GEELONG REGIONAL COMMISSION
REPORT OF THE HEARING COMMIT I EE TO AMENDMENT NO. 6 TO THE GEELONG REGIONAL INTERIM DEVELOPMENT ORDER
DECEMBER 1978
~~ 1. 3099 452 GEE:H ,· .. ~
GEELONG REGIONAL COMMISSION
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·- REPORT OF THE HEARING ~OMMITTEE ON OBJECTIONS TO AMENDMENT No. 6 Td THE GEELONG REG)ONAL INTERIM DEVELOPMENT ORDER
~' \ , L-~------~------1( : 711. 00106487 "\ 3099 452 Report of the hearing I I GEE:H committee to amendment no. 6 to the Geelong regional interim DECEMBER' 1978 .· development order
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CONTENTS
Introduction
1.0 Sequence of Events
2.0 Response to Issues Raised by Objectors J
3.0 Conclusions 4
4.0 Recommendations 1 5 Part A Modifications Part B Policy Guidelines Part C Determination of Objections Part 0 Final Comments
Attachment "A" The I. C. I. Proposal Attachment "B" Objections to the Proposal Attachment "C" Hearing Committee - Initial Report
Attachment "D" ~1inistry for Conservation - Assessment of Point Wilson Rezoning Environmental Effects Statement
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INTRODUCTION
The following. report and its recommendations were adopted by the Geelong ·Regional Commission at its meeting on 7th December, 1978 and Notice of Approval of the Amendment appeared in the Government Gazette on 20th December, 1978 in a modified form. Modifications made by the Minister provided for the inclusion of the 11 Policy Guidel inesn as part of the statutory document (the Geelo~g Regional Interim Development Order) rather than have them adopted by the Shire and the Commission as policy as was originally intended by the Commission. No modifications were made to the map as adopted by the Commission and the final modified wording is as follows: After Sub-clause 23 (1) the following new Sub-clause shall be inserted: ''(lA) Notwithstanding the provisions of Sub-clause (1) of this clause in any of the areas defined below in the Table to this Sub-clause, the following provisions shaTl apply (a) All use and development shall be in accordance with a plan of development prepared to the satisfaction of the Responsible Authority in consultation with the Geelong Regional Commission. A plan of development shall be prepared fOr each major phase of works or building or redevelopment on such areas.
(b) The Responsible Authority may approve a modification of a previously approved plan of development where it is satisfied that the changes and layout sought are of a minor nature and are consistent with the overall concept of the plan of development. (c) In considering any plan of development or application for a permit, if the Responsible Authority determines that information on the environmental impact of the propo~ed use is required in accordance with Sub-clause (5} to this Clause, it shall seek the advice of the Minister for Conservation as to whether a Preliminary Environment Report or Environment Effects Statement should be prepared for his assessment in accordance with Section B of the Environment Effects Act 1978. (d) In considering any plan of development or application for a permit, the Responsible Authority shall have regard to (i) the protection of existing wildlife I ~ . habitats and adjoining land uses through I the layout of plant elements on the site; .•.
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(ii) the direction of polluted stormwater and waste discharges away·from~~Viron- mentally sensitive areas; ··
(iii) the bunding and sealing of s~rfac~s·ta minimise environmental damage as ~ result of accidental leakage-of liquids in processing and storage areas or other locations where such leakage~.may occur;
( i v) the protection of wildl·ife ~abitats and significant bird flight paths-duri·ng the construction and operation of plant through measures to.minimise the adverse effects of erosion, noise, lighting and high structures and structure support wires; (v) the feasibility of closing or relocating the Point Wilson Road to the Explosives Reserve to provide further.protection to wildlife habitats; (vi) the feasibility of joint management of buffer areas and adjoining .lands for their habitats; and
I I (vii) the planting and landscaping of buffer I ~reas in a manner which is consistent i with the requirements of adjacent wildlife ' habitats. Table to Clause 23 (1A) Firstly: Crown Portion B and part of Government Portion A of Section 1 part of Crown Portion A of Section 2 Parish of Murtc~in being the land more particularly descirbed in Conveyance No. 146 Book 695. Secondly: All those pieces of land being parts of Crown Portion B Section 2, part of Crown Portion A, Section 3, part of Crown Portions A and B Section 4, and part of Crown Allptment 2C Parish of Murtcain, being the whole of the land contained in Certificate of Title, Volume 8634 Folio 202." 2. In Sub-clause 23 (5) (a) there shall be added to the list of industrial purposes the· following i'ndustrial purpose, "Pet rochemi ca 1 Camp 1ex" . · · 3. Sheet Nos 5 and 6 comprising part of the Interim Development Order maps shall be varied in the manner and to the extent shown on the map attached hereto. "'
One objection lodged by the Amendment by the Barra Group Pty. Ltd. was not heard by the. Hearing Committee. This objection was disallowed by the Corruniss-ion. ..
GEELONG REGIONAL·COMMISSION
Report of the Hearing Committee on Objections to Amendment No. 6 to the Geelong Regional I~terim Development Order
1.0 SEQUENCE OF EVENTS
1.1 This report considers the proposal by I.C.I. Australia Limited ·to establish a major petrochemical complex at Point Wilson, on the north shore of Corio Bay, and the consequent proposal by the Geelong Regional Commission to zone land at Point Wilson for ·industrial use to permit the I.C.I. project to proceed. The I .C. I. proposal is summarised in Attachment A. 1,2 ·J.C.I. Australia Limited requested the Geelong Regional Commission, on 16th January, 1978 to amend the Geelong Regional Interim Development Order to provide for an industrial zone or a special use zone over the 766 hectares (1,891 acres) Karr~rra Grazing Company property at Point Wilson. I.C.I. at that time·had purchased the property. (which was zoned Rural {_General Farmi.ng)}, on a con ditional basi.s. ·. 1.3 This formal request followed some weeks of preliminary discussions between I.C.I., the Commission, the Shire of Corio, the Geelong Water and Sewerage Trust and other relevant agencies. 1.4 At its meeting on 26th January, 1978 the Commission resolved to place on exhibition as Amendment 6 to the Geelong Regional Interim Development Order the proposed rezoning of land at Point .Wilson from Rural (General Farming) to Industrial "B", with an . 80 metre reserve of Proposed Public Open Space along the eastern ·and southern foreshores of the site, intended to protect public rights and interests in the foreshore areas. The proposed rezoning was placed on public exhibition in accordance with Section 17 of the Town and Country Planning Act 1961, from February 1, .1978.
1.5 During the calendar month ~f the period of exhibition, a variety· of objections to the proposed tezoning wer~ received and most objectors requested that their objections be heard, as provided for under Section 28 of the Town and Country Planning Act, 1961. 1.6- At its meeting of 30th March, 1978 the Commission resolved to establish a panel of five Commissioners to constitute a committee to hear objections to the proposal. The nominated Commissioners were: - 2 -
Commr. R. Beckley (Chairman) Commr. W. McCann Commr. W. Whiteside Commr. B. Backwell Commr. B. D'Arcy 1.7 The Hearing Cgmmittee reviewed the objections received, and arrangements were completed for a hearing on May 5, 1978. The Minister for Planning was asked by the Commission to direct the Commission to take into account a number of late objections, and the appropriate direction was issued on 11th April, 1978. 1.8 Objections were heard on 5th May, 1978 with most objectors providing detailed and informative supplementary submissions to support their lodged objections. The objections are summarised in Attachment B. 1.9 Having heard the objections the Hearing Committee prepared an interim report which was presented to the Commission at its meeting of 27th July, 1978, and which concluded, among other things, that the Commission should seek an Environmental Effects Statement on the proposed development, as provided for in Clause 8 of the Environment Effects Act 1978. A copy of the Committee's conclusions at that time is included as Attachment C. 1.10 The Environment Effects Act provides that, once requested, the proponent of a development project shall prepare an Environmental Effects Statement which can then be made available for public comment. In the case of I.C.I. Australia Limited, a report titled "Point Wilson Rezoning, Environmental Effects Statement" was prepared under the general supervision of the Ministry for Conservation, the Commission, and the Town and Country Planning Board, and was made available for public comment for one month from 11th September, 1978. 1.11 The Minister for Conservation has responsibility for preparing an assessment of the Environment Effects Statement, taking into account any public comments received. Comments on the E.E.S. prepared by ICI were forwarded to the Minister for Conservation by a number of public agencies, interest groups and individuals, most of whom had previously lodged objections to the rezoning. 1.12 On 8th November, 1978 the Minister for Conservation wrote to the Chairman of the Geelong Regional Commission enclosing a copy of the·Ministry's assessment of the Statement, and seeking consideration of the conclusions of the.Ministry's report when decisions are made about the proposed rezoning. The Ministry's report, incorporating a summary of comments received on the Environmental Effects Statement, is included as Attachment D. 1.13 During the period following the hearing of objections in May, ICI Australia Limited also completed a study of the archaeology of the Point Wilson site, and the first stage of a major avifauna study of the site and its environs, particularly the Spit. The reports of these studies are available for inspection. - 3 -
1.14 The responsibility of the Geelong Regional Commission 1 s Hearing Committee, having the benefit of the original ICI rezoning proposal; the objections lodged to Amendment 6 to the Geelong Regional Interim Development Order; the Environment Effects Statement; the public comments on the E.E.S.; the Ministry of Conservation 1 s.report on the E.E.S. and the public comments; the supplementary studies; and other relevant background research and material, is· to recommend to the Geelong Regional Commission whether the· objections lodged to the proposed rezoning should be allowed; allowed in part; or disalloWed; and what action the Commission should take in respect of Amendment 6. - 4 -
2. 0 RESPONSE TO ISSUES RAISED BY OBJECTORS· 2.1 In its fnterim report to th.e Gee long Regional Commission on' 27th. July 1978, the Hearing Committee set out the main issues raised by objectors to the rezoning, as follows: (i) The need for a petrochemicals complex and more particularly the desirability of permitting the develop ment of a complex which will inevitably increase the direct and indirect consumption of resources inside and beyond the region, with particular regard to sources of raw materials, fuels, power and water. (ii) The location of the complex in the "buffer" between Melbourne and Geelong, and the possibility that it will stimulate further demand for development in the immediate vicinity and further reduce the buffer. This includes ·general concern over the loss of a large area of open, undeveloped land. (iii) Protection of the flora and fauna of The Spit and other nearby habitat areas from disturbance by construction activity, plant process noise, airborne or waterborne emmissions·, traffic noise and physical intrusion, or other adverse impacts. (iv) Protection of the waters of the Bay from pollution, either through discharge of wastes ~o the Bay or accidental spillage of materials. (v) Provision of access to the site for vehicles and for other services (rail, power, pipelines). (vi) The possible effects of any airborne effluent on the activities of the Melbourne Metropolitan Board of Works Sewerage Farm. (vii) The intrusion of physical structures into the migration paths of birds. (viii) The location, extent of and access to open space zones and other buffer areas between the plant and the shore line, or the plant and habitat areas su~h as· The Spit. (ix) The methods of disposal to be used by I.C.I. in disposing of waste products and the standards to be set by the Environment Protection Authority for effluents discharged to the environment. (x) The impact of the project on employment, unemployment and business activity in the Region.
2.2 Most of these issues related to the environmental effects of the development on and around the site, and it was these concerns which resulted in the Committee's decision to recommend that the Commission.request an Environmental Effects Statement. - 5 -
2.3 In so doing the Committee also recommended certain modific.ations to the zo~ing proposal and ather on-sit~ constraints within which the ehvironmental assessment should be undertaken, and als6 ~et down a number of environmental objectives. These were:
safeguarding the wildlife sp~ties and habitat in The Spit area and nearby foreshores; avoiding interference with bird flight paths across the site, particularly with high structures involving supporting guys, or other elevated wires and masts; minimising visual intrusion of the plant, particularly from Corio and Port Phillip Bay; retaining foreshore. areas· for conservation purposes; maintaining airborne plant emissions within chemical groups and levels as specified by the appropriate Environment Protection Authority licenses; .. maintaining and treating waterborne wastes and. effluents so as to avoid pollution of the surrounding environment and the Bay areas as provided for by the appropriate licenses issued by the En~ironment Protection Authority; creating a development which is as far as possible an environmental as well as an economic asset to the Geelong Region and the State.
2.4 Ptits meeting on 26th July, 1978 the Commission accepted the Committee's conclusions and recommendations, and, after receiving advice from the Minister for Conservation, formally requested the preparation of the Environmental Effects Statement. The work which has been completed since that ·time, including the comments made on the E.E.S. and the further advice of the Ministry for Conservation, now enabl~s the Committee to respond to the issues raised by objectors in more detail.
2.5 It· should be noted that the ~1inistry for Conservation summari.sed its findings relating to objections to the proposal, as follows:
"The major concern associated with the project is the possible incompatibility of a major petrochemical complex being sited adjacent to a ~roposed State Wildlife Reserve. The Wildlife Reserve and its adjacent foreshore being the most important feeding ground for migratory waders in Victoria as well as one of the few known winter refuges .of the endangered Orange-bellied Parrot. 6
''If the development is to proceed, the safeguards relating to discharges to air and water, landscape, public access, construction, structure desi·gn and off-site servi~es which are.discussed in this assessment, together with the safeguards outlined in the Statement (under flora, solid wastes and archaeology) should be incorporated in the rezoning proposal and detailed design of the complex. In . addition the conclusions of the Hearing Committee for Amendment No. 6 that are outlined in Appendix 1 of this assessment are fully supported.
"Finally a committee comprising representatives of Fisheries and Wildlife Division, Melbourne and Metropolitan Board of Works, Geelong Harbor Trust and ICI should be set up to manage The Spit area, buffer strip (set back) areas adjacent to it and the coastal reserves."
2. 6 Against this background the Committee makes the following comments on issues raised by objectors. 2. 7 The need for a petrochemicals complex. The Ministry for Conservation has taken the view that 11 the economic justification for constructing a petrochemical plant on the proposed site is a matter for the company concerned." The Committee agrees that this is qenerally so, and considers that the interest of I.C.I. and other major petrochemicals producers in establishing a major plant. is sufficient . evidence of the potential for at least one such plant to rneet Australia's requiremer:~ts over the next two to three decades and possibly beyond.
2.8 .In relation to the issue of consumption of scarce resources (raw materials, fuels, power and water) the Committee takes the view that, apart from water resources, such materials will be required by the petrochemical industry regardless of location, and have little regional impact. Petrochemical feedstocks will be consumed while they are available and at a rate supported by the market and/or by related governmental decisions at a national and inter national level. Raw materials such as salt are readily available and can be produced with low technological investment. · Fuels and power for plant operations will be required regara1ess of location, and fuel availability in particular will be determined by market factors operating in a context of national and international government policies. Victoria is in any event well placed to provide gas, coal and electric power for industrial production. 2.9 In the case of water, however, there are important regional effects which must be considered .. ICI's proposed total consumption of water for all purposes will reach some 10,000 ml. p.a. in the 1990's. Work undertaken by the Geelong Waterworks and Sewerage Trust and ICI to supplement the statements in the E.E.S. indicates that, if 50% of this supply is provided from the Geelong ~Jaterworks and Sewerage Trust supply systems (the remaining 50% coming variously from potential ground water sources, M.M.B.W. or other waste water, - 7 -
and from the Bay), then there would need to be a number of changes ~ ·in both the planned capacity and timing of headworks and m~jor elements of the reticulation system, as well as a number of new facilities specifically to service the ICI site. 2.10 In particular the ICI project increases the urgency of the Gellibrand River development as the next major source of water supply to Geelong and elsewhere. 2.11 A number of f.eeder mains to the west and north of the city which are either existing or planned would require either augmentation or advances in priority of associated works such as booster pumps, to ensure supply to ICI. The Committee considers that negotiations on the nature and basis of ICI's contribution should be commenced as a matter of urgency. 2.12 The E.E.S. and the supplementary work undertaken by ICI and the GWST clearly indicates that it will be necessary for supplies beyond 4,000 ml. p.a. to be drawn from secondary sources~ ground water, re-used waste water from. the MMBW sewerage farm or elsewhere, or sea water. ·The Committee considers that it is of major importance to the Region as a whole that such sources of supply be utilised, so that ICI's dependence on the GWST supply system is minimised. 2.13 An investigation should be commenced to determine:
the avai 1abi 1i_ty, quantity and. qua 1i ty of groundwat~r on or near the ICI site. the availability, suitability and methods of treatment of waste water from the MMBW sewerage farm. the extent to which use of sea water is feasible. 2.14 This investigation should consider not only the supply of industrial grade water to ICI, but also the possible supply of water from such secondary sources to other industries iri the area. The GWST, the GRC, ICI and the Shire of Corio, should participate in the study together with any other appropriate bodies. 2.15 The commitment of a substantial share of the Region's water resources . to this major project could reduce the scope for supply of water either to alternative possible industrial developments, or to future urban expansion. This depends, however, on the extent to which industrial quality supplies from secondary sources can be used to replace town water currently used by existing industries, or to ·serve other future industry. -----~-
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2.16 Gene.rally, there is lit.tle·doubt that provid~d the·Gellibrand River development is commenced in the very near future, water will be available to meet I.c.r·s·needs. rcr•s plant·is planned·-to·commence initial operations as early as 1985, by which time ~at~r would need to be available in significant quantities. To avoid shortfalls elsewhere in the Geelon~ system due to rcr•s heavy Water ~sage, supply augmentation must be substantially achieved by that time. The support of the State Government in achieving this objective is essential. 2.17 The intrusion of development into the Geelong-Melbourne •buffer•. The Committee considers that an effective and permanent buffer between Werribee/Laverton and Geelong is a necess~ry feature of development in the western Port Phillip Region and should be a matter of stated Government policy. 2.18 Development of Point Wilson poses no direct threat to the •buffer• in that the site is surrounded by large areas of publicly owned and controlled land in committed long-term uses - the Melbourne Metropolitan Board of Works Farm, Avalon Airfield, the Explosives Reserve - which, because of their public ownership and bro~d-acre .,1 . character, will not become locations of intensive dev~lop~ent. 2.29 However, the ICI project obviously involves a major change of land use in an area related to, if not central to, the buffer, and should not be a precedent for further urban or industrial development north of Lara to the east or west of the Princes Highway. This situation is already clearly reflected in the Geelong Regional Planning Scheme, and should be a matter of stated planning policy for the Commission, and form a feature of any regional strategic plan. 2.20 Adequate opportunity exists elsewhere in the northern parts of urban Geelong for any new industrial and other activities related to the ICI project. In terms of housing, capacity exists in the Lara, Corio and Lovely Banks areas for substantial growth in population. 2.21 Protection of the flora and fauna of the Spit and other habitats. This issue is central to the objections to the development, and was a major reason for seeking an Environmental Effects Statement. There is no doubt that as the ICI project proceeds, sources of disturbance to flora and fauna in the area will arise. There will of course be variations in the extent to which this occurs, between the various phases of plant construction and operation.
