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View Submission Dan Monceaux Force of Nature http://forceofnature.eco To whom it may concern, Please accept my submission below in response to the proposal to construct and operate at port at Smith Bay on Kangaroo Island’s north coast. This submission seeks to detail and highlight the significant risk that the establishment of regular international shipping to Kangaroo Island poses. It is my view, based on my own comparative observations of the ecology surrounding port and maritime infrastructure in South Australia, that the introduction of exotic species to Kangaroo Island will be an inevitable consequence of the approval of this proposal (should that decision me made). I have come to appreciate that bio-security resources in South Australia are very limited, so much so that removal or eradication responses to the detection of introduced species are rare. This port proposal, if approved, will inevitably alter the composition of the ecology of Smith Bay with unknown long-term consequences. The surrounding ecology of the north coast and other parts of the island may also be at risk if introduced organisms find local conditions favourable and proliferate beyond the port area. Once introduced, total eradication of any introduced species is almost impossible to achieve.[1] Given that Kangaroo Island has had very few records of introduced species, and its reputation is one of “a place apart, of unspoilt nature”[2] it is in my view, not environmentally acceptable to establish a new international shipping port on Kangaroo Island at all, given the project’s inevitable detrimental impact to the island’s inshore marine ecology. Ships’ ballast discharges and hull fouling provide proven pathways for the introduction of various exotic organisms. Status of exotic marine species on Kangaroo Island I have been visiting Kangaroo Island, and occasionally snorkeling there during annual visits from 2009 to present. During this time I have rarely seen evidence of introduced species. On a recent visit to Kangaroo Island, I looked specifically for evidence of introduced species at three locations: Kingscote, Penneshaw and Bay of Shoals (all located on Kangaroo Island’s north coast, east of Smith Bay). No introduced species were found at Penneshaw jetty. Only the Spaghetti bryozoan (Amathia verticillata) and the pleated sea squirt (Styela plicata) were found at Bay of Shoals’ boat ramp. Beneath Kingscote jetty, the Branching byrozoan (Schizoporella errata), the Spaghetti bryozoan and a single European fanworm (Sabella spallanzani) were seen and photographed.[3] These records were all uploaded to iNaturalist, and can be seen here: https://www.inaturalist.org/projects/introduced-marine-species-of-kangaroo-island-s-north-coast It is worth noting that international shipping to and from Kangaroo Island did occur prior to the formal establishment of the colony, by way of whaling and sealing vessels which traveled to and from the northern hemisphere. It is possible that some of these organisms were introduced during that early period. The european fanworm introduction (to SA) was far more recent, since the advent of modern shipping and KINRM has organised occasional removal efforts beneath Kingscote jetty 1 (Ben Florance, pers. comm). Since the end of sealing and whaling industries on Kangaroo Island, maritime traffic has consisted of mostly domestic vessels, ranging from personal craft and fishing vessels to passenger ferries. In more recent history, visiting cruise ships on domestic routes have moored off Penneshaw, but have done so with no discernible impact to the ecology at the nearest maritime infrastructure: the Penneshaw jetty. Visiting yachts are another example of potentially international shipping, but are few in number and present much lower risk than large ocean going bulk carriers. This is because large vessels take onboard large volumes of water as ballast when crossing oceans. This is then partly or fully discharged close to the destination port, in order to accommodate the receiving cargo. By this means, larvae of a great range of species can be translocated from one international port to another. Hull fouling is another vector for the introduction of exotic organisms. Hull fouling organisms such as bryozoans can grow on the outside of the hulls of vessels. That growth can also feed other organisms, such as gastropod molluscs. A good local example of this is the discovery of the Winged thecacera (Thecacera pennigera) at Outer Harbour, Port Adelaide.[4] This exotic organism feeds on an introduced bryozoan (Bugula plumosa) exclusively, and that bryozoan is known to foul the hulls of ships.