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Friends of Wonthaggi Heathland & Coastal Reserve

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Friends of Wonthaggi Heathland & Coastal Reserve Inquiry into the Environmental Effects Statement process in Victoria Submission no. 48 Friends of Wonthaggi Heathland & Coastal Reserve Inc PO Box 849, Wonthaggi VIC 3995 28th April 2010 Executive Officer Environment and Natural Resources Committee Parliament House Spring Street East Melbourne, VIC, 3002 Dear Sir/Ms Re: Inquiry into the Environmental Effects Statement process in Victoria The Friends of Wonthaggi Heathland & Coastal Reserve Inc (FOWH&CR) thanks the Committee for the invitation to make a submission to the inquiry in the letter dated 16 March 2010. The members of Friends of Wonthaggi Heathland & Coastal Reserve Inc (FOWH&CR), are an active Friends group, vitally interested in the flora and fauna of our area and the revegetation of public land for wildlife corridors, refuges, biodiversity and to provide green space for health and recreation pursuits. As a Friends Group working closely with Parks Victoria, it has as its prime foci the identification and recording of natural history values the identification of any potential threats working to maintain and improve habitats where appropriate The Friends Group also liaises with other Groups, including the Cape Paterson Coastal Plains Landcare, Wonthaggi Seedbank, the Bass Coast Friends of the Hooded Plover, the South Gippsland Conservation Society, Greening Australia, Cape Paterson Residents and Ratepayers Association and Birds Australia on projects of common interest, both formally and informally. The sites of the Wonthaggi Windfarm and the Victorian Desalination Plant adjoin our main areas of interest, the Wonthaggi Heathland and Coastal Reserve stretching from Coal Point at Harmers Haven to the cemetery at Kilcunda. The Friends Group was closely involved with the Environment Effects Statement (EES) for the Wonthaggi Windfarm and the Victorian Desalination Project (VDP). FOWH&CR presented submissions for both studies and made presentations at both Panel Hearings. The Friends Group also maintained a close interest in the planning and EES process for the Bald Hills Wind Farm. As a result of concerns for the potential for environmental impact, the Friends Group was involved in the EES process including: Presentation at the Panel Hearing for the Wonthaggi Windfarm (September 2003) Written submission to the EES Referral documents dated November 2007 for the Victorian Desalination Project (December 2007) Written submission to the Referral of proposed action to the Department of Environment, Water, Heritage and the Arts (DEWHA) under the Environment Protection and Biodiversity Conservation (EPBC) Act (January 2008) Representation in the Community Forums Formal discussions with scientists representing CEE and Biosis Research in relation to flora and fauna studies for the terrestrial and marine environments in the study areas prior to the EES Inquiry Written submission on EES Draft Scoping Requirements Environmental Effects Statement (March 2008) Written submission to the EES inquiry and presentation at the EES inquiry public hearing for a time allocation of twenty minutes (October 2008) Communication with DSE and Aquasure informally and in written form in respect to environmental concerns in relation to the Project post planning approval Therefore the Friends Group feels that it is in a position to offer some comment on Victoria’s EES process. Our comments have largely arisen out of the EES process for the Victorian Desalination Project and focus on paragraphs A and C. The Friends Group is concerned that the current level of environmental protection could be improved. Our experiences as part of the EES process are offered as constructive criticism in the hope that the EES process is strengthened in order to offer better protection for the environment and that all local environmental, social and economic concerns are addressed for future Projects required to undergo the EES Process. Yours faithfully, Geoff Glare President, Friends of Wonthaggi Heathland & Coastal Reserve Inc 2 Submission: Inquiry into the Environmental Effects Statement process in Victoria Response to paragraph A. “Any weaknesses in the current system including poor environmental outcomes, excessive costs and unnecessary delays encountered through the process and its mechanisms.” 1.1 Difficulties encountered in obtaining hard copy of the EES, Technical Reports and the Works Approval Application for the Victorian Desalination Project In order to cross reference between Technical Reports and the EES Document, a hard copy was considered an advantage when preparing a response for the EES process, especially when stakeholders were seeking to read and assess the maps on disk, especially given that a significant number of people still do not have access to computers and/or the Internet. A number of issues with the initial release on 20 August 2008 were identified. These included: At several venues, disks in the initial release were recalled There were limited numbers of hardcopies available at the Official Exhibition venues at the start of the Exhibition period There were delays of more than one week in the availability of additional hard copies at the various Exhibition venues There were delays of more than one week in the availability of hard copies Given that an EES Exhibition period is limited (6 weeks for the VDP EES), access to the material and reports presented is important. 