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Yannarie Solar Salt East Coast of Exmouth Gulf Yannarie Solar Salt East Coast of Exmouth Gulf Straits Salt Pty Ltd Report and recommendations of the Environmental Protection Authority Environmental Protection Authority Perth, Western Australia Report 1295 July 2008 Environmental Impact Assessment Process Timelines Date Progress stages Time (weeks) 28/5/04 Level of Assessment set (following any appeals upheld) - 4/12/06 Proponent Document Released for Public Comment 131 12/3/07 Public Comment Period Closed 14 23/1/08 Proponent response to the issues raised 45 25/2/08 Proponent release of modified proposal and supplementary 5 reports. 24/3/08 Public Comment Period Closed 4 7/5/08 Final Proponent response to the issues raised 6 23/7/08 EPA report to the Minister for the Environment 11 Report Released: 23/07/08 Appeals Close: 6/08/08 ISSN 1836-0483 (Print) ISSN 1836-0491 (Online) Assessment No. 1521 Summary and recommendations Straits Salt proposes to construct and operate a 4.2 million tonne per annum solar salt farm on the east coast of Exmouth Gulf. This report provides the Environmental Protection Authority’s (EPA’s) advice and recommendations to the Minister for the Environment on the environmental factors relevant to the proposal. Section 44 of the Environmental Protection Act 1986 requires the EPA to report to the Minister for the Environment on the environmental factors relevant to the proposal and on the conditions and procedures to which the proposal should be subject, if implemented. In addition, the EPA may make recommendations as it sees fit. The EPA is also required to have regard for the principles set out in section 4A of the Environmental Protection Act 1986. Relevant environmental factors and principles The EPA decided that the following environmental factors relevant to the proposal required detailed evaluation in the report: (a) Conservation status and policy framework; (b) Mangrove and algal mat communities – changes to relative sea level; (c) Marine productivity - nutrient input; (d) Biota and water quality - salinity and bitterns management; (e) Water quality – acid and heavy metal release; (f) Marine fauna - vessel operations; and (g) Habitat loss. There were a number of other factors which were relevant to the proposal, but the EPA is of the view that the information set out in Appendix 3 provides sufficient evaluation. The following principles were considered by the EPA in relation to the proposal: (a) The principle of conservation of biological diversity and ecological integrity; (b) The precautionary principle; (c) The principle of intergenerational equity; and (d) The principle of minimisation of waste. Conclusion Having considered the proponent’s Environmental Review and Management Programme report and supplementary information, public and government agency submissions, separate expert advice and the proponent’s response to submissions, the EPA has concluded that the proposed solar salt farm is located in an area that presents unacceptably high risks of environmental harm to wetland values and unacceptable levels of uncertainty in relation to long term management of bitterns. i The whole of the east coast of Exmouth Gulf, including all of the salt flats and in- shore waters, are listed as a wetland of national importance in A Directory of Important Wetlands in Australia (ANCA, 1993). The EPA considers that it is environmentally unacceptable to locate a 17,765 hectare salt field within a wetland of national importance. While the salt farm is proposed to be largely located on an area of apparently bare salt flats, these flats form an integral part of the wetland ecosystem and land unit supporting the algal mats and mangroves which underpin the productivity of the wetland and Exmouth Gulf. Disturbance on the salt flats could have serious and irreversible adverse impacts on the algal mats and mangroves. The EPA recognises wetlands that are listed in A Directory of Important Wetlands in Australia as ‘critical assets’ (EPA, 2006) representing the most important environmental assets in the State and requiring the highest level of protection. The status of the site as a critical environmental asset, together with the extent of predicted impacts, the high degree of residual uncertainty and the unacceptably high risks posed by the proposal have lead the EPA to conclude that the proposal is environmentally unacceptable. The key areas where significant impacts or risks of impacts have been identified are: • Loss of biodiversity and wetland values in a listed wetland of national importance; • Significant loss and fragmentation of benthic primary producer habitat and associated ecosystem services as a result of salt pond levee walls blocking the distributional adjustments of algal mat and mangrove communities in response to sea level rise. • Potential loss of regionally significant mangroves and algal mats caused by the mobilisation of hypersaline groundwater; • A high level of uncertainty in relation to the proponent’s ability to manage the ongoing production of over 1 million cubic metres per annum of bitterns C, which is toxic to marine biota and therefore likely to degrade wetland and biodiversity values should bitterns discharge occur either accidentally or be required to maintain salt farm production in the long term; • Potentially significant and damaging changes to nutrient availability and delivery to coastal waters, affecting productivity in Exmouth Gulf; and • Potential release of acid and heavy metals to coastal wetland environments during dredging operations and from stored acid sulphate sediments following excavation. The proponent has not been able to demonstrate to the EPA that the environmental values of the area could be maintained with a high degree of certainty, nor that the risks to those values would be acceptably low in the long term. Based on this assessment, the EPA does not believe that the proposal could be made environmentally acceptable and recommends that the proposal should not be permitted to proceed. Accordingly, the EPA has not recommended any conditions as it does not consider that the current proposal could be implemented in an environmentally acceptable manner. ii Other advice The EPA makes the following recommendation in relation to the potential for future expansion of the proposed salt field. Should the Minister for the Environment consider the current proposal acceptable and issue a Statement permitting its construction, there is a likelihood that the proponent may wish to expand the proposed 4.2 million tonne per annum (Mtpa) of salts proposal to produce up to ten Mtpa of salts in the future. The EPA considers the known impacts and residual uncertainties associated with the assessed 4.2 Mtpa proposal to be unacceptably high. Many of these impacts and risks are directly related to the size of the development footprint, the proportional length of coastline affected and the quantities of materials and natural resources consumed. An expanded salt field beyond four Mtpa would therefore be expected to have further unacceptable cumulative impacts. Recommendations The EPA submits the following recommendations to the Minister for the Environment: 1. That the Minister considers the report on the relevant environmental factors and principles that the EPA considered relevant to the proposal, as set out in Section 3; 2. That the Minister notes that the EPA considers that a 17,765 hectare salt field should not be located within a wetland of national significance that is a critical environmental asset; 3. That the Minister notes that the EPA has concluded that the proposal cannot meet the EPA’s environmental objectives and is considered environmentally unacceptable, particularly with regard to the risk of impacts to biodiversity values and ecosystem functionality within a listed wetland of national significance, regionally significant mangrove communities, and water quality within an area recommended for ‘maximum’ water quality protection; 4. That the Minister notes that the EPA has not included in this Report conditions and procedures to which the proposal should be subject, if implemented, because the EPA holds the view that the proposal should not be implemented; 5. That the Minister not issue a statement that the proposal may be implemented; and 6. That the Minister notes the EPA’s other advice presented in Section 4 in relation to the potential for future expansion, if consideration is given to approving the construction of the solar salt farm which is the subject of this assessment report. iii Contents Page Summary and recommendations.................................................................................i 1. Introduction and background.............................................................................1 2. The proposal.........................................................................................................2 3. Relevant environmental factors and principles ................................................6 3.1 Conservation status and policy framework................................................9 3.2 Mangrove and algal mat communities - changes to relative sea level.....14 3.3 marine productivity - nutrient input.........................................................21 3.4 Biota and water quality - salinity and bitterns management....................29 3.4.1 Discharge of contained brines and bitterns...................................30 3.4.2 Long term bitterns management ....................................................37 3.4.3 Salt production and transport........................................................41
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