2.22 The central issues have been the extent to which these changes will impact upon flora and fauna in the area; whether or not such impact will·be harmful; and whether once in operation the activities of the plant can exist harmoniously within the present environment.
2.23 The Ministry for Conservation has identified these issues in its conclusions as follows:
11 The major concern associated with the project is the possible incompatibility of a major petrochemical complex being sited adjacent to a proposed State Wildlife Reserve ..... being the most important feeding ground for migratory waders in Victoria as well as one of the few known winter refuges of the endangered Orange-bellied Parrot ... 9
2.24 The Ministry identified a number of steps which should be taken to protect avifauna and their habitat from any adverse eftects ot the plant's development and operation, and this Committee is satisfied that in accordance with the assessment made by the Ministry, provided adequate controls are designed and put into effect covering: exclusion of portions of the site from development and access; . flora and fauna management programs; adequate development buffers; controls on emissions and waste discharges; controls on construction, erosion and run-off; controls on traffic movement and noise; then the habitat areas and their dependent species will not be endangered, and may in fact be enhanced as grazing and other disruptive activities cease and habitat restoration commences. The Committee's recommendations reflect this view. 2.25 The Orange-bellied Parrot. Many objectors expressed concern regarding the impact of the project on the endangered Orange-bellied parrot. ICI undertook an extensive study of the parrot and other birdlife in the area as part of the EES, and the progress report of the first stage of this study is separately available. 2.26 The study was made by a team of three avifauna experts who worked in the area on a daily basis from July 1978 onwards. In the case of the Orange-bellied parrot the study report states: "Regular observations of the Orange-bellied Parrot were made ... in the Point Wilson area from July through to early October . . . . . The times of observation and areas of observation were varied to provide broad coverage of daily patterns of movement as well as a wide areal view of parrot locations". 2.27 ·The study of the parrot will continue, with the team visiting Tasmania during the summer to observe the bird in its assumed breeding areas. The Ministry of Conservation has proposed that: "The avifauna study currently being undertaken should be of at least two years duration in an attempt to cover seasonal and climatic variations " The Committee supports this proposal. 2.28 The study identified the feeding,movement and other behavioural patterns of the parrot, and locates the significant habitat areas used during the period of observation. It proposes a number of preliminary habitat management considerations which would protect habitat areas and reduce disturbance to the parrot. 2.29 These proposed measures include: r~s~riction of access by people to the principal habitats (Samphire shrublands) to scientific study and occasional .organised naturalist trips only. reducfion.of grazing. reduction of the rabbit population 10
2.29 cont. removal of predators, particularly foxes reduction of traffic along the Point Wil~on Road restoration of tidal flow patterns further investigation of the location and intensity of on-site· lighting. wide buffer areas between the saltmarsh and any industrial development including setback of buildings maintaining a variety of habitats.
2.30 The Committee considers that these measures and others identified by further study should become basic guidelines for the'planning and management of any development on the site. Provided this is done, the habitat areas, and the parrot, as well as other birds, could be well protected, and indeed the secu.ri ty of bi rdl i fe could be enhanced. The immediate cessation of shellgrit mining in the area should also be sought. The Point Wilson Road should if possible be closed, and physically removed where it crosses the Spit wetlands to the north of the ICI boundary. In accordance with the conclusions of the Ministry of Conservation_, alternative access routes to the Explosives Reserve should be the subject of negotiations between ICI, MMBW and the Commonwealth, assisted as necessary by the Shire of Corio and the Commission. ·
2.31 Protection of the Bay. Objectors expressed concern that Port Phillip Bay and Corio Bay would become further polluted as a result of ICI•s operations. There will be a need for the discharge of treated site effluents to the Bay, but the quality, quantity and ~anner of disposal of $UCh effluents will be subject to Environment Protection Authority licensing. It must also be seen in the context of E.P.A. action in respect of other pollution sources affecting the Bays, given that upper limits for pollutant levels in the Bays are set as poli~y. · 2.32 However, the E.E.S. identifies potential levels of water discharge to the Bay, and the proposed methods of dispersal which the Ministry of Conservation have reviewed. The Ministry in turn considers that discharges to the Bay, within appropriate license conditions, are acceptable. 2.33 Any proposals for the use of the Bay area for shipping products to and from the ICI site,. including modifications to port and wharfage facilities, would be expected to be the subject of further environ m~ntal study, and this would in turn cover the issue of the possible effects of accidental spillage of transported raw materials and products. 2.34 In addition, the Ministry is satisfied that measures such as construction of retarding basins and the diversion of contaminated run-off to appropriate treatment facilities should ensure that the water quantity and quality entering the Spit is such as to maintain the habitat value of the Spit. The Committee, agrees with. this view. 11
2.35 Provision of access to the site. Objectors were concerned tha~ · access to the s 1te for de 1 i ve r·i es dntl u Lher Lra'ff·i c, and for services, would affect the Spit and other wildlife habitats. The Committee considers that all access should be via Dando's Road and/ or Government Road, and that the location of any future service corridors can be such as to readily avoid any sensitive areas. In any event, separate environmental investigations will be required for major service connections- power, rail, pipeliries, etc .. · 2.36 In addition, discussions should proceed with the Geelong Harbor Trust and persons holding licenses for boat moorings offshore from the site .to review the provision of such moorings. 2.37 Effect of airborne effluents on the Melbourne & Metropolitan Board of Works Farm. The MMBW stated their concern that airborne effluents from the ICI complex might adversely affect their farm operations through destruction of micro-organisms. The EES indicates that this is not a major risk and the MMBW in their comments on the EES appeared satisfied that, with proper monitoring programs and EPA licensing of discharges, there would not be difficulties. 2.38 The Ministry for Conservation is also satisfied that measures can be undertaken as a result of EPA licensing and location of plant elements, which will ensure that MMBW farm activities are not jeopardised by airborne contaminants. The Committee accepts this assessment. 2.39 Effects on bird flight paths. The ongoing study of bird movements across the site ensures that adequate information is/will be available on flight paths to allow site and plant planning to avoid ~ajor conflict~: 2.40 Most flight paths, from data already available, appear to be at heights well above likely plant heights. The Committee considers that the location, height, support structures, colouring and lighting of plant can be readily and adequately controlled to avoid conflict with bird movements, and building setbacks as recommended by the Ministry of Conservation can also be put into effect. 2.41 The location, design and operation of any elevated flares will need to be considered in this context when development plans for the site are under consideration. 2.42 Location, extent, and accessibility of buffer areas. Objectors frequently requested the provision of buffer zones between the plant and habitat areas, particularly the Spit, with suggestions as to appropriate widths ranging from 30 metres to 500 metres. Opinions were varied as to the extent and nature of ownership, and public access to such buffer areas, with many objectors seeking some form of public management, particularly of the Spit area. 2.43 The Committee considers that the proposals put forward in its interim report, providing buffers of 200 metres to 500 metres around the Spit, and 80 metres along the foreshores, have been shown by the results of the EES and the comments thereon, to be generally adequate. However, a number of modifications are recommended, as follows: - 12 -
2.43 cont. ... The Ministry of Conservation has raised some doubts as to the adequacy of the setbacks along the eastern shoreline of the site, and the Committee considers that the 80 metre open space buffer should be widened, as set on the modified rezoning plan, and a further building setback is desirable, to ensure that no major structures are created within 150 metres of the shoreline at any point, not within 200 metres in most locations. Immediately south of the Spit, the 200 metre building line should be slightly varied to ensure that all the presently vegetated areas of the Spit catchment remain within the buffer zone. Special provisions should be made to protect the other minor habitat areas identified by the Ministry for Conservation in the north, north-east and east of the site. This has been done through their designation as Areas of Special Significance. 2.44 The Committee considers that these provisions together with the establishment of a formal management agreement for buffer areas, will adequately protect those areas and their surrounds. The management agreement should be part of a wider management program for the Spit area, under the auspices of a committee as suggested by the Ministry for Conservation. The Hearing Committee believes however, that membership of this Management Committee could be wider than that·. suggested by the Ministry and could include reoresentation from amonq the following organisations: Royal Australasian Ornithologists Union Fisheries and Wildlife Division Melbourne and Metropolitan Board of Works Geelong Harbor Trust I.C.I. Australia Limited Department of Transport Shire of Corio 2.45 The Committee does not consider public ownership of buffer zones to be necessary, but proposes that they be zoned Rural (Conservation). Public access to buffer areas should be restricted, with the extent of restrictions forming part of the overall management policy for the Spit and eastern foreshore areas. The areas zoned Public Open Space (Flora and Fauna Reserve) are to pass into public o~nership. A legal· agreement to facilitate this transfer is being prepared. While these areas may initially come under the ownership of the Geelong Regional Commission, they should as soon as practicable be passed over to the body which becomes the owner of the proposed Spit Reserve. 2.46 Methods of Waste Disposal. Objectors expressed concern that ICI may not adopt adequate methods for the disposal of plant wastes and other site effluent, and that EPA licensing was not an adequate safeguard.
2.47 The Committee is satisfied that proper technology will be used on site and that EPA licensing of air emissions, liquid discharges, and solid waste disposal sites will provide adequate controls. - 13 -
·2.48 Impact on Employment. Some obj~ctors questioned the benefits of the ·- project in terms of employment opportunities created in the Region. The Committee considers ·that the establishment over time of up to 1,200 new jobs _will provide a major opportunity for people within the Geelong community to receive specialist training to meet the skill needs of the complex, or to take up jobs if they already have the required skills. The multiplier effects of the project in terms of other servic~s required and jobs indirectly created will also be important. Certainly the Committee believes that it is fundamental that ICI seek job applicants from within the Geelong labour market, and that discussions take place between ICI and .the principal Geelong Educational Institutions regarding desirable training programs. - 14 -
. 3.0 CONCLUSIONS 3.1 The Committee concludes that the Environment Effects Statement, the public comments made upon it, and the assessment by the Ministry for Conservation establish that the proposed ICI petrochemicals complex can be planned, developed and operated at the Point Wilson site in such a manner as to avoid environmental effects of sufficient magnitude to justify refusal of the rezoning. 3.2 In reaching this conclusion however, the Committee has set out in its recommendations a considerable number of constraints and conditions which it believes must be applied to the development to ensure that an environmentally acceptable project is achieved and that environmental values are protected into the future. 3.3 The Committee is confident that ICI Australia will pursue the develop ment of the site with full consideration for the environment and wildlife habitat in the area. However, because of the very general nature of existing provisions relating to land zoned Industrial B under Geelong 1 S statutory planning controls, the Committee has recommended that the Commission modify Amendment 6 as exhibited to include changes to the Geelong Regional Interim Development Order to ensure that planning controls affecting Point Wilson relate specifically to the intended development. In particular the Committee has recommended that site development proceed only in accordance with approved plans of development prepared to the satisfaction of the Shire of Corio in consultation with the Commission, and where necessary, only after further environmental investigation. 3.4 In recommending that the Commission adopt these conditions as a necessary part of the rezoning, the Committee considers that the way will be open to allow the development of a major petro-chemical plant from a 11 green-fields 11 situation which will incorporate sophisticated envrionmental control processes and equipment. 3.5 Finally, the Committee concludes that it is essential to the preservation of the Spit area and environs that the proposed Management Committee of interested parties be formed with responsibility for the existing and proposed Crown Land around the Spit area as well as the 11 buffer 11 setback areas within the site. Negotiations to establish this Committee should be commenced by the Geeiong Regional Commission at the earliest practicable opportunity. - 15 -
RECOMMENDATIONS PART A - MODI FI C/\TION OF- 1\Mt:NDME:NT NO. 6 TO THE GEELONG REGIONAL INTERIM DEVELOPMENT ORDER
4.1 The Hearing Committee recommends to the Geelong Regional Commission that, following objections to Amendment No. 6 to the Geelong Regional Interim Development Order, the subsequent Envrionment Effects Statement and the report of the Ministry for Conservation, the Commission adopt Amendment No. 6 with the following modifications, in accordance with the provisions of Sections 17 of the Town and Country Planning Act 1961. 4.2 The Committee has set out on the attached Zoning Plan for the Point Wilson site its recommended modifications to the zones and zone . boundaries exhibited as Amendment No. 6. These modifi~ations include:
reduction of the area~of Industrial •s• zoning adjacent to the Spit. increase to the area zoned Public Open Space (F) on the eastern foreshore of the site. introduction of Rural (Conservation) zoning in buffer areas to the Spit. introduction of two Area of Special Siqnificance desiqnations on two minor sites of value w~thin the Industrial •s·-zone. 4.3 In addition, the Committee recommends that Amendment No. 6 be further modified by the inclusion of a Clause to be inserted as.Clause 23 (1A) in the Geelong Regional Interim Development Order a.s follows:
.. Notwithstanding the prov1s1ons of Sub-Clause (1), in the area defined below in the Table to this Sub-Clause, the following provisions shall apply: (a) Land shall not be subdivided except with the permission of the Geelong Regional Commission; (b) No development shall be permitted other than in accordance with a plan of development prepared to the satisfaction of the Responsible Authority in consultation with the Geelong Regional Commission; (c) In considering any such plan of development the Responsible Authority shall determine, in consultation with the Geelong Regional Commission, if the ~rovisions of Sub-Clause (5) to this Clause shall apply and if so shall request the preparation of a preliminary Environment Report in accordance with Clause 8 of the Environment Effects Act, 1978. - 16 -
(d) Such plan of development and any accompanying· Environment Effects Report or Statement shall be for the purpose of a decision by the Responsible Authority on the issue of a planning permit. Each pla~ of development should therefore be concerned with major expansions of site operations and not with alterations within an existing approval plan_ of development which do not breach the intent of such approved plans or of permits issued. TABLE TO CLAUSE 23 (1A) Firstly: Crown Portion B and part of Government Portion A of Section 1 part of Crown Portion A of Section 2 Parish of Murtcain being the land more particularly described in Conveyance No. 146 Book 695. Secondly: All those pieces of land being parts of Crown Portion B Section 2, part of Crown Portion A, Section 3, part of Crown Portions A and B Se~tion 4, and part of Crown Allotment 2C Parish of Murtcain, being the whole of the land contained in Certificate of Title, Vo 1 ume 8634 Fo 1 i o 202. 11 4.4 The purpose of these Ordinance provisions is to ensure a degree of continuing oversight of the long-term development of the Point Wilson area, without requiring ICI Australia Limited to seek planning permission for minor works. Changes of technology or patterns of demand will, over the long term, result in changing production pro cesses or elements, and these need to be regularly reviewed in an environmental context as part of the process of considering whether or not planning permission for major new stages should be granted. 4.5 The zoning changes recommended by the Committee reflect the environ mental studies undertaken since Amendment 6 was exhibited. The changes are discussed in more detail below. 4.6 Public Open Space Reserves. Amendment 6 as exhibited provided for an 80 metre (approx.) Public Open Space (F) reservation (F =flora and fauna reserve) along the eastern and southern foreshores of the site. While the Committee considers that the reservation along the .southern boundary is adequate, it has recommended a considerable extension of the reseryation along the eastern foreshore, in accordance with objections received, and the views of the Ministry for Conservation. 4.7 The minimum width of the new Public Open Space reservation on the eastern foreshore is 100 metres, while its maximum width in the vicinity of the Spit is almost 250 metres. A further 50 metre strip zoned Rural (Conservation) has been recommended inland from the Public Open Space reservation (inside the future ICI title boundary) to create an additional set-back of development from the foreshore.
