CEE Pty Ltd

Environmental scientists and engineers

Gas Import Jetty and Pipeline Project Environment Effects Statement (The EES)

Inquiry Advisory Committee

Expert Witness Statement of Scott Selwyn Chidgey

Prepared for: Ashurst and Hall&Wilcox Lawyers

September 2020

CEE Pty Ltd Unit 4 150 Chesterville Road Cheltenham VIC 3192 03 9553 4787 cee.com.au

Expert Witness Statement Scott Chidgey Marine Biodiversity Impact Assessment CONTENTS

1 Introduction 3 2 Details of significant contributors to witness statement 4 3 INSTRUCTIONS AND INFORMATION RELIED UPON 6 4 Public consultation and Technical Reference Group 6 5 Field studies 6 6 Reporting 7 7 CEE’s approach to EES Technical Report the EES 7 8 Potential impact pathways 8 9 Marine Environmental Impact Mitigation Measures 13 10 Response Agency Submissions 14 Submission 1. EPA 14 Submission 2. Environment Victoria 18 Submission 3. Department of Agriculture, Water and the Environment (DAWE) 22 Submission 4. Mornington Peninsula Shire 29 Submission 5. Port of Hastings 32 Submission 7. Submission Bass Coast Shire Council 32 Submission 12. Sea Shepherd 32 Submission 15. Victorian National Parks Association 32 Response to Public Submissions 33 Declaration 36 Annexure A,. Scott Chidgey CV Annexure B,. Introduced Marine Pests MS Management Report

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 2 of 38 Expert Witness Statement Scott Chidgey Marine Biodiversity Impact Assessment

1 Introduction 1.1 Name and Address Scott S Chidgey, CEE Pty Ltd, 150 Chesterville Road, Cheltenham VIC 3192

1.2 Qualifications Qualifications: BSc MSc University of Melbourne

1.3 Professional Experience Project biologist, Jabiluka, Pancontinental Mining Ltd Marine environmental scientist, Melbourne, Caldwell Connell Engineers Lead marine environmental scientist, Melbourne, Consulting Environmental Engineers Principal Marine Environmental Scientist, Melbourne, CEE Pty Ltd

1.4 Area of expertise and understanding of Western Port • Integrated marine ecosystem studies, ecology, water quality, ecotoxicity • Marine ecosystem impact pathways and risk assessment I have more than 35 years’ experience assessing the effects of wastewater discharges to the marine environment and a comprehensive knowledge of marine environmental conditions in Western Port through a range of investigations reviews and studies beginning with CEE’s review of the Western Port Marine environment for EPA in 1995 EPA Publication No. 493). I have been responsible for marine monitoring, investigation and environmental assessments for various projects in North Arm for Esso, Port of Hastings, Port of Hastings Development Authority, Victorian Regional Channels Authority and, most recently, AGL. I am responsible for a range of effluent discharge monitoring and compliance assessment programs to the marine environment throughout Victoria and Tasmania that involve understanding of effluent quality and ecotoxicity, discharge arrangements, ambient water quality, effluent dispersion and ecosystem resilience. In Victoria, this has included wastewater discharges at Portland, Port Fairy, Warrnambool, Apollo Bay, Lorne, Anglesea, Breamlea (Geelong), Werribee (WTP), Altona, Gunnamatta (ETP), Long island Point, Pyramid Rock, Wonthaggi (VDP and SGW), Venus Bay, Foster, Toora, Welshpool, McGauran’s Beach and Delray Beach. I have been involved in a range of Environmental Effects Statements, Works Approval Applications and Marine and Coastal Act (previously Coastal Management Act) and planning approvals applications including: • Victorian Desalination Plant EES • St Kilda Pier Redevelopment 2020 (MaCA) • Port of Melbourne Port Expansion Project EES • Port Phillip Channel Deepening Project EES

I have attended twelve public consultation sessions related to this EES from March 2018 to September 2019. My detailed CV is attached as Annexure A.

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 3 of 38 Expert Witness Statement Scott Chidgey Marine Biodiversity Impact Assessment 2 Details of significant contributors to witness statement This expert witness statement has been prepared entirely by me. The CEE Report Technical Report A: Marine EES Technical Report A Marine biodiversity impact assessment June 2020 was prepared by a team of scientists and engineers at our firm, CEE Pty Ltd (CEE), with contributions by specialist subconsultants whose reports are appended to Technical report Annexures. The chapters and figures were provided in CEE format to AECOM who compiled material into a common EES format presented as Technical Report A: Marine EES Technical Report A Marine biodiversity impact assessment June 2020. • I take responsibility for all components of that report that address marine ecosystem existing conditions, including field studies and ambient temperature monitoring. • My colleague, Dr Ian Wallis, takes responsibility for all components of that report that address hydrodynamic and water quality issues, including supervision of modelling, communications with Hydronumerics and presentation of all model outputs. • Dr Wallis and I jointly take responsibility for Chapter 7 Risk and Impact Assessment of Technical Report A. • I took part in all aspects of the field collection programs and I take responsibility for the design, implementation and reporting of the marine ecosystem investigations reported in Technical Report A. I was assisted by other CEE marine scientists in these tasks. Various subconsultants with specialist expertise and experience provided significant input to the content of Technical Report A. Their inputs are cited where appropriate in Technical Report A. The subconsultants, their specialist area of expertise and contribution to the marine ecosystem descriptions are listed in Section 2.1 below.

2.1 Subconsultants 2.1.1 Chlorine Ecosystem Protection Guideline Values CSIRO Land and Water Lucas Heights were contracted by CEE Pty Ltd to describe the behaviour of chlorine chemicals produced by electrolysis of seawater in marine waters and to develop 99% marine environment protection Guideline Value for chlorine in the marine environment associated with the AGL Gas Import Jetty Project. This was necessary because the existing Australia New Zealand Water Quality Guidelines did not list definitive 95% or 99% ecosystem protection guideline values for chlorine in the marine environment. CSIRO’s report “Behaviour and regulation of chlorine and waters associated with the AGL Gas Import Jetty Project” provided detailed explanation of the procedure used to calculate 99% and 95% chlorine values for marine ecosystem protection in situations of constant environmental exposure and variable environmental exposure. CSIRO’s report is provided as Annexure A to Technical Report A. CSIRO concludes that the 99% and 95% chlorine values for ecosystem protection in marine environments described in the report will be proposed for inclusion in the Australian New Zealand Water Quality Guidelines, where they will apply to all marine waters in Australia and New Zealand. 2.1.2 Phytoplankton Drs S Brett, D Hill and T Smith-Harding of Microalgal Services were contracted by CEE Pty Ltd to provided advice on program design, analyse sets of 13, monthly phytoplankton plankton samples from up to seven sites and provide a report on sample analysis and ecological description of the phytoplankton flora of the sampling program. Their report is provided as appendix to Annexure B to Technical Report A.

