrelle bat will need to be ascertained through further survey work. The land crab fauna is also present at South Point. Each of these species will be exposed to a range of possible impacts dependent upon their behaviour and use of the surrounding habitat. These may include startle responses, territory abandonment, breeding failure,

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 89 and hearing impairment (which may be a particular issue with the Pipistrelle and Glossy Swiftlet, which both use echolocation).

APSC proposes to monitor land birds with an area search technique in each vegetation type on a range of sites on South Point and in control sites elsewhere on the island (March 2000 additional information p6). This would involve the assembly of baseline data, before and after surveys for launches and continuing long term monitoring of baseline survey areas.

More intensive monitoring would be conducted for the Goshawk and Hawk- Owl. APSC proposes that as many pairs of the Goshawk be located as possible, which would be checked upon each field trip – the disappearance of several pairs being an indication that a decline was taking place. APSC proposes that the Hawk-Owl be monitored by listening for calling Hawk- Owls at several points in the South Point area to gain some measure of their abundance. This proposal differs with the Natural Impact Matrix (P28) which requires no commitment of APSC as no Hawk-Owl nests were found in the surveys, which is not surprising given that they were not systematically searched for. Given that both these species are listed under the Endangered Species Protection Act 1992, additional monitoring such as location of nests and non-intrusive video monitoring of nests during launches would be appropriate.

Apart from commitments in relation to lighting impacts, there is little indication of recognition of the importance the occurrence of the Goshawk and Hawk-Owl on South Point. Given that the total population of the Christmas Island Goshawk is estimated to be 100 to 200 mature individuals, the removal of the territory of just one breeding pair (such as the pair noted by surveys near the proposed launch facility area) should be considered as further endangering the species.

Other species such as the Christmas Island Gecko, Christmas Island Blind Snake, and Christmas Island Pipistrelle have been dismissed as requiring no commitment by APSC based on surveys that Environment Australia considers are inadequate (see Natural Impacts Chapter). The Natural Impact Matrix (p30) considers that no commitment is required in relation to the Christmas Island Fruit Bat on the basis that the bats were only found on the western terrace, which would not be exposed to launch accidents. In response to a comment that there had been no surveys for fruit bats on the eastern terrace, the March 2000 additional information stated that “on the completion of survey of eastern terrace, no populations were found”. It is uncertain what survey this is referring to given that the second survey reported on in Attachment V of the Supplement did not systematically survey for mammals and, as with the first survey, did not occur on the eastern coastal terrace.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 90

Recommendation 29: Monitoring proposed in the EIS for land fauna must be significantly revised in consultation with Environment Australia in the preparation of the Environment Management Plan.

Recommendation 30: An adaptive management regime must be developed for all endangered and vulnerable species present on South Point, as well as for species for which significant populations have been found in the vicinity of the launch area. The management regime must take into account recovery plans prepared for endangered and vulnerable species. The management regime must be included in the Environment Management Plan to be approved by the Minister for Environment and Heritage.

6.4.4 Impacts of a launch vehicle accident on or near the launch pad

The Draft EIS states that the companies providing the launch vehicles for APSC have an overall success rate of approximately 97%. The launch vehicle will only be on or over the island for the first 25 seconds of flight. APSC states that space insurance statistics suggest that there is a one in five hundred chance of an accident of any sort occurring during that 25 seconds (Draft EIS p8-14). The Supplement (p61-62) provides further information based on historical failure statistics of all available launch vehicles and flights for the last 25 years (excluding solid rocket booster failures). Based on this information, APSC concludes that the probability of a failure over the APSC site is one in 909 flights, while the probability of a failure over the terraces is one in 6670 flights. Specific data is not available for the ARS-3K and Angara launch vehicles because they are both new vehicles without a launch history (although the ARS-3K is based on the reliable Soyuz launch vehicles which are used for Russian manned space flights).

No launch vehicle flight paths are intended to be directed towards the township on Christmas Island. Given the distance from South Point to the Township, and the launch safety procedures undertaken, APSC concludes that there would be no possibility of damage to the housing, structures or people in the Dogs Head area (Draft EIS p11-4).

During the first 13 seconds of flight, the rocket rises over the launch pad, so that if there is a failure, debris will fall back over the launch pad and

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 91 surrounding area. Between 13 and 25 seconds, the launch vehicle continues to rise and moves across the terraces, before crossing the reef and moving out to sea. A launch vehicle explosion would cause:

Ø Shock wave – causing death or physical injury to fauna up to 500m radius and considerable damage to exposed structures up to 900m; Ø Fireball – with heat hazardous up to 250m radius; Ø Smoke Plume- with a hazardous ellipse of 200 m by 400 m (which would rise rapidly and move down wind, or, later in the flight, remain at altitude above 1000 m); Ø Debris thrown up to 500m, possibly including some fuel not consumed in the fireball.

Figure 10. The envelope of potential impact calculated by APSC

from APSC Draft EIS

While there is a low chance of such an explosion occurring, given the significance of the surrounding environment and the expected 200 or so launches of the 20 year lifespan of the project, the impacts of such an event must be considered. An explosion over the island would cause damage to an area of vegetation, would kill nearby wildlife (or those in the path of falling debris) and startle those further away, and has the potential to cause a fire. While the first 13 seconds (or 19 seconds in the Supplement) of flight will be over the launch pad area, as noted previously, some of the borders of the launch pad security zone are within 50 m of the western launch pad, and thus even an explosion at this stage will result in shockwave, fireball, launch plume and debris effects beyond the boundary of the complex. This is

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 92 another reason for a revision of the buffer zones surrounding each launch pad (see recommendation 23).

ICF Consulting was satisfied with the shockwave calculations (ICF Consulting April 2000).

The nature of Christmas Island vegetation currently means that a fire would be unlikely to spread. However the likely impacts resulting from the introduced Yellow Crazy Ant such as increased forest floor leaf litter and denser understoreys may alter this in the future. Given the ruggedness of the terrain on the eastern coastal terrace, APSC states that small mobile fire fighting units with individuals on foot would be required to contain a fire. Parks Australia officers with experience on the island find it difficult to imagine firefighters on foot able to safely deal with a fire on the coastal terraces.

There is also a small possibility of the payload not being totally destroyed by the accident and falling to earth with fuel tanks still containing space fuels. While unlikely, this has happened once with a Delta III rocket. Space fuel that was released on the island terraces could have impacts upon the fauna in the vicinity (see S6.2.3).

APSC has committed to recovering all debris from a launch accident that falls on the island or the surrounding reef, and have committed to the rehabilitation of all areas affected by a launch anomaly with native flora species as soon as practical following devastation of an area by fire (Natural Impact Matrix p19). APSC has also committed to conducting a site inspection prior to launching to remove any robber crabs or other significant fauna from the vicinity of the rocket blast (Natural Impact Matrix p24). As mentioned above, given that some of the 500 m radius will be areas of natural habitat, it may be difficult to carry out an effective search.

Recommendation 31: The Environment Management Plan must include a plan for how APSC will respond to the environmental impacts of a launch accident over the island. The plan must include a survey of impacts upon flora and fauna, and immediate, short term and longer term responses to minimising and remediating impacts.

6.4.5 Impacts of launch vehicle in flight

6.4.5.1 Impacts on the atmosphere of APSC rocket exhaust gases

Exhaust gases from liquid-oxygen-kerosene rockets consist mainly of carbon dioxide and water, plus carbon monoxide at high altitudes, with traces of other components (elemental gases H2, N2, O2 and ions OH- and H+). At high altitudes, the expansion of the exhaust cools the rocket exhaust gas

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 93 immediately, so no further reactions occur. At low altitudes (below about 50 km), the gases remain hot for a few seconds until they mix with air. APSC states that the global removal rate of removal of about 2 billion tonnes per annum, means that exhaust carbon monoxide will not accumulate in the atmosphere. Any remaining carbon monoxide will be removed by natural processes involving the hydroxyl radical, with a lifetime of about 3 months.

APSC states that the project is expected to provide a net reduction in exhaust gas generation on a global basis, by attracting business from competing rockets (existing and planned) which use solid or toxic propellants and have greater impacts on the environment. The rocket burns about 70 tonnes of kerosene while in the atmosphere which APSC states is equivalent to one fuel load for one flight of a mid-size jetliner, and APSC says the emissions and environmental effects are similar (in reviewing the EIS, ICF Consulting noted that the basis for this analysis had not been provided). In addition, most commercial rockets are launched at higher latitudes than APSC, requiring more fuel to change plane at the equator.

The deposition into different parts and layers of the atmosphere is governed by the length of the active plume and how long the LV spends traversing the layer, as determined by the trajectory. Once the rocket is above 300 metres, the exhaust gases will form a trail of increasing altitude along the flight path, leaving the atmosphere after 170 km over the Indian Ocean. APSC states the gases will mix with and be diluted by the global atmosphere.

APSC failed to analyse the potential impacts of the launch vehicle exhaust on the ozone layer and instead in the Supplement (p57) refers the reader to the Environmental Assessment for the SeaLaunch Project, (which was prepared for the U.S. Department of Transportation in 1999) in regard to the impacts of liquid-oxygen-kerosene rockets on the free troposphere, stratosphere and mesosphere

According to this report the impact of rocket exhaust emissions on the atmospheric boundary layer (up to 2 km) would only last for a few hours. Emissions would be dispersed by winds and local turbulence caused by solar heating.

Models predict a substantial, temporary reduction in ozone levels in the exhaust trail of liquid propellant rockets. However, recovery to near background levels occurs within a few hours. The atmosphere being capable of replacing the destroyed ozone by migration and regeneration.

The effects of rocket launches on total global ozone are less well understood. It is possible that solid particles in the exhaust might provide surface area for heterogenous chemical reactions that might lead to the destruction of stratospheric ozone, however this area has not been adequately studied.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 94

Rocket launches contribute to less than 0.034% of annual global ozone destruction. Rocket exhaust components that play a role in ozone destruction in the stratosphere are chlorine compounds, nitrogen compounds and hydrogen compounds. Chlorine is the largest contributor to ozone destruction. APSC rockets will not be releasing chlorine or chlorine compounds.

The high speed movement of the rocket and the re-entry of stages after their use may impact stratospheric ozone. Shock waves caused by the high speed motion of the rocket or re-entry components enhance the formation of NOx which in turn contributes to ozone destruction, however this effect is considered to be relatively small. In addition, the heating of the rocket or re- entry components may cause the production of chemical compounds that may play a role in ozone destruction. Even though the chemistry and significance of these processes is uncertain, the SeaLaunch report concluded that the impact of after burning and re-entry of the Launch Vehicle is likely to be minimal.

6.4.5.2 Sonic Boom Impacts

Launch vehicles produce sonic booms in flight which may be experienced in a “footprint” along the flight path. The sonic boom footprint for launches from South Point would be out to sea, however there has been concern at other launch sites about the impact of sonic booms upon marine mammals (Thorson et al 1998). This has not been properly discussed in the EIS, however the marine notification procedures set out in the supplement (p69- 70) include the checking by aircraft of the sonic boom footprint area for aquatic mammals such as whales. The EIS does not specify whether a launch would be delayed if marine mammals were spotted.

Recommendation 32: APSC must delay launches when aircraft surveys detect that marine mammals are present within the sonic boom footprint. APSC may comply with this condition by demonstrating to the satisfaction of Environment Australia that launch vehicle sonic booms do not cause significant impacts upon the species of marine mammals found in the waters where sonic booms can be expected as a result of the proposal.

6.4.6 Drop Zone Impacts

The first and second spent rocket stages and the fairings fall in predetermined drop zones. The components have a mass in the range of 1 to ten tonnes and a length of up to 28 tonnes. Launch stages are composed of aluminium alloys, titanium, and stainless alloys. Fairings may be composed of metal or of composite materials containing carbon and glass fibres in a resin matrix. Each fairing segment is about 0.8 tonnes with dimensions 19 x 4 x 2 metres. The Draft EIS notes that all of these materials are commonly used in boats.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 95

The first and second launch stages will contain residual kerosene in the fuel tanks when they fall into the ocean. While some of the kerosene would have been vented to the atmosphere during descent, APSC estimates that the maximum volume of kerosene released at any one location would be 0.35 tonnes, while the average total volume per launch would be one tonne. The Supplement (p44) does however refer to an initial model of the Angara which would release 3.3 tonnes of kerosene per launch, with 1.1 tonnes at any one location. APSC contrasts this with referenced estimates of the amount of hydrocarbons released into the marine environment via land based and tanker spills, and natural seepage (Supplement p45).