4;8 Buffer Areas to the Spit. Amendment No. 6 provided for a continuous building line set back 80 metres from the ICI title boundary on the northern and north-eastern boundaries of the site adjoining the Spit. The Committee recommended modifications to these building lines in its interim report. - 17 -
4.9 The Committee now recommends, as indicated on the attached Zoning Plan, that Rura 1 (Conservation) zones be introduced in addition to these building lines, extending to a width of 200 metres along the northern ICI boundary at the southern end of the Spit, and to a w·idth of half a kilometre along the north-eastern ICI boundary west of the Point Wilson Road. 4.10 These changes . will provide.for effective planning and manage ment of these important buffer areas. Only minor works are permitted in Rural (Conservation) zones, s~ that no active industrial plant could be deve 1oped within these bu.ffers. The Committee considers that the buffer areas are sufficient to avoid the effects of noise, traffic, dust, heat, other ground level emissions, and physical intrusion on the sensitive habitat areas, and also that they reflect the views of most objectors on desirable buffer zone widths. 4.11 The areas zoned Rural (Conservation) will remain in ICI ownership, but their management will form one part of the role of the Management Committee recommended elsewhere, to ensure continuity of landscape and habitat management between the Conservation zones and the ~djoining Public Open Space reserves. 4.12 Areas of Special Significance. One smaller habitat area on the site, together with the old Point Wilson homestead area, are designated Areas of Special Significance to afford them a measure of protection and consideration at the planning permit stage. · PART 8 - POLICY GUIDELINES 4.13 The Committee considers that the following policy guidelines which arise from the E.E.S., public comments, the Ministry's assessment, the Committee's own interim report and elsewhere, should be adopted by the Commission as the basis for consideration of any development plans submitted for approval by ICI. In addition, the Committee considers that the guidelines should be presented for consideration and adoption by the Shire of Corio. 4.14 The guidelines are as follows:
( i ) The layout of the plant elements on site should protect the existing wildlife habitat as well as uses carried out on adjoining lands. In particular all chlorinated hydrocarbon plants should be located to the west of existing Point • Wilson Road and all plants with potentially noxious emissions should be located as far to the south of the site as possible .
. { i i ) Polluted stormwater and waste discharges should be directed away from environmentally sensitive areas (especially the Spit area). However current drainage patterns should be maintained in both quantity and quality where they contribute towards the well being of birdlife habitat and·the general environment. Bunding and sealing of surfaces to prevent environmental damage as a result of accidental leakage of liquids should be carried out in processing and storage areas, or other locations where leakages might occur. - 18 -
.· (iii) During site construction, earthworks should proceed under guidelines agreed with the Soil Conservation Authority to avoid erosion, and drainage of eroded materials to the Spit and other sensitive areas. Noise controls should be established for construction activities. (iv) Measures to protect the significant bird flight paths identified in the Avifauna Study should be undertaken during both the construction and operation of the plant, including measures to eliminate adverse effects of noise, lighting, high structures and structure support wires on bird flight paths. (v) Design and location of structures and lighting should take full account of visibility of the works in the landscape. (vi) The Point Wilson Road to the Explosives Reserve should if possible be closed and physically removed where it passes through the Spit wetlands to the-north of the ICI site. Negotiations with the Department of Transport and MMBW should proceed on this basis, with the assistance of the Commission and the Shire of Corio if necessary. (vii) All site access shall be via. Dando's Road/Government Road. (viii) A Management Committee should be established with responsibility for integrated planning and management policies for the Spit area, buffer areas adjacent to it, and the coastal reserves, as proposed by the Ministry for Conservation. The Committee could consist of representation from among the following organizations: Fisheries and Wildlife Division Royal Australian Ornithologists Union MMBW Commonwealth Department of Transport Geelong Harbor Trust • Shire of Corio ICI (ix) The principal purpose of the Committee should be to assist the long-term protection of the Spit and adjacent areas as important wildlife habitats. (x) Access to the Spit, adjoining foreshores and buffer areas should be restricted to persons engaged in scientific study and to occasional visits by naturalists as agreed by the Management Committee. . - 19 -
. (xi) .Buffer areas are to be treated as important bird habitat locations and managed on ~ basis agreed with the Management Committee. Programsof planting and landscaping shouldbe agreed and undertaken for both the Public Open Space Reserves and the Rural (Conservation) zones. (xii) The Avifauna Study· currently under way should continue for at least two years and its findings should be considered as a basis for management decisions by the Management Committee. PART C - DETERMINATION OF OBJECTIONS
'4.15 The Committee recommends that the Commission, in accordance with Section 28 of the Town and Country Planning Act 1961, determines objections received to Amendment No. 6 to the Geelong Regional Interim Development Order, as follows:
Objection by Recommended Determination 1. ICI Austrlaia Ltd. Allow 2. Royal Australasian Ornithologists Union Allow in part 3. Fisheries and Wildlife Division· Allow in part 4. Bird Observers Club Allow in part 5. Geelong Environment Council Allow in part 6. Port Phillip Authority Allow in part 7. Geelong Field Naturalists Club Allow in part 8. Conservation Council of Victoria Allow in part 9. Victorian Field and Game Association Allow in part 10. Melbourne and Metropolitan Board of Works Allow in part 11. P. G. Brown All ow i n part 12. B. Elstone Allow in part 13. I. Penna Allow in part
4.16 A further objection lodged by the Barro Group of companies has not been considered by the Committee as it was lodged only two days before the Hearing. A separate paper has been prepared for the Commission on this objection. PART D - LEGAL AGREEMENT
4.17 That the Commission enter into a legal agreement with ICI Australia for the purpose of facilitating the transfer of those areas zoned Public Open Space - Existing - F - on the adopted Amendment as modified. Also, that the Commission pay the sum of $2 for such land.
PART E - FINAL COMMENTS
4.18 The Committee wishes to express its thanks for the contri~utions of objectors, and for the work of the Ministry_for Co~ser~at1on a~d of ICI Australia Limited in providing the Comm1ttee w1th 1nformat1on and assistance whenever this was sought. Many other government and private organisations have also contributed to the work of the Committee and assisted significantly in the development of these conclusions and recommendations. Their help is al.so gratefully .acknowledged. ATTACHMENT "A". Al.
THE I.C.I. PROPOSAL
Introduction ICI Australia Limited completed the purchase of 766 hectares of land at Point Wilson, Victoria in March 1978 with a view to developing the ~roperty as a major Australian chemicals manufacturing site. The company had already lodged an application with the Geelong Regional Commission for the zoning of the property to be changed from Rural (General Fq,rming) to Industrial "B". ICI described its proposal in two reports. On 18th January, 1978 the company issued its first report, "Point Wilson Development: Outline of Proposal", and presented additional information on 20th April, 1978. The following description of ICI Australia's application is a summary of these two reports.
The Proposal It is proposed that a petrochemical complex will be constructed and operated as an extension of the company's existing operations at Botany in New South Wales. ICI plan to begin construction in 1981 and complete the first operating units by 1985. The site is intended for use for the production of petrochemicals and some heavy chemicals, as set out below:- Petrochemicals Ethylene Polythene Ethylene Dichloride Ethylene Oxide and derivatives Polypropylene P.V.C. Vinyl Chloride Monomer Chlorinated Solvents and by-products which would stem from these processes Heavy Chemicils - Caustic Soda Chlorine The major raw materials that would be required are: (a) Naphtha a liquid petroleum product similar to kerosene which is used in large quantities in the production of ethylene. Naphtha would be brought to the site by pipeline from an oil refinery or by sea tanker. (b) Propane (LPG) a gas used in the manufacture of ethylene. It would be brought to the site via sea or road LPG tanker, or by pipeline. · (c) Industrial Salt this would be required in large quantities to ~ake. b~ine from whith chlorine and caustic soda are made. The consumption of salt would far exceed the capacity of the Lara . salt field, and thus requiremerits would be met from salt fields elsewhere and brought· to Point ~~ilson by ship, rail ·or road. I . A2.
(d) The processes contemplated at Point Wilson would· consume substantial quantities of electric power, fresh-water and natural gas.
The Site Location: ICI Australia's property is located at Point Wilson, Victoria. The land is bounded by the Commonwealth Explosives Reserve, the Melbourne and Metropolitan Board of ~Jorks sewerage farm, Avalon Airfield, Cheetham Salt Works and Port Phillip Bay, which together completely buffer the site. · Terrain: The site and environs has a very flat to slightly· undulating topography with a maximum relief amplitude of less than 15 metres. There are no well developed or prominent drainage lines. Soils comprise duplex dark grey silty clayey sand over gravelly clay, with underlying unconsolidated or semi-consolidated basalt. Vegetation is grassland, some swamp and cultivated areas, with coastal marsh vegetation along the eastern shoreline. Advantages: The company believes that the Point Wilson site enjoys a number of advantages which are not available for any other site~ of comparable size within the Melbourne/Geelong corridor or in the Port Phillip region as a whole. These advantages are:-
( i ) the site is of sufficient size to ensure the provision of the company's long term expansion needs;
( i i) the site is protected on all sides by natural buffers and thus does not rely on long-term maintenance of zoning controls to ensure that residential development does not encroach; ( i i i ) the site is large enough to ensure that the adjacent areas of conservation value will be preserved;
( i v) the site is relatively flat and presents no building problems; (v) the site presently enjoys good road access with a well constructed road from the north and relatively good metalled roads from th~ west; (vi) the site is within pipelining distance of the Shell refinery at Geelong, and Geelong port installations for delivering caustic sida to the Australian market; (vii) ICI Australia .is already active in the area as the major user of the Point Wilson Commonwealth Explosives .Reserve where the company's explosives magazines are located. Constraints: ICI Australia's use of the Point Wilson site would be ·limited by three main factors:- (i) possible extension of the Point Wilson Explosives Reserve. A minor extension to the western boundary of the explosives reserve could be required should the _Commonwealth wish to construct additional magazines on the western side of the .. A3.
main road within the reserve. (ii) height limits imposed by Avalcin Airfield. Plant layout must be accommodated within the height limitations set by the nearby Avalon Airfield. .The height of structures associated with the proposed plants v~ry considerably and although columns and stacks in certain plants will reich 70 metres most plants can be located within the lowest effective height limit applicable to the site (45 metres).
The ~ffect of these two constraints is that the structures which are greater than 45 metres in heights must be located toward~ the eastern side of the site.
Services Road Access: Good access is available from the north along Point Wilson Road, but the route which is most likely to be used is Dandos Road in the west. Point Wilson Road is no longer a suitable route because of its close proximity to The Spit and because of its status as a Commonwealth Road. Rail Access: The Point Wilson site can be provided with rail access by one of three main alternative routes. -. Gas: The feasibility of supply of sufficient quantities of natural gas is presently being investigated with the Gas and Fuel Corporation. Water Supply: Preliminary investigations suggest that the Geelong Waterworks and Sewerage Trust will be able to provide ICI's town water supply requirements up to 1990 without major supplementing of Geelong's supply headworks. Potable water would form some 50% of ICI's water requirements. For a 1985 commencement of plant operations at Point Wilson, a new 375-450 mm main will be required running from the Lovely Banks reservoirs at North ·Geelong, across Hovell •s Creek and along Dandos Road. The source of the additional 50% of water requirements has yet to be ident ified. It may comprise a combination of M~1B~I treated effluents, artesian water and sea water. · · Sewerage: Detailed investigations have yet to be undertaken in regard to methods of industrial and other effluent disposal. At present, it is not envisaged that any effluent would be carried by the Geelong Waterworks. and Sewerage Trust system. Methods of liquid waste disposal have yet to be investigated but liquid waste standards will be in accordance with E.P.A. criteria established for the site. Power: Supply to the site is feasible and alternative 220KV power routes are under investigation with the State Electricity Commission. A4.
Flora and Fauna The section of beach from Point Wilson to Point Kirk consists of mudflats and saline ponds which provide a secluded habitat fQr a large variety of birds. The area is utilised as a general feeding ~nd resting area as well as an important winter feeding gro~nd for mariy migratory species. The Spit area is an important breeding ground for many of these species ·and it also provides habitat for the rare Orange-bellied Parrot. The company expressed concern that its actions should not adversely affect wildlife in adjacent areas. The f611owing actions were incorporated in the rezoning and site development proposals to ensure a basis for adequate protection of The Spit:
( i ) Eighty metre wide coastal strips were proposed to be rezoned as "Public Operi Space" Reserves under Amendment N~. 6 with restricted ~ccess and protection of wildlife therein.
( i i ) The plant drainage system would be designed such that stormwater that could be contaminated by ·Chemical spillages did not drain into The Spit. •(iii) Site development and grazing along·the northern b6undary would be kept clear of the low-lying "swamp" lands.
( i v) The hydrological factors influencing the formation of The Spit, including the effect of both tidal and inland water sheds on the ecology of the area, are to be identified arid J protected. I
Public Access To ensure both public and plant safety, ICI Australia would like to see only li~ited public access to The Spit. The company would support therefore, the Land Conservation Council's recommendation that an area of 300 hectares at The Spit be reserved under Section 14 of the Land Act, 1958 as a Wildlife Reserve and be managed by the Fisheries and Wildlife Division, primarily to conserve native animals, and for public education and recreation where this does not corrlict with the primary aim.·
. Liquid Effluents
The design of the pl~nts will be to a very high standard of safety and environmental protection, with the aims of firstly preventing·spillages, and secondly, providing for the trapping and recovering of any process materials that might escape, for subsequent reprocessing or neutralisation, as appropriate. A feature of the protective measures will. be the provision of holdin~ storages for treated effluents to enable final testing.and temperature equalising before discharge. ·Storages will be designed and located in a manner that will obviate the potential risk of leakage into The Spit. A5.
Atmospheric Emissi'on's
The major continuous e~ission source frdm a major development on the · Point Wilson site will be sulphur dioxide (S02) and oxides of nitrogen ·(NO x) from the boiler house. Prevailing winds could move combustion gasesfrom the Point.Wilson site towards The Spit. The ICI report indi~ates that the maximum concentrations that might occur within The Spit ~auld be far below the threshold for toxic effects in hu~~ns and would conform to established ambient air quality standard·s. Clearly, licensing by the Environment Protection Authority would establish the permitted emission leve 1s. Plants are to be designed to modern, internationally established, technical ~standards that ensure a very low risk of accident emissions and also provide fail-safe mechanisms that, in the unlikely event of a mishap, limit the volume of escaped emissions to a small amount:
Other Conservation Measures ICI Australia has undertaken to carry out a number of further studies. The results of these studies will be combined to enable a better ·assessment of the impact of the development on The Sp.it to be made. The proposed studi~s include: (a) Marine Biology (b) Flora (c) Avifauna (d) Meteorology - the site falls wtthin a relatively low rainfall area with an average arinual rainfall of 45 em. Winds from the southern and western quadrants predominate. The pre dominant wind direction associated with inversion conditions conducive to low rates of natural dispersion of plant emissions is from the west. Under these conditions atmospheric movement will be towards the open waters of Port Phillip Bay. (e) Geology/Soils (f) Hydrology- the low-lying areas referred to as "swamps" on the northern side bf the site are fed by salt water from extreme high tides and fresh water run off from the surrounding ~rasslands during occasional heavj rainfall periods. ·A preliminary evaluation indicates that the inland catchment area will be reduced by only 15% as a result of site develop ment. This is within the annual rainfall variations expected. (g) ·coastal Geomorphology
Benefits of the Proposed Development l. Land Management In the event that permission were not granted to develcip the IC1 Australia site for low intensity industrial use, then under the present zoning it would be possible to break the holding up into 8 or 10 "hobby farms". Development of the area for this purpose would bring ~ith it a number of land management problems commonly associated with more· intensive settle- A6. ment of the land, including the possible introduction of ferne an·imals and alien plants.
The proposed use of th~ ICI Australia l~nd, for a low intensity industrial development, ensures that the present pattern of land holdings in the area is perpetuated. This, together with the reduction in grazing activities, will provide better opportunities for the effective manage ment and conservation of the significant habitat areas on the site, although obviously the bulk of the site's grasslands will be affected by development.
2. Job Opportunities The petrochemical plant could eventually employ up to 1,200 people and it is estimated that another 1,000-1,200 new jobs would be created to service the needs of the plant employees and their dependants. It is estimated that approximately 7,200 people could be directly or indirectly dependant on the petrochemical plant for their income. Many of-the new jobs created by the plant may be expected to be taken up by Geelong residents and it is assumed that many new indirectly generated jobs would also be filled by Geelong residents.
The plant's workforce would include a very high proportion of.skil~ed workers and a number of graduates. Increasing the range of job opportunities for skilled workers and graduates in Geelong would have beneficial effects for tertiary institutions in the region.
3. Business Receipts Part of the site's expenditure, including a large part of the wages bill, could be spent in the Geelong region. This amount may be roughly doubled to give the total boost to business receipts in the region. Some of the expenditure on construction would be within the Geelong region.
4. Council Rates The pla"nt will form a significant source of rates for Corio Shire. In addition many employees, especially newcomers to the region, may be expected to buy or build homes in Corio Shire. In the longer term, the development of a major ICI Australia facility at Point Wilson would sub~tantially strengthen Geelong's economic base, not only through a direct contribution of capital investment and employment, but also by virtue of the linkages that would be created with other major petrochemicals and related industries in the Geelong Region. · ATTACHMENT "B" Bl.