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 4 of 38 Expert Witness Statement Scott Chidgey Marine Biodiversity Impact Assessment 2.1.3 Zooplankton Dr Kerrie Swadling, Institute of Marine and Antarctic Studies, University of Tasmania was contracted by CEE Pty Ltd to provide advice on program design, analyse 13, monthly zooplankton samples from up to seven sites and provide a report on sample analysis and ecological description of the zooplankton fauna of the sampling program. Dr Swadling’s report is attached as appendix to Annexure C to Technical Report A. 2.1.4 Ichthyplankton and fish: Prof Greg Jenkins, University of Melbourne was contracted by CEE Pty Ltd to provided a description of existing conditions of fish in Western Port, which is reproduced as cited in Technical Report A. Prof Jenkins also advised on ichthyplankton and zooplankton program design and sample handling and sorting, provided equipment and a detailed data analysis of ichthyoplankton sampling results and report. Jenkins’ report is attached as appendix to Annexure G of Technical Report A. Dr A G Miskiewicz, Principal, Ichthyological Investigations, was contracted by CEE Pty Ltd to final-sort sets of 13, monthly ichthyoplankton samples from up to seven sites collected and pre-sorted by CEE, and to count and identify all individuals to lowest possible taxa. Data files were provided directly to CEE, who compiled data into a consolidated database and forwarded the database to Prof Jenkins for data analysis and reporting. 2.1.5 Threatened Ghost Shrimp Dr Gary C B Poore, Curator Emeritus, Museums of Victoria, Melbourne, was contracted by CEE Pty Ltd to provide advice on sampling methods for Western Port ghost shrimps, to analyse samples during collection on the three days of field sampling and provide a report on the status of threatened host shrimps based in the EES sampling program and his extensive understanding of the status of rare crustaceans worldwide. Dr Poore’s report is attached as appendix to Annexure F of Technical Report A. 2.1.6 Introduced Marine Pests Mr John Lewis, Principal Marine Consultant ES Link Services was contracted by CEE Pty Ltd to provide a description of existing documented conditions of marine pest species in Western Port and to assess the risks of introduction of pest species resulting from the operation of the FSRU and additional traffic of LNG tankers to Western Port. Mr Lewis’ report is cited as Lewis 2018 in Technical Report A, and is provided as an annexure to this statement. 2.1.7 Infauna Ms Lynda Avery of Infauna Data was contracted by CEE Pty Ltd to sort sediment infauna samples collected by CEE, and to count and identify all individuals to lowest possible taxa. Data files were provided directly to CEE, who compiled the data and reported the results in Annexure G of Technical Report A 2.2 Other sources of Information Other sources of information used are cited as references, data sources or web sites within Technical Report A, Annexures to Report A, or appendices to Annexures.

2.3 Adoption of EES Technical Report A. Marine biodiversity Impact Assessment I formally adopt those parts of EES Technical Report A. Marine biodiversity Impact Assessment that apply to my area of expertise described above.

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 5 of 38 Expert Witness Statement Scott Chidgey Marine Biodiversity Impact Assessment 3 INSTRUCTIONS AND INFORMATION RELIED UPON My Instructions to prepare this expert witness statement were provided jointly by Hall and Willcox, and Ashurst in a Brief dated 13 July 2020. The specific instructions were as follows:. You are instructed jointly by Ashurst and Hall & Wilcox on behalf of AGL and APA respectively. We will work cooperatively and common interest privilege will apply to your engagement. We would like engage you as an expert witness for the purposes of: (a) adopting and filing your Report as an expert witness statement at the Hearing; (b) reviewing any public submissions filed with the IAC during the public exhibition period which raise issues relevant to your witness statement; (c) if called to do so, presenting your witness statement at the Hearing for the Project (which may be held by digital medium depending upon the restrictions in place at the time); (d) if required to do so by the IAC, attending a conclave with other experts in your field of expertise who are giving evidence in the Hearing; and (e) if you consider necessary, attending a site visit of the areas relevant to your witness statement in advance of the Hearing. I am aware of marine environment related questions raised in IAC’s Request for further information. To the extent that these are not specifically addressed in my Witness Statement, I will provide responses to Ashurst.

4 Public consultation and Technical Reference Group I attended twelve public consultation sessions related to the EES from March 2018 to September 2019: • Hastings (27 Mar 2018, 18 Sep 2018, 2 Mar 2019, 24 Aug 2019); • Crib Point (25 Sep 2018, 26 Feb 2019, 27 Aug 2019) • Cowes (13 Sep 2018, 23 Feb 2019); • Somers (15 Sept 2018); • Flinders (7 Sep 2018); and • Grantville (3 Sep 2019). I presented a progress summary of the marine ecosystem studies and description and impact assessment procedures to the Project Technical Review Group on 10 December 2019.

5 Field studies I was involved directly in design, implementation, reporting and integration of: • Phyto-, zoo-, and ichthyo-plankton 13 month, monthly sampling program o CEE team and specialist subconsultants • Ghost shrimp sampling program o CEE team and specialist subconsultants • Benthic habitat mapping and infauna sampling o CEE team and specialist subconsultants • Ambient water temperature12 month, 15 min logging program at Crib Point o CEE team

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 6 of 38 Expert Witness Statement Scott Chidgey Marine Biodiversity Impact Assessment 6 Reporting 6.1 Existing Conditions I was involved in all aspects of reporting on existing marine ecosystem related conditions reported in Technical Report A. 6.2 Integrated Risk and Impact Assessment I was involved in all aspects Risk and Impact Assessment with Dr Ian Wallis, Technical Report A. 6.3 Monitoring Program I contributed to possible monitoring program topics on the basis of risks that we identified. In my experience any monitoring program and tasks would be developed in consultation with all regulators should the project be approved, as discussed in Section 9. The program must include consideration of the forthcoming regulatory changes, which will include documentation of the risks to beneficial uses and the general environmental duties (GED’s) of licence holders. The monitoring programs should be designed to detect potential spatial gradients of stressor effects on ecosystem components.

7 CEE’s approach to EES Technical Report the EES My contribution to the EES was to provide expertise as an experienced, marine environmental scientist ecologist with a solid understanding of the EES process, to joint-lead with Dr Ian Wallis as CEE’s Principal Environmental Engineer CEE’s team of environmental scientists and engineers and specialist subconsultants through the EES process.

7.1 My responsibility in the EES process In all aspects of this project, CEE’s aim was to provide clear, accessible, high quality, impartial and relevant environmental information collected from Western Port, known processes and process-based models so that the public, stakeholders, regulators and the panel were equally informed of the environmental characteristics and processes that formed the basis of our assessment. Our ultimate responsibility is to provide expert independent information and interpretation of that information to the IAC.

We also aimed to provide our risk and impact assessment reasoning as a clear and transparent process in public meetings and in our final document. This informed readers of the evidence and processes used by us to assess risks as experienced environmental scientists and engineers, and also to allow others to form their own conclusions based the same or additional information.

My understanding is that our assessment of risks is part of the greater risk assessment elicitation process that is more generally known in Victoria as the EES process. That process includes consideration of submissions from the public, stakeholders and agencies; the Hearing before the IAC; the IAC’s assessment and their recommendation to the Ministers; the assessment of the relevant regulators and their recommendation to the Ministers, and: the assessment and Decision by the Ministers.