Kerosene is moderately to highly toxic to aquatic life dependent upon the type of kerosene and aromatic compounds present. Kerosene does however readily evaporate, and APSC refers to studies that have shown that in an open environment, 95% or more would be lost to evaporation within a few hours. The remainder is dispersed by turbulence and consumed via photochemical oxidation and microbial degradation within several days.

While covering the surface, waves and wind would break up the spill into patches, reducing the likelihood of contact with marine mammals and reptiles. APSC refers to studies that show that marine mammals and fish actively avoid oil spills in open water. The potential impact of such spills do not appear to be significant.

The kerosene slicks would not reach land from any of the planned drop zones, however, in the case of an explosion soon after launch, kerosene spills might impact upon coastal Christmas Island communities. Kerosene would adhere to rock faces along the coast, potentially smothering and killing organisms it came into contact with. Wave action would rapidly degrade the kerosene. On exception would be if the spill reached one of the few sandy beaches along the east coastline. The kerosene could be adsorbed by the sand and protected from degradation by sediments. Given the importance of these beaches to nesting sea turtles, such an impact would not be acceptable. The supplement refers to responses according to a spill response plan.

Recommendation 33: APSC’s spill response plan must include effective mechanisms that prevent the contamination of Christmas Island beaches from fuel spills.

The deposition of spent stages upon the ocean floor may be of concern depending upon the benthic life on the ocean floor. The Draft EIS proposed a drop zone in the Timor sea which was of concern for a number of reasons including the occurrence of shallow banks and shoals, some of which support coral reefs. The Supplement proposed a revised drop zone to the west where the shallowest water is 1800m (see Figure 11).

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 96

The supplement also demonstrates that the proposed drop zones do not overlap with the MOU 74 zone which allows for traditional Indonesian fishing within an area of the Australian Fishing Zone. The rocket flight will cross over routes to and from the zone and presumably such fishing activity would take place in other areas within Indonesian waters. APSC states that it will “undertake, where appropriate, to notify such fishermen of drop zones

Figure 11. Drop Zones in Timor sea area on the path to Geostationary Transfer Orbit

from APSC – March 2000 additional information. and impending launches at their home ports”. Some comments on the Draft EIS expressed concern regarding the repercussions of the close proximity of the proposed flight path to Indonesia. APSC notes that Australia and Indonesia have agreements in place which provide for reciprocal notification (Supplement pII-56). This issue is considered to be beyond the scope of the Environment Assessment Process.

Some concern also remains in relation to the composite fairings, which the Supplement explains will break up, gradually become waterlogged and eventually sink within a period of weeks or years. The concept of fairings weighing up to 0.8 tonnes floating for years does not appear to be desirable for safety or environmental reasons.

Recommendation 34: APSC should investigate means of ensuring that fairings sink soon after impact.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 97

Over 600 rocket stages and fairings would be dumped into the ocean over the expected twenty year lifespan of the launch facility. The apparent wastefulness and potential resulting environmental degradation attracted criticism in a number of public comments. APSC has stated that this is currently world practice and in the General Impact Matrix (p4) commits to investigating the recovery of debris components from the ocean in the future should this become international practice.

Although not operated on a commercial basis, the space shuttle solid fuel booster rockets are currently retrieved from the ocean and re-used, while future plans may include a change-over to liquid fuelled boosters that would fly back to the launch site (Brown 1988), the commercial Kistler proposal for Woomera involves a new (untried) vehicle with recyclable stages that return via parachute for collection, and the Russian Krunichev Angara family of launch vehicles (some models proposed to be used by APSC) may include a version with a winged recoverable first stage that would use two jet engines to fly back to an airfield for recovery (Wade, M. 2000).

Obviously this is an area of practice currently undergoing change. Rather than simply committing to investigating keeping up with international practice, it would be appropriate for this proposal and other proposals for Australian based launch facilities to keep up with international best practice.

Recommendation 35: APSC should develop and implement recovery procedures for rocket stages as this becomes international practice for other commercial launch operations.

Another concern raised in public comments related to both the original drop zone A6 (no longer to be used) and the proposed drop zone B3 (see Figure 12). Submissions from Woodside Energy, Australian Petroleum Production and Exploration Association Limited (APEA), and Western Australian Departments of Minerals and Energy and Environment Protection all registered concerns about the proximity of oil and gas installations in the Timor Sea and the North West Shelf to the proposed drop zones. Concerns were also expressed regarding possible impacts upon associated transportation operations and future exploration activities. Since the public comment period, correspondence (either to Environment Australia or the Minister for Environment and Heritage) has also been received from APPEA, Woodside Energy, the Petroleum and Electricity Division of the Commonwealth Department of Industry, Science and Resources, WA Department of Ministry and Cabinet, and Esso Australia regarding this issue.

In the Supplement (p67 – 71) APSC responded to these concerns by providing further information regarding the determination of drop zones, their frequency of use and flexibility. By making adjustments to the launch trajectory and incurring a small payload penalty, as noted above, the A6 drop

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 98 zone was moved beyond environmentally sensitive areas and further from oil and gas installations. The number of potential B3 drop areas was also expanded in order to increase opportunities to select a drop zone depending on both the mission and location of oil and gas facilities at the date of a launch. In the March 2000 additional information, APSC summarised its criteria for selection of drop zones (p30). This included commitments that drop zones would not include present fixed assets, and would be adjusted to avoid any future such assets. APSC states that consultation with oil and shipping companies would occur to enable mobile assets to avoid drop zone areas on launch dates.

Figure 12. Inclined Drop Zone B3 Options

from APSC – March 2000 additional information.

The A and B trajectories do still pass over petroleum industry areas, the B trajectory also passes over sparsely populated areas of Australia and the A trajectory flight corridor will pass over small inhabited islands including Melville and Croker Islands and pass over an area of Papua New Guinea for six seconds at an altitude of 200 km. There is a possibility of launch vehicle failure along its flight path, bringing debris down upon what is known as the instantaneous impact point. APSC provided initial calculations of the Casualty Expectation analysis which indicated that in all instances the hazard is well within the accepted value of 30 x 10-6. ICF Consulting was of the view that further casualty expectation should be calculated for each population area crossed (ICF Consulting Feb 2000). APSC notes that the Space Licence and Safety Organisation (SLASO) will be required under the Space Activities

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 99

Act 1998 to provide independent assessment of acceptable risk and safety parameters and all launch permits are likely to be require a detailed casualty expectation analysis. Environment Australia agrees that final responsibility for safety analysis should rest with SLASO.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 100

The petroleum industry remains concerned in relation to:

Ø The EIS does not provide estimates of the potential economic and environmental consequences of an incident due to a launch vehicle accident; Ø The EIS does not consider the value of petroleum industry assets in the North West Shelf ($12 million according to DISR) or the potential value of the petroleum industry; Ø The potential for revised drop zones to affect any future oil and gas exploration and development in those areas.

In relation to the potential for future conflicts, APSC notes the possibility of performing dogleg manoeuvres to avoid future operations (at a payload penalty cost), and the potential for the development of a collaborative response to the use of the relevant areas over the next few years before potential conflicts may occur (Supplement p70).

This issue is of relevance to the environment assessment process both in terms of:

Ø the potential for a launch accident involving petroleum industry infrastructure to have environmental consequences in terms of oil spills; and, Ø the potential for the curtailing of the range of beneficial uses of the environment (para 3.1.2 of the EPIP Act Administrative Procedures).

The EIS has given consideration to these issues and addressed the bulk of them, however there remains the potential for future conflict of use of some offshore areas.

Recommendation 36: The Minister for Industry Science and Resources, in exercising portfolio responsibilities in relation to petroleum exploration and production and the regulation of space activities, should ensure that the potential for conflict of resource use in offshore areas be taken into account.

6.4.7 Launch Impacts Upon Aircraft

As noted in the project proposal, aircraft exclusion zones will be established around Christmas Island, along the flight corridor as far as the first drop zone and then at the second and third drop zones. The March 2000 additional information notes that final details for each launch would need to be negotiated with Airservices Australia and the Space Licensing Office. The risk assessment aspects would be included in the calculations required for

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 101

SLASO. Diversions around flight corridors and drop zones may require diversions of up to 30 km and delay arrival by up to 2 minutes.

6.5 CREATION OF ORBITAL DEBRIS

The NASA Policy for Limiting Orbital Debris Generation describes orbital (or space) debris as referring to human generated debris, specifically:

Ø Payloads that can no longer perform their mission; Ø Rocket bodies and other hardware (e.g., bolt fragments and covers) left in orbit as a result of normal launch and operational activities; Ø Fragmentation of debris produced by failure or collision (gases and liquids in free state are not considered orbital debris). (NASA 1997).

Radar and optical telescopes regularly track over 10,000 artificial objects in space, amounting to an estimates 4,500 tonnes. Of this number, only five percent are functioning spacecraft (Johnson, N.L. 1998(b)). The number of untrackable objects ranging in size from 1 cm to 10 cm, is estimated at between 100,000 and 150,000 (ESA 1999). For the past two decades the tracked satellite population has grown at an average rate or roughly 175 additional objects a year – more than one quarter of this has been due to satellite break-ups.

Orbital debris can have the following impacts:

Ø Collisions with operational satellites and manned spacecraft. Collisions may disable satellites (and thus the services such as telecommunications or remote sensing they provide), create further space debris in a cascade effect, and endanger human life in colliding with an operational spacecraft (the space shuttle occasionally has to take evasive manoeuvres to dodge large pieces of debris, while the International Space Station will be equipped with about 200 shields in order to defeat impacts of particles up to about 1-2 cm in size). Ø Reduce the amenity of near earth orbits for future missions that may be of benefit to humans and the environment; Ø Contribute to the light pollution of space , adversely affecting ground based astronomical observations (UNISPACE 3 1999); Ø Larger objects may partly survive re-entry through the earth’s atmosphere and pose a danger to humans or the environment either through direct impact, or in some cases fuel remaining on- board.

In the case of APSC launches, the third rocket stage, and, if used, a final kick stage will remain in orbit along with the satellite being launched. Johnson (1998(b)) notes that derelict rocket bodies have been known to detonate as a

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 102 result of overpressurisation or ignition of residual propellant, with nearly every booster type vulnerable (we are unaware at to whether ARS-3K or Angara rockets are vulnerable). An upper stage of a Pegasus rocket broke up in 1996 creating more that 700 objects large enough to be tracked in orbits from 250 to 2,500 km in altitude.

APSC has stated in the EIS that their rocket suppliers have informed them that no operational material such as bolts or explosive stage separators are left in space during launch campaigns. The Draft EIS also notes that it is possible for the third stage of a launch vehicle to be de-orbited , but it is not currently common practice. APSC notes that “there are worldwide efforts within the space industry generally to endeavour to incorporate facilities within the rockets to enable the components which would generate space debris to either be de-orbited or destroyed in ways that do not contribute to space debris. APSC will follow world trends in this area” (Draft EIS p8-11).

The second party with direct responsibility for this issue would be the owner of the payload, the design of which will influence the production of space debris by the payload (instrument covers, paint chips) and the fate of the satellite once it has reached the end of its operational lifespan. Operators can deliberately steer their spacecraft into the atmosphere, have them removed by the space shuttle, move them to less crowded “graveyard orbits” or allow them to spiral down in natural orbital decay (which will occur with those in lower orbits).

This is a recognised issue of concern – the Inter-Agency Space Debris Coordination Committee met in October last year to consider these issues, which were also to be considered by the United Nations Committee on the Peaceful Uses of Outer Space.

Recommendation 37: Launch approval should include an assessment of debris generation potential and debris mitigation options based on international best practice, but at the least including the following:

The potential for orbital debris generation in both nominal operation and malfunction conditions; The potential for orbital debris generation due to on-orbit impact with existing space debris (natural or human generated) or other orbiting space systems; Post mission disposal; and, The potential for items to pose a safety or environmental threat upon re- entry.

Where the assessment finds that debris contributions or the risk to the environment or safety are not acceptable, additional design and mitigation measures must be implemented.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 103

6.6 IMPACTS ON CAVE SYSTEMS AND CLIFFS

As noted in the Natural Environment Chapter, Environment Australia is of the view that the proponent should be required to carry out further investigations into the presence of cave systems and subterranean fauna around the South Point Facilities (see Recommendation 5).