OBJECTIONS TO THE PROPOSAL As a consequence of the public exhibition of the proposed rezoning as set out in Amendmnet 6, objections were received from the following individuals and organisations:
ICI Australia Limited Royal Australasian Orthologists Union
Fisheries and Wildlife Division, t~ini$try for Conservation Bird Observers' Club Geelong·Environment Council Port Phillip Authority Geelong Field Naturalists' Club Conservation Council of Victoria Victorian Field and Game Assocation Melbourne and Metropolitan Board of Works P.G. Brown B. Elstone I. Penna [ These objections, and supplementary hearing on 5th May, 1978 are presented in full in Attachment A. However, the substance of the objections can be summarised as follows:
I.C.I. Australia Limited This objection made the following points: 1. The company requests that a 100 metre coastal access strip at the southern end of the eastern shoreline be zoned Industrial "B" and be excluded from the agreed setback area. 2. The company objects to unrestricted public access to the eastern "Public Open Space" reserve, because it would be inconsistent with - (a) the recommended designation of the eastern shoreline as "Nature Conservation A" under the Port Phillip Authority coastal study. They support the concept that activities within this reserve be restricted to "scientific study" and "nature study" on a permit basis.
(b) safe op~rations of the proposed plants - congregation of people in close proximity to petrochemical and chemical I. plants is not advisable. I I • B2.
3. The company accepts rezoning of the southern foreshore a~ "Public Open Space Reserve" within a setback of 80 metres, but requests that a 100 metre wide coastal access strip at the eastern end of this section be excluded and incorporated in the area proposed as Industrial "B" zoning. · 4. The company requests that the Public Open Space reserves and the coastal access strips be defined in more detail as shown in ICI•s survey plans.
Fisheries and Wildlife Division The Division objects in principle to any proposed industrial development of the land at Point Wilson on the grounds that such development would not be in the best long-term interests of conserving wildlife and wildlife habits in that area. Specific objections to industrial development at Point Wilson are: 1. That it would directly alter habitat on the site. The site includes some coastal land and salt marsh which are primary habitat for the main classes of birds utilising the locality water birds, sea brids, waders, and the Orange-bellied Parrot. The Division recognises that it is possible for industrial development to avoid these habitats with a. buffer of 0.5 km. 2. That it would disturb adjacent habitats by noise, earthworks, dust and other fallout, liquid effluent and drainage, during construction and operation of any industrial plant. 3. That the proximity of the Point Wilson Road to The Spit and to habitats in the ~1MB\-J Farm makes it essential that it not be used for access to the site. 4. That as The Spit is down-wind of the site for prevailing winds, it must be assumed that fall-out from discharge to air will occur in the reserve, and along the adjacent coastline. It is unlikely that the effect of any such fallout on wildlife habitat would be beneficial. Any discharges to air, therefore, should be as far as 'possible from The Spit, not adjacent to it as is currently proposed. 5. The location of high structures and power lines may disturb traditional flight patterns. These obstructions are likely to cause a considerable number of deaths among bird population. The Division recommends that any high structures be sited well away from coastal areas, salt-marshes and lagoons. In answer to questions from the Hearing Committee the Division•s representatives added further that the Division.would not like to see unre~tricted public access to the foreshore area and The Spit because of the effects that it might have on the Orange-bellied Parrot, and that it is possible to use a permit system to regulate public access under the Wildlife Act 1975. B3.
Royal Australasian Ornithologists Union
The R.A.O.U. is a scientific society which was establish~d in 1901. It has 1,100 members in Australia and overseas. The Union has participated in many studies but this is the first time that it has been represented at an objection hearing. The R.A.O.U. sees this as a measure of the importance that it attaches to the issues involved. Objections were presented by Mr. T. Garnett, Secretary of the R.A.O.U. and Mr. J. Forshaw, Chairman of World Working Group on Parrots, etc. 11 11 11 11 and author of The Parrots of Australia and The Parrots .of the l>Jorld • The Union's objections were: 1. That the ICI proposal may disturb the Orange-bellied Parrot's habitat at The Spit. The Orange-bellied Parrot feeds on a plant called 'Sea Rocket•, \'Jh.ich grows in the salt tidal areas. The Sea Rocket only survives at a specified temperature and salinity. It is important, therefore, that ICI's operations are not allowed to upset The Spit. 2. That there is reason to believe that discrete populations of the Orange-bellied Parrot favour different wintering grounds. If the habitat at The Spit is disturbed, it is possible that the population that winters there will die out rather than relocate to one of the other possible habitats. This event would not be desirable because the Orange-bellied Parrot is extremely rare. 3. That waders and other birds come to The Spit. If the Point Wilson Road is used this may disturb these birds and their use of The Spit as a major habitat. 4. That the ICI proposal will disturb plans for the Bird Observatory that is to be set up on.Limeburners Bay by the Corio Shire and Geelong Grammar School. Since little is known of Australian birds, it is vital that every opportunity be taken to study them. 5. Mr. Garnett also commented that use of the land for industrial purposes was better than using the area for residential purposes, but that there were more favourable land uses (not specified) than these two alternatives.
Victorian Field and Game Association The V.F. & G.A. is a national association and it has over 400 members in its Geelong branch. It is the biggest amateur organisation concerned with wetlands conservation. It started as.a hunting group but it became concerned about the depletion of bird numbers. It now concentrates on conservation activities. The objection was presented by Mr. P.G. Brown who is the national and state president of the association. He also presented his bwn personal objection together with that of Mr. G. Elstone and the V.F. & G.A. •', B4. !
Their objections were:
1. That the wetlands on and adjacent to the ICI site are of prime quality, and it is desirable that no further wetlands should be lost because the loss of habitat would mean decreases in the population of water birds. 2. That the proposed location of ICI's structures may interrupt flight lanes and cause death and injury to birds. 3. That insufficient information has been given about air emissions and liquid effluents. A lack of confidence was expressed in the ability of the Environmental Protection Authority to regulate the quality of these discharges satisfactorily. 4. The extra waste generated from ICI may aggravate the already existing sewerage problems .. 5. That if the land is rezoned and ICI do not develop the land, any industry could move in.
6. That a minimum buffer of 35 metres should be imposed behind the wetland areas to protect them. In ansv1er to a question from the Hearing Committee, Mr. Brown replied that public access should be restricted on The Spit but allowed on the other foreshore areas.
Bird Observers' Club The B.O.C. has a membership of more than 2,800 of which abut 80% are in Victoria, with the remainder being distributed throughout Australia. It was founded.in 1901 and is now more than twice as big as all the other bird organisations in Australia. The club has participated in many studies in Victoria. The Bird Observers' Club's objections were presented by its President, Dr. D. Robertson. These objections are: 1. That any industrial development would be an eyesore and a petro chemical industry would not preserve natural beauty by its appearance. 2. That buildings are proposed to be built near the shoreline. 5cientific study cannot be carried out in a developed, active industrial environment. 3. That ICI's development would adversely affect The Spit.which is an important habitat for both local and migratory birds. Any effluent or discharge could become trapped in the lagoon and this would adversely affect marine organisms, and thus the birds that feed on them. · I [ 85. 4: That migratory birds are.subject to an Agreement between the governments of Australia and Japan which provides that each government· shall:- (i) endeavour to establish sanctuaries and other facilities for the management and protection of migrat6ry birds and birds in danger of extinction. (ii) take appropriate measures to preserve and enhance the environment of birds protected under the provisions of this agreement by preventing damage to birds and their environment. 5. That pollutants such as chlorinated hydrocarbons and sodium sulphate ar~ likely to affect both birds and marine life. 6. That there are other places for ICI to build their petrochemical complex. 7. Icr•s development will not help unemployment in Geelong except for a transitory effect during construction. 8. That by allowing the "ezoning, there will be pressure for other zoning changes in areas nearby. This may result in a sprawling indu~trial slum around the Bay. 9. That Point Wilson and The Spit should be handed over to Fisheries and Wildlife Division to be run as a State Wildlife Reserve in accordance with the findings of the Port Phillip Coastal Study.
Geelong Field Naturalists• Club The G.F.N.C. is a local group with a membership of over 400. The club•s Presideht, Mr. J. Mathison submitted the following objections: 1. The development of the industrial .complex, with the tallest structures nearest The Spit, will have serious adverse effects because of its interference with flight paths to other areas. 2. The prevailing \'Jind direction will carry most of the stack and site airborne effluent over The Spit and adjac~nt areas. Problems associated with the airborne wastes include fallout of solid matter, heat and reduced air quality. This could adversely affect The Spit as a wildlife habitat. 3. The drainage cannot be altered without some adverse effect on the lagoon. About 50% of the site drains to The Spit lagoon. If the runoff is allowed to flow over and through the site, it will inevitably pick up contaminants which will be transported to the lagoon. If the site is gr~ded and drained to pondage, then the lagoon is deprived of its natural input of fresh water. B6. ] ' 4. Birds could be attracted to on-sit~ ev~po~ation ponds whtch may have chemicals concentrated in them. Seepage ·from such ponds could also create problems.
This group also expressed their lack of confidence in the Environme~nt Protection Authority's ability to protect The Spit and adjacent habitats.
Mr. I.W. Penna
Mr. Penna was not present at the hearing, but h~d prepared a detailed submission, the main points of which are: 1. That it has not been shown that there is sufficient demand for the end products of the complex to' justify the construction of a new petrochemical plant. 2. That ICI should provide furzher information on the extent of their future demands on services and resources. The avail abi 1 ity, cost and environmental impact of obtaini.ng large quantities 6f materials such as Naptha, Propane, industrial salt, electric power, fresh water and natural gas should be considered. 3.· That discharge standards are a matter for negotiation between ICI and the EPA, rather than absolute, fixed standards. 4. That liquid effluent disposal has not been fully discussed. The e~tent to which ICI are prepared to outlay capital t6 protect the water quality and ecosystems along the coastal zone needs to be spelled out. 5. That the treatment of gaseous effluents and the cost of this treatment has not been discussed. 6. That the ICI complex will not help Geelong's unemployment problem because the petrochemical industry is capital intensive. The new complex may compete with existing industries and thus cause unemp 1oyment.
Geelong Environment Council
The G.E.C. is concerned with many environmental problem~, particularly those which affect the urban area. It currently has a membership of 180-200 .. The Horiorary Secretary, Mr. D. King, presented the following objections to the prciposed ICI Point Wilson installation:
1. It would intrude into the Geelong/~1elbourne buffer zone. 2. It would add to the degradation of the Port Phillip coastal strip. 3. Liquid effluent may have adverse effects on The Spit lagoons. Tidal flushing of this area is minimal and any pollutant would I r B7. l have disastrous consequences, This is an important consideration because ~~o~i.56%~of the site drains naturally into the lagoon.
4. It would add to the poll~tion loading in a segment of Port Phillip where the EPA have already -been forced to reduced water quality criteria due to the adjacent discharges from the MMBW sewerage treatmerit and the limited dispersion capability of the Bay system. · 5. It would make significant demands on the public water supply, accelerate the degradation of the natural Otway Forest region through the construction of additional water storage capacity, and make consequent demands on public moneys. 6. It would make significant inroads into the amount of area surrounding the Bay that has not already been sacrificed to uses +hat degrade its scenic and aesthetic qualities. Ih the event that ICI are permitted to go ahead with its plans, the Council would like to see the following five constraints imposed on the construction and operation of the plant: (i) Best available technology must be used in limiting waste di~charges to air, water and land, with th~ objective of zero discharge to water in particular. (ii) Maintain a buffer zone (150 metres minimum) between the construction and the company's site boundaries adjoining the foreshore and the nature conservation areas. (iii) Rev1ew the regional plan to ensure that other industries, related or otherwise, do not move in and generate a sprawl further into the zone. (iv) Ensure that the topographical arrangement of the factory, the design and location of security fencing and ancillary services make minimal aesthetic intrusion.
(v} bevelop a plan for the enhancement of the ove~all site aesthetics through the extensive use of site contouring, ve~eiation planting program and such other means as are qva i1 ab 1e.
Port Phillip Authority The Authority has two basic objections to Amendment 6 and these were basedon the Port Phillip Coastal Study. They were presented by Mr. G. Wright, Chief Planner in the Ministry for Conservation. i. The development would conflict with proposals outlined in the Port Phillip Coastal Study: the siting of the taller structures close to the coastline is inappropriate; B8.
major effluent discharge to the ~ir would occur ·in the vicinity of The Spit· which is the area of most significant bird habitat; the Spit is to be designated as Coastal Conservation "A" where scientific study is to be ~ncouraged. Other activities such as parking, picnics and 'boating are·to be phased out. There will be only restricted public acces~. 2. The proposals could be detrimental to the birdlife in the area. The Authority gives its support to the comments made by the Fisheries and Wildlife Division on this subject. 3. If industry is established, an 80 metre buffer zone would not be· adequate. Mr. Wright•s· personal opinion is that a_ 500 metre buffer would be more appropriate.
Conservation Council of Victoria The Conservation Council of Victoria represents over 100 groups, ·all of whom have as one of their activities, a prime concern for the environ ment. Membership of these groups extends.all over Victoria and totals about 25,000 individuals. The Director of the Conservation Council, Mr. H. Johnson, and Miss C. Kunert, B.Sc., presented the Council•s objections to the proposed rezoning at Point Wilson. · · 1. The proposed rezoning would attract other supporting and servicing businesses to apply for further rezonings clo~e to thei~ t~~tomer ·industry, thus beginning a slow attrition of land now zoned rural. This would decrease the amount of open space available to Geelong. 2. Any industrial zoning will jeopardise the ability of the western shores of Port Phillip Bay to continue to provide marine, wetland, and coastal habitat of importance to internazional waders and to vast number ·of Australian water birds. 3. Provision of services to industries would be a burden on the community. 4. The Spit must be protected as a habitat for birds and be used only by ornithologists for scientific purposes.
Melbourne Metropolitan Board of Works The MMBW has lodged an objection to the rezon1ng of the land at·Point Wilson through its Concern as an adjoining landowner. Mr. J. Middleton, acting in his capacity of solicitor for the MMBW, presented the following reasons for the Board•s objection: B9.
1. The prevailing winds are such that the Board wi 11 ·be affected by any gaseous emissions that are created by the proposed develop ment. 2. The proposed development wi.ll affect the background levels that were determined in relation to the effluent which is permitted into Port Phillip Bay, and thus affect the Board's current effluent disposal into the Bay. 3. The increase in traffic is both undesirable and dangerous, because of the possibility of accidents between vehicles carrying dangerous substances and due to the possipility of damage to livestock. 4. The Board is concerned over the possibility of industrial accidents, for should any such accident occur the environmental impact could seri6usly affect the delicate natural balance on which the farm entirely depends.
As part of its s~bmission, the Board issued an invitation to ~he members of the Hearing Committee to visit the Werribee Sewerage Farm and inspect its operations. This was subsequently ·accepted by the Committee .. 5. The subject area is important for the birdlife which is supported therein. The birdlife serves a useful purpose from the Farm's point of view in that it assists with the maintaining of the natural balance. More general points that were presented for consideration were: 6. The problems involved in providing the ICI complex with an adequate water supply. 7. The implementation of the amendment would result in a decrease in the overall amenity of Point Wilson and adjoining areas. In addition to these objections, comments on the proposal were received from Telecom Australia, regarding cable locations in the vicinity of the site; the Country Roads Board, regarding planning of future road access; the Environment Protection Authority of Victoria, requesting a 50 metre coastal buffer zone, construction of catch drains to prevent stormwater run-off to coastal swamps, and licensing of cischarges under the Environment Protection Act; the Ministry fbr Conservation, suggestin~ that further details were needed for a proper evaluation of the project; .the State Electricity Commission, pointing out the location of existing transmission lines; the Geelong Waterworks and Sewerage Trust supporting the ICI project and setting out preliminary assessment of availabilizy of water supplies; the Shire of Corio, supporting the project; and Barbour and Arnold, Solicitors, on behalf of the Barra Group of quarry operators, lodging a late objection on 3rd May, which was not heard, to the proposed Public Open Space reservation and its possible effect on installation of wharfing facilities associated with quarrying . .In addition, a great deal of supplementary material was provided by ICI objectors, or obtained by the Commission as sources of reference. C1
ATTACHMENT C . The Hearing Committee:reviewed the objections re.ceived, and arrangements were completed for a· hearing on May 5, 1978. The Minister for Planning was asked by the Commission to direct the Commission to take into account a number of late objections, and the appropriate direction was issued on 11th April, 1978. Objections were heard on 5th May, 1978 with most objectors providing detailed and informative· supplementary submissions to support their lodged objections. The objections are summarised in Attachment B. This report records the nature of the I.C.I. proposal; the nature of objections received, and the Hearing Conrnittee•s recommendations to the Corrrilission as to the action it should take to appropria-tely respond to those objections and conclude its deliberations on the rezoning . propos a 1 .. ·
ISSUES RAISED BY OBJECTIONS The principal issues raised by the objecions to the proposal can be· summarised broadly as follows: . 1. The need for a petrochemicals complex and more particularly the desirability of permitting the development of a complex which will inevitably increase the direct and indirect consumption of r resources inside and beyond the region, with particular regard to sources of raw materials, fuels, power and water. ·
11 2. The location of the complex in the buffer•' between ~1elbourne and Geelong, an·d the possibility that it \'Jill stimulate further demand for development in the immediate vicinity and further reduce the buffer. This includes general concern over the loss of a l~rge area of open, undeveloped land; 3. Protection of the flora and fauna of The Spit and other nearby habitat areas from disturbance by constr:uction activity, plant process noise, airborne or waterborne emissions, traffic noise ~nd physical intrusion, or other adverse impacts.