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 7 of 38 Expert Witness Statement Scott Chidgey Marine Biodiversity Impact Assessment 7.2 Marine Environment Team • The CEE team (led by me and Ian Wallis), AECOM, AGL, other consultants and subconsultants, peer reviewers, TRG. 7.3 Project description • Provided by AGL via AECOM.

8 Potential impact pathways As set out in Section 7.4, we identified three groups of risks to the marine environment in the referral stage of the project: 1. Ship related operations: a. The FSRU: Arriving from an international origin and mooring at Berth 2 b. LNG carriers: 12 to 40 carriers entering the port from an international origin, mooring alongside FSRU, unloading LNG and departing port c. Noise, light, visibility 2. Port operation and facility improvements at Crib Point Jetty a. Various refurbishments and upgrades 3. Operation of a floating storage and regasification facility (FSRU) as a scheduled premise at Crib Point Jetty a. Entrainment of biota by intake of seawater; b. Cooler seawater discharge; c. Warmer seawater discharge; and d. Chlorinated seawater discharge.

8.1 Ship and port related stressors Impact Pathway Groups 1 and 2 above were identified as stressors consistent with the current and future operation, maintenance and management of the Port of Hastings as an operating port with four separate active shipping hubs within North Arm including Crib Point. The Port of Hastings Development Authority (PoHDA) submission has provided information on the existing shipping and port operational management within Western Port and its approaches from Bass Strait. PoHDA has listed the regulatory requirements for managing the range of risks to marine environmental values from operation of the port. PoHDA has explained that the proposed shipping related activities are within the past, present and planned capabilities and regulatory responsibilities of the Port. These are listed as Mitigation Measures in the Section 25 of the main EES document. 8.1.1 Environmental information and assessment Ian Wallis and I reviewed available information on the nature and distribution of environmental receptors to these ship and port related stressors in Western Port. In view of the existing widespread dispersion of these stressors and key receptors, we decided that it was appropriate to address risks to these receptors due to the project (1) using available information on key receptors and (2) the proportional increase of existing risks due to project related increased in likelihood of existing consequences occurring. The assessment is presented by Dr Wallis. In stating this approach, I am aware that some of these stressors at a regional or national scale are significant to some populations or species. This is particularly relevant to migratory threatened species, such as the Southern Right whale, that have very diminished populations and migration paths that correspond with major national and international shipping routes. The loss of an individual from these populations due to strike by any form of vessel anywhere is truly unfortunate. The risk of these stressors to diminished populations is at a larger geographic scale and should be addressed at a state or national scale.

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 8 of 38 Expert Witness Statement Scott Chidgey Marine Biodiversity Impact Assessment 8.2 FSRU operation stressors – integrated model I recognized that the FSRU intake and discharge effects pathways to ecosystem receptors were based on hydrodynamic processes of transport and dispersion. We also recognized the key marine ecosystem receptors and trophic interrelationships from our understanding of the Western Port ecosystem as simplified in our ecosystem conceptual model provided Technical Report A. We decided that the assessment of these effects of the FSRU operation were best informed by an integrated hydrodynamic, water quality and particle transport model. My understanding was that a validated, calibrated model would predict hydrodynamic currents, seawater exchange, discharge dispersion and dilution contours and particle dispersion and fate. The model would: • Provide the extent of effect on the marine ecosystem using a 99% protection guideline value for chlorine. The model would show the extent of the chlorine 99% protection guideline value contour frequencies under a range of FSRU operating scenarios. This would provide boundaries of potential effect of the chlorine discharge on marine ecosystem values. • Provide the extent of effect the discharge temperature differential on the marine ecosystem using a guideline value for temperature differential (positive or negative) from ambient temperatures. The model would show the extent of the temperature differential guideline value contour frequencies under a range of FSRU operating scenarios. This would provide boundaries of potential effect of the temperature differential from ambient on marine ecosystem values within the boundary area. • Provide information on the natural tidal exchange of waters from different parts (zones) of the Western Entrance and North Arm with Bass Strait, and the loss of ‘particles’ from those areas due to natural flushing processes at different time steps. This would provide a comparison of particles entrained within a zone, with those entrained and those transported to other zones or Bass Strait.

8.2.1 Environmental quality objectives inputs to the model – Chlorine The discharges to the marine environment comprise seawater that has been used for various heat exchange processes, fire-prevention or firefighting. All seawater used passes through an electrolytic cell that produces chlorine to prevent biological growth in the steel pipework and heat exchangers. Seawater naturally contains a range of dissolved salts, including chloride and other halides such as bromide and iodide. Chlorine can be produced by passing an electric current through seawater to convert the chloride salt to chlorine. Chlorine reacts quickly with bromide ions to create bromine chemicals, while the chlorine returns back to chloride salt. The bromine chemicals oxidise organic matter and most return to bromide salt. There are no other process additives or contaminants added to the seawater flows. As discussed earlier, I recognized at the commencement of the project that the existing National chlorine guideline value for chlorine toxicity in the marine environment was not defined. We contracted CSIRO develop an appropriate guideline value for the project. CSIRO developed 95% and 99% ecosystem protection Guideline Values for chlorine in marine environments with constant environmental exposure and variable environmental exposure. We used the 99% protection Guideline Value for chlorine under conditions of variable environmental exposure as specified in SEPP Waters 2018 as the required level of ecosystem protection in the Western Port sub-segment Western Entrance and North Arm.

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 9 of 38 Expert Witness Statement Scott Chidgey Marine Biodiversity Impact Assessment The 99% chlorine guideline value was used to show contours of chlorine concentration exceeding the guideline value as an indication the area of marine ecosystem values that exceeded the Policy objective for ecosystem protection for this toxicant, and therefore resulted in toxicant risk of the discharge to all marine biota within the area at any time of year. As stated earlier, CSIRO concluded that the 99% and 95% chlorine values for marine ecosystem protection described in the report will be proposed for inclusion in the Australian New Zealand Water Quality Guidelines, where they will apply to all marine waters in Australia and New Zealand.