Launch vibrations could result in aesthetic or structural damage to cave systems, and to subterranean fauna habitat. One public submission (Yorkston, sub 23) notes that the last major construction on the island – the Casino – had to modify plans because of limited understanding of the porous substrate environment. The Arup Geotechnics report noted that if cavities were identified in areas proposed for construction of facilities, it would be necessary to assess the risk of sink holes forming either as a result of natural failure of the cave roof, or as a result of structural foundation loads. The report suggests three options to address this risk if the cavities are assessed as a risk to the structural integrity of buildings:

Ø Relocating the building; Ø Infilling the cavity; or, Ø Construction bored piles through the roof rock and sleeved through the open cavern to found or the floor of the cavern.

The Geological survey report also noted the possible presence of sinkholes based on analysis of aerial photographs, and the presence of a deep structural irregularity at one of the boreholes. Due to access difficulties, borehole investigation was not carried out over the old tailings ponds present on the site (a product of phosphate processing on South Point), and noted that the overall depth of tailings is unknown, as was whether the tailings had solidified at depth.

Environment Australia is of the view that it would be undesirable for the construction activities to cause degradation of the karst environments because of their intrinsic, aesthetic and habitat values as well as their record of geological processes. In addition, it would be important to demonstrate prior to construction that the proposed area was sufficiently stable to support the proposed structures and withstand launch and launch accident vibrations and shockwaves. The Draft EIS states that the anticipated repeat loading from rocket launches may have the potential for long term settlement of the immediate locations of the launch pads, but that the structural design of high performance base structures and foundations would also minimise any potential vibration effects. Instability might have repercussions for both human safety and the environment.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 104

Recommendation 38: Approval for construction of the proposal should not occur until it is demonstrated that the underlying geological structure is sufficiently stable to support the proposed facilities and able to remain stable during launch activities or accidents.

Recommendation 39: The report on the survey for possible cave systems and subterranean fauna on South Point focusing on the proposed site of the Technical and Launch Complexes should be used to develop measures to avoid, monitor or remediate impacts upon these environments. These measures must be included in the Environment Management Plan.

A launch or launch accident on or over South Point has the potential to result in rockfalls from nearby cliffs. The Arup Geotechnics survey noted evidence of recent rockfalls below the cliff adjacent to the NW border of the Technical Complex and recommended that construction be limited if possible to not closer that 50 m from the cliff line. This is the area where APSC proposes to locate storage facilities for the hazardous space fuels, causing concern that these storage facilities may be susceptible to rockfalls. In the March 2000 additional information APSC provided an assessment of rockfalls on these stores (p36-38) which concluded that the proposed store locations are sufficiently far from the cliff so as to not be in any danger. APSC estimated that the NTO store is 96 m from the cliff line.

Launch initiated rockfalls from the surrounding cliffs bordering the coastal terrace could impact upon cliff nesting seabirds, or damage coastal terrace vegetation.

Recommendation 40: APSC should monitor and report on launch vibration initiated rockfalls as part of the Environment Management Plan.

Concern was expressed at public meetings of the possible impacts of launch vibration upon the high cliffs behind the Kampong area of the township. This area has already been evaluated in relation to rockfall hazard resulting in barricades being erected below the cliffs. APSC states in the March 2000 additional information (p40) that it is not expected that vibration would influence the stability of the rocks at the Kampong area due to the distances involved.

6.7 IMPACT OF SPILL AND WASTE WATER ON SOUTH POINT:

The South Point facilities would include storage for large quantities of diesel fuel and kerosene as well as quantities of UDMH and NTO. As noted in the project proposal section, all above ground fuel storage areas would be bunded to appropriate standards. The exception to this would be the petrol station where the Draft EIS states that petrol storage would be below ground. The Supplement (pII-41) states that the fuel supply at South Point will be diesel. In any case, given that all other fuel storage facilities are above

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 105 ground, it would be desirable for the fuel storage at the “petrol” station to be above ground and appropriately bunded as well, so as to further reduce the possibility of fuel leaks entering the groundwater system.

ICF Consulting (February 2000) noted that while consideration was given to issues relating to the transport of hazardous substances and the fuelling of vehicles, appropriate attention was not given to the emergency arrangements in relation to spills during storage on site.

Recommendation 41: The Hazardous Materials Contingency Plan should include emergency response actions to be made to spills during storage as well as transportation.

While the chances of a fuel leak entering the groundwater system from the South Point storage facilities would appear remote, the potential impacts would be similar to those described in S6.2.3.3.

The Arup Geotechnics report states that Christmas Island lies to the South of one of the most seismically active areas in the world, known as the Java Trench. Large earthquakes along this plate boundary have caused destruction in both Java and Sumatra. The report advises that due to the proximity of this region, there is potential for an earthquake to affect Christmas Island and recommends that the seismic hazard associated with these earthquakes must be determined using state-of-the-art seismic hazard assessment techniques. Buildings would then be able to be designed to withstand an earthquake of an expected magnitude over a set return period. The report notes that normal buildings are generally designed to experience the full Ultimate Limit State conditions during a 500 year return period, while hazardous installations may be required to perform during higher intensity events having a return period of up to 10,000 years.

The Draft EIS (p6-8) notes that Christmas Island is located on an active tectonic zone and that it is expected that seismic tremors do occur, but that there are no records of major seismic activity affecting the island. These records only dated to 1960. Concerns were raised in a public submission, and at community meetings where some islanders noted tremors that had been felt on the island. More information was provided in the Supplement, noting that minor tremors had been recorded, that a major concentration of activity in the Java Trench was to the North of the island, while a lesser concentration had been recorded in the immediate area surrounding the island. The Supplement stated that “whilst there is little risk of major seismic activity on the island the design and construction of the facility will be in compliance with prevailing earthquake design codes”.

Recommendation 42: A Potential Seismic Hazard Assessment should be carried out and be taken into account in the design of foundations and

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 106 building structures. All fuel storage facilities should be designed to the standards required for hazardous installations.

The South Point facilities would include a sewage treatment plant that would treat sewage to a tertiary level – removing suspended solids, micro-organisms and nutrients to an acceptable level approved by the WA Health Department for reuse in irrigation systems. The resulting water would be irrigated on the facility grounds, while solids would be dried in a manner similar to the existing sewage plant on the island. The assessment report does not state how these dried solids would then be disposed of (see waste management section in Social and Economic Impacts Chapter).

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 107

7 POSSIBLE IMPACTS UPON THE SOCIAL AND ECONOMIC ENVIRONMENT AND IMPACT AVOIDANCE AND REMEDIATION

7.1 ACCESS TO SOUTH POINT AND CHINESE TEMPLE

As explained in the project description, APSC proposes that for a period of up to 24 hours before a launch, people would be excluded from a land and sea exclusion zone in a 2 km radius from the launch pad. Viewing areas outside this radius would be established in consultation with the Shire Council. This restriction in access would occur up to twelve times a year. At all other times APSC activities on South Point would not restrict public access apart from the fenced security areas.

In reviewing the Draft EIS and Supplement, ICF Consulting noted that safety specialists who had reviewed the documents were unable to determine how the exclusion zone had been set at 2 km for the 24 hours preceding launch. ICF recommended that if there was a technical reason why this distance was selected, this information should be provided (ICF Feb 2000).

Recommendation 43: APSC should provide information on the criteria used to set the 2 km exclusion zone around the launch site so that it may be considered in the space licence procedure.

While there may be some recreational use of the South Point area (fishing for example), the primary impact of this restriction will be upon access to the South point Chinese Temple and the two shrines. As noted in the Supplement (p81) the main issue would be if a launch coincided with a major religious event in the Chinese calender. The location of the Temple and shrines is shown in Figure 13.

APSC states that while it believes that there can be a harmonious coexistence between the spaceport and its operations, and access to the temples, there may be times when proposed launch exclusions would clash with religious events, despite the best intentions of both groups.

APSC met with available members of the Temple Committee, including the President and the Deputy President on 14 December, 1999, and reports that agreement was reached, with APSC deferring from launching during two key religious celebrations: God’s Birthday and certain days in the Chinese New Year period (1st and 15th days). The actual dates would be determined by the lunar calender.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 108

Provided ongoing consultation takes place as part of APSC’s community consultation plan, this agreement would appear to be a satisfactory resolution to the key access problem.

Figure 13. Location of Chinese Temple and Shrines at South Point

from APSC Draft EIS

Recommendation 44: Launch activities should not result in closure of access to the South Point Chinese Temple during religious celebrations associated with God’s Birthday and the 1st and 15th days of the Chinese New Year Period (as determined by the lunar calendar). Alterations to this restriction may only be made with the agreement of the South Point Chinese Temple Committee.

A second issue is the proximity of the shrines in particular to the launch sites as shown in the following table:

Launch Pad 1 Launch Pad 2 Shrine 1 730 m 430 m Shrine 2 1200 m 940 m South Point Temple 1400 m 1250 m

The first shrine therefore falls within the 500 m area that APSC expects would be exposed to the fall of debris and potential shockwave damage to structures in the case of an on-pad explosion. The other shrines fall into the area where, according to APSC’s calculations, there would be damage to only the flimsiest of structures. APSC states that the nearest shrine would possibly suffer some damage, however, due to its small size and distance from the launch pad, any

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 109 damage would be slight. The chances of an on-pad explosion are small but not inconceivable (discussed further in Chapter 6).

ICF Consulting verified APSC’s calculation of shockwave intensity (ICF April 2000), but noted that while the EIS discussed the impacts of an on-pad explosion, it did not consider in detail the impacts of the vibration associated with normal launch operations (ICF February 2000).

It is also of concern that in assessing the potential impacts, APSC did not give any indication that it had considered the materials or structural integrity of the buildings. As with the proximity of the launch pads to natural habitat, the proposed launch pads would be located closer to the Shrines and the Temple than to the Technical Complex (1.4 km).

In the Supplement, APSC also states that they would be prepared to consider funding the construction of a new shrine and temple in an alternative location, if this was deemed an appropriate alternative for whatever reason in the future.

Recommendation 45: APSC, in consultation with the Temple Committee, must further analyse the potential for launches or on-pad explosions to damage the South Point Temple and Shrines. This information should be provided to the Temple Committee so that they are in a position to evaluate the potential impacts in considering the future of the South Point Temple and Shrines.

Recommendation 46: APSC must investigate and report on alternative configurations which would allow for a wider buffer zone between the launch pads and the South Point Temple and Shrines. The Temple Committee and the Minister for Environment and Heritage should be allowed to comment on the alternatives prior to the final siting decision being made.

7.2 ROLL-ON ROLL-OFF FACILITY

Submissions on the Draft EIS (including from residents living nearby and the Christmas Island Tourism Association), expressed a number of concerns regarding the proposed Roll-on Roll-of (Ro-Ro) facility. These included:

Ø The proximity of the facility to the Temple Court retail and residential area. (Submission 3 was a letter of objection specifically directed only at that aspect of the proposal and carried signatures of 30 residents of the Temple Court area); Ø Impacts upon parking and traffic flow along Gaze Road; Ø Noise impacts upon local residences and retailers;

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 110

Ø The facility would be detrimental to the aesthetic appeal of the foreshore and the area in question is part of a proposed foreshore beautification; Ø Concern that use of the facility by members of the public would lead to boats, trailers etc in the area; Ø Concern about the safety aspects of unloading and transporting hazardous substances in such close proximity to the residential area; Ø The Ro-Ro might have an impact upon the view from the Chinese Temple at Temple Court; Ø The proposal did not consider the “Gaze Road Townscape Master Plan”; Ø Alternative locations had not been discussed; Ø Concern that the ramp could allow storm waves to damage buildings (as noted in the Draft EIS (p7-21) buildings along this shoreline had previously suffered damage or destruction during severe storms).

In addition, the Australian Heritage Commission (AHC) noted that the proposed site was within the Settlement Service Precinct that is entered in the Register of the National Estate. AHC requested that as the facility had the potential to impact on national estate values, draft documentation (including plans and design details) should be referred to the Commission in line with section 30 of the Australian Heritage Commission Act 1975. The AHC noted the possibility that the Ro-Ro facility has the potential to impact on the National Estate values as well as the urban design and amenity values of Gaze Road.

The Supplement provided a detailed response to some of these issues (P72-80 & II-20), and provided information on changes to the proposed location (see Chapter 3).