4~ .Protection of the waters of the Bay from pollution, eithef through discharge of wastes to the Bay or accidental spillage of materials. 5. Provision of access to the site for vehicles and for other services (r~il, power, pipelines). 6. The possible effects of any airborne effluent on the activities of the Melbourne Metropolitan Board of Works Sewe~age Farm.
7. · The intrusion of physical structures into the ~igration paths of birds. 8. -The location, extent of and access to open space. zones and other buffer areas between the plant and the shoreline, or the plant and habitat areas such as The Spit.
I - C2
9.. The methods of disposal to be used by ICI in disposing of waste products and the standards to be set by the Environment _Prot~ction Authority for effluents ~ischarged to the environment. 10. The impact of the project on employment, unemployment and· business activity in the Region.
In considering these issues, followi-ng discussions between Commission officers and - ICI.Australia Limited M1-nistry for Conservation ·MinistrY for Planning Town and Country Planning Board Department of Environment, Housing and Community Development, Canberra ~elbourne and Metropolitan Board of Works and the Hearing Committee, the Committee has reached a number of conclusions as to _the- manner in which a response can best be made to objections and further necessary work can be undertaken to provide an informed basis for responding to each major issue. These interim conclusions and proposed actions ite ~et out below.
CONCLUSIONS The Committee considers that the objections received to the rezoning proposed in Amendment 6 to the Geelong Regiqnal Interim Development Order do not establish a clear case against proceeding with th~ rezoning. They do, however~ raise a number of matters of environmental significance which must be further investigated before a final decision _is made by the Commission.
Such an i~vestigation should establish if the plant and its processes c9-n be planned, developed and operated on the site in such a- manner as to meet specific environmental objectives. The investigation should, however, be set in the context of a number of constraints which the Committee considers, as .a result of the objections, to be desirable ·modifications to the rezoning proposal, and it should focus on the broad environmental effects of proceeding with a petrochemical complex within those constraints. The constraints are set out below.
1. On-site Constraints (a) Public Open Space
The 80 metre public open space reserv~ along th~ eastern arid southern shorelines of the site should be retained, except that a 100 metre access corridor should be provided to each shoreline as requested in the objection by ICI Austra_lia Limited, for the purposes of wharf or pipeline access.
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ICI Australia Limi~ed should be requested to plan development adjoining the open space zone so as to create a further on-site planted area of as great a width as possible, particularly along the eastern shoreline, and to set back structures, particularly high profile structures, well beyond this planted area. These requirements should become an integral part of development planning for the site.
Public access to these open space r~serves should be restricted, and. they should be managed under an appropriate management agreement between the Fisheries and Wildlife Division, Ministry of Conservation and ICI. The foreshores should be designated Public Open Space (Flor·a and Fauna Reserve) as indicated on the Amendment as exhibited. (b) Buffer Area to The Spit Most objections. to the proposed Amendment focussed on the significance of The Spit and its adjoining swamplands and foreshore areas as a bird habitat, particularly for the rare Orange-bellied Parrot. It is clear that every possible step should be taken to protect The Spit from any adverse environmental effects associated with this development, and accordingly the Committee considers that the environmental investigation should be based on the principle of locating all chlorinated hydrocarbon plants to the west of the existing road to the Explosives Reserve. In any event, the Committee considers that any works located east of the road to the Explosives Reserve should be located so· that works areas do not drain to The Spit catchment. This implies location south of the ridgeline crossing The Spit "peninsula", or alternatively, on or slightly north of the ridgeline with appropriate "catch-drain" provisions, to avoid drainage to The Spit. In addition, to avoid physical intrusion, effects of noise, traffic, dust, heat and other ground level emissions, works should be set back around 200 metres from .the presently vegetated areas of The Spit, and up to 500 metres from the normal tidal zone, as shown on the attached plan. The Special Building Line shown 80 metres from the title boundary on the Amendment as proposed should be modified to provide setbacks of this order, and no works should occur between that building line and The Spit area. The revised building line is indicated on the modified plan. The buffer area should be planted, and a management program agreed between ICI and Fisheries and Wildlife Division, including provision fo~ controlled access for scientific and nature study purposes. (c) Location of Plant Elements The Committee considers that many of the claimed environmental hazards set out in objections may not exist, or would be of minor significance if the- loc~tion_of pa~ticular plant elements is carefully planned and managed. C4
This would involve location of plants with potentially noxious emissions to the south of the site, at as great a distance from the Spit and the MMBvJ Farm as possible, with such locations and associated factors such as st~ck heights and permitted discharge level~ to be subject to controls designed to influence the pattern of dispersal of such emissions to maintain acceptable levels. The preferred locational option mentioned earlier is to have no chlorinated hydrocarbon plant east of the existing road to the Explosives Reserve. ~his option should form the principal basis for the environmental investigation. (d) Access to the Site The Committee considers that the principal access to the site should be along Dandos Road and/or Government Road, to avoid traffic impacts in The Spit area and to increase accessibility to Geelong. These routes could also provide corridors for major services, which in turn should be located to avoid intrusion into the Limeburner•s Bay area. These provisions would avoid objections regarding possible traffic noise intrusion in The Spit area.
2. Ordinance Amendments In addition to the above on-site constraints it is proposed that the following amendments, which are subject to final legal drafting, be made to the Geelong Regional Interim Development Order Ordinance, and subsequently to the Planning Scheme Ordinance, affecting the Point Wilson Industrial 11 811 Zone. Clause 23 would be amended by the insertion of the following new Sub-clause (2), which are still the subject of legal advice on drafting and content; and the renumbering of exi$ting Sub-clauses (2), (3), (4) and (5) .
.. Notwithstanding the provisions of Sub-clause (1), in the area defined below in the Table to this Sub-clause (which will be a description of the ICI site) the following provisions shall apply: (a) Land shall not be subdivided except with the permission qf the Geelong Regional Commission; (b) No development shall be permitted other than in accordance with a plan of development prepared to the satisfaction of the Responsible Authority in consultation with the Geelong Regional Commission; (c) In considering any such plan of development the Responsible Authority shall determine, in consultation with the Geelong Regional Commission, if the provisions of Sub-clause (6) (existing Sub-clause 5) to this Clause shall apply and if so shall request the preparation of an Environmental Effects Statement in accordance with the provisions of the Environment Effects Act, 1978. I I' C5 l (d) Such plan of development and any accompanying Envir onment Effects Statement shall be for the purpose of a decision by the Responsible Authority on the issue of a planning permit. Each plan of development should therefore be concerned with major expansions of site operations and not with alterations within an existing approved plan of development which do not breach the intent of such approved plans or of permits issued.'' The purpose of these amendments is to ensure a measure of on-going control over the long-term development of the Point Wilson area, without requiring ICI Australia Limited to seek planning permission for minor works. Changes of technology or patterns of demand will, over the long term, result in changing production processes or elements, and these need to be regularly reviewed in an environ mental context as part of the process of considering wh~ther or not planning permission for new works should be granted.
3. Environment Effects Statement
The above physical constraints provide a basis for the environ~ental investigation of the project, to provide evidence to the satisfaction ·of the Commission and other relevant authorities that the project could proceed while achieving the following environmental objectives:
safeguarding the wildlife species ~nd habitat in The Spit area and nearby foreshores; avoiding interference with bird flight paths across the site, particularly with high structures involving supporting guys, or other elevated wires and masts; minimising visual intrusion of the plant, particularly from Corio and Port Phillip Bay; retaining foreshore areas for conservation purposes; maintaining air-borne plant emissions within chemical groups and levels as specified by the appropriate Environment Protection Authority licenses; ' maintaining and treating water-borne wastes and effluents so as to avoid pollution of the surrounding environment and the Bay areas as provided for by the. appropriate licenses issued by the Environmental Protection Authority; creating a development which is as far as possible an environmental as well as an economic asset to the Geelong Region and the State. In order to establish that these objectives can be met and that the project could proceed on the site within an appropriate planning and development.framework which would safeguard the environment, the Committee considers that iCI Australia Limited should prepare an Environment Effects Statement. C6
This Statement should pe prepared in the context of the prov1s1ons set out in the State Government's Environment Effects Act 1978 (which is yet fo be proclaimed), to ensure that all parties who might have authority over the project can have their interests satisfied, at least as far as the location and general character of the plant is concerned, subsequent tb any decision by the Commission on rezoning. This will minimise. delays in proceeding with the project if a decision is made by the Corrimission to adopt the rezoning. The report should be concerned with the issue of the suitability of the site for this project, and should concentrate on those matters related to the rezoning decision, which is in essence a decision about the use of the land. As set out in Part 2 above, other safeguards are proposed to ensure that environmental matters are considered at each future stage of plant development, when more precise assessment of each plant stage can be undertaken in the context of the measured effects of development to that time. The Committee considers that: the Commission shou•ld seek the--advice and assistance of the Minister for Conservation, as provided in Clause 8 (1) of the Environment Effects Act 1978 on the preparation of an Environment Effects Statement. Assuming the Minister advises that such a Statement should be prepared, the Commission should formally request the company to prepare the Statement; the modifications to the proposed rezoning, including the ·proposed Ordinance amendments, are a response to objections received, and should form the context within which the Environment Effects Statement is prepared;
the Commission should invite senior officers of the r~inistry for Conservation and the Town and Country Planning Board to meet with Commission staff and staff of ICI Australia Limited to agree on the contents of the Environment Effects Statement and to receive reports on its p~ogress; ICI Australia has already undertaken considerable work in the course of recent months on many aspects rif the environ ment of the area as part of their own forward planning. This work will form a considerable part of the Statement, which should be completed by September, and passed to the Ministry for Conservation for processing in accordance with their guidelines. the Commission will receive an assessment of the report from the Ministry for Conservation and should also seek comments from the Town and Country Planning Board. On the basis of the Statement, the relevant assessment, and the Hearina Committee's final report, the Commission should then - determine its views on Amendment 6. C7
the Comm·ission should-take every step to assist ICI Australia, other Ministries, and the Minister for Planning in resolving the Amendment as quickly as is consistent with responsible consideration of the issues. in particular, the Commission shou.ld now advise the Minister for Planning and the Minister for State Development of progress in considering the Amendment-and the objections thereto, and the course of action now _planned. The Minister forPlanning should be requested to advise the Town and Country Planning Board to work closely with the Commission in the next stage of consideration of the Amendment, to avoid any delay if the Commission subsequently adopts the rezoning.
RECOMMENDATION
The Hearing Committee recommends that the Commission adopt the conclusions of the Committee as the basis for further action on Amendment 6 to the Geelong Regional Interim Development Order. DL
ATTACHMENT "D"
MINISTRY FOR CONSERVATION
ASSESSMENT OF POINT WILSON REZONING . ENVIRONMENT EFFECTS STATEMENT
November 1978
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SUMMARY
A proposal to r~zon~ land at Poi.nt Wilson for de~~lopmenf ~s a petrochemical chlor-alkali manufacturing site was submi.tted by ICI Australia Ltd.,· to the Geelong Regional Commission. in January, 1978, ~ho requested that an Environment Effects Stat~ment. be prepared. The 766 ha site located adjacent tG Point Wilson Explosives Reserve, Cheetham Salt Works, Avalon Airfield and Melbourne and Metropolitan Board of vJorks Sewerage Farm is currently zoned Rural (General Farming) under the Geelong Regional Interim Development Order. The Statement proposes the rezoning of this area to an Industrial B classification in order to be able to construct ethylene, caustic chlorine, ethylene dichloride, vinyl chloride monome~, po1ythene and polypropylene manufacturing plants. Buffer zones of 200 - 500 m width are proposed for the north-eastern boundary of. the property (adjacent to The Spit) and a P'ubl ic Open Space (Flora and Fauna Reserve) of BOrn minimum width is proposed along the eastern and southern coastlines. The major concern associated with the project is the possible incompatibility of a major petrochemical complex being sited adjacent to a proposed State Wildlife Reserve. The Wildlife Reserve and its adjacent foreshore is the most important feeding ground for migratory waders in Victoria as we 11 as one of the few known winter refuges of the endangered Orange-bellied Parrot. If the development is to proceed- the safeguards relating to discharges to air and water, landscape, public access, construction, structure design and-off-site services which are discussed in this assessment, together with the safeguards outlined in the Statement (under flora solid wastes and archaeology) should be incorporated in the rezoning proposal and detailed design of the complex. In addition, the conclusions of the Hearing Committee for Amendment No. 6 that are ·outlined in Appendix I of this assessment are fully supported. Finally, a Committee comprising representatives of Fisheries and Wildlife Division, Melbourne and Metropolitan Board of Works, Geelong Harbor Trust and ICI should be set up to manage The Spit area, buffer strip (set back) areas adjacent to it and the coastal reserves. D3.
INTRODUCTION A proposal to rezone land at Point Wilson for development as a petrochemical clor-alkali manufacturing site was .submitted by ICI Australia Ltd., to the Geelong Regional Commission in January, ~978. Following a period of public comment and the hearing of objections, the Geelong Regional Commission decided that an Environment Effects Statement be requested to enable investigation of the matters of environmental significance raised in the objections. This Environment Effects Statement is the first prepared by a non government proponent under Clause 8(1) of the recently proclaimed Environment Effects Act 1978. It has been advertised seeking public comment, resulting in a response from four individuals, six private organisations, and six government departments. This assessment report ts based on the prepared Statement, submitted comments and site visits.
JUSTIFICATION OF THE PROPOSAL On the basis of forecasted growth in local demand for petrochemical products ICI have determined a need to increase their production capability. Since _the Victorian market is expected to absorb a significant proportion of the petrochemicals manufactured, a Victorian site was sought having good access to transport routes and the Melbourne area, as well as other attributes. The economic justification for constructing a petrochemical plant on the proposed site is a matter for the company concerned.
DESCRIPTION OF THE PROPOSAL The 766 ha site located adjacent to Point Wilson Explosives Reserve, Cheetham Salt Works, Avalon Airfield and Melbourne and Metropolitan Board of Works Sewerage Farm is currently zoned Rural (General Farming) under the Geelong Regional Interim Development Order. The Statement proposes the rezoning of this area to ari. Industrial B classification in order that a petrochemical chlor-alkali complex could be constructed. This complex is expected to comprise ethylene, caustic chlorine, ethylene dichloride, vinyl chloride monomer, polythe.ne and polypropy lene manufacturing plants. Buffer zones of 200 - 500 m width are proposed for the north-eastern boundary of the property (adjacent to The Spit) and a Public Open Space {Flora and Fauna Reserve) of 80 m minimum width is proposed along the eastern and southern coastlines.
ENVIRONMENTAL EFFECTS AND ASSOCIATED SAFEGUARDS A_number of potential effects have been discussed in the Statement and raised in submissions; namely flora, avifauna, landscape, public access, air emissions, discharges to water, noise, solid wastes, archaeology, construction, off-site services and .safety. 04.
With regard to flora, noise, solid wastes and archaeology, the environment effects, which would probably result from construction or operation of the proposed complex could be minimised provided the safeguards outlined in the Statement are undertaken. The other areas of concern require more detailed discussion which follows:
(a) Avifauna
The ICI site itself could be be considered a r~latively unimportant bird habitat area. However, the significance of the adjacent "Spit" area and the Melbourne and Metropolitan Board of Works farm, for avifauna has been emphasised in a number of submissions. In particular the rare Orange-bellied Parrot as well as migratory waders, wetland birds, and birds of prey use the areas adjacent to the north east boundaries of the ICI site for nesting and feeding.(!} To a lesser extent areas adjacent to the southern boundary of the site (Point Wilson and Cheetham Salt Works} also provide valuable habitat areas for wetland birds. Works on the site could have an adverse impact on the habitat areas adjacent to the site (The Spit, M.M.B.w: farm, Point Wilson, Cheetham Salt Works) in terms of drainage, noise air quality and lighting; these aspects are discussed below. The Port Phillip Coastal Study proposed a strategy of "Nature Conservation A" for the coastal area from the Explosives Reserve boundary northwards along the ~1elbourne and Metropolitan Board of Works farm, including The Spit. Under this classification it is noted that "The primary purpose inthese coastal segments is to protect important regional , national and inter-national flora and faunal habitats as part of the natural heritage''.(2) As such, scientific study would be encouraged, nature study would be controlled and all other activities would be prohibited or phased out. To uphold t~ Nature Conservation A classification, emissions from the complex and public access will have to be controlled. Currently 29 Mile Road (leading to the Explosives Reserve) passes adjacent to The Spit and some lagoons of the Melbourne and Metropolitan Board of Works farm. The potential disruption to birdlife and habitat from the general public and from traffic generated by the Explosives Reserve is therefore substantial. Di~cussions should be undertaken between ICI, D~partment of Transport and Melbourne and Metropolitan Board of Works with a view to restricting public access past The Spit, either by relocating the Explosives Reserve gatehouse to a point north of The Spit, or establishing alternative access to the Explosives Reserve along Dandos Road and the southern boundary of the ICI property. Disturbance to the flight paths of birds may occur due particularly to high stacks. To reduce this possibility and provide an area for landscaping, all major structures should be set back at least 200 m. from the coastline. (1) The final recommendations of the Land Conservation Council for the Melbourne Study Area have stated that "The Spit" area should become a State Wildlife Reserve to be manag~d by·the Fisheries and Wildlife Division. The Land Conservation Council report states "The Spit and adjacent foreshore is regarded as being the most important feeding ground for migratory waders in Victoria. It is also one of the few known winter refuges of the endangered Orange-bellied Parrot''. (2) Port Phillip Coastal Study, Ministry for Conservation 1977, p90. D5.