8.2.2 Environmental quality objective inputs to the model -Temperature I was involved in the conceptualisation of the temperature differential guideline value for the project. SEPP Waters 2018 does not list a Water Quality Objective for temperature, but provides that unlisted environmental water quality guideline objectives can be established by calculating the 25th and/or 75th percentiles for reference sites using data collected at least monthly over a minimum of 12 months. ANZECC (2000) differs slightly in specifying the 20th and 80th percentile. Dr Wallis developed a 25 to 75 percentile range, or temperature differential value as the Guideline value for this project. The value was derived from 12 months of 15 minute temperature records from Crib Point between January 2019 and January 2020. The value adopted is consistent with my understanding of the temperature variation and ranges I observed in the logged temperature records. 8.2.3 Marine ecological input to entrainment model My involvement in ecological inputs to the entrainment model were: • General discussions between ecologists and modelers to optimize ecologically relevant outputs for Western Port characteristics; • Neutrally buoyant particles were determined to best simulate the natural movement of most plankton occurring in the entrainment zone of the FSRU located in the strong tidal currents of the deep central channel of Lower North Arm. • Range of time steps that may represent duration of typical larval periods of fish species typical of Western Port and benthic invertebrates and fish, and turnover rates of key zooplankton species found in Western Port (Acartia spp) and phytoplankton typical of Western Port of marine biota – based on cited scientific literature and knowledge and advice of specialist subconsultants; • Ecological spatial units (zones) for particle transport, natural flushing and entrainment outputs were provided based on Crib Point jetty as the point of extraction. The boundaries of the zones were based on tidal excursion distance, topography, water depth and known benthic habitat character; • The entrainment consequence criteria were developed in consideration of biological factors (plankton growth rates and mortality) and physical factors (natural tidal flushing losses to Bass Strait); • The standard measures to minimize entrainment adopted for this project to mitigate entrainment were those used at desalination plants in Victoria, Western Australia and South Australia including; o (1) maintaining water velocities below 0.15 m/s (9 metres per minute) at the intake which allows most free-swimming biota from around 2 cm long the ability to avoid entrainment threats (USEPA 2004), and o (2) locating the intake a suitable distance above the seabed and below the seasurface to minimize intake of biota or drifting buoyant or negatively buoyant material, in this case approximately 2 m above the seabed and 2 m below the surface. These mitigation measures were adopted as project mitigation measures in Section 25 of the EES, are described in full Section 7.5 of Technical Report A, and included in the list of mitigation measures in Section 0 of this Witness Statement.

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 10 of 38 Expert Witness Statement Scott Chidgey Marine Biodiversity Impact Assessment 8.2.4 Model outputs The integrated model presented percentile contours of chlorine guideline value, temperature differential guideline exceedances and entrainment percentages and relative percentages for particles passing within the entrainment zone of the FSRU intake. The hydrodynamic model provided the predictive likelihood (percentile occurrence) and consequence (area of guideline value exceedance) based on physical processes and conservative ecosystem protection values. Dr Wallis was responsible for, and has explained the development of the model, its structure and capabilities and quality of the various module outputs (currents, dilutions, entrainment). He has also explained all seawater intake and discharge flows and characteristics. The model has been used to show outputs for a range of FSRU seawater usage scenarios provided by AGL.

8.2.5 Ecosystem receptors The topography, tides, currents and seawater exchange between Western Ports segments and with Bass Strait are key to shaping the marine biodiversity characteristics Western Port. The patterns of large tides and strong tidal currents in and out Wester Port from Bass Strait and through the main channels and around the Islands, and provide seawater for all marine life in Western Port. These currents maintain connectivity of marine communities within Western Port and with Bass Strait. A conceptual model of ecological pathways in Lower North Arm of Western Port was used to identify ecosystem receptors (habitats and associated communities) in the effects risk pathways. Chlorine and Temperature Modelling demonstrated that the coldwater discharge was likely to have greatest potential temperature differential with ambient seawater, resulting in a discharge that descended towards the seabed. Hence, the key impact pathway for chlorine and temperature was the effect of temperature and chlorine exposure to biota in the water column (plankton) and on the seabed (benthic and demersal community). We recognised that the natural seabed of North Arm of Western Port is predominantly unconsolidated sediments – the closest known significant subtidal natural reefs are known as Crawfish Rock, located approximately 10 km north of Crib Point. The physical nature of the seabed is a key factor in determining the distribution of biological communities on soft seabeds. We also knew from our previous investigations that the soft seabed texture and composition were relatively patchy in North Arm. We considered that the most effective method of documenting the nature of the seabed habitat and associated biota was using towed video. Hence, we initiated surveys to document the nature of the seabed habitat and associated biota in Lower North Arm focussing on Crib Point. We collected grab samples of sediments around Crib Point Jetty and various reference points to document the general nature of the infauna at Crib Point Jetty with reference to other parts of Lower North Arm. I consider that the results of the towed video surveys results provide the most valuable broadscale information on the distribution of soft seabed habitats and associated epibiota, infaunal and sedentary fish communities in Lower North Arm that may be affected by the discharge as demonstrated by the modelled chlorine and temperature guideline values. These effects on a range of receptors and as accumulated impacts are discussed and assessed in detail in Section 7.

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 11 of 38 Expert Witness Statement Scott Chidgey Marine Biodiversity Impact Assessment Entrainment Entrainment was recognized as a potentially significant stressor on plankton populations in North Arm. Existing information was deficient in characterising plankton community of North Arm and so a program of monthly phytoplankton, zooplankton and ichthyoplankton sampling in the water column of North Arm was initiated. The program spanned 13 months. The most detailed previous plankton sampling program was in the central East Arm of Western Port during from 1982 to 1983. The EES zooplankton program followed the 1980s methods and produced remarkable similarities in abundance and seasonal variation of the key zooplankton species in Lower North Arm compared to the central East Arm program 35 years earlier.

The plankton program also documented the strong differences in the plankton community of inner Western Port (North Arm and East Arm) with adjacent Bass Strait and Port Phillip Bay. The key driver for the particular plankton species mixes in inner Western Port have previously been convincingly attributed to the elevated quantities of fine suspended material and strong tidal currents of inner Western Port compared to Bass Strait and Port Phillip Bay. The model outputs demonstrated the natural dispersion of particles from various modelled zones and confirmed the presence of a flushing gradient along Lower North Arm and into the Western Entrance. The plankton sampling program also showed evidence of this gradient which is an important factor in assessing the incremental effects of entrainment mortality in the context of loss of plankton from inner Western Port to Bass Strait by the natural, continuous process of tidal flushing. I consider that the documentation of temporal and spatial patterns in the plankton communities in North Arm, the modelling of natural flushing of plankton by tidal processes and the modelled entrainment of plankton by the FSRU provides a thorough basis for the assessment of entrainment effects provided in Section 7 of EES Technical Appendix A.

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 12 of 38 Expert Witness Statement Scott Chidgey Marine Biodiversity Impact Assessment 9 Marine Environmental Impact Mitigation Measures EES Chapter 25 lists and described the following 16 measures to mitigated marine environmental impacts from vessel, port and operational related potential impacts on marine biodiversity values. MM-ME01 Design of intake, velocity and screening grilles MM-ME02 Limit seawater regasification flows between September and February MM-ME03 Use 6 port design to increase mixing MM-ME04 High velocity discharge to increase dilution MM-ME05 Port of Hastings Handbook MM-ME06 Compliance with the environment management plan, regulations or policies MM-ME07 No unauthorised below water cleaning of vessels MM-ME08 Operation within dredged area MM-ME09 Vessel Class and IMO standards compliance MM-ME10 FSRU mooring and LNG carriers pilotage MM-ME11 Limiting lights to the number for safe operations MM-ME12 Appropriate antifoul, cleaned and inspected in accordance with regulations MM-ME13 Vessel exclusion zone around FSRU MM-ME14 Policing of exclusion zone MM-ME15 Vessel Speed Restrictions MM-ME16 Monitoring Programs