APSC provided information on an assessment of wave conditions which concluded that in the case of maximum expected wave size, the wave run-up would be approximately 35 metres up the road ramp, which would have a total length of 115 metres. The final design analysis would need to be made at the building approval stage.

The new location would not be in sight of the Temple at Temple Court, and APSC states that the facility (presumably the ship docking area) would be almost obscured from vision at the level of Gaze Road. The facility entry to Gaze Road would of course be visible.

In relation to use of the facility by others, APSC’s position is that it would consider public utilisation of the Ro-Ro only if the community and local governing authorities accepted such an arrangement. In terms of the Ro-Ro becoming an alternative sea freight handling facility, APSC has stated that

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 111 the facility would be for the use of APSC only, and is not viewed as being an alternative sea freight handling facility in direct competition or in tandem with the existing port (March 2000 additional information).

Increased traffic would occur along Gaze Road only when vessels are unloading, which is expected to be once a month (this may be more variable and frequent in the 18-20 month construction phase). APSC proposes to position a traffic watchman at the intersection during those times. APSC expects that about 41 heavy vehicle movements would be made from Settlement to South Point per month when the facility is fully operational. The use of the Ro-Ro facility would focus around a number of days after the arrival of a ship at the facility.

The noise impacts would be similar to that experienced at the existing port. APSC states that with the exception of the large rocket component, there will be no unusually large vehicles generating noise at the site and that a large portion of the noise will be deflected by the edges of the cut formed by the graded ramp. Predicted sound levels were not provided, nor was information on the ambient noise levels in the area despite this being requested by the assessment guidelines (Guidelines S7.1.12).

The residential and retail nature of adjoining land uses demands more careful consideration of the noise impacts of the Ro-Ro facility. Currently there are no applicable noise regulations.

Recommendation 47: If the Roll-on Roll-off facility is to be located as proposed in the supplement, restrictions on maximum noise levels to be produced must be developed in consultation with the Western Australian Department of Environmental Planning and the Shire of Christmas Island. The facility should only be used during normal business hours.

The supplement stated that further information would be provided in the final design on the following issues:

Ø Traffic management of the ingress and egress to the facility; Ø Amendments to road infrastructure in accordance with the Department of Roads; Ø Parking requirements for the facility and general public; Ø Maximum retention of public amenity to the adjacent and surrounding area; Ø Heritage and streetscape aspects of the facility; Ø All engineering issues including the realignment of existing stormwater and sewer lines; and, Ø Landscaping and aesthetics management.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 112

The AHC remained concerned that issues that may impact upon the national estate values of the area needed to be dealt with at the assessment stage. In the March 2000 additional information, APSC stated that the proposed location and design of the Ro-Ro facility would meet with the “general thrust” of the Godden Mackay Logan Development Guidelines, and listed a number of ways in which the facility would be designed to be consistent with the heritage value of the Settlement Services Precinct (March 2000 additional information p13-14).

After considering information provided in the supplement, the AHC remains concerned that the location of the Roll-on Roll-off facility, as proposed in the final EIS, has the potential to impact on the national estate values of the Police Station (Settlement Services) Precinct and will compromise the opportunity to regain the townscape and associated cultural values of the place in the future. While the AHC accepted that the proponent had attempted to minimise the adverse impact on the Precinct and agreed that the measures listed by the proponent would help to protect the heritage values of the place, the AHC did not believe that it was sufficient for the proponent to only “meet the general thrust” of the Godden Mackay Logan Development Guidelines recommendations. The AHC remains of the view that the proposal cannot be verified without detailed drawings that provide information such as where the ramp intersects Gaze Road and the parallel configuration of the ramp and parking on Gaze Road, as these may have the potential to impact upon the future planning of the area.

Recommendation 48: Further documentation on the proposed Roll-on Roll-off facility including plans, elevations, sections, design details and a landscape plan should be referred to the Australian Heritage Commission for comment in line with Section 30 of the Australian Heritage Commission Act (1975) prior to a final decision being made about construction of the facility.

The environment assessment process post the issuing of the supplement has not provided an opportunity for the local residents to respond to APSC’s proposal to shift the Ro-Ro facility further down Gaze Road. While this move may alleviate some of the concerns of retailers and residents, given that the facility is still nearby, it is unlikely that concerns will be fully satisfied. Environment Australia is of the view that based on available information, the proposed location of the Ro-Ro facility will have a major impact upon the community and heritage values of the area and that options for an alternative means of bringing freight onto the island should be further investigated. However, given the detailed local planning nature of this particular issue, it would be more appropriate for the decision making process to further involve the local community and the Christmas Island Shire Council.

Recommendation 49: Further community consultation on the design and location of the Roll-on Roll-off facility should occur before final designs are completed. This process should be overseen by the Christmas Island Shire

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 113

Council. Subject to comment from the Australian Heritage Commission on the potential impact on the national estate values, the final decision on the current proposal for the Roll-on Roll-off facility should rest with the Shire Council. If the current proposal is rejected, APSC must further examine and report on other options for the delivery of freight to Christmas Island. This analysis must be referred to Environment Australia for further consideration and possible recommendations prior to a final decision on siting being made.

7.3 IRVINE HILL RESIDENTIAL AND ADMINISTRATION COMPLEX

As noted in the description of the project, limited information has been provided on the proposed residential and administration complexes to be sited at Irvine Hill. APSC states that the layout and planning of these facilities will involve close cooperation and liaison with the Shire Council, the WA Ministry for Planning and all other relevant statutory authorities.

The submission on the Draft EIS by officers of the WA Ministry for Planning noted that the subdivision and development of any land at Irvine Hill would require comprehensive /structure planning and more detailed rezoning prior to its subdivision and development, including consideration of issues such as vegetation protection, servicing requirements, aircraft noise impacts as well as off-site impacts associated with the nearby refuse disposal site. The Shire of Christmas Island submission raised similar concerns while also questioning whether it would be acceptable for the workforce to be located outside of existing residential areas.

The issue of segregation was also raised in some community meetings. One participant noted that existing Christmas Island residents had previously not been allowed to obtain land at Irvine Hill. While the plan to locate construction workers at South Point is probably logistically the best solution (and would alleviate concerns expressed by the Christmas Island Tourism Association that pressure on accommodation during the construction period might limit accommodation available for tourism), there appear to be issues both from a planning sense and potentially from a social impact sense in the construction of the residential complex at Irvine Hill. The fact that the planning framework for Christmas Island has yet to be finalised makes issues more difficult. The development of the residential complex would perhaps be more acceptable if efforts were put into preventing the complex from becoming isolated (both physically and socially) from the rest of the small island community.

APSC has already committed to making the active recreational facilities of the complex available to local residents for their use and enjoyment, and has stated their interest in encouraging development of the surrounding area for residential housing on a commercial basis (pending land availability, suitability and acceptance and approval by the relevant governing

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 114 authorities) (March 2000 additional information p52). The Supplement (pII-25 also notes that discussions with the Commonwealth regarding the planning and approval process suggest that a collaborative process of various statutory bodies, including the Shire, would be established as a formal instrument to deal with the complex demands of the exercise.

It would be in the interest of all concerned if the planning and the development of the residential and administrative complex was carried out through a transparent process, and one that did not occur outside of the normal bounds of residential planning on Christmas Island – that is, it should occur within the context of planning for the Irvine Hill area rather than as a special case.

The aircraft noise issue mentioned by the WA Ministry of Planning was also raised in a submission by the manager of Christmas Island Airport, who noted that in evaluating Irvine hill as a future urban area, a study into the effects of aircraft noise had been conducted which concluded that much of the area was inappropriate for residential development due to much higher than allowable aircraft noise based on the relevant Australian Standard. In response, APSC stated in the Supplement that the noise contours of the Irvine Hill area had been studied and the residential accommodation placed to minimise the incidence of aircraft noise generated at the runway, with the noise contours being at acceptable levels except for single event noise levels (which would impact upon the entire existing settlement area). Given the positioning of the complex within an overall planning complex and environmental complex has yet to be considered, the issue of noise would also need to be considered when a final siting decision was made.

Recommendation 50: The planning and design of the proposed residential and administration complex at Irvine Hill should be carried out within the context of the planning for the future of the Irvine Hill area in accordance with the Shire of Christmas Island Town Planning Scheme and give particular consideration to the integration of the complex into the existing island residential framework and siting to avoid aircraft noise impacts.

In relation to the design of the administration and residential complex buildings, APSC states that design will be undertaken with due consideration and attention to the existing prevailing site conditions (terrain, landscaping, orientation, climate) and that the use of energy efficient systems such as solar heating and recyclable materials will also be considered where possible. Given that this would be a “greenfields” development, there should be little to constrain adoption of these issues.

Recommendation 51: Design of the Residential and Administration Complex should reflect the existing architectural styles on Christmas Island. APSC must demonstrate that energy efficiency measures and use of renewable

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 115 energy have been incorporated wherever possible into all buildings to be constructed as part of the proposal (including those at South Point).

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 116

7.4 WASTE GENERATION AND HAZARDOUS MATERIALS.

The level of information provided by APSC on waste management was limited. APSC has stated that it will prepare and implement Environmental Management Plans for waste removal, disposal and recycling if and where possible, and will be discussing waste management with the Shire.

Launch facility staff and dependants will contribute to the production of domestic waste on the island, and shorten the life of landfill sites. The potential increase in cars on the island will also lead to an increased in the problem of how to dispose of them. The statement in the Draft EIS that this contribution will be offset by the fact that the population of the island is substantially lower than it has been in the past, is questionable given the estimates of a cumulative population increase to 3000 (including the proposal and the potential re-opening of resort casino) provided in the March 2000 additional information. ASPC did not provide an estimate of the amount of wastes the proposal would produce in categories such as domestic wastes and construction wastes.

APSC will require all suppliers and contractors to manage waste in accordance with the plan. And that penalties for non-conformance will be imposed in the contract for all suppliers and contractors (Supplement pII-24).

APSC has also committed to implementing an eco-office policy.

Environmental managers and regulators dealing with launch preparation and assembly activities at the US Kennedy Space Centre and Cape Canaveral launch facilities have likened the sites as having similar pollution and waste issues to many other industrial sites (Busacca 1999 pers com, Garfein, 1999 pers com). Industrial activities associated with such a site need to be examined in their entirety rather than simply focusing upon the launch activity. The evolutionary nature of the launch industry over the last few decades, combined with the pressure to ensure and improve safety standards has meant that wasteful and polluting processes, materials and techniques have been adopted with little further consideration for assessing whether there might be better alternatives that meet the requirements of the launch industry while also reducing environmental impacts. In recent years the Florida Department of Environmental Protection has worked with NASA, airforce and commercial launch operators to assess processes to be used so as to find ways to reduce environmental impacts.

While the EIS has provided information on the hazardous materials to be brought onto the island in bulk (space fuels, kerosene, diesel), ICF Consulting noted that there had been no information provided on pollution prevention strategies, nor information provided on hazardous material such as:

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 117

Ø Hazardous material contained within the delivered components; Ø Hazardous materials used and wasted during testing, maintenance and support of launch vehicles; and, Ø Materials and or waste used or emitted during the system operation phase (ICF Consulting February 2000).

Careful consideration will need to be given to the storage, use and disposal (including transportation off the island) of hazardous and polluting materials such as oil, paints, grease and solvents. The Draft Hazardous Materials Management Plan (Supplement Attachment IV) does provide some broad commitments to some of these issues, but consideration has not been given to the setting of strategic goals for reduction, elimination, or process modification to reduce or eliminate the generation of waste. Christmas Island is very removed from recycling centres – alternative strategies aimed at reducing the amount of wasteful material being brought onto the island need to be developed.

The APSC proposal involves the translocation of overseas technology, and processes that have not been developed within the context of the Australian regulatory environment. While it is understandable that there may be proprietary interests associated with launch facility, launch vehicle and payload technology, sufficient information relating to the processes, materials used, and waste produced must be made available to appropriate regulators so as to ensure that all efforts have been made to reduce or eliminate the generation of waste.

Recommendation 52: In developing plans for the management of waste and hazardous materials, APSC must identify processes, materials and techniques to be used at the launch facility and work with regulators to ensure all efforts have been made to reduce or eliminate the generation of waste. The waste management component of the Environmental Management Plan must be approved by the Shire of Christmas Island.

