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Bmission to the Senate Inquiry Into the Perth Freight Link

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Bmission to the Senate Inquiry Into the Perth Freight Link Submission to the Senate Inquiry into the Perth Freight Link This submission refers to the term of reference of the Inquiry: b) the information relied upon by state and Commonwealth governments informing the decision to fund this project This submission asserts that processes for environmental approval by the WA Environmental Protection Authority (EPA) for this project have been flawed and will result in unacceptable damage to the Beeliar Wetlands, part of Beeliar Regional Park. Therefore, the information relied upon by the State and Commonwealth governments to fund the Perth Freight Link, which includes the Roe 8 extension, is invalid. There are three major problems with the Roe 8 approval: 1. The approval contradicts research which has been accepted by the EPA as part of the Public Environmental Review. 2. The offset package conflicts with State and Federal guidelines for protection of high conservation value lands, especially wetlands. 3. The Public Environmental Review of the Roe 8 Extension does not include the Perth Freight Link project (of which the final route and traffic load is presently unknown), therefore the full impact of the project on the Beeliar Wetlands cannot be known. Contradictions in the Approval The Roe Highway Extension - Public Environmental Review (PER) acknowledges that there will be significant impacts of the project. A major response to this impact is an offset package. Documents cited as being used for guidance in this proposal specifically preclude the use offsets for destruction of critical environmental assets. The PER contains evidence that the Beeliar Wetlands constitute a unique environmental asset. Much of this information is contained in the appendices of detailed reports by contracted expert scientists and researchers, which appear to have been overlooked or misunderstood in formulating the preferred option. For example from Appendix D: Wetland Ecological Investigations Report: Regarding the uniqueness of Beeliar wetlands: …… it can be seen that the Bibra Lake wetlands system, with its complexity, is the only representative of this type of wetland system developed along the interface between Bassendean Dunes and Spearwood Dunes on the whole Swan Coastal Plain. However, the Bibra Lakes system has a second level of complexity: it has complex stratigraphy (with some buried wetlands), complex micro-hydrology, complicated hydrochemistry, and a very complex subsurface geochemistry and, as a result, a complex mosaic of vegetation related to the variability of these surface and subsurface natural features (Syrinx/VCSRG Part 2 Report). As such, the Bibra Lakes system is an area of high natural values that is under the protection of the State. (Roe Highway Extension Public Environmental Review: Appendix D, p. 117) 1 Regarding the impact of the proposed project on Beeliar Wetlands: The impacts associated with the construction of Roe Highway Extension on the stratigraphy, hydrology, geochemistry and groundwater dependent ecosystems within the Bibra Lakes System are significant and complex. Both wetlands and groundwater-dependent ecosystems are a priority for protection at national level, state level and directly within the context of the globally unique Swan Coastal Plain. Specific expectations of the EPA are that there will be no irreversible changes to wetland values and functions over time resulting from this project. (Roe Highway Extension Public Environmental Review: Appendix D, p. 178) These two excerpts are indicative of the Appendix D: Wetland Ecological Investigations Report and are underpinned by extensive scientific measurement carried out by the contracting researchers and which attests to the value of the Beeliar Wetlands (of which the Bibra Lake system is part). The detailed documentation of the attributes of the wetland area affected by the Roe 8 extension project, including past research and measurement, do not appear to have been taken into consideration in formulating the preferred options. Roe Swamp is specifically identified as a high conservation value, unique wetland being the only basin in the Bibra lake system filled with spongilitic peat. The precise hydrology of Roe Swamp remains to be elucidated and the Wetland Ecological Investigations Report explains that the impact of the proposed road construction cannot be fully assessed until this is completed. Conflict with Offset Guidelines Offsetting with “like for like or better” is a key principal of both State and Federal environmental guidelines. As the Beeliar Wetlands system is unique, it cannot be offset by the purchase of additional land (details of which have not been provided in the offset package).The offset package contravenes the EPAs own guidelines which, in general terms, preclude offsetting of critical assets including Public Conservation Reserve Lands, Bush Forever lands, native vegetation of high conservation value and wetlands. For example: Conservation category wetlands not included in an Environmental Protection Policy may be viewed in the context of whether they have a reasonable chance of medium to long term survival of their environmental values although the underlying presumption is that they would normally be considered a critical asset. EPA Position Statement No. 9- Environmental Offsets (2006). The Beeliar wetlands contain components falling into all these categories and the conflict between the proposed construction and the guidelines is even noted within the PER: 2 The construction footprint extends through existing legislative boundaries including Aboriginal Heritage Sites, Conservation Category Wetlands, Bush Forever Site and Significant GDEs and therefore is in conflict with the State policies for protection of wetlands, and protection of priority flora. (Roe Highway Extension Public Environmental Review: Appendix D, p. 178) Therefore approval for this project should have been withheld as the EPA have ignored their own guidelines. Inclusion of Roe 8 within the Perth Freight Link Project. The original environmental assessment work for Roe 8 was carried out prior to the possibility of federal funding for the Perth Freight Link. Roe 8 has thus become part of a much larger scope project which has not yet been clearly articulated by the WA State Government and has not received environmental scrutiny as a whole. The nature of traffic flows on the completed Perth Freight Link, and their impact on the Beeliar Wetlands, are presently unknown due to changing suggestions about the route to link Roe 8 and Fremantle. I recommend that representatives of V & C Semeniuk Research Group, who prepared the Appendix D: Wetland Ecological Investigations Report of the Public Environmental Review, be called to the Public Hearing for this inquiry in order to explain: a) the true environmental impact of the Roe 8 section of the Perth Freight Link; b) the technical definition of why the Beeliar Wetlands are unique in WA; and c) why offsetting cannot replace this critical asset to WA Dr Danielle Brady 3.
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