I have colour-highlighted the measures according to the impact pathways listed in Section 8 of my statement. • Mitigation measures highlighted in green are consistent with managing the effects of operation of the FSRU as a storage and regasification facility, including mitigation of effects of entrainment and discharge of seawater at a different temperature from ambient and containing chlorine. • Measures highlighted in blue are existing Port of Hastings Development Authority (PoHDA) management measures consistent with managing the effects of commercial shipping and facility maintenance related impacts in the Port of Hasting. • Measures highlighted in magenta are existing PoHDA management measures that, subject to discussion and PoHDA approval, may be augmented or modified to mitigate shipping impacts on migratory species and recreational fishing in the existing exclusion zone around Crib Point Berths 1 and 2. • Monitoring programs are highlighted in yellow. We have suggested five examples of monitoring programs that may be relevant to monitoring and managing the effects of the operation of an FSRU at Crib Point Jetty. • In my experience, environmental approvals are usually conditional on an approved monitoring and management plan. o The scope and detail of any monitoring and mitigation programs would be determined in consultation with relevant environmental regulators: EPA (State), DELWP (State) and DAWE (Commonwealth). o Monitoring programs should include specific environmental objectives and levels of remedial management response. o Program designs should consider potential spatial or temporal gradients of stressor effect on marine ecosystem values, the independence of reference locations and tiered management response triggers and corresponding remedial actions. o In this case the programs should include specific objectives and remedial actions to address Western Port Ramsar Components, Processes and Services

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 13 of 38 Expert Witness Statement Scott Chidgey Marine Biodiversity Impact Assessment

10 Response Agency Submissions Submission 1. EPA 6.1.2 Chlorine Mixing Zone (P 11) Chlorine chemistry EPA p 11: The chemistry of chlorine in seawater is quite complex and may present some difficulties for compliance monitoring of the chlorine mixing zone, particularly given the low concentrations involved. Chlorine in seawater is highly reactive and decays rapidly. The presence of high concentrations of dissolved chlorine and significant concentrations of bromine salts in seawater is natural. Chlorine and bromine are known as halogen chemicals as shown in the Periodic Table, because they have similar characteristics (one electron missing from their atomic outer shell). As salts, they have accepted an electron to fill their outer shell to become a negatively charged ion or salts. In simple terms, electrolysis removes the electron from the most common salt ion (chloride) and creates chlorine. The chemistry of ‘chlorine’ (as the molecule Cl2, dissolved hypochlorous acid HOCl, or hypochlorite ion HCLO-) in seawater is complex compared to freshwater (Section 7.8.4 of our Technical Appendix A, Annexure A, Technical Appendix A and CEE’s referral document (ref CEE 2018b in Technical Appendix A). Chlorine that is added to freshwater is relatively stable and remains at relatively constant equilibrium with its other oxidant forms in pure freshwater. However, seawater contains chloride (the salt of chlorine) and a range of other halogen salts, particularly bromide. The presence of these salts is the reason chlorine and bromine can be produced by electrolysis of seawater, and not from freshwater (unless a catalyst is added). The dissolved chlorine, halogen salts and other organic matter react through a series of halogen forms (CPOs) back to their natural salt form, chloride and bromide. The reduction is very rapid initially (seconds), and continues to low concentrations within 30 minutes. The decay rate is increased by mixing with seawater containing more bromide. Consequently, dilution of chlorine with seawater results in very rapid reduction in the concentration of CPO due to the combination of the chemical reaction and dilution. The decay rate is also faster at higher temperature. The processes of electrolysis of seawater also produce a small proportion of halogenated by-products. Natural biological processes also produce these halogenated chemicals as discussed below.

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 14 of 38 Expert Witness Statement Scott Chidgey Marine Biodiversity Impact Assessment Chlorine by-product Bioaccumulation EPA p11: Studies suggest there is a low risk of bioaccumulation of halogenated by- products given the environment at Crib Point (Section 7.8.25 of Technical Report A). However, these issues should be assessed in more detail during the IAC hearing. Earth’s entire marine ecosystem has evolved in the presence of relatively high concentrations of these halogens as salts. As discussed in section 7.8.25 of our EES Technical Report A, marine biological systems have evolved in an environment of high chloride, bromide and iodide availability and these salts are involved in many natural chemical and marine biological processes. We provided the following figure in Section 9.8.25 from Jenner and Wither 20111.

Natural halogen cycle in the marine environment In addition to the discussion and references cited in Technical Report A, Gribble 20152 states: “From fewer than 50 examples of halogenated natural products that were known in 1968, the number today is more than 5000 and steadily increasing. A majority of these compounds are found in marine organisms and several recent reviews are available of marine natural products in general, in algae, in sponges, in invertebrates, in gorgonians, in bryophytes, in fungi, in cyanobacteria, in marine bacteria, and those cyano-containing marine triterpenoids”.

1 Jenner H and A Wither (2011). Chlorination by-product in power station cooling water. Science Advisory report. BEEMS Expert Panel. EDF Energy UK.

2 Gribble GW 2015. “Biological activity of recently discovered halogenated marine natural products”. Marine Drugs 2015 13: 4044-4136

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 15 of 38 Expert Witness Statement Scott Chidgey Marine Biodiversity Impact Assessment All halogenated by-products (HBP) produced by electrolysis of seawater (Allonier et al 19993) are listed in those as naturally produced by Gribble. According to Gribble 2015, the biological activity of these complex halogen compounds manufactured by marine biota are listed as antibacterial, antiparasitic, antiviral, antitumor, anti-inflammatory, and antioxidant. Unlike freshwater, halogenated chemicals are present naturally in many coastal environments. Also unlike freshwater, chloramines and bromamines are seldom formed from electrolysis because of the affinity of chlorine to bromide and the relatively low concentrations of ammonia in marine seawater. Research quoted in our Technical Appendix A and its Annexure A (CSIRO) show that electrolysis of seawater mostly produces CPOs, but also produces a small quantity of halogenated bi-products (HBPs), mostly bromoform in well-mixed environments. We note that all halogenated by-products that may be produced from electrolysis of seawater in mixing conditions such as Western Port are listed in Gribble 2015 and others (eg, Jenner and Withers 2011) as being produced and regulated naturally and in marine ecosystem processes. The acute and chronic toxicity of all HBPs is included in the overall toxicity of the CPOs used by CSIRO. CSIRO explained in the considerations in interpreting the toxicity data used to develop the 99% Guideline Values CSIRO’s report Appendix A to EES Technical Report A. These included the decomposition rates of the various chlorine by-product species and “the time of exposure required to elicit ether acute or chronic toxicity to determine the nature of the impact” and where contaminants are “non-persistent due to dispersion, volatilisation or degradation”. I accept that that the use of continuous flow bioassays for toxicity tests used to establish the species sensitivity distribution (SSD) and the Guideline values are appropriate to the well-mixed, strong tidally influenced environment of Western Port. These well-mixed conditions supress the formation of more complex HBPs that may occur in low mixing conditions (experimental beakers, Allonier et al 1999) or low mixing conditions and high ambient concentrations of CPOs (Boudjellaba er al 2016). I consider the information in EES Technical Report A, its Appendix A and the additional information here provides a suitable background to support our conclusion of “low risk of bioaccumulation of halogenated by-products given the hydrodynamic environment at Crib Point”.