7.5 IMPACTS UPON INFRASTRUCTURE

The proposal will impose additional demands upon the island’s infrastructure both in terms of project specific activities and the increase in population on the island.

The March 2000 additional information (p7) identifies that the launch facility will result in a number of categories of additional people:

Ø Direct staff (employees of APSC or its contractors); Ø Dependents of direct staff; and,

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 118

Ø Support industry personnel and their dependents (eg, people employed in new business enterprises in areas that provide ancillary services to APSC.

The number of employees on the island at any given time would fluctuate and would peak at the time of a launch. APSC estimates that once the stable operating rate of 12 launches per year was attained, the above categories would contribute approximately 747 additional people to the island population. In addition, each launch would involve short term visitors such as satellite launch clients and VIP guests (about 40 per launch) as well as some tourists.

This would increase the island’s population to about 2147 people, which does not exceed recent high levels associated with the operation of the resort casino. However the current closed status of the resort casino is most likely a temporary situation. The Weekend Australian of 15 April reported that APSC had agreed to buy the Casino and hotel buildings (but not the licence). When resort casino employees, dependents and tourists (based on available number of beds) are all taken into account, the estimated total population could rise to about 3000 people – well above recent levels of population.

Such an increase has the potential to lead to added pressures on island infrastructure including power, sewage treatment, water supply, roads, hospital, educational and recreational facilities.

7.5.1 Power Supply & Sewage Treatment

APSC estimates that the existing power station should be able to provide for the population increase expected from the proposal (estimate made at the Draft EIS stages did not cover the re-opening of the resort). As noted previously, the current sewage treatment plant is designed to cater for up to 4000 people. The South Point facilities would include a sewage treatment plant that would treat sewage to a tertiary level – removing suspended solids, micro-organisms and nutrients to an acceptable level approved by the WA Health Department for reuse in irrigation systems. The resulting water would be irrigated on the facility grounds, while solids would be dried in a manner similar to the existing sewage plant on the island. The assessment report does not state how these dried solids would then be disposed of.

7.5.2 Road use

Road use will increase – both in terms of personal vehicle use, and heavy vehicles used associated with the proposal. This will potentially lead to increased traffic, some congestion in relation to road closures for hazardous goods transport, and the need for some alterations to intersections to cater for

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 119 long loads. APSC committed to contribute to the maintenance and upkeep of the existing road system (draft EIS p8-3).

7.5.3 Water Supply

The water demand of the South point facilities is unlikely to impact upon the Island’s town water supply. Much of the launch facility’s 40,000kl annual requirement would be sourced from roof top water harvesting from the facility buildings (20,000m2). APSC estimates this would produce between 32,000kl and 38,000kl a year, to be stored in the 38,000kl on-site reservoir. The remainder of the required supply would be sourced from the Jedda Cave source (the entire supply for the construction period would be sourced from Jedda Cave and stored in temporary lined areas on South Point).

The large storage area enables the facility to stockpile water, therefore not needing to access draw on large quantities from Jedda Cave at any one time. With at least 32,000kl harvested from roofs, APSC estimates that the maximum daily draw rate would be 16m3/day. Existing demand on Jedda cave ranges from 778 m3/day to 1261 m3/day while flow rates range from1123 m3/day to 12096 m3/day (average 5184 m3/day).

APSC also considered the impacts of other likely future population increases – resort casino, Irvine Hill development, and additional infill development (Supplement p38). The estimated total demand was a minimum of 3,655 m3/day and maximum of 6,022 m3/day, while the flow-rates of existing supplies is a minimum of 2,765 m3/day and maximum of 35,337 m3/day. It would appear that in the near future the cumulative impacts of these developments could lead to demand exceeding supply. APSC suggests three possible approaches to resolving this issue:

Ø Initiate a water conservation strategy (1995 data indicated that water usage was four to five times higher than metropolitan Australia); Ø Initiate an improved maintenance program ensuring pipelines and equipment are routinely inspected, rectified or replaced; and, Ø Initiate investigations o potential new water sources.

7.5.4 Education

An increase of more than 30 school students would require the establishment of new classroom facilities. Increases in students could lead to changes in the student to teacher ratio and may require the employment of new teaching staff. It is also possible that an increase might facilitate the extension of the

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 120 current on-island schooling system to cover years 11 and 12. APSC notes that it is difficult to estimate the level of impact as it will depend on the family status of the workers to be employed. APSC has committed to make efforts to forewarn the school of anticipated increases in student numbers at all stages of the project.

7.5.5 Recreational Facilities

APSC would provide additional recreational facilities at the Irvine Hill complex and states that it will consider the location of some recreational facilities at the construction camp at South Point. The draft EIS states that the present recreational facilities are of a high standard and are not likely to require upgrading as a result of the increase in population associated with the proposal.

Water based recreation on the island (swimming, fishing, diving, boating, snorkelling etc) focuses on Flying Fish Cove – which doubles as a commercial port. The increase in the number of recreational users of the cover – particularly temporary residents – may increase chances for conflict between the two uses of the cove. APSC notes that the increase in population may place greater pressure on resources of the National Park. In particular this pressure might focus on visitor facilities. Some visitor facilities are also likely to serve a secondary purpose as launch observation areas for the public. APSC states that it will “discuss the need to construct access areas in less sensitive areas of the National Park to accommodate visitors with Parks Australia North” (Draft EIS p9-21). It is also likely that liaison with APSC in relation to the implementation of the Environmental Management Plan during both the construction and operational phases will place additional demands upon Parks Australia North staff on the island.

Recommendation 53: APSC’s contribution to the maintenance of visitor facilities in Christmas Island National Park should be set out in the Environment Management Plan.

7.5.6 Hospital

The current hospital facilities are designed to provide for a residential population of up to 3000 people. This would suggest that while the facilities would be able to cater for the expected population increase associated with the proposal, the cumulative increase discussed above could result in demand reaching design limits.

While it is unlikely that there will be any immediately severe impacts upon island infrastructure, there would appear to be a number of areas where the

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 121 cumulative impacts of predicted population increases in the next five years could lead to pressure upon infrastructure and resulting degradation of the quality of infrastructure standards on the island. It would be unreasonable to expect existing residents to bear the burden of the pressures placed upon the island by new commercial activities, and it could be expected that any such impact could serve to compound any community dissatisfaction with the launch facility.

While in some instances such as road maintenance APSC has made commitments to contribute to costs, in other areas of infrastructure and community development APSC has been non-committal in terms of making a contribution. APSC’s stated view is that it considers the significant amount of corporate tax that it will pay “ … would be an indirect contribution to the provision of basic infrastructure and services on the island. Of course the extent to which this will occur is a matter for the Commonwealth Government” (Supplement pII-52). Concern was expressed by some attendees at community meetings as to whether this form of contribution to the community would ever reach Christmas Island.

Recommendation 54: The Territories office should develop strategies to monitor the cumulative impacts upon infrastructure and community services of the increase in population due to the launch facility project.

7.6 EMERGENCY PROCEDURES

Christmas Island has an Disaster Plan that deals with emergency management arrangements and is organised by the Christmas Island Counter Disaster Committee. Some submissions and community meeting attendees expressed concern about how the voluntary fire service would cope with the new scenarios. The draft Hazardous Material Contingency Plan includes the provision of training on UDMH and NTO related emergencies to the police, fire brigade and hospital staff.

APSC has stated that if a medical emergency or in-flight emergency arises, then the required airport movements would be permitted immediately, with launches placed on hold or recycled until the emergency movements are completed (March 2000 additional information p18).

7.7 SOCIAL IMPACTS

The Draft EIS notes that the presence of launch facility staff would be likely to increase the number of persons between the age of 25 and 40, and potentially reinforce the existing trend towards a larger percentage of males on the island. The balance of the religious make-up of the island will be altered.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 122

Launch facility workers from off-island will be inexperienced in how the Christmas Island community functions. They may need time to become familiar with the mix of ethnic groups, and to respect religious beliefs (for example, the call to prayer from the Kampong Mosque. Russian technicians may have language difficulties.

Islanders will be faced with a large group of strangers. As discussed in the Social and Economic Environment chapter, some islanders may harbour suspicions based on the partial failure of the resort casino operation to integrate with the local community. Factors such as the temporary nature of many staff, a new ethnic group and language, and potentially isolated accommodation could all serve to cause problems if not dealt with.

Christmas Islanders are also likely to be concerned about the operation of the launch facility. Notes from community consultation meetings indicate a level of concern and uncertainty about dangers of launches and space fuels. Some of these concerns have been fuelled by misinterpretation of information about other launch facilities elsewhere in the world, some of the concerns have been developed in response to conflicting information provided in early attempts by APSC at relating to the local community.

Given the existing diversity and strengths of the local community, there would be every likelihood that the proposal would be able to operate on Christmas Island with minimal social impact if it implemented with sensitivity and a commitment to integrate with and involve the local community as opposed to operating as a stand-alone project.

APSC states that in determining the most viable way to integrate the APSC workforce into the island community, APSC was “cognoscente of the dangers of developing an insular enclave of citizens that were seen as remote and contributing little to the Island’s economy and culture” (March 2000 additional information p25). Yet APSC concluded that for reasons of both practicality (availability of land) and efficiency (economies of scale in service provision), APSC decided on a centralised housing model for its workers. The approach allows APSC to provide the maximum standard and range of facilities for staff, thereby reducing the dependency on existing infrastructure and services. However in some areas such as medical and hospital services it would be more feasible to utilise existing public sector infrastructure.

APSC argues that despite the centralised housing location, staff will move freely within the Island community and will be encouraged to do so by APSC. Apart from that encouragement, and a commitment to making the active recreational facilities of the complex available to local residents it is difficult to identify how APSC proposes to take action to deal with this issue (see recommendation 50).

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 123

APSC has outlined a range of actions aimed at ensuring that the present cultural norms and relaxed lifestyle of the Christmas Island community are not compromised these are outlined in the following draft plans (Supplement, Attachment IV):

Ø Employee Cultural Education Plan; Ø Employee Environmental Education Plan; Ø Community Consultation Plan.

7.7.1 Employee Education

APSC proposes the development of cultural training workshops aimed at:

Informing employees of the cultural history of the island; Informing employees of appropriate customs to adopt when in the Kampong and other culturally sensitive areas; Training employees in conflict resolution techniques.

In addition, APSC would maintain a register of complaints received regarding the conduct of their staff within the wider community, and would develop a set of guidelines setting out what is considered acceptable practice for employees whilst on the island. Employees in breach of the guidelines would be disciplined.

Recommendation 55: The Employee Cultural Education Plan and cultural training workshops should be developed in consultation with community organisation representative of the major cultural groups present on Christmas Island. APSC should also consider the possibility of employing members of the local community to conduct all or part of the cultural training workshops.

7.7.2 Community Consultation

The community consultation plan focuses on ensuring information regarding APSC activities would reach the community – via notices in three languages, public meetings, information seminars etc. APSC would employ a Community Liaison Officer representing each ethnic sector of the community. “The primary role of this officer will be to act as a spokesperson for the sector of the community he/she represents and will act as an interpreter which will maintain effective community consultation” March 2000 additional information p51).

APSC proposes to liaise with the community via regular meetings held between members of APSC and representatives of the community. These would be structured as a presentation by APSC followed by questions and answers. Other means of liasing with the community would include:

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 124

Ø Information available at the APSC Office; Ø Information packages provided to schools and other public facilities; Ø A quarterly newsletter published in “The Islander” (local newsletter); Ø A telephone number and email address made available for inquiries.

The draft consultation plan appears to focus on the dissemination of information, which while essential is only half of the task required. Performance indicators in the draft plan mostly refer to ensuring copies of notices and correspondences are kept and reviewed. More emphasis needs to be given to openly being prepared to receive feedback from the community, and acting on this feedback in a positive and transparent manner wherever possible. Auditing procedures need to include assessments of how APSC has responded to the needs of the local community.

While the employment of community liaison officer could be seen as a valuable recognition of APSC’s regard for the community and recognition of their potential contribution, some effort would need to go into ensuring that the liaison officers are not perceived as by-passing the community organisations formed by the community itself. Recognition of local community organisations should also extend beyond ethnic groups to encompass other active groupings in the community with common needs and goals such as business groups (Chamber of Commerce and Tourism Association), and the Christmas Island Women’s Association.