1.2 Allowing enough time for the EES process In a National Water Week advertising feature in the Sunday Herald Sun (October 19, 2003), the Victorian State Government launched the Regional Urban Water Authorities. An article on page 2 of the eight page liftout stated: Seven years of below average rainfall have put Melbourne’s water storage levels at their lowest point in 20 years. A predicted increase in Melbourne’s population of one million people by 2030, combined with expected climate changes will place yet more pressure on our limited water resources, says John Thwaites, Minister for Water. So the challenge we all face is how to ensure Melbourne’s future water supplies are sustainable, he says. Water restrictions and other measures can only go so far in reducing consumption of our most precious natural asset. 3 The key to securing our future water supplies is changing the way we each use water. The need for augmentation of Melbourne’s water supply was well known and had been documented by the Victorian State Government and the relevant authorities for many years before the State Election in 2006 and before the announcement of the Water Plan in June 2007. The need to secure Melbourne’s water supply had been clearly established in the year 2007. However, the need for the Proposed Desalination Plant had not yet been clearly established and, in our opinion, the production of potable water using desalination by reverse osmosis should have been the method of last resort. Alternative methods that should have been considered as a first resort to supply additional water for Melbourne included recycling, harvesting of urban stormwater, state- wide reduction of private, industrial and agricultural water use, the use of domestic ‘grey water’, plugging leaks, leading to an increase in the efficiency of the current transfer system both in Melbourne and regional Victoria, and the addition of water tanks on private and public properties that should be seriously considered as part of the EES process. Some of those measures have been since adopted in part. The wording of the decision by the Minister for Planning (28 December, 2007) that an Environment Effects Statement is required for the Desalination Project and the document Draft scoping requirements for the Desalination Project, February 2008 suggested that the Desalination Project works would have proceeded regardless of the findings of the EES and that the only considerations need to be “How, Where and When” rather than “Whether or not the Project should proceed at all”. The EES process for the VDP could have considered whether or not this method of production for augmenting Melbourne’s water supply is, in fact, appropriate for Victoria or, in fact, whether or not it should be one of the key options at all. The following references suggest that the perceived urgency and set deadlines for the Project influenced the approach taken throughout the study period and throughout the EES Exhibition process. The Technical Appendix 31, EES, CEE, page 94 stated: DSE have stated the urgency for the project and the need to commence production of potable water by desalination in 2011 due to forecast reductions in water levels for Melbourne (Figure 48). The Technical Appendix 31, EES, CEE, page 3 states: In view of the urgency for the project the baseline assessment is based on available information on the marine ecosystem, targeted investigations and the range of physical and chemical processes predicted as a result of the reference design and modelling. The Technical Appendix 31, EES, CEE, page 94 stated: In recognition of the urgency for the assessment of impacts and associated risk, the framework of further baseline field studies and 4 a monitoring program based on the systems assessment of the likely marine ecology effects of the proposal is discussed in Section 20. The report then documented a number of additional studies needed. For a Project as large and as complex as the Victorian Desalination Project, baseline studies should have been completed before planning approval was given. The EES process was scheduled to be completed before the end of 2008. Given that this Project is arguably the largest Infrastructure Project ever undertaken in the history of this state and given the scope and magnitude of the potential environmental, social and economic impacts on the local area, the region and the state, a reasonable timeframe should be set in order to facilitate a transparent and comprehensive EES. Recommendations 1 In relation to access to EES documentation and the EES process and Inquiry: (i) The release of EES documentation should be available to stakeholders and interested groups in a variety of forms, both in hardcopy form and on disk to allow for timely, comprehensive and informed comment.
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