The avifauna study currently being undertaken should be of at least two years duration in an attempt to cover seasonal and climatic variations, to provide additional data for detailed plant design in order that adverse effects on birds and their habitats will be_ minimised. This should include investigation or simulation of the effects of operating the flare and of construction/operational noise on birdlife, and whether ameliorative measures are required. Preliminary findings of the avifauna survey su-ggest that some areas of the ICI site provide habitat for a variety of birdlife, in particular the Herbfield mozaic area (north-eastern part of site}, Samphire scrubland (north-eastern}, three areas of Juncus radula sedgelands (centre and north), and a small group of planted Boobeallas (east coast). Much of these areas are included in the proposed set back areas. However, those parts that are not should be retained and protected; during construction and operation of the plant.
(b) Discharge to Water (i) Site drainage: The quantity and quality of water passing from the ICI site to The Spit as overland flows play an important part in maintaining the variety and· quantity of vegetation there, and hence at least part of the area•s value for birdlife. Construction of retarding basins, and the diversion of contaminated runoff to appropriate treatment facilities, should occur to ensure that the water quantity and quality entering The Spit approximates that occurring at present and to maintain the habitat value of The Spit. Consturction of retarding basins on the water course leading to Point Wilson (catchment area 4) should be investigated for similar reasons. (ii) Groundwater: Leakage of contaminants to groundwater represents a significant concern. Provided the ground surface is sealed where spillages or leakages would occur and this material, and any rainfall runoff, is treated by appropriate waste water techniques, groundwater should not be adversely affected. Care should_ be exercised to ensure that an adequate area of ground is sealed and bunded at each possible point of spillage/leakage to contain such leakages, and that sealing will ensure that a long-lasting, imperfl\eable surface results. (iii) Discharge to Point Phillip Bay: It is proposed to segregate all contaminated waste waters (domestic sewerage, oily water, chemical waste water and that containing chlorinated hydrocarbons) for treatment by specialised processes; 11 Clean .. rainfall runoff being directed to natural watercourses. The treated wastewater would be discharged to the Bay via a diffuser at the end of a submarine pipeline, the quality of the discharge being subject to an Environment Protection Authority discharge licence~ Construction of the pipeline itself should have minimal environmental effects. The discharge should be licensed so that the water quality criteria outlined under the State Environment Protection Policy for the Bay, are upheld. ------~------
06.
(c) Air Emissions Concern over air emissions has been expressed in submissions by the Environment Protection Authority, Australian Conservation Foundation and others because of effects on the regional airshed and on birdlife in The Spit. The Environment Protection Authority has noted that the lack of data in these areas should be overcome before decisions on siting the plant are taken. All emissions to air will be the subject of Environment Protection Authority licences and some techniques for control have been outlined by the Authority. The leakage of toxic gases is a possibility that can be greatly reduced by incorporating appropriate technology into the plant design. The risk of damage from accidental leakages would be further reduced by the planned separation'of the plant from The Spit (setbacks of 200- 500 mare proposed); the planting of barriers of vegetation between the complex and The Spit would take the initial impact of any leakage and help to reduce downwind effects. The standards of the National Health and Medical Research Councfl should be followed to ensure the safety of workers from the release of tpxic gases occurring as a function of plant operations. Monitoring of toxic releases by instrumented equipment should be adopted to provide data for main tenance and improvement of equipment to ensure that leakages are minimal. The expected low levels of concentration coupled with dispersion away from the plant should ensure that the risk of damage to The Spit is minimised.
(d) Landscape Landscaping the site, particularly around the boundaries and adjacent to The,Spit, should be undertaken to help the complex to blend into .the land form. Consideration should be given to selecting plant material to provide additional and more diverse habitat for birds than currently exists on the site. Painting the structures in appropriate subdued tones will ensure that they do not detract from the effects of the planting. Night time "visibility" of the P.lant should be minimised by using low powered lighting where possible, elsewhere lighting with appropriately designed "cut off" features and so sited to minimise the escape of incident and rellected light rays from the site would be.required.
(e) Coastal Reserves and Public Access The Port Phillip Authority submission proposed a m1n1mum 200m wide Public Open Space reserve to be consistent with the definition of "coast" under the Port Phillip Authority Act, and to maintain the general amenity of the coast; 80 m is considered inadequate. However, provided major structures are located a minimum of 200 m from the coastline and no development other than minor works such as fencing, piping and access tracks takes place between 150 m and the 80 m reserve boundary, amenity and habitat values of the coastal strip should be maintained. Management of the 80 m Public Open Space reserve and the area between this reserve and the development line, together with the 200 - 500 m setback strips adjacent to The Spit. should be planned and undertaken in a co-ordinated manner. D7.
I A committee representing Fisheries and Wildlife Division, Melbourne ~ and Metropolitan Boards of Works, ICI and Geelong Harbor Trust should I be formed to look after management of these areas. This committee should liaise with Department of Transport to ensure continuity of I wildlife habitat areas within the Explosives Reserve with those managed by the committee. To maintain the wildlife values of the coastal reserves public access should be restricted and this would be in keeping with the current restrictions on coastal access through the Melbourne and Metropolitan Board of Works farm, Explosives Reserve, and quarry. However, since the coastal fringe is generally in public ownership the potential for public access should be maintained. Consequently, the two lOOm wide proposed coastal access strips should preferably be zoned Public Open Space, to be consistent with·theadjacent 80m reserve, rather than Industrial B, and lOOm wide access right of ways be provided for in the same locations. This would preserve both the options of access for ICI and for continuous public access around the coastline if required in the future.
(f) Construction Activities Earthworks associated with construction could result in erosion on the site and sedimentation along drainage paths. Precautions should be taken to prevent erosion and to stop eroded material from reaching sensitive areas such as The Spit; sedimentation ponds and catch drains may be required to intercept drainage destined for The Spit. Soil Conservation Authority should be consulted on appropriate methods of erosion and sedimentation control. Noise from construction activities is often· significant and consideration should be given to using quietened items of equipment, or alternative noise control measures, when working within 500m of the vegetated areas of The Spit.
(g) Off Site Services (i) Water Supply: Ideally the complex should be supplied with water obtained near the site (treated from the sewerage farms, groundwater, sea water) and the recycling of process water, rather than relying on high quality water being conveyed over considerable distances and future expansion of facilities for collecting same. (ii) Rail Spur, Port Facilities and Pipelines: If a rail connection or shipping berth were considered desirable in the future or if it were proposed to lay pipelines in other than existing-easements, the environmental effects of the alternatives should be examined and brought to the attention of the Environment Assessment Division (Ministry for Conservation); prior to detailed planning being commenced.
(h) Safety Proximity of the proposed complex to the Point Wilson Explosives Reserve and Avalon Airfield has raised questions in some submissions regarding the possibility of an aeroplane crashing into the complex or of an accident at ICI or the Explosives Reserve causing a sequence of destructive events. Heights restrictions around the airfield have D8.
_I been outlined by Department of Transport, but discussions with Department of_Tr~nsport regarding ~et backs from the Explosives I Reserve should continue to ensure that the latest standards are adopted. Height restrictions on structures should ensure that the complex does not present any unnecessary hazard to aircraft;
CONCLUSIONS The major concern associated with the project is the possible incompatibility of a major petrochemical complex being sited adjacent to a proposed State Wildlife Reserve. The Wildlife Reserve and its adjacent foreshore being the most important feeding ground for migratory waders in Victoria as well as one of the few known refuges of the endangered Orange-bellied Parrqt. If the development is to proceed, the safeguards relating to discharges to air and water, landscape, public access, construction, structure design and off-site services which have been discussed in preceeding sections, trigether with the safeguards outlined in the Statement (under flora, solid wastes and archaeology) should be incorporated in the rezoning proposal and detailed design of the complex. In addition, the conclusions of the Hearing Committee for Amendment No. 6 that are outlined in Appendix I are fully supported. A.committee comprising representatives of Fisheries and Wildlife Division, Melbourne and Metropolitan Board of Works, Geelong Harbor Trust and ICI should be set up to manage the Spit area, buffe~ strip (set back) areas adjacent to it and the coastal reserves; liaison with Department of Transport would help to ensure that wildlife management policy for theExplosives Reserve was consistent with those of the committee. Results of the avifauna study will provide a basis for the committee•s management as well as providing valuable information for the detailed placement and design of structures on the ICI property. 09.
APPENDIX .1
Conclusions of Hearing Committee for Amendment No. 6 (Statement p66 & 67) l. ON-SITE CONSTRAINTS Public Open Space The Committee's proposal for an 80 m open space reserve and two 100 m access corridors are discussed in the Assessment under .. Public Access". ''ICI Australia Limited should be requested to plan development adjoining the open space zone'so as to create a further on-site planted area of as great a width as possible, particularly along the eastern shoreline, and to set back structures, particularly high profile structures, well beyond this planted area. These requirements should become an integral part of development planning for the si~e . .. Public access to these open space reserves should be restricted and they should be managed under an appropriate management agree ment between the Fisheries and Wildlife Division, Ministry of Conservation and ICI. The foreshores should be designated Public Open Space (Flora and Fauna Reserve) as indicated on the Amendment as exhibited ...
Buffer Area. to The Spit "Most objections to the proposed Amendment focussed on the significance of The Spit and its adjoining swamplands and foreshore areas as a bird habitat, particularly for the rare Orange-bellied Parrot. It is clear that every possible step should be taken to protect The Spit from any adverse environmental effects associated with this development, and accordingly the Committee considers that the environmental investigation should be based on the principle of locating all chlorinated hydrocarbon plants to the west of the existing road to the Explosives Reserve. In any event the Committee considers that any works located east of the road to the Explosives Reserve should be located so that works areas do not drain to TheSpit catchment. This implies location south of the ridgeline crossing The Spit .. peninsula .. , or alternatively, on or slightly north of the ridgeline with appropriate 11 Catch-drain" provisions, to avoid ~rainage to The Spit. In addition, to avoid physical intrusion, effects.of noise, traffic, dust, heat and other ground level emissions, works should be set back around 200 metres from the presently vegetated areas of The Spit, and up to 500 metres from the normal tidal zone, as shown on the attached plan. D10.
The Special Building Line shown 80 metres from the title boundary on the Amendments as proposed should be modified to provide setbacks of this order, and no works should occur between that building lineqand The Spit area. ·The revised building line is indicated on the modified plan. The buffer area should be planted, and a management program agreed between ICI and Fisheries and Wildlife Division, including provision for controlled access for scientific and nature study purposes''.
.. Location of Plant Elements
11 The·Committee considers that many of the claimed environmental hazards set out in objections may not exist, or would be of minor significance if the location of particular plant elements is carefully planned and managed. This would involve location of plants with potentially noxious emissions to the south of the site, at as great a .distance from The Spit arid the M.M.B.W. Farm as possible, with suth locations and associated factors such as stack heights and permitted discharge levels to be subject to controls designed to influence the pattern of dispersal of such emfssions to maintain acceptable levels.
The pr~ferred locational option mentioned earlier is to have no chlorinated hydrocarbon plant east of the ~xisting road to the Explosives Reserve. This option should form the principal basis for the environmental investigation. 11
Access to the Site
11 The Corrnnittee considers that the principal access to the site should be along Dandos Road and/or Government Road, to avoid traffic impacts in The Spit area and to increase accessibility to Geelong. These routes could also provide corridors for major services, which··in turn should be located to avoid intrusion into the Lime burner's Bay area. These provisions would avoid obje dions regarding possible traffic noise intrusion in The Spit area. 11
ORDINANCE AMENDMENTS
'~a Land shall not be subdivided exce.pt with the permission of the Geelong Regional Commission; b No development shall be permitted other than in accordance with a plan of development prepared to the satisfaction of the Responsible Authority in consultation with the Geelong Regional Commission; c In considering any such plan of development the Responsible Authority shall determine in ~onsultation with the Geelong Regional Commission, if the provisions of Sub-clause (6) (existing Sub-clause 5) to this Clause shall apply and if so shall request the preparation of an Environment Effects Statement in accordance with the provisions of the Environmental Effects Act, 1978. 011.
[ d Such plan of development and any accompanying Environment Effects Statement shall be for the purpose of a decision by the Responsible Authority on the issue of a planning permit. Each plan of development should therefore be concerned· with major expansions of site operations and not with alterations within ~n existing approved plan of development which do not breach the intent of such approved plans or of permits issued. 11 D12.
APPENDIX II Analysis of Submissions
.Submissions were received from four individ~~ls, six private 6rgan isations and six government departments. - The majority of comments related to the quality of air emissions from the proposed ICI complex and the possible effect~ of these emissions on the bird life and habitat values of The Spit, and on air quality in the Melbourne and Geelong airsheds (particularly with regard to ozone levels). The possible detrimental effects of air emissions to the Orange bellied Parrot, whose rarity was consistently noted, was a concern which was often raised.
Effects from noise, artificial li~hting, the flare, changes to rain fall runbff patterns and erection of buildings or wires in the flight . paths of birds were factors raised to demonstrate the possible effects to avifauna, both the Orange-bellied Parrot and migratory waders that were noted to be subject to an international treaty signed by the Australian Government. The need for careful review of waste water discharges to Port Phillip Bay and construction of any port facilities was noted. In some cases there was felt to be a risk associated with construction of a chemical complex adjacent to an airfield and an explosives reserve. Erosion of the 11 green belt" between Melbourne and Geelong and concern that additional development would occur around, and on, the ICI site were noted. Some submissions questioned the evaluation of site selection criteria presented in the Statement and considered that alternative sites should have been more fully investigated. Concern was expressed over the need to maintain a coastal strip (wider than proposed was suggested) and public access along the coast. A summary of the submissions follows.
Mr. C. Winteringham The need for locating the complex near water sources, shipping or pipelines is questioned. One must look with grave suspicion at companies making profits directly proportional to the damage that they do. It appears unnecessary to locate the complex near water, cooling tanks could be constructed as an alternative. Dumping of waste products is suspected; the Mediterranean sea is polluted by allowing these kind of complexes. There is plenty of land a few miles inland, high and dry with no water to be affected, and the complex could be made self-contained, complete with large cooling and settlement tanks. We do not need to make the plastic items that appear as rubbish. 013.
Australian Conservation Foundation These comments deal only with the.air quality aspects of the proposal. The proposal highlights the need for a policy of air quality for Victoria. In the absence of such a policy, it is difficult to comment on the proposal. The A.C.F. recommends a policy position similar to that outlined in the U.S.E.P.A. Interpretive Ruling of 21 December 1976 which pro vi des 11 in genera 1 that a major new source may be· 1ocated in an area with air quality \'Jorse than a national standard only if stringent conditions can be met. .. 11 In the absence of alternatives the WHO goals are proposed as a standard; the relevant one for ozone being 5.6 pphm, not to be exceeded more than once a yea~. It should be noted that air quality in the ~1elbourne airshed is worse than the recommended standard. (or any creditable alternative). Acco.r9ing to the U.S.E.P.A. Interpretation Ruling, the ICI complex would be a major source of non-methane hydrocarbons (NMHC} and nitrogen oxi~e~ (NOx); these compounds are precursors of ozone. It is agreed that ozone may b~ regarded as the pollutant of greatest potential cbncern for Melbourne, but not only in the summer months. The relationship between emissions of NMHC and NOx and concentrations of ozone remains ·to be established. However, the annual report of State Pollution Control Commission for N.S.W. relates ozone concentrations to precursor concentrations,· and the indications are that ozone may be ·little increased under the conditions generally claimed for the ICI proposal, on a day when ozone concentration equals 8 pphm. This relationship needs to be verified for Melbourne.
In summary it is concluded that the proposal is a major new source proposed to be located in an area with air quality worse than the WHO standard. Two conditions should be required, namely: emissions should be controlled to the greatest. degree possible (a matter for E.P.A. licensing); and more than equivalent offsetting emission reductions should be obtained from existing sources (ICI should be required to develop proposals). The evidence available is insufficient to accept the suggestion that the proposed complex will have sufficient controls on air emission to enable operation without adverse effect on local and regional air quality.
Geelong High School Students - Ms. A. A~derson, C. Anderson, C. Jennings, B. Pittaway, R. Wells, Mr .. A. Bird, Mr . T. Trem a i n . Following an absence from The Spit during migration, the Orange bellied Parrot species may, on its return, be upset by industrial activity; this could be to its detriment. It is unlikely that the extremely rare parrot would move to alternative wintering grounds, and the parrot would become extinct. As plant structures are relatively close to The Spit, the physical and .visual intrusion, and noise levels will adversely affect the bird life. Much of the air emissions from the complex will be trapped at The Spit since it is down wind of the plant, possibly causing detrimental effects to the large number of wild-fowl. Dl4.