Recommendation 56: The Community Consultation Plan must be extended to encompass mechanisms for receiving and acting on feedback from the local community and auditing this process. The final Community Consultation Plan must be developed in consultation with a wide range of local community groups and should be endorsed by the Shire of Christmas Island and Christmas Island Administration.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 125

8 ENVIRONMENTAL MANAGEMENT

8.1 ENVIRONMENT MANAGEMENT PLANS

The EIS presents a two stage environmental management system. Impact matrices examine the potential for adverse and beneficial impact associated with the project; identify the implications and magnitude of these impacts; outline APSC’s commitment to mitigating any adverse impacts; and, assign the commitments to an Environmental Management Plan. The final version of the Impact Matrices can be found appended to the March 2000 additional information. The Draft EIS described the second stage - Environmental Management Plans (EMPs) as formalising APSC’s commitments to mitigating adverse environmental impacts associated with the construction and operation of the proposed satellite launch facility. A second version of the EMPs was attached to the Supplement. The Supplement noted that the current EMPs were a framework for future EMPs as part of the Facilities Environmental Management System to be developed after the EIS.

The impact matrices were found in some places to too readily dismiss the possibility of negative impacts, and in some cases base this dismissal on insufficient information. In other instances the conclusions or commitments conflicted with those made in the text of the EIS. Examples have been noted where relevant in the discussion of impacts in this report. The draft EMPS were also found to be unsatisfactory in terms of some performance indicators and adaptive management responses.

As noted in this report, further data collection will be required on some issues prior to the finalisation of the EMP. Environment Australia is of the view that the Environmental Management Plan for the proposal should be completed in consultation with Environment Australia and other agencies responsible for relevant regulation (via WA legislation). Many of the recommendations in this report relate to issues that would need to be resolved in the EMP.

In addition to commitments in relation to specific activities and potential impacts, APSC makes a number of more general commitments relating to the environmental management of the project. These include:

Ø Close cooperation with Parks Australia North to ensure consistency with the land management strategies Parks Australia North already has in place;

Ø Establishment of an Environmental Management Division within APSC to cover all environmental aspects of the construction and operation of the Space Centre.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 126

Ø Development and implementation of an Employee Environmental Education Plan;

Ø The establishment of the “Christmas Island Environmental Foundation”, which, in recognition of the interconnected nature of the ecological regime on the island, would contribute to the management of the natural heritage on Christmas Island. APSC would contribute $1.0 million over ten years to the Foundation, and use the initial contribution to leverage funds, real and in kind, from other companies and government agencies. A small board of directors would manage the foundation with representatives from APSC, major financial contributors and Parks Australia North.

In relation to the last point, it should be noted that due to past and ongoing impacts, the management of Christmas Island’s natural environment is a high cost exercise. For example, the cost of rehabilitation of previously mined areas is approximately $100,000 per hectare. The potential threat of the Yellow Crazy Ant may require further resources in the near future.

The Space Activities Act 1998 requires that before a space licence is granted, the relevant Minister (intended to be the Minister for Industry, Science and Resources) must be satisfied that all necessary environmental approvals under Australian law have been obtained, and that an adequate environmental plan has been made, for the construction and operation of the launch facility. Regulations to the Space Activities Act 1998 are still being developed.

The second key approval for the project would be the transfer of land to APSC (via lease or freehold) by the Minister for Regional Development, Territories and Local Government. The Supplement states that APSC expects that the company would initially be granted a 99 year lease over the site, with this lease converting to freehold possession once construction has finished and the space centre is ready for operations (pII-3).

Further approvals will be required under the Space Activities Act 1998 for each launch or series of launches. APSC has expressed the view that the current EIS is intended to encompass all possibilities, so that no further environmental issues are raised at that stage (March 2000 additional information p31). Given that ongoing operations and implementation of the EMP may result in restrictions on launch timing, it is not possible for all issues (for example, restrictions on launch scheduling in relation to bird nesting seasons) to be considered in this assessment.

It is considered that it would be appropriate for the Minister for Environment and Heritage to approve the Environment Management Plan prior to the proposal proceeding.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 127

Recommendation 57: The final Environmental Management Plan for the proposed Christmas Island Satellite Launch Facility and associated infrastructure must be developed in consultation with Environment Australia and agencies responsible for other relevant environmental regulation. The Minister for Environment and Heritage must approve the Environmental Management Plan prior to the commencement of the construction of the project.

Recommendation 58: The granting of a Space Licence for the Christmas Island Launch Facility must be conditional on APSC complying with the recommendations of the Minister for Environment and Heritage, and in particular compliance with the Environmental Management Plan approved by the Minister for Environment and Heritage. Granting of launch permits for the facility must also be conditional upon ongoing compliance with the Environmental Management Plan.

Recommendation 59: The granting of land to Asia Pacific Space Centre Pty Ltd as either leasehold or freehold for the construction and operation of the Christmas Island Launch Facility must be conditional on APSC complying with the recommendations of the Minister for Environment and Heritage, and in particular compliance with the Environmental Management Plan approved by the Minister for Environment and Heritage.

8.2 REHABILITATION

A noted in Chapter 6, the EIS commits APSC to rehabilitation of areas as soon as possible after construction activity has ceased in a given area.

The Supplement (pII-3) provides some information on the end of life plan for the project. APSC’s expectation is that based on financial viability and foreseeable market demand, the lifespan of the project would be 15-20 years but that should the market provide an ongoing demand, the facility might operate beyond this. The EIS provides two alternative scenarios for the conclusion of the project:

“Upon the expiration of a viable operation, the Facility and its buildings may be converted into an appropriate future development such as a research centre, museum and/or tourist/recreational facility. Alternatively, should it prove that the buildings are of no functional or productive use, the proponent will dismantle and remove the structures and sensitively rehabilitate the site in accordance with the prevailing statutory requirements and land use approvals. A detailed Decommissioning Plan will be prepared by APSC Pty Ltd within 5 years.”

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 128

The South Point areas are currently held under mining leases by Christmas Island Phosphates. The leases require that the company must revegetate all mining leases before handing them back to the Commonwealth. Given that APSC will be receiving this land, therefore preventing this condition from being complied with, it would be appropriate for APSC to be required to undertake the rehabilitation at the end of the life of the launch facility.

Recommendation 60: South Point Facilities should be decommissioned and removed from the site and preferably the island at the end of the life of the project. The South Point facility areas should be rehabilitated to a condition consistent with the surrounding natural environment.

Recommendation 61: The Decommissioning Plan should be prepared in consultation with Environment Australia.

While the form of title that APSC will hold on the land for the South Point facilities has yet to be decided by the Minister for Regional Development, Territories and Local Government, it is intended that a bank guarantee will be required during the construction of the facilities. This would be intended to cover the cost of restoration of the sites to original condition if the project fails partway through construction.

The Space Activities Act 1998 requires that the holder of a launch permit must satisfy insurance requirements by insuring both the permit holder and the Commonwealth for an amount not less than the maximum probable loss that may be incurred in respect of damage to third parties caused by the launch or return, as determined using the method set out the regulations.

APSC have committed to the rehabilitation of all areas affected by a launch anomaly with native floral species as soon as practical following devastation of an area by fire (Natural Impact Matrix p19). In the case of environmental damage to rainforest areas, rehabilitation may take decades before the area resembles its original condition and possibly becomes suitable habitat for wildlife such as tree-top nesting seabirds. Given this, it would be appropriate in such cases for the proponent to be required to undertake additional, compensatory efforts to improve habitat on the island. This may involve rehabilitation of other sites, or stress mitigation in terms of reducing other threats to fauna and flora (eg, feral animals). This option is suggested by APSC (Supplement p28-30), although no commitment is given. APSC notes that before such a program was initiated, there needs to be confirmation that the activity (eg, removal of feral cats) would be beneficial. The control of the Yellow Crazy Ant would be one possible avenue that the proponent could contribute to.

Recommendation 62: APSC must give a legally binding commitment (enforceable by the Commonwealth) that it will, at the request of the

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 129

Commonwealth, rehabilitate any aspect of the environment that is significantly damaged as a result of the construction or operation of the proposed launch facility and associated infrastructure

Recommendation 63: In the event of a launch accident over the island which destroys significant habitat, APSC must provide additional compensation measures to improve habitat on the island.

Recommendation 64: APSC should be required to lodge a security so as to reduce the risk to the Commonwealth that may be incurred by failure of the proponent to meet environmental management responsibilities.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 130

9 CONCLUSION

This assessment report has provided an examination of the environmental impact statement prepared by ERA. In other chapters of this report, recommendations have been made regarding either actions that should be taken prior to any Commonwealth approval for this proposal, or conditions that should be placed on approvals given by the Commonwealth for this proposal. There are two key Commonwealth approvals required before construction of the proposal may proceed:

Ø Approval for the transfer of land to APSC (via lease or freehold) by the Minister for Regional Development, Territories and Local Government;

Ø Granting of a Space Licence by the Minister for Industry, Science and Resources as required by the Space Activities Act 1998.

Approval of Launch Permits will also be required under the Space Activities Act 1998 for each launch or series of launches. This provides the opportunity for the Departments of Regional Development, Territories and Local Government, and Industry Science and Resources to determine in consultation with Environment Australia the most appropriate means of implementing the recommendations in this report.

In addition to the recommendations, APSC has outlined numerous commitments regarding the design, management and operation of the proposal that are aimed at avoiding or minimising environmental impacts.

Recommendation 65: APSC must ensure that the proposal is implemented in accordance with the commitments and safeguards identified in the Christmas Island Satellite Launch Facility Draft Environmental Impacts Study August 1999, or as modified or added to in the Christmas Island Satellite Launch Facility Final Environmental Impact Statement January 2000, and the additional information provided by APSC on 24 March 2000 unless these commitments and safeguards are superseded by recommendations made by the Minister for the Environment in relation to this proposal.

Final planning and design of the project and the environmental management plans has yet to be completed. This environmental assessment report has been prepared in that context. The recommendations identify where APSC will need to involve Environment Australia, the Territories Office (and through the Office, relevant Western Australian Government Departments acting as service providers), the Shire Council of Christmas Island and relevant community groups in implementing recommendations as the planning for the project proceeds.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 131

In conclusion however, Environment Australia is of the view that the proposed establishment of a launch facility on Christmas Island may not be an activity that will be compatible with the natural environment of Christmas Island and in particular the environment of South Point. As discussed in Chapter 4 of this report, the environment of Christmas island has many features that are unique – including a number of endemic species, some of which are endangered, and unique habitats and ecological interrelationships. These unique aspects are confined to the 135 square kilometres of Christmas Island, and many of them to specific habitats distributed across only part of the island. In addition, Christmas Island also harbours species that are under threat elsewhere in their ranges, and also possesses important geological features.

As set out in Chapter 6, the proposal, if undertaken, would present this important natural environment with a range of potential impacts which cannot be completely ruled out through mitigation measures. Some, such as the possibility of a fuel spill that harms the natural environment have only a very small chance of occurring. Others, such as the explosion of a launch vehicle over the island have a greater but still small chance of occurring during the life of the project. Such an accident would probably cause damage to valuable habitat for important seabird colonies on South Point. Each launch will expose those same South Point colonies to the impact of launch noise. This noise will have some impact upon the seabird colonies, but it cannot be known whether the impact will be significant until after a series of launches are monitored and the data compared to baseline data. The launch activity could also cause the loss of one or more territories of the endangered Christmas Island Goshawk.

As noted in Recommendation 27, Environment Australia is of the view that if launch activities are found to cause a significant negative impact upon the South Point seabird colonies, this must result in a suspension of the launch regime while the possible causes are investigated by a panel of avian experts appointed by the Minister for Environment and Heritage. In order to prevent further impacts to the colonies launches would need to be delayed until such a time that it has been determined whether further launches are possible without bringing about further decline or preventing recovery of numbers. While adaptive management of the launch facility may offer solutions in some cases, APSC has not been able to demonstrate to our satisfaction that it would in all cases be able to modify launch activities so that they might continue without causing further significant negative impacts upon the seabird colony. Therefore, the only course that could be taken to protect the colonies would be to discontinue rocket launches from the facility.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 132

10 REFERENCES

Much of the information in the assessment report is derived from the information provided by APSC in the Draft EIS, Supplement and additional information. Page numbers for specific points made by APSC are referenced in the text. Additional information on the natural environment of Christmas Island is sourced from the 1999 National Park Draft Plan of Management, and input from Parks Australia staff. Other sources are referenced in the text where referred to.