[5] Comparison with a working harbour (Port Adelaide) The comparison between the apparent state of the ecology surrounding working marine infrastructure on Kangaroo Island and the long-established working harbour of Port Adelaide is stark. The Port Adelaide River (comprising the Port River, Inner Harbour and West Lakes) is heavily modified and dominated by introduced species, most conspicuously Sabella spallazani, Caulerpa taxifolia, Magellana gigas and Stylela plicata. The system supports resident populations of numerous other introduced species and seasonal blooms of even more still (Ercolanea boodlea and Cassiopea sp. are examples of seasonal bloomers). A broad range of taxa are represented in the records of introduced species living in the Port River, from alga and ascidians to nudibranchs, shellfish and fishes.[6] Since 2017, I have been opportunistically exploring the Port River, seeking to photo document all biota. I report my findings via the website iNaturalist.org ( http://bit.ly/PortRiver ) and where pertinent, I also notify PIRSA and relevant scientists at the South Australian museum. Prior literature on introduced species occurring in the Port River circa 2010-11[7] creates the false impression that there are only a few introduced species present there. If this was the case at that time, it certainly doesn’t hold true today. Perhaps there were shortcomings and limitations to PIRSA’s search efforts at the time. Or perhaps many of the recently recorded species have only recently arrived and established themselves. My recent body of work has been extended and verified through the efforts of many other individuals, including Steve Reynolds (President of the Marine Life Society of South Australia), Janine Baker (independent marine invertebrate expert) and Ralph Foster (icthyologist at the South Australian Museum). To accompany this submission, I have created three relevant projects on iNaturalist. They are intended to illustrate the difference in introduced species occurrence between a busy working harbour (Port Adelaide) and a relatively pristine coastal environment (the north coast of Kangaroo Island). 2 My project methodology was as follows: • Distribute search effort geographically across whole system (West Lakes to Outer Harbour) • Photograph all taxa observed • Upload and identify collaboratively via the website iNaturalist.org • Ascertain which species are introduced or likely to have been introduced • Report new introductions to PIRSA/SAM • Establish a list of introduced species to apply to three regions: Port Adelaide, north coast of Kangaroo Island, and whole state of South Australia’s marine waters The resulting searching revealed 33 species of introduced organisms living in the Port Adelaide river, harbour and West Lakes combined. This number may increase further as more already- documented organisms remain unidentified. The known results can be viewed here: https://www.inaturalist.org/projects/introduced-marine-species-in-port-adelaide-west-lakes The same list of species was then used to capture iNaturalist records from the northern coast of Kangaroo Island. This yielded a comparatively small result, with just four of the same set of introduced species from the Port River also occurring in northern Kangaroo Island waters. The results can be seen here: https://www.inaturalist.org/projects/introduced-marine-species-of- kangaroo-island-s-north-coast A side by side comparison, which also compares both projects with the total statewide occurrence record of the same set of known, introduced species is also provided for your reference: https://www.inaturalist.org/projects/introduced-marine-species-in-south-australia-by-region This comparison is not without its problems, but it still provides a valuable indication of the relatively pristine state of Kangaroo Island waters when compared to Port Adelaide. For starters, far fewer hours of effort have been invested in searching for introduced species along the north coast of Kangaroo Island than in the Port River. Despite this imbalance, a critical observation was made. In the Port River, introduced species dominate, and often smother or crowd out native species. On Kangaroo Island’s north coast, this inverse is true, and one must look hard to find any occurrence of an introduced species. PIRSA’s readiness to respond to biosecurity breaches One of my recent discoveries was a small colony of a carnivorous nudibranch, the Brazilian aeolid (Spurilla braziliana), in the Port River in April 2019.[8] This was a first sighting of the species in that locality. I brought the sighting to the attention of PIRSA, and pointed out that the location for their destruction was easily accessible: a floating pontoon at a boat ramp that could be reached by foot. Regardless of the convenient location, I was informed that PIRSA would not be collecting or destroying the animals, even though they are a quite recent introduction
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