3 Allonier A-S, Khalanski M, Camel V and A Bermond (1999). Characterisation of chlorination by- products in cooling effluents from coastal nuclear power stations. Mr Poll Bull 38(12):1232-1241

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 16 of 38 Expert Witness Statement Scott Chidgey Marine Biodiversity Impact Assessment Monitoring Program Technical Report A includes a Marine Monitoring Program (Section 8.6) with five key parameters to be monitored: 1. Rates and Characteristics of all Discharges 2. Plankton Survival Study 3. Seabed Biota Monitoring in Port Area 4. Water Quality Sampling 5. Transplanted Mussel Monitoring. EPA considers that these programs cover most of the principle risks, but recommends the following change to Mitigation Measure ME16. I accept EPA’s recommended change to Mitigation Measure ME 16:. “EPA recommends Mitigation Measure ME16 stipulate that the proponent will consult with EPA about the exact nature of the monitoring programs, as part of the discharge licencing conditions.” EPA’s recommendation is consistent with usual practise that monitoring programs in relation to discharges and other impacts associated with marine, freshwater terrestrial and atmospheric aspects of a project would be conditions of any DAWE/DWELP Environmental Approval, Planning Approval, EPA Works Approval and License to discharge. These monitoring programs will be designed in consultation with and subject to approval by DAWE, DWELP and EPA. (See Section 9 of my Witness Statement).

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 17 of 38 Expert Witness Statement Scott Chidgey Marine Biodiversity Impact Assessment Submission 2. Environment Victoria

Contaminants other than chlorine AGL does not provide evidence to support its claim that wastewater discharges would have no contaminants other than residual chlorine. (Section 4.7, p. 49 of the Ecological Impact Assessment). All wastewater discharges to the marine environment from the FSRU are from heat- exchange processes, ballast water, water curtain and fire water on the FSRU. The flows and usages are listed in Tables 6-1, 6-2 and 6-3 and described in Section 6.1 of Technical Appendix A. The flows comprise seawater that passes through an electrolytic cell as it is withdrawn from Western Port at Crib Point. The seawater is in-contact only with mild steel pipework and process vessels (heat exchangers and ballast tanks) before discharge. Hence, no other contaminants are added to the seawater other than chlorine residuals (iron – Fe - is not considered a contaminant or toxicant). As discussed above, chlorine and other halogenated by-products of seawater electrolysis are also produced by natural processes in the marine environment. The chemistry, behaviour in the environment, toxicity and potential bioaccumulation of constituents resulting from the electrolysis of seawater (residual chlorine) described in Section 7.8.4 of our Technical Appendix A, Annexure A, Technical Appendix A and CEE’s referral document (ref CEE 2018b in Technical Appendix A). Our approach to this matter is provided in our earlier response to EPA’s submission. 99 % protection guideline value The documents do not explain why a 99% guideline value for protection was not adopted, considering that the project would be developed in a Ramsar site. 99% Guideline Values for chlorine were used for this assessment. 99% Guideline Values were not available in previous ANZECC 2000 Guidelines or the present on-line Guidelines, so CEE contracted CSIRO’s Drs Graeme Batley and Stuart Simpson to develop a 99% Guideline Protection Values for chlorine toxicity in the marine environment. Their report contents and results are cited extensively as “CSIRO 2019” in our Technical Appendix A and their report is provided as Annexure A to our report. More recently, Drs Batley and Simpson’s review, analysis and results have been accepted for publication in the international peer reviewed journal Environmental Toxicology and Chemistry, and will be proposed as ANZ National Water Quality Guideline Values for chlorine in the marine environment in Australia and New Zealand. Chronic toxicity data and significant exposure The guideline values used to assess the impacts on the ecosystem do not use chronic toxicity data. This is material as sedentary organisms could be chronically and significantly exposed to the Project’s wastewater toxicants. As discussed above, chlorine and other halogenated by-products of seawater electrolysis are also produced by natural processes in the marine environment. Unlike freshwater, halogenated chemicals are present naturally at low levels in many coastal environments. The 99% Guideline value for chlorine in marine waters developed by CSIRO using data from a wide range of toxicity bioassay data that passed rigorous quality assurance assessment

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 18 of 38 Expert Witness Statement Scott Chidgey Marine Biodiversity Impact Assessment criteria as described in Warne et al 2018 (cited in Technical Appendix A). Only data that conformed with these criteria, including continuous exposure to high concentrations of chlorine relative to those likely at Crib Point, were included in the species sensitivity distribution used to calculate the Guideline values. CSIRO explain that the decomposition rates of the various chlorine produced oxidants and by-products and “the time of exposure required to elicit ether acute or chronic toxicity to determine the nature of the impact” and where contaminants are “non-persistent due to dispersion, volatilisation or degradation” were included in the development of the 99% protection value. See our response to EPA. Hence, the 99% ecosystem protection guideline value includes consideration of chronic exposure with respect to the persistence of by-products in a well-mixed environment. We modelled 99% ecosystem protection guideline value frequency contours for various periods and operational flows, mostly focussing on the maximum flow rate in open loop (that is, the maximum amount of discharge flow possible by the FSRU). We discuss the nature of the marine habitats and associated biota within these contours and their wider distribution as context for our assessment of risk to marine ecosystem values. EPA has acknowledged that we recommended that a monitoring program should be developed and included in any Approvals or licence that would monitor for potential changes in by-product levels in indicator organisms should the project proceed. Potential discharges during construction The EES failed to provide adequate information to allow for the accurate identification of potential discharges to the marine environment during the construction phase and to quantify the character of these discharges (key components, volumes, temperatures, concentrations) The EES states that FSRU will arrive in a fully operational conditions for LNG loading, storage, regasification and gas loading only after fulfilling all regulatory requirements for arrival of an international vessel including ballast changes and marine pest inspections described in Sections 7.11.2 and 7.11.3 of our Technical Appendix A. Hence, we are unaware of any discharges to Western Port due to construction on the FRSU. The Port of Hastings Development Authority’s submission provides a description of port operational upgrades related to the Crib Point jetty and shipping basin. These works have received Consents that are valid under the Marine and Coastal Act 2018. The works do not require any discharges to the marine environment, and will be managed by Environmental Management Plans and other requirements of the Port Safety and Environment Management Plan (SEMP), as described in the Authority’s submission. These EMP’s must aim to ensure spills and discharges to the marine environment area avoided, or that they are appropriately managed should they occur. Hence, from my perspective, there were no discharges to the marine environment planned during the construction phase that were relevant to the EES consideration of marine environmental impacts at Crib Point within the Port of Hastings that would not readily be management with a Construction Environment Management Plan.