Adams, J., Neale, M. 1993 “Christmas Island, The Early Years”, Southwood Press, Marrickville NSW.

ARUP Geotechnics, May 1999 “APSC Christmas Island Project – Report on Geotechnical Investigations”, ARUP Geotechnics Brisbane, QLD.

Asia Pacific Space Centre Pty Ltd, 1999 “APSC Christmas Island Satellite Launch Facility- Draft Environmental Impact Statement”, Sinclair, Knight, Merz August 1999.

Asia Pacific Space Centre Pty Ltd, 2000 “APSC Christmas Island Satellite Launch Facility- Final Environmental Impact Statement”, Sinclair, Knight, Merz January 2000.

Asia Pacific Space Centre Pty Ltd, 2000 “Proposed Satellite Launch Facility on Christmas Island – Assessment of Final Environmental Impact Statement – Responses From Asia Pacific Space Centre Pty. Ltd. On further Information Required Under Para 9.2 of the Administrative Procedures of the Environment Protection (Impact of Proposals) Act 1974”. Additional Information received by Environment Australia 24 March 2000.

Busacca, M., 1999, Pers Com, Kennedy Space Centre Environmental Program Office.

Breininger, D. R, et al March 1994, “Endangered and Potential Endangered Wildlife on John F. Kennedy Space Centre and Faunal Integrity as a Gaol for Maintaining Biological Diversity”, NASA Technical Memorandum 109204.

Briggs, J.D., and Leigh, J.H (1995). “Rare or threatened Australian plants”. CSIRO Publishing. Collingwood, Victoria

Brown, I. K., 1998 “New Millenium NASA – International Space Station and 21st Century Space Exploration”, Pioneer Publications, California.

Curl, D., 1997 “The Changing Fortunes of Christmas Island”, Australian Geographic, January-March 1997.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 133

De Korte, J. “Status and Conservation of Indonesia’s Seabird Colonies” ICBP Technical Publication No 11, 1991.

ESA (European Space Agency) 1999 “World experts on space debris meet in Europe on 11-13 October” ESA Press Release No 41-99 Paris, 4 October 1999.

Garfein, V. 1999, Pers Com, Florida Department of Environment Protection.

Great Barrier Reef Marine Park Authority (1997) “Guidelines for Managing visitation to Seabird Breeding Islands”, Great Barrier Reef Marine Park Authority, Townsville, Queensland.

Green, P.T., O'Dowd, D.J., and Lake, P.S (1997) “Control of seedling recruitment by land crabs on a remote oceanic island”. Ecology 78:2474--2486

Green, P.T., O'Dowd, D.J., and Lake, P.S (1998) “Long term control of seedling recruitment and litter dynamics by red land crabs in rainforest on Christmas Island Indian Ocean”. Unpublished report to Environment Australia, Parks Australia North. 41pp

Green, P.T., Lake, P.S., and O'Dowd, D.J (1999) “Monopolization of litter processing by a dominant land crab on a tropical oceanic island”. Oecologia 119:435-444

Humphreys, W.F. , in press. Chapter 0. Background and glossary. Pp 1-14. In: H. Wilkens, D.C. Culver and W.F. Humphreys (eds). Ecosystems of the World, vol. 30. Subterranean Exosystems Elsevier, Amsterdam.

ICF Consulting, December 1999 “Review of an Environmental Impact Statement for the Construction and Operation of a Satellite Launch Facility on Christmas Island”, ICF Consulting Pty Ltd, North Fitzroy, Victoria.

ICF Consulting, February 2000 “Review of an Final Environmental Impact Statement for the Construction and Operation of a Satellite Launch Facility on Christmas Island”, ICF Consulting Pty Ltd, North Fitzroy, Victoria

ICF Consulting, April 2000, “Verification of Selected Environmental Impact Statement Analyses for the Christmas Island Satellite Launch Facility”, ICF Consulting Pty Ltd, North Fitzroy, Victoria.

Johnson, L. August 1998(a) “Submission on the Social Impact of the Proposed Satellite Launch Project, Christmas Island”, Christmas Island.

Johnson, N. L., August 1998(b) “Monitoring and Controlling Debris in Space”, Scientific American,.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 134

Lynch, K. (Christmas Island Phosphates Environmental Coordinator) Pers Com, 18 November 1999

Lumsden, L. (Arthur Rylah Institute, Victorian Dept of Natural Resources and Environment), Pers Com, 30 March 1999

Lumsden, L; Silins, J; Schulz, M; 1999; “Population Dynamics and Ecology of the Christmas Island Pipistrelle, Pipistrellus murrayi, on Christmas Island – Consultancy for Parks Australia North – Christmas Island”; Arthur Rylah Institute for Environmental Research, Department of Natural Resources and Environment, Victoria.

Mazurski, E., Project Officer Hazardous Substances Unit, National Occupational Health and Safety Commission, Pers Com, 3 February 2000.

McGovern, N. (Christmas Island Harbourmaster) Pers Com 24 September 1999

NASA 1997 “NASA Policy Directive. Office of Safety and Mission Assurance. NASA Policy for Limiting Orbital Debris Generation” NPD 8710.3, NASA

Nettleship, D. N., Burger, J., Gochfeld, M. “Seabirds on Islands: Threats, Case Studies and Action Plans”, Birdlife International 1994.

Parks Australia, Environment Australia (Oct 1999) “Christmas Island National Park – Draft Plan of Management”, Commonwealth of Australia 1999.

Schultz, S. J., “Californian Least Tern Monitoring Report for the July 9, 1997 SLC-2 Delta Space Vehicle Launch, Vandenberg Air Force Base” Bioresources, 18 August 1997.

Spence, P. (Australian Federal Police, Christmas Island) pers com 24 September 1999

Thorson, P., Francine, J., Eidson, D., (1998) “Acoustic Measurement of the Titan IV A-18 Launch and Quantitative Analysis of Harbor Seal (Phoca vitulina richardsi) Behavioural and Auditory Responses”, SRS Technologies, California

UNISPACE 3 “Draft Report of the Third United Nations Conference on the Exploration and Peaceful Uses of Outer Space”, 16 April 1999

United States Environment Protection Agency, US Department of Transportation, Office of Commercial Space Transportation, August 1990, Safety Evaluation of Astrotech Payload Processing Facility Titusville Florida.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 135

United States Fish and Wildlife Service “Merrit Island Wildlife Refuge” (information brochure) US Government Printing Office.

United States Fish and Wildlife Service “Biological Conference Opinion for the Delta II Launch Program at Space Launch Complex 2, and Taurus Launch Program at 576-E, Vandenberg Air Force Base 1-8-98-F-25R” Dec 4 1998, provided by Lee An Naue, US Fish and Wildlife Service.

Wade, M., 2000 “Encyclopedia Astronautica”, http://www.friends-partners.org/~mwade/lvs/angara.htm

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 136

11 GLOSSARY

Anchialine anchialine (or anchihaline) * Anchialine habitats consist of bodies of haline waters, usually with a restricted exposure to open air, always with more or less extensive subterranean connections to the sea, and showing noticeable marine as well as terrestrial influences. They typically occur in volcanic or limestone bedrock. APPEA Australian Petroleum Production and Exploration Association APSC : Asia Pacific Space Centre Pty Ltd BH Bore hole CAMBA China and Australia Migratory Birds Agreement CI Christmas Island CIP Christmas Island Phosphates DB Decibel dBA Decibel A weighted sound level DEIS Draft Environmental Impact Statement DISR Department of Industry Science and Resources EIS Environmental Impact Statement EP Act Environmental Protection Act (WA) 1986 EPIP Environment Protection (Impact of Proposals) Act 1974 ESA European Space Agency GBMRPA Great Barrier Reef Marine Park Authority Ha Hectare ISO International Standards Organisation JAMBA Japanese and Australia Migratory Birds Agreement KBOM Design Bureau of General Machine Building KBTM Design Bureau of Transport Machinery LV Launch Vehicle Assembly m Metre ML Mining lease MOU Memorandum of Understanding MW Megawatt NAERG North American Emergency Response Group NASA National Aeronautics and Space Administration NTO Nitrogen tetroxide RO-RO Roll-on Roll-off (Port facility) SLASO Space Licence and Safety Organisation UDMH Unsymmetric di-methyl hydrazine USA United States Of America

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 137

Proposal To Establish A Satellite Launch Facility and Associated Infrastructure on Christmas Island.

Recommendations Contained in the Environment Assessment Report Prepared by Environment Australia, May 2000.

Recommendation 1: APSC, in consultation with the Christmas Island Conservator, should establish a comprehensive baseline by identifying areas of vegetation on the proposed Launch and Technical Complex that are of important habitat value.

Recommendation 2: APSC, in consultation with the Christmas Island Conservator, should establish a comprehensive baseline by conducting flora and fauna surveys of the Administration and Residential Complex, and any areas to be disturbed during construction of additional airport facilities.

Recommendation 3: APSC should establish a comprehensive baseline for the Christmas Island Pipistrelle Bat by conducting surveys of its distribution using ultrasonic detectors, and where appropriate, radio tracking, in order to establish the distribution and abundance of the bat on South Point. The survey should be completed prior to the commencement of any construction activity on South Point by APSC and the survey design should be approved by the Environment Australia.

Recommendation 4: APSC should establish a comprehensive baseline, by undertaking a survey of the occurrence of endemic reptile species should be carried out in the areas that would be disturbed during the construction and operation of the Technical and Launch Complexes on South Point. The survey should be completed prior to the commencement of any construction activity on South Point by APSC and the survey design should be approved by Environment Australia.

Recommendation 5: APSC must develop a proposal to conduct a survey for possible cave systems and subterranean fauna on South Point focusing on the proposed site of the Technical and Launch Complexes and using non damaging techniques such as ground probing radar. This plan is to be approved by Environment Australia prior to the survey taking place. A report on the survey results must be provided to Environment Australia and should be taken into account in the development of the Environmental Management Plan for the project.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 138

Recommendation 6: The layout of buildings and infrastructure in all areas of the proposal must be designed as far as possible (without compromising safety requirements) to avoid necessitating the clearance of important regrowth habitat during construction. Project layout and construction must not involve the clearance or damage of primary rainforest. Buffer zones at least 20m in width, consisting of regrowth vegetation or rehabilitated areas must be left between primary rainforest and project areas. Cleared vegetation must not be burnt and should be mulched where possible. APSC must obtain the approval from Environment Australia for vegetation clearance prior to construction commencing.

Recommendation 7: Rehabilitation and landscaping plans must be developed as part of the Environment Management Plans to be approved by Environment Australia.

Recommendation 8: The water pipeline from Jedda Cave to South Point must be placed underground. Placement of the pipeline through a section of national park will require separate consideration under the National Parks and Wildlife Conservation Act 1975 or Environment Protection and Biodiversity Conservation Act 1999.

Recommendation 9: The cost for control of feral animals on project sites and feral animals dispersed to adjacent areas as a result of construction activity must be met by APSC. Control techniques must be approved by Parks Australia.

Recommendation 10: A strategy for the prevention of transportation of the Yellow Crazy Ant and soil micro-organisms through the movement of earthmoving and construction vehicles must be developed and implemented as part of the Environment Management Plan.

Recommendation 11: APSC must include awareness of quarantine procedures and requirements in introductory training for all employees and contractors.

Recommendation 12: APSC, in consultation with the Australian Quarantine and Inspection Service, must construct appropriate quarantine facilities at all new points of entry to Christmas Island that are established as part of the proposal.

Recommendation 13: Territories Office must ensure that adequate levels of suitably trained inspection staff are available to undertake quarantine inspections and treatments of the expected increased levels of cargo and containers arriving on the island as a result of the proposal.

Recommendation 14: In addition to APSC’s commitments in the EIS, APSC should record instances of significant avifauna road mortality, both on the South Point project area and during cross-island transportation and report

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 139 instances to the Conservator (monthly). Modification of transport activity may have to be made if Environment Australia determines that levels of road mortality may endanger or further endanger native species. APSC should install crab tunnels under new and existing roads at points to be determined by the Conservator, and should contribute to the maintenance of existing crab tunnels.

Recommendation 15: APSC must present the results of a routing analysis (including the landing of materials onto the island) describing and evaluating all options for the transportation of Kerosene, Diesel fuel, Unsymmetric di- methyl hydrazine and Nitrogen Tetroxide, so that the Minister for the Environment and Heritage can provide additional advice on the preferred route in relation to his responsibilities under the Environment Protection (Impact of Proposals) Act 1974.