If at a later date port facilities are constructed adjacent to the Point Wilson site, the extra shipping in Corio. Bai would increase the amount of waste products deposited by ships and would assist in increasing the heavy metal concentrations in the Bay. ·An extra port in Corio Bay would call for more control of shipping. Fishing could be affected by the dredging of another channel leading to any new port facilities. Road traffic generated by the complex will result in an increase in traffic accidents. Dangers of the closeness of the proposed site to the Avalon Airfield are high~ _since.there is a possibility of an aircraft crashing into the complex, possibly resulting in leakage of chemicals from the site. Expansion of the production capacity of the complex is being considered, and this will result in higher adverse environmental effects. Arrangements must be undertaken soon to meet future fresh-. water requirements to thecomplex. With the waste discharged from the ICI complex into Port Phillip Bay, the M.M.B.W. farm will have to limit its disposal of effluents even more, and there are no feasible alternatives for thier discharge. · Conservation Council of Victoria ·The Council recognises that in response to objections to the original rezoning proposal, ICI has slightly modified its proposal. However, the Councii completely opposes the rezoning of land at Point Wilson to industrial use. It appears that a major proportion of the population of the rare Orange-bellied Parrot uses the area, and could be affected by the proposed development. It is unrealistic for a decision on land use to be made until an adequate study has been done on the parrot and general bird life of the area. Eroding the green belt between Melbourne and Geelong must not be allowed to occur. The Statement does not supply sufficient information on the effects of the effluent pr6duced, on the Bay, air~ groundwater or the possibility of inversions .. If studies show that the Orange-bellied Parrot depends on this area, either the Heritage Commission or the World Wildlife Fund should be approached with a view to purchasing sufficient habitat land. With regard to the objectives, it is considered that the environmental needs of this particularly sensitive area cannot be adequately met, and that the responsibility for proving there will not be any environ mental damage rests with ICI. That the site complies with environmental and community objectives is disputed; also, it does not have compatibility with adj~cent land use. The site has not been shown to have satisfactory access to water with adequate mixing qualities, and there are n~ means to disperse heavy metals. The. site represents a major intrusion into the planned separation between Melbourne and Geelong. Development could significantly reduce the habitats and ranges of avifauna in the area due to restrictions on flight paths, general disturbance of the area, noi~e and deterioration of the coastal water due to effluent. 015.
While purchase of the whole site for conservation ~nd recreation would be difficult to justify, it is suggested that purchase·of a smaller area to protect an endangered species and other bird life, and the i~tegrity of the coastline would be highly desirable. Also the complete buffer zone should be at least 500 metres and should follow the five metre contour line. The· building$ from which noise or activities emanate should be located away from the sensitive areas, and masked by other buildings or tank farms. Relocation of.the Commonwealth Road co3ld have a greater impact on The Spit that the present road; Commonwealth access should be along Dandos Road. Chemical plants must be operated according to the best practicable technology for emission control, with stringent controls set by·the Environment Protection Authority. The Spit area must·not be drained into. The height limitations of Avalon could be more flexible to enable the stacks to be located outside the parrots' flight path. The buffer zones must not be zoned industrial. It must be quite clear that the Geelong Regional Commission will not allow the site to be other than low density. Recommendations regarding flora should be implemented. Due to the lack of scientific study, decisions .regarding the location and design of the plant are premature. It appears that the stacks will intrude upon the scenic viewpoint of the Bellarine Peninsula. Air emissions could be detrimental to the operation of the M.M.B.W. farm. There appears inadequate consideration of the concentration of ~missions which could fall on the buffer zone, and its effect on the vegetation therein which is vital for the p~rrot habitat. The lack of information on the effect of ozone levels requires more consideration. The development is in conflict with the State Environment Protection .Policy fo~ Port Phillip Bay. Any addition of effluent to this area of the Bay is totally unacceptable; tidal flushing of the area is minimal. No explanation is given as to the source of chemical and oil contamination from 30 hectares of run-off. The complete waste water situation appears unsatisfactory and further investigation is warranted before any decision is made. Also, the descri.ption of disposal of solid wastes is inadequate. Regarding water supply, there is evidence to suggest that the unit cost of tertiary treatment of effluent for industrial purposes from M.M.B.W. farm is considerably less than the unit cost of .winning new and more distant catchment water. Alternative siting of the complex on land already zoned industrial east of Point Henry, a less sensitive area, could be investigated.
Melbourne and Metropolitan Board of Works The Board generally considers that the Statement is reasonably sound but does not provide adequate detail on a number of environmental and technical matters, particularly with regard to the unique location of the Point Wilson site. The Board wo 11 ld expect that progressively more detailed statements would be prepared and made available at· the planning permit application and Environment Protection Authority licence stages, should the company's proposal proceed. D16.
Detailed investigations of the many aspects of· the effects of the waste discharges have apparently not been undertaken, and in this regard the effects of the temperature of any discharges on the extent of phytoplankton growth in the waters of the Bay is one issue of concern. The Board is licensed to discharge to the Werribee segment, ·and the effects of additional discharges to the Werribee and Corio segments need to be carefully considered .. The Board would recommend that the company become involved, through the Joint Advisory Committee, in the Phase 2 study of Port Phillip Bay. Monitoring programs to determine the existing and future status of water quality, where liquid effluents might be discharged, the air quality above Point Wilson, and the yield and composition of the M.M.B.W. farm's pasture in the areas immediately adjacent to the Point Wilson site ought to be undertaken and possibly be incorporated as part of any Environment Protection Authority licence conditions. Any pipeline linking the ICI complex to the Altona petrochemical complex should be the subject to a separate Environment Effects Statement. The Board is also generally concerned that the land is to be zoned for noxious industry and that this might encourage further rezonin~ in the Point Wilson area.
Fisheries and Wildlife Divisio~
There is nothing in the Statement which suggests that the Di~ision should amend fts opposition to the proposed development. Rather the Statement reinforces the concern as to the probable impact of the proposed development on wildlife, especially the Orange-belled Parrot. The Statement glosses over the wildlife aspects incorporating many bland unsubstantiated statements on the likely impact on wildlife. The Statement does not consider the need for detailed assessment of the likely impact on wildlife values. This would include simulation studies of the impact, e.g. of noise; Northern hemisphere studies have indicated a significant effect on wildlife values by man-made structures and noise. The report does not cover the impact of physical structures (stack height, guy wires) or of lights on wildlife. In particular, the Point Wilson site does not meet site selection criteria I (Environmental and Community objectives) and VI (provisions of adequate buffer space). In addition, criteria XI (access to water body for adequate treatment of effluents) implies discharge which could affect fish and wildlife values. The listing of land ownership, rather than land use, ignores other adjacent land uses, including wildlife conservation and The Spit.· Changes of land use should be in the interests of the .people of Victoria, or Australia, and this may or may not be to the economic benefit of Geelong people .. In view of the proposed capital input by ICI, and the nature of the proposed plant, the development does not seem to be "low intensity industrial development". Nor will the development of the plant provide .~~.better opportunities for the effective management and conservation of the significant habitat areas". Public comment indicates that adverse effects on adjacent wildlife habitat will be minimised, but not eliminated. Diagrams in the Statement indicate re-routing of the road to the Explosives Reserve, thereby increasing the length of road in close proximity to the Spit, especially the section of road on higher ground and on the skyline as viewed from The Spit. 017.
The Division would prefer·to se~ an objective a~sessment of the flora of the area made by the Herbarium. The grasslands are of value as wildlife habitat. The Division is aware of data on the Orange-bellied Parrot overwintering in Port Phillip Bay (The Spit only) and at Robe in South Australia, and of data on the parrot at Port Fairy, but not at King Island. With regard to 11 0therwetlands birds 11 the M.M.B.W. farm occupies large areas of former swamp land which contained breeding colonies of birds. · The Comments on the effect of noise on wildlife is an unsubstantiated statement, and probably inacctirate. This perhaps is orie aspect that the ICI sponsored bird study should investigate, preferably by a simulation on site. The Statement does not provide details of the study which should be for a period of at least two years to tover seasonal and annual climate variation. The Statement implies that the development of the· site by ICI is compatible with the Port Phillip Authority classifications. The Division and the E.P.A. would dispute this. Also the Statement implies that the values which resulted in the classification would remain after the development; this is only an assumpiton. The likely effects of emissions b air on birdlife in the area are not understood. Continued liaison between E.P.A. and the Division is needed on this aspect. It would appear that, since run-off from developed parts of the site would need to be diverted, the water supply to the lagoon part of The Spit will be further reduced. It was hoped that the avifauna study was to investigate the impact of noise on the birds of the area. It would seem that ICI have already concluded that the noise they might generate will not affect wildlife.
I Geelong Environment Council The Council sees no reason to modify its opposition as already expressed to the Geelong Regional Commission. It is essential that no decision be made on the future land use until studies of the Orange bellied Parrot are completed. Studies indicate that the world population of the Orange-bellied Parrot may be very low an9 that most of the birds in existence rely on the Point Wilson area for their winter habitat. The establishment of a petroc~emical plant in such proximity to their feeding grounds could cause the extinctiori of the species. The value of the adjacent nature conservation area to migratory birds species has not been adequately evaluated and considered in the proposal. The Statement does not supply sufficient information on the effects of fall-out of gaseous effluent which would adversely affect the salt marsh vegetation and the physiDlogy of the avifauna. The further pollution of this portion of Port Phillip Bay; which has very limited dispersion properties, is unacceptable. Intrusion into th~ Melbourne-Geelong buffer zone is unacceptable and presents a risk of high density industrial development eventually occurring. Land near the coast should be purchased to ensure its continuing value for conservation purposes, or ICI should re-site the plant on the property and· allow perhaps 80 hectares of the coastal ·area to' be zoned and managed for wildlife by the Fisheries and Wildlife ~ivision. 018.
The desirability of further industrial development in the Geelong district is.not disputed. It is considered that the environmental objectives cannot be met in such a significant and sensitive . conservation area. More scientific study and evidence to pr.ove there will be no detrimental effects are required. Industrial land east of Point Henry could perhaps be considered. Compatibility with adjacent land uses is disputed. There is a risk of accidents associated with the airfield. The Bay in this area does not have adequate dispersal qualities. The problem of heavy metals in the effluent is not discussed. Proliferation of services or allied industries on the site is a definite hazard for the future. Further degradation of the coastline is to be deplored as it will reduce the ability of the western shores of Port Phillip Bay to provide the marine wet land and coastal habit~t so important to migr~tory species. Development of the ICI site will significantly reduce the habitat and the range of avifauna in the area. Objections to the rezoning indicate a broad based concern for the problem associated with large scale industrial development in a significant conservation zone, and ·the stated need for adequate scientific fact prior to decision making. There is insufficient information on the pollutants being produced and the quality of discharges would require stringent control by the Environment Protection Authority. The stacks should be located away from the Parrots• flight path. The buffer zones should be a minimum of 500 metr~s and should be zoned flora and fauna reserve, not industrial. The proposals for the preservation of the existing native flora and program for re-vegetation are supported. A further setback of the buildings would be advantageous. Results of the studies on the Orange-bellied Parrot should be considered in the decisions regarding plant layout. Some concern has been expressed that an industrial plant on the bay side would be a visual intrusion when viewed from the Bellarine Peninsula. Restricted public access to the foreshore and Spit areas is supported. Air emissions could be extremely detrimental to the bird life and vegetation of The Spit and M.M.B.W. farm areas; insufficfent information is available to evaluate the risks involved. Zero discharge to the Bay must be aimed at. No discharge must be allowed into The Spit area. Use of the Bay for dispersal of any waste water containing effluents is a concern. The possibility of using treated effluent from the M.M.B.W. should be investigated.
Environmental Studies Section (Ministry for Conservation) The objectives of the proposal have not been adequately described. There is insufficient information on the need for the plant and its location in Victoria. Government funding would be involved, indirectly through provision of additional facilities and services, so~ section on financial feasibility should be included. The list of site selection criteria does not specifically cat"er to the need for maintaining or enhancing the quality of air, water and land environments. A rating scheme would have. assisted in a comparison of the attributes of alternative sites. Regarding alternative land uses for the site, other uses may appear more attractive if the real trade-offs between econonomic benefits and environmental quality of important assets such as The Spit, were examined in greater detail. 019.
A more detailed plan and a prov1s1on of alternative development futures would allow a better assessment of the proposed complex. No reference is made to the ·precautions undertaken in the use and storage of highly inflammable materials. The compatibility of the complex with the explosives reserve and airport, particularly in terms of ·safety, have not been discussed. · The disposal of organic and more particularly chemical sludges, and the possible effects on groundwater quality of any possible land fill disposal schemes, are significant issues _which have largely been avoided. While an analysis of risks a~sociated with major pl~nt breakdowns, and consequent discharge of toxic chemicals to the atmosphere, has been outlined verbally to the Board•s officers, such information should have been indicated in the Statement. The use of reclaimed water from the M.M.B.W. Werribee sewerage farm should be seriously considered. Detailed plans·for a system of transport and descriptions of materials to be transported should be presented for a proper assessment as the effects on the environment will differ according to the mode of transport and the type of material transported. The alternatives of utilising existing port facilities in Geelong and a shipping facility adjacent to the ICI site should be thoroughly examined and weighed in light of their ·environmental implications. The maintenance of the natural vegetation occurring in the salt marsh environment is vitally important for the preservation of a salt marsh such as The Spit. Studies indicate that the upkeep of natural water ·-flows is necessary for the maintenance of suchvegetation. No mention is made in the Statement of the damage that unpolluted stormwater runoff can cause to the vegetation of a salt marsh area, and recommendations for retaining the central area of the site dominated by 11 Juncus .. have apparently been ignored (Ref fig. 15). The possibility of endangering the very rare Orange-bellied Parrot, a 1ocal i sed species, is not noted in the Statement; the 120 or so birds sited in the area in the past may represent a substantial portion of the Parrot population. Should the possibility of endangering an entire species exist, more stringent measures for protection of the bird and its habitat will be necessary. The problem of the potential lethal effects of th~ intrusion of high structures into the ~igration paths of birds has not been examined in the Statement. ·A buffer, in the order of hundreds of metres, may be required to provide adequate protection of the avifauna. Use of the Port Phillip Coastal Study as a source for landscape assess ment for the entire site is misleading; the report covers only the coastal boundaries. The complex will be a major intrusion on the landscape. It is important that effects on the night-time vistas be reduced by measures such as special shading of lights, minimal night time use of waste gas flare, etc; there should be covered as conditions of the planning permit. Public access to the foreshore area is a right which should be removed only if absolutely necessary, such as for reasons of human safety, and/or wildlife management. This should be made a condition of development of the site. Potential effects of air emissions on the-vegetation of The Spit area have not been·considered. The air quality standards, quoted in Table 4, apply only to human health and are not sufficient for analysing the effects on vegetation. 020.
It is likely that the major source of precursors for ozon~ originate in the Ge~long area. The assumption that low sulphur fuel ·oil will be economically available thorughout the life of the plant is questionable. A more accurate prediction of the concentration of emissions from boiler stacks would be yielded if calculations were more on the basis of inversion conditions. The calculations of ground level concentrations should include the sum of all contributions. Better estimates of ground level contributions may reveal the need for basing standards on local conditions. The· suggestion that the release of a large quantity of phytotoxic material will h~ve only a minor or temporary effect on the surroundings is unsubst~ntiated. No data is offered to support the notion that the air quality in the region seldom approaches pollution levels experienced in other countries: even so, this would fail to justify increasing the amount of pollution in the.region. The combined emission of. nitrogen oxides and hydrocarbons from the plant will be a significant source of pollution, particularly for a basically rural area otherwise free of petrochemical smog. The Statement makes no reference to the odour problem, which is characteristic of petrochemical plants, and can have undesirable effects on surrounding communities. Apparently no consideration was given to the possibility of ammonia from the r~.~1.B.W. farm combining with ac:id emissions, such as hydrochloric acid, to cause a I!Teeside 11 type smog. 11 Best practicable emission control technology~~ may not be adequate in terms of protecting the environment, Utilisation of the 11 best available emission control technology 11 would be more compatible with meeting environmental objectives. There· is some concern over the effect of direct discharges to marine environments which are poorly flushed. An accumulation of hydrocarbons and chromium in the sediments may have acceptable short term effects, but unacceptable long term effects on the marine ecosystem. rt is important that increases in polluted, turbid and fresh water are not allowed to enter the salt marsh area. Measures to retard·the drainage must be undertaken, while ensuring a base flow of good quality water to the marsh areas. As groundwater is important in maintaining the salinity regime of a salt marsh, any disruption to the ground water system will need to be carefully assessed. The proponent should ensure that waste water discharges are of a sufficiently low temperature in the vicinity of the discharge, so as to keep temperature variations of local water at a minimum. It is recommended that the discharge limits for oily waters meet the proposed MRC for hydrocarbons of lppb (soluable aromatics) in receiving waters. Water from EDC and VCM plant~!are unlikely to be entirely free of high molecular weight chlorinated hydrocarbons, including EDC tars and other materials. Indications exist that petrochemical plants may produce and discharge traces of by-products unknown to the company, thus the most stringent monitoring of both effluent and environment for any halogenated hydrocarbons should be applied, preferably by an independent body. Continued plant operation should be conditional on meeting guarantees of no halogenated hydrocarbon pollution of water, biota or sediment. The maximum possible recycling of waste water should be undertaken both to minimise the discharge of EDC (lOppm in a minimum net discharge volume) and to facilitate monitoring .of higher molecular.weight chlorinated compounds. It is essential that th~ quantity as well as quality is specified in the licence conditions established by the D21.