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 19 of 38 Expert Witness Statement Scott Chidgey Marine Biodiversity Impact Assessment Use of Barramundi for ‘acute lethality’ test The EES analysed the impact of chlorine on juvenile marine stage barramundi (Lates calcarifer). This fish does not inhabit Westernport Bay. While this could be part of a standard testing approach the best practice would be to conduct the test with fish that actually inhabit Westernport Bay. Considering the high conservation value of the area we think that a best practice approach is warranted. State Environment Protection Policy “Waters” 2018 states: “The Authority must not approve a mixing zone which, according to tests approved by the Authority, will result in any of the following (a) acute lethality at the point of discharge; (b) chronic toxicity outside the mixing zone;” Any environmental assessment of toxic effects of a discharge on marine biota for licence purposes would most importantly consider National Guideline values for toxicants. Since the discharge from the FSRU contains only chlorine and ambient seawater, the 99% guideline value for chlorine developed during this project has been used, as discussed in my previous responses. EPA’s requirement for acute lethality tests is peculiar to Victoria’s environmental regulation. The Waters Policy (SEPP 2018) wording “acute lethality at the point of discharge” is unchanged from the Waters of Victoria Policy 2003 (SEPP 2003) and is consistent with the 1988 Waters of Victoria Policy (SEPP 1988) that stated “the waste shall be deemed to be acutely toxic if more than 50% of a representative test species nominated by the Authority die within a 96 hour toxicity test using 100% effluent”. The science of bioassays and the rigorous quality assurance and ethical requirements for toxicity testing has advanced substantially since 1988, but the individual intent of EPA’s inclusion that a discharge must not result in “acute lethality at the point of discharge” according to a test approved by EPA has not changed. There are few laboratories in Australia who are accredited by National Association of Testing Authorities (NATA) to carry out marine toxicity bioassays, and there is a limited range of accredited lethality toxicity tests on temperate climate marine biota. The culture and quality requirement on lethality tests restricts the availability of test organisms. Two “acute lethality tests” that have been used consistently for this purpose in Victoria are: • Marine invertebrate (Allorchestes compressa) 96 hour acute lethality (LC9650) • Juvenile (late larval) fish (marine species) 96 hour acute lethality (LC9650) Ethical considerations governing bioassays since the 1988 SEPP have resulted in changes to “death” as the endpoint determining lethal concentrations or LCs. End points for these tests are now “morbidity” or “imbalance” as the effect concentration (EC) indicating impending lethality. Test biota are humanely euthanised prior to lethality. As I have mentioned, procedures for acceptable laboratory bioassays have stringent statistical requirements on control or reference organism populations. Firstly, test organisms must be reliably available. They must meet strict quality requirements of consistency including single population, same age, same development state and more than 90% of individuals must survive in the reference or ‘control’ preparations (artificial seawater and fresh, filtered seawater). Wild caught local individuals do not meet these requirements.

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 20 of 38 Expert Witness Statement Scott Chidgey Marine Biodiversity Impact Assessment Although commercial supplies of kingfish, snapper and Australian Bass post-larvae or juveniles are sometimes available these supplies are unreliable and fish frequently do not meet the QA survival requirements on control preparations. Barramundi are the only species to consistently met the supply and QA requirements. For these reasons, barramundi Lates calcifer are the fish most frequently used for this test elsewhere in Victoria in recent years. Hence, these were used for the fish imbalance test for the AGL chlorine acute lethality test. In addition, their preferred marine environment as juveniles is similar to Western Port (other than water temperature): tidally characterised environment, mudflats, seagrasses and mangroves.

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 21 of 38 Expert Witness Statement Scott Chidgey Marine Biodiversity Impact Assessment Submission 3. Department of Agriculture, Water and the Environment (DAWE)

Monitoring Program The Marine Monitoring program does not contain specific objectives or remedial actions to address the Ramsar CPS (Pages 110-111 Attachment 1) See Section 9 of my Witness Statement regarding Monitoring:

• “In my experience, environmental approvals are usually conditional on an approved monitoring and management plan. o The scope and detail of any monitoring and mitigation programs would be determined in consultation with relevant environmental regulators: EPA (State), DELWP (State) and DAWE (Commonwealth). o Monitoring programs should include specific environmental objectives and levels of remedial management response. o Program designs should consider potential spatial or temporal gradients of stressor effect on marine ecosystem values, the independence of reference locations and tiered management response triggers and corresponding remedial actions. o In this case the programs should include specific objectives and remedial actions to address Western Port Ramsar Components, Processes and Services”

Entrainment of grayling larvae and eggs seasonality Entrainment predictions on fish eggs and larvae notes spring and summer as times of higher abundance and potential impacts. _see. 7.2.2 p.109 The discussion of Australian Grayling in Chapter 6 (p.6-57) and Section 7.2.2 p.109 Attachment 1, states the species larvae drift downstream and spend time in the marine environment before returning upstream as young juveniles from September to December and concludes their eggs are not likely to be entrained as they are not viable in marine waters. This information was compiled from published research literature on grayling populations in Victoria, which are cited in the text in Technical Appendix A (Bacher and O’Brien 1989, Backhouse et al 2008, Crook et al 2006 Koster et al 2013) Entrainment predictions on fish eggs and larvae notes spring and summer as times of higher abundance and potential impacts. _see. 7.2.2 p.109 This information was compiled from published research literature on grayling populations in Victoria , which are cited in the text in Technical Appendix A (Bacher and O’Brien 1989, Backhouse et al 2008, Crook et al 2006 Koster et al 2013) The discussion of Australian Grayling in Chapter 6 (p.6-57) and Section 7.2.2 p.109 Attachment 1, states the species larvae drift downstream and spend time in the marine environment before returning upstream as young juveniles from September to December This information was compiled from published research literature on grayling populations in Victoria, which are cited in the text in Technical Appendix A (Bacher and O’Brien 1989, Backhouse et al 2008, Crook et al 2006 Koster et al 2013)

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 22 of 38 Expert Witness Statement Scott Chidgey Marine Biodiversity Impact Assessment The discussion of Australian Grayling … concludes their eggs are not likely to be entrained as they are not viable in marine waters. This information was compiled from published research literature on grayling populations in Victoria, which are cited in the text in Technical Appendix A (Bacher and O’Brien 1989, Backhouse et al 2008, Crook et al 2006 Koster et al 2013) Identity of single larva as Grayling in ichthyoplankton sampling program However, as a late larval Australian grayling was caught during the ichthyoplankton sampling program in September, Table 6.14 (page 6-80) notes entrainment these juveniles is possible. The data record for the single individual “Retropinnidae, Smelts and Grayling” was interpreted by our team as possibly a migrating grayling larva on the basis of its occurrence corresponding to the grayling return migration period of juveniles from September to December. Hence, we conservatively reported this for the purpose of the assessment as a late larval or juvenile Australian grayling. Recently, the ichthyoplankton specialist advised that the larva described as “Retropinnidae, Smelts and Grayling larva” was small (approximately 5 mm long) and likely to be only days old (photos below).