Recommendation 16: APSC must produce a report modelling the impacts of worst case releases of Unsymmetric di-methyl hydrazine and Nitrogen Tetroxide in inhabited and ecologically sensitive areas of the island and provide it to the Minister for Environment and Heritage no later than the provision of the routing analysis.

Recommendation 17: APSC should not use helicopters as a means of transporting construction material to South Point. If APSC believes that it has no alternative to the use of helicopters, then a trial should be carefully designed and approved by Environment Australia (and other relevant authorities). After approval, the trial should be carried out with appropriate monitoring to determine the reaction of seabird colonies to helicopter disturbance. After considering the outcomes of the trial, the Minister for the Environment may provide further recommendations.

Recommendation 18: Lighting facilities must be designed in such a manner that light from the South Point facilities must not be visible in the sky over Greta or Dolly Beaches.

Recommendation 19: Strategies for lighting design and the minimisation of lighting and tall structure impacts and for the monitoring of impacts and subsequent management responses must be approved by Environment Australia as part of the Environmental Management Plan.

Recommendation 20: The management of liquid oxygen must be addressed in the Hazardous Material Contingency Plan.

Recommendation 21: All UDMH and NTO storage and transport containers (including payload fuel tanks) must be approved as safe for use under the relevant Western Australian legislation. The payload processing facility, its safety features and certification of fuel handling teams must also be approved under relevant Western Australian legislation. Where such

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 140 regulation does not currently exist, it must be developed to match or exceed world’s best practice prior to any operation involving these fuels proceeding.

Recommendation 22: APSC must monitor the impact of the ground cloud in the first five launches. Monitoring reports must include measurements on the cloud composition, temperature, dispersal and area of harmful impact. Surveys for impacts on fauna and flora must be conducted at a number of sites spaced downwind of the launch pad concerned (100m, 300m, 600m, 1km, 2km). Reporting arrangements and possible management responses will be specified in the Environmental Management Plan.

Recommendation 23: APSC must investigate and report on alternative configurations which would allow for a wider buffer zone between the launch pads and areas of natural habitat. Comment should be sought from the Minister for Environment and Heritage on the alternatives prior to the final siting decision being made.

Recommendation 24: APSC must carry out and report on measurements of launch noise for the first launch of each model of rocket so that the predicted noise levels may be verified. Distances at which noise levels are measured should be determined in consultation with Environment Australia and appropriate noise regulation authorities under applicable Western Australian law.

Recommendation 25: APSC must develop weighted sound filters for a range of target species to be agreed with Environment Australia.

Recommendation 26: A full seabird monitoring program be developed and tested as part of the Environment Management Plan to be approved by the Minister for Environment and Heritage. The seabird monitoring program must include the collection of baseline data for at least three years prior to the first launch. The monitoring program must be developed in consultation with Environment Australia and scientists recognised as having expertise in relation to both the seabirds concerned and expertise in the development of monitoring techniques.

Recommendation 27: The adaptive response management regime must be revised as part of the Environment Management Plan to be approved by the Minister for Environment and Heritage. The revised regime must be developed in consultation with Environment Australia and scientists recognised as having expertise in relation to the seabirds concerned and expertise in monitoring techniques. A significant impact upon the seabird colony such as a decline in reproductive output of seabirds at 15-30% or more of sites monitored on South Point (without a corresponding decline at control sites) must result in a suspension of the launch regime while the possible causes are investigated by a panel of avian experts appointed by the Minister for Environment and Heritage, until such a time that the panel has

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 141 determined whether further launches are possible without bringing about further decline or preventing recovery of numbers.

Recommendation 28: For any night launches conducted, APSC must carry out the monitoring program to ensure effective monitoring of short term impacts.

Recommendation 29: Monitoring proposed in the EIS for land fauna must be significantly revised in consultation with Environment Australia in the preparation of the Environment Management Plan.

Recommendation 30: An adaptive management regime must be developed for all endangered and vulnerable species present on South Point, as well as for species for which significant populations have been found in the vicinity of the launch area. The management regime must take into account recovery plans prepared for endangered and vulnerable species. The management regime must be included in the Environment Management Plan to be approved by the Minister for Environment and Heritage.

Recommendation 31: The Environment Management Plan must include a plan for how APSC will respond to the environmental impacts of a launch accident over the island. The plan must include a survey of impacts upon flora and fauna, and immediate, short term and longer term responses to minimising and remediating impacts.

Recommendation 33: APSC’s spill response plan must include effective mechanisms that prevent the contamination of Christmas Island beaches from fuel spills.

Recommendation 34: APSC should investigate means of ensuring that fairings sink soon after impact.

Recommendation 35: APSC should develop and implement recovery procedures for rocket stages as this becomes international practice for other commercial launch operations.

Recommendation 36: The Minister for Industry Science and Resources, in exercising portfolio responsibilities in relation to petroleum exploration and production and the regulation of space activities, should ensure that the potential for conflict of resource use in offshore areas be taken into account.

Recommendation 37: Launch approval should include an assessment of debris generation potential and debris mitigation options based on international best practice, but at the least including the following:

Ø The potential for orbital debris generation in both nominal operation and malfunction conditions;

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 142

Ø The potential for orbital debris generation due to on-orbit impact with existing space debris (natural or human generated) or other orbiting space systems; Ø Post mission disposal; and, Ø The potential for items to pose a safety or environmental threat upon re-entry.

Where the assessment finds that debris contributions or the risk to the environment or safety are not acceptable, additional design and mitigation measures must be implemented.

Recommendation 38: Approval for construction of the proposal should not occur until it is demonstrated that the underlying geological structure is sufficiently stable to support the proposed facilities and able to remain stable during launch activities or accidents.

Recommendation 39: The report on the survey for possible cave systems and subterranean fauna on South Point focusing on the proposed site of the Technical and Launch Complexes should be used to develop measures to avoid, monitor or remediate impacts upon these environments. These measures must be included in the Environment Management Plan.

Recommendation 40: APSC should monitor and report on launch vibration initiated rockfalls as part of the Environment Management Plan.

Recommendation 41: The Hazardous Materials Contingency Plan should include emergency response actions to be made to spills during storage as well as transportation.

Recommendation 42: A Potential Seismic Hazard Assessment should be carried out and be taken into account in the design of foundations and building structures. All fuel storage facilities should be designed to the standards required for hazardous installations.

Recommendation 43: APSC should provide information on the criteria used to set the 2 km exclusion zone around the launch site so that it may be considered in the space licence procedure.

Recommendation 44: Launch activities should not result in closure of access to the South Point Chinese Temple during religious celebrations associated with God’s Birthday and the 1st and 15th days of the Chinese New Year Period (as determined by the lunar calendar). Alterations to this restriction may only be made with the agreement of the South Point Chinese Temple Committee.

Recommendation 45: APSC, in consultation with the Temple Committee, must further analyse the potential for launches or on-pad explosions to

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 143 damage the South Point Temple and Shrines. This information should be provided to the Temple Committee so that they are in a position to evaluate the potential impacts in considering the future of the South Point Temple and Shrines.

Recommendation 46: APSC must investigate and report on alternative configurations which would allow for a wider buffer zone between the launch pads and the South Point Temple and Shrines. The Temple Committee and the Minister for Environment and Heritage should be allowed to comment on the alternatives prior to the final siting decision being made.

Recommendation 47: If the Roll-on Roll-off facility is to be located as proposed in the supplement, restrictions on maximum noise levels to be produced must be developed in consultation with the Western Australian Department of Environmental Planning and the Shire of Christmas Island. The facility should only be used during normal business hours.

Recommendation 48: Further documentation on the proposed Roll-on Roll-off facility including plans, elevations, sections, design details and a landscape plan should be referred to the Australian Heritage Commission for comment in line with Section 30 of the Australian Heritage Commission Act (1975) prior to a final decision being made about construction of the facility.

Recommendation 49: Further community consultation on the design and location of the Roll-on Roll-off facility should occur before final designs are completed. This process should be overseen by the Christmas Island Shire Council. Subject to comment from the Australian Heritage Commission on the potential impact on the national estate values, the final decision on the current proposal for the Roll-on Roll-off facility should rest with the Shire Council. If the current proposal is rejected, APSC must further examine and report on other options for the delivery of freight to Christmas Island. This analysis must be referred to Environment Australia for further consideration and possible recommendations prior to a final decision on siting being made.

Recommendation 50: The planning and design of the proposed residential and administration complex at Irvine Hill should be carried out within the context of the planning for the future of the Irvine Hill area in accordance with the Shire of Christmas Island Town Planning Scheme and give particular consideration to the integration of the complex into the existing island residential framework and siting to avoid aircraft noise impacts.

Recommendation 51: Design of the Residential and Administration Complex should reflect the existing architectural styles on Christmas Island. APSC must demonstrate that energy efficiency measures and use of renewable energy have been incorporated wherever possible into all buildings to be constructed as part of the proposal (including those at South Point).

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 144

Recommendation 52: In developing plans for the management of waste and hazardous materials, APSC must identify processes, materials and techniques to be used at the launch facility and work with regulators to ensure all efforts have been made to reduce or eliminate the generation of waste. The waste management component of the Environmental Management Plan must be approved by the Shire of Christmas Island.

Recommendation 53: APSC’s contribution to the maintenance of visitor facilities in Christmas Island National Park should be set out in the Environment Management Plan.

Recommendation 54: The Territories office should develop strategies to monitor the cumulative impacts upon infrastructure and community services of the increase in population due to the launch facility project.

Recommendation 55: The Employee Cultural Education Plan and cultural training workshops should be developed in consultation with community organisation representative of the major cultural groups present on Christmas Island. APSC should also consider the possibility of employing members of the local community to conduct all or part of the cultural training workshops.

Recommendation 56: The Community Consultation Plan must be extended to encompass mechanisms for receiving and acting on feedback from the local community and auditing this process. The final Community Consultation Plan must be developed in consultation with a wide range of local community groups and should be endorsed by the Shire of Christmas Island and Christmas Island Administration.

Recommendation 57: The final Environmental Management Plan for the proposed Christmas Island Satellite Launch Facility and associated infrastructure must be developed in consultation with Environment Australia and agencies responsible for other relevant environmental regulation. The Minister for Environment and Heritage must approve the Environmental Management Plan prior to the commencement of the construction of the project.

Recommendation 58: The granting of a Space Licence for the Christmas Island Launch Facility must be conditional on APSC complying with the recommendations of the Minister for Environment and Heritage, and in particular compliance with the Environmental Management Plan approved by the Minister for Environment and Heritage. Granting of launch permits for the facility must also be conditional upon ongoing compliance with the Environmental Management Plan.

Recommendation 59: The granting of land to Asia Pacific Space Centre Pty Ltd as either leasehold or freehold for the construction and operation of the Christmas Island Launch Facility must be conditional on APSC complying

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 145 with the recommendations of the Minister for Environment and Heritage, and in particular compliance with the Environmental Management Plan approved by the Minister for Environment and Heritage.

Recommendation 60: South Point Facilities should be decommissioned and removed from the site and preferably the island at the end of the life of the project. The South Point facility areas should be rehabilitated to a condition consistent with the surrounding natural environment.

Recommendation 61: The Decommissioning Plan should be prepared in consultation with Environment Australia.

Recommendation 62: APSC must give a legally binding commitment (enforceable by the Commonwealth) that it will, at the request of the Commonwealth, rehabilitate any aspect of the environment that is significantly damaged as a result of the construction or operation of the proposed launch facility and associated infrastructure

Recommendation 63: In the event of a launch accident over the island which destroys significant habitat, APSC must provide additional compensation measures to improve habitat on the island.

Recommendation 64: APSC should be required to lodge a security so as to reduce the risk to the Commonwealth that may be incurred by failure of the proponent to meet environmental management responsibilities.

Recommendation 65: APSC must ensure that the proposal is implemented in accordance with the commitments and safeguards identified in the Christmas Island Satellite Launch Facility Draft Environmental Impacts Study August 1999, or as modified or added to in the Christmas Island Satellite Launch Facility Final Environmental Impact Statement January 2000, and the additional information provided by APSC on 24 March 2000 unless these commitments and safeguards are superseded by recommendations made by the Minister for the Environment in relation to this proposal.

Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000