Environment-Protection Authority; account must be taken of the total r load. A concentraLiu11 ur l!JIJIII ·in the receiving waters is an unreasonably high concentration of EDC or any chlorinated compound. ·The flow of additional suspended soiids·into the salt marsh area and Bay during construction will post difficult problems, such as those connected with the blanketing of vegetation. Such problems need to be anticipated and appropriate measures taken to correct them. The Statement failed to examine the potentially large environmental impacts of port development, transport, power and water supply. Plans for such additional facilities will have to be presented in detail, before a proper assessment can be made. There is a case for the additional capital cost of services to be charged to the proponent.
Port Phi 11 i p Author1 ty (r~i ni stry for Conservation) An 80 metre wide public open space strip is inadequate. There should be a minimum of 200 metres of public open space between the ICI land and the coast. This is consistent with the definition of 11 COast 11 under the Port Phillip Authority Act. This 200 metre strip should be surrendered to the Crown by ICI and managed by an appropriate local authority, with assistance from the Fisheries and Wildlife Division. It must be clearly and conclusively demonstrated that the Point Wilson explosives jetty is either unusable or unavailable before ICI are permitted to develop alternative berthing facilities for large craft in the Point Wilson region. Facilities for loading and unloading of vessels are inappropriate in an area gazetted for Nature Conservation under the Port Phillip Coastal Study.
Geelong Field Naturalists Club The Club continues to express opposition to the rezoning since: the development of the site as proposed places the Orange-bellied Parrot in danger of extinction; the incompatibility of this use with those existing on adjoining land; the rezoning will destroy the 11 green belt 11 which must remain between the Geelong area and Melbourne; and the amounts and nature of effluents released in the Bay and air ~re unacceptable. Rezoning and permits to proceed should be refused. The world population of the Orange-bellied Parrot may be between 100 and 200 birds. During the winter of 1978 some 50-60 were present in the Point Wilson area. Studies launched by ICI and the Fisheries and Wildlife Division are incomplete. Results in 1978 cannot reflect the normal conditions encountered because of different rainfall figures. Indications are that t~e minimum time needed to obtain representative answers from the studies would be at least 5 years, and preferably 10 years. The Club contends that to proceed with the ICJ development. project where there is a chance of bringing about the extinction of a bird species, is premature; to approve ~uch a project, without knowing the result of the development is irresponsible. There seems to be .a substantial conflict between the proposed development and the existing uses of adjacent land. Components in the air-borne emissions may cause deterioration in vegetation on the M. M. B. W. Farm. 022.
It is an unwarrant~d risk to build a 'plant of this nature·~ithin such close proximity to ~n aircraft landing fi~ld. (Avalon) and adjacent to an explosives storage area. There is complete 1ncompatibility between the construction and operation .of an industrial complex of this form and the maintenance of a wildlife reserve (The Spit and ·environs) which is acknowledged as being of national, even inter national significance. Point Wilson is the last substantial "green wedge" in the Geelong Werribee block. It is unrealistic to consider that ICI will·remain a "low density" industrial complex in the long term. Avalon Airfield will become obsolete and there will be ~ressures to develop this site. If ICI exists there will be no precedent to refuse such development. Point Wilson will be "over-run" by development, as occurred at Botany Bay. Ancillary industries will be required by ICI, and logically some of these will be built and developed as close as possible to the "parent" plant. It is impossible to halt development once it begins.
The Bird Observers Club The Bird Observers Club remains totally opposed to any rezoning and any industrial development on the site. ICI has not shown that a petrochemical plant is needed in Victoria. The plant at Botany is capable of being expanded. If other companies are examining proposals for ethylene plants, their proposed locations should be examined . . Given that ICI has recently decided to shelve a£80 million VCM plant at Wilton, England, and there is a well known drop in consumption of plastics generally, the need for the Point Wilson plant is further questioned. The advisability of siting a large and potentially dangerous or explosive chemical plant next to an explosive storage area is doubtful; processes used will be mostly high pressure and high temperature reactionsas at the plant at Flixborough, England, which exploded in 1974. The need for wide buffer zones is questioned as this implies that the plant will affect "aesthetic quality of life and safety". If the smell, noise, discharges, traffic, night lights are likely to affect commercial and residential land-users, then these will also adversely affect wildlife. With regard to site selection: the current requirement is for Rural (General Farming), which is incompatible with industrial use; the explosives depot has a simple wharf, which is far from being "port facilities•• (expanding this wharf would increase the risk of pollution through collision of ships); access to land transport routes does not argue particularly in favour of Point Wilson; good access to Melbourne markets argues in favour of the site at Altona, not Point Wilson; compatibility with the explosives depot, airfield and sewerage farm is questionable; service industries do not presently exist anywhere near the siteand will have to be created; Geelong is ·the only area within commuting distance and it does not have a surplus of technical or skilled labour (labour would be imported from r~elbourne or Interstate); except for a powerline, no services exist at Point Wilson; the existing road access is inadequate. r D23. r The photograph on Page 8 (Statement) clearly shows that the petro chemical· co~plex couTd ·be fitted into existing space at Altona. ICI has· chosen the Poirit Wilson site because it was convenient to acquire· it: the Company is now gambling on a rezoning decision to meet its needs. The site should continue to be used for farming, but the area immediately adjacent to The Spit, along the shore, should be given to the Fisheries and Wildlife Division to administer as a nature reserve. The proposal that subdivision of the land should be ·prevented is supported. Requirements on building heights and distance from Avalon Airport and the buffer zone on the eastern and southern shorelines, effectively force the plant buildings dangerously close to the explosives store. The Orange-bellied Parrot may face extinction as a direct result of interference at its wintering grounds. No guarantee can be given that this will not happen if the ICI plant is constructed in any form. Despite more than 600,000 records by about 2,000 observers 'since January 1977, the only winter sightings of the Parrot have been at The Spit, and possibly at Swan Island. The figure of 120 birds previously reported is an extremely low number fti~ any bird or animal population and clearly indicates that the slightest disturbance could have serious adverse effects. No one can predict what will happen to this unique bird and therefore any development of any sort on the site is objected to. The effects of buildings, lights and a flare on the flight paths of birds, and especially migratory shore birds and the Parrot, both of whom are known to.fly at night, could be substantial. The proposed development is in the direct line of an existing flight path from The Spit to the Cheetham Salt Works~ No flare should be permitted on the site. An agreement between the governments of Australia and Japan provides that each shall endeavour to establish sanctuaries and other facilities for th~ management and protection of migratory birds and those in dnager of extinction, as well as measures to protect and enhance the environment for these birds. Nothing in the proposed development will preserve ~nd enhance the birds 1 environment but is more likely to destroy it. The petrochemical plant will be an intrusion to the landscape. The stacks will be visible for many miles in any direction·. Recent demonstration of the toxicity to humans of VCM is of concern, but it appears that no work has been done on its effects upon the environment. Similarly, the NHMRC safe working levels for VCM are calculated for humans. Wildlife is frequently more sensitive to toxic che.micals than humans, and birds in particular have a well doc~mented sensitivity to chlorinated hydrocarboms, which are the same chemical type as EDC and VCM. The incineration process (for EDC tars) is of concern since the tendency of organic compounds such as these is to form volatile carcinogenic compounds on heating, and the possible liberation of these compounds into the atmosphere exists. ICI has ignored the real danger of EDC and VCM in the environment, which exactly parallels the dangers of chlorinated hydrocarbon pesticides in the environment. These chemicals even at minute concentrations are picked up by micro organisms and stored in body tissue. Concentration of these chemicals in the food chain occurs irrespective of the actual or original concentration of thechemicals in the environment. Low initial concentrations merely take a longer time to show their effects. 024.
In summary, the proposed development cannot but have an adverse l effect upon the Point Wilson area, and in particular; the avifauna.
Royal Australasian Ornithologists Union A number of questionable and unsubstantiated statements are included in the Statement, particularly about the Orange-bellied Parrot, and little account seems to have been taken of the fact that birds fly across the proposed ICI site. No real attempt seems to have been made to meet the objections set out in the Union's evidence and that of the other objectors, other than the undertaking of studies. On the basis of the studies, would ICI seriously consider a decision that the plant should be located elsewhere? The Union still contends that the location of the site in the area proposed is likely to push an extremely rare bird further along the path to extinction and that ICI has so far produced no evidence to show that this will not be so.
Mrs. A. M. Swan Satisfaction that "All environmental aspects raised during the rezoning hearing can be adequately protected" should not be expressed until the study of bird life has been properly assessed. The Statement has been published too soon, before all environmental data has been presented; particularly regarding the Orange-bellied Parrot. If studies indicate that bird activity would be adversely affected by fumes or structures in their flight paths, and if those structures cannot be moved west owing to aircraft, the whole site is unsuitable for this form of development. Since much of the raw material and finished products will have to be transported to and from the site, financial advantage of a coastal site with expensive port facilities cannot be great. Mixing of the effluent with waters of-the Bay needs more study. The environmental consequences of establishing port facilities in the vicinity have not been included in the Statement; this is a most important factor to be taken into account before any decision is made. Existing port facilities should be fully utilised before new ones are built. Atmospheric inversions are recognised as a possibility with gases drifting towards the lagoon and The Spit. Has a complete shut down of the plant been considered under adverse conditions, and is such a shut down actually possible? Possible pollution of the lagoon by noxious fumes has been discussed, but the levels of pollution tolerable to birds or the organisms on which they feed have not. Birds can be used as indicators of pollution, but need special protection if they are to survive successfully in their ~an-managed environment. If the proposed plant is allowed close to prime bird habitat there must be provision for a swift shut down if needed. If this is not possible, ICI should seek another site. 025.
The fact that ICI seeks a site remote from housing indicates that the environs will be unpleasant for ordinary living; or dangerous. Yet thousands of birds at The Spit will be expected to tolerate this. The Spit in summer is by far the best area around our coast for the international migratory waders; these birds and their habitat are protected by an international treaty signed by the Australian Government, which we are bound to respect. The planning map of the proposed Amendment (ref Statement) does not agree with that published in the report of the Port Phillip Authority. If these are both correct, then more foreshore reserve is to be alienated by the Amendment and the two areas marked "Coastal Access". While it is appreciated that public access has to be controlled for safety and security reasons around the. explosives site, no more coastal land should be alienated for·access to the ICI site, since it is important to maintain coastal access for the public; e.g. the BP jetty and pipes at Crib Point have been carefully designed to allow public access along the coast in contrast to miles of alienated coastline at Long Island Point. The Premier has given assurance that concerns relating to public access along foreshore reserves would be borne in mind. A public walking track along the coast and linking the two segments of coast between the explosives area and ICI site is suggested. The two alternative coastal "access-to-ICI" sites should be removed from the Amendment and the land remain Crown reserve. These sites could be borne in mind for future alternative sites for a pipeline or jetty, but they should be regarded as alternatives. Until an Environment Effects Statement is produced on the effects of port works ahd until the results of the bird study are available, it is· impossible to say which alternative access route would be less environmentally damaging. Decisions about landscaping buffer zones or boundaries should be made with full recognition of the existing flora and its value to birds, particularly the Orange-bellied Parrot. Alteration of surface drainage due to building requirements could change wildlife patterns in the salt marsh, to the detriment of wildlife habitat.
Shire of Corio Council resolved; "That the Council note the Environmental Effects Statement and considers that nothing has been revealed by the study which would cause the Council to reconsider the proposal to rezone the land. Further, Council reaffirms its belief that the development of the Point ~Jilson site and the manner proposed by ICI will be of considerable economic and social benefit to the Geelong region, particularly with the large-scale capital investment envisaged and the employment during the construction period of more than 1000 people.
Council noted also the fact that benefits will accrue to local industries and businesses which will supply the proposed plan with goods and services." Council supports the rezoning and requests that the rezoning be expedited as far as possible. 026. l Environment Protection Authority Meteorology of the Geelong region is not known ·in detail and there is reason to .be concerned about emissions. The 3.00 a.m. and 3.00 p.m. wind roses cited for Corio do not cover the critical periods for wind direction change nor wind patterns at the ICI site; wind patterns can change dramatically with time and plume trajectories undergo direction reversal under complex recirculation patterns. Emissions from ICI would contribute to ozone levels in the Melbourne airshed, and also influence ozone levels at Geelong, Werribee, Bellarine Peninsula and Mornington Peninsula bayside suburbs. The frequency of surface inversions in the Geelong area is quite high. Based on concentrations provided in the Statement a plume height of 200 metres can be inferred; emissions would be trapped within inversions with a high frequency possibly resulting in fumigating conditions. Increased ozone levels after such inversions are likely. Stack height restriction imposed by the airfield makes a stack height solution questionable. On. the limited ambient data available for the Geelong region there is cause for concern for ozone levels. Ozone levels exceeded WHO goals on 21 occasions and the US standards on 10, while the Japanese NO standard was exceeded 6 times and the maximum desirable Canadian CO level once. Elevated levels for NO and the Airborne Particle Index are also important. Emissions could affect already elevated ambient levels in the Geelong and Melbourne airsheds so that further monitoring and meteorological studies are necessary. Table 5 indicates an emission of NOx (as N02) of 8.6 t/day (or 4.3 t/day if halved according to NHMRC) but on page 41 of the Statement 4-5 t/day is stated. Newport emissions. The proposed 60 m ICI stack must be compared with the 180 m Newport D stack. The relatively large emissions and their relatively low proposed height could affect ambient levels of ozone, particularly when combined with the large hydro3arbon emissions. It is advisable that NHMRC levels for NOx (0.5g/NM ) be adopted as an upper limit; there is a strong case for reducing these levels by some factor if the proposed location is adopted. Fluidized bed combustion, if solid fuels are used, and possible flue gas NOx removal may be involved. Particulate emissions would need strict control and bag-houses would be necessary. Emissions of hydrocarbons and NOx could represent 0.4 and 1% of emissions to the Melbourne airshed (1990), but 6% and 18% to the Geelong airshed (large additions to this a i rshed). Other emissions are listed but not quantified. A safety factor is routinely applied by the Authority to NHMRC hygiene standards to cover non-occupational exposure and the presence of these emissions and other contaminants in combination. The effects of low levels of these contaminants, andshort tenn large levels (unplanned releases) on adjacent processes (e.g. M.M.B.W. fann) are not known and should be evaluated by relevant experts. Dealing with hydrocarbon release by flaring is unacceptable, unless a satisfactory design can be achieved . to effect complete hydrocarbon combustion to overcome noise and glare. ' ~ 027. l The ICI proposal would involve emission of hydrocarbons and NOx (precursors of photochemical smog). The effects on ozone levels are of concern. Meteorological and ambient monitoring in the Point Wilson-Geelong area, and ambient monitoring at Werribee should be undertaken before irrevocable decisions on siting the ICI complex are undertaken. Otherwise it would be necessary to maintain emissions well below levels indicated by the use of advanced and developing technology, and it may be appropriate to apply the emission off-set principl~ (as in the US where ambient standards are exceeded). ICI would be expected to design and plant to meet noise levels at any noise sensitive areas (i.e. residential areas).
Off-site incin~ration facilities for combustible oils are currently unavailable unless at another chemical plant. Run-off from the 7000-8000 t of boiler ash could have a high T.D.S. and contain selenium; more details of the ash analysis is required before it could be directed to a municipal tip. Iron sludge from the EDC plant could be highly odorous and unacceptable at a municipal tip. The local tip could not be licenced to accept brine sludge if mercury were present. Insufficient information has been presented to assess toxicant levels .. particularly heavy metals and chlorinated.hydrocarbons. Temperature of 350C for discharged effluent could be excessive. The possible effects of ICI discharges in combination with those from the M.M.B.W. farm should be evaluated. Details of hydrodynamic studies would be required in any application for a waste discharge licence. Studies should commence as soon as possible, possibly in conjunction with M.M.B.W. work. Pre-discharge monitoring of toxicants in filter feeding organisms could also be useful for the purposes of licence assessment. All discharges would be required to contain no visible oil or grease. Final waste discharge requirements can only be specified following detailed application for a licence; having regard to any public comment, objections and appeals.
Mr. I. W. Penna The Statement has confined discussion to the issues surrounding the actual site and has not discussed the broader planning issues that are involved in the project. The Statement should be rejected since it does not follow the guideline principles expounded, and the discussion of impact of the project on the site, adjacent land and Bay are inadequate. ICI should detail a policy for public health and environmental safeguards. Alternative land uses are not adequately discussed. An adequate Statement requires more than 3-4 months preparation. Insufficient detail is known about the plant to allow a proper evaluation of environmental effects. Human costs have not been discussed; only benefits to the Geelong region. There is no discussion of the effects of greater usage of land transport, nor of the effects of the proposal on the Orange bellied Parrot (or on the maintenance of its habitat). Consultant's reports on the potential effects on the Parrot must be made public. The effects of air emissions are not discussed. Port Phillip and Corio Bays are already polluted; more investigation is required into the standards for ICI waste water disposal. The location and disposal method for non-aqueous liquid by-products and wastes are not discussed. 028.
The Statement does not discuss major areas of concern and should be rejected. The need for the complex ha~ not been checked and approval of the project would set a dnagerous precedent, with grave implications for the usef~lness of the Environment Effects Act (1978). Approval of the project may help prevent constructiqn of competitors• plant,.but it will be without determining the full social and environmental impact.
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