Dorsal view Ventral view Larval specimen from Lower North Arm, September 2019,

His further examination of the “Retropinnidae” sample from Lower North Arm and comparison with known Retropinna sp and galaxid larvae from elsewhere indicated that the pigmentation pattern (small black dots on ventral view) of the Lower North Arm individual was more consistent with common galaxid species than Retropinna. Hence, it is likely that the Lower North Arm individual was not an Australian Grayling. The Grayling spawning period (when adults travel downstream in their freshwater stream and eggs and larvae are found in the lower freshwater reaches of streams rivers), has been comprehensively documented in the Bunyip River as March to June, with peak months of April to May - or autumn to early winter (Koster et al 2013). The North Arm individual was caught in September, which is inconsistent with all known grayling downstream late autumn to early winter migrations. As discussed above larvae return from their development period in the marine environment to migrate as young juveniles into freshwater streams from September to December. Juveniles returning from Port Phillip Bay to the Yarra River during this period have a recorded length range 46 mm to 75 mm (Jones et al 2016). The size of the North Arm

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 23 of 38 Expert Witness Statement Scott Chidgey Marine Biodiversity Impact Assessment specimen caught in September is about one tenth of the size expected for a returning Grayling and is therefore most unlikely to be a juvenile grayling . Overall, therefore, the weight-of-evidence suggests that the specimen conservatively identified as a returning grayling larva is not a grayling, but a more common galaxid. The actual identity of the individual; is not likely to be resolved in the near future. So our conservative estimate of the likelihood of grayling being entrainment stands at “Possible”. Mitigation of fish and juvenile fish entrainment (including Grayling) Mitigation (screening of intakes) therefore should be designed to avoid entrainment. No conclusive statement is made about the effectiveness of the intake grille (100 x100 mm) for this species and this needs to be provided. We did not suggest or infer that the screens were intended to provide a physical barrier to entrainment of grayling juveniles. In that section we stated that the mitigation provided by the screen was to act as a physical barrier “to deter large biota from entering (large fish, squid, penguins, cormorants or seals) or prevent large, slow-moving invertebrates (eg, jellyfish such as Catostylus mosaicus) from being entrained.” The mitigation measure to prevent impingement or entrainment of fish and juveniles included limiting the water intake speed passing the screens to less than 0.15 m/s. USEPA 2004 states: “To develop a threshold that could be applied nationally and is effective at preventing impingement of most species of fish at their different life stages, EPA applied a safety factor of two to the 1.0 ft/s threshold to derive a threshold of 0.5 ft/s. This safety factor, in part, is meant to ensure protection when screens become partly occluded by debris during operation and velocity increases through portions of the screen that remain open… The data suggest that a 0.5 ft/s (0.15 m/s) velocity would protect 96 percent of the tested fish.”

This mitigation measure was adopted at the Victorian Desalination Plant and is included as Mtigation Measure MM-ME1 for this project in Chapter 25.

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 24 of 38 Expert Witness Statement Scott Chidgey Marine Biodiversity Impact Assessment In view of the strong seasonality of fish larvae (including the possible migration of grayling through North Arm), we also recommended that gas production should be lowered and thereby volume of seawater used over spring and summer to increase the protection of fish larvae (including grayling) over the period August to December – which is the grayling larvae migratory period: The entrainment consequence ratings, with a particular focus on fish larvae, are shown in Table 4-4 and their development is described in Section 4.5.4. A more stringent consequence was defined for the fish breeding months in spring and summer with a less stringent consequence for months outside the principal fish breeding season. In summary, in spring and summer, the average intake and discharge from the regasification process (including the freshwater generator and seawater discharge filter) must be below 315,000 m3/d in any 14-day period. This is included as Mitigation Measure MM-ME2 for this project in Chapter 25. Cool water effects on grayling EES Attachment I MNES. Table 6.17 dealing with risks for protected species from the cool water discharge … did not specifically address this species (Grayling). In CEE’s Technical Appendix A Section 5.5.6, we introduce the water temperature differential guideline value used in the assessment that is based on ambient seawater temperature variations measured at crib Point at 15 minute intervals for a 12 months period in 2018-2019. The risks to marine biota are relative to natural variations and apply to any species that occurs in lower North Arm, including larval and post larval juveniles. It is noted in this response that juvenile grayling are likely to experience substantially greater variation as adults in their freshwater environment. Chlorine risk grayling Risks of chlorine, did not specifically address this species (Grayling). As discussed in my response EPA’s submission, the 99% ecosystem protection guideline value for chlorine concentration used in this section of our report was developed by CSIRO. CSIRO recommends that it becomes the National guideline value and applies to all assessment situations, including grayling in Australia. Possible migratory path of grayling from marine environment to freshwater However, the risk (to grayling) is discounted on the basis the species is unlikely to be present in the vicinity of the FSRU as they use the eastern channel of the Western Port. DAWE’s sentence is a summary of the context of previously presented text for Grayling in Section 7.6.16 of EES Technical Report A: “Adult Australian Grayling populations occur in the freshwater parts of the Bunyip River, Lang River and Cardinia Creek, are possibly in the freshwaters of the Bass River. As discussed in Section 5 larvae drift downstream and enter Western Port from April to July with a peak in May (Koster and Dawson 2010; Koster et al. 2013; 2018). Larvae then undergo a period of marine residency for four to five months before returning upstream as young juveniles from September to December (Crook et al. 2006; Koster et al. 2019). It is not known whether larvae remain in Western Port or are dispersed offshore over the period of marine residency (Crook et al. 2006). Flushing periods in the Lower North Arm and Western

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 25 of 38 Expert Witness Statement Scott Chidgey Marine Biodiversity Impact Assessment Entrance as indicated by the modelling are short relative to the four to five month larval and juvenile period of Grayling in the marine environment. Hence, this and the lack of Grayling juveniles in samples from March to September, indicate that it is unlikely that significant proportions of Grayling larvae disperse or remain in Lower North Arm. However, the low flushing rates in the north, northeast and Rhyll segments of Western Port suggest that it is possible that larvae and juveniles could spend significant periods there. Salinity data and physical processes show that freshwater discharges from the northern Western Port streams disperse into the Eastern Arm of Western Port. Eggs are not viable in the marine environment, hence there is no risk of entrainment of viable eggs being entrained. No early larvae of Australian Grayling were identified in the ichthyoplankton sampling program in Lower North Arm over the thirteen-month period of monthly sampling. Hence, the likelihood of Australian Grayling late larvae or juveniles being entrained is possible. As the larger proportion of returning Australian Grayling late larvae or juveniles would follow the easier migratory current paths and freshwater cues into the East Arm the consequences are minor.”

Marine Turtles Leatherback turtles are known to occur in the vicinity of the proposed activity and the increased shipping activity associated with the proposed development may increase the risk of ship strike for this endangered species. The impact of ship strike does not appear to have been considered for any marine megafauna. Green and loggerhead turtles are also known to occur, but in very low numbers and it is unlikely that the propose activity will impact on the recovery of these species in Australia. We have addressed impacts of ship strike on whales (which are megafauna) extensively in 7.11.4 of EES Technical Appendix A. I agree that green and loggerhead turtles are also known to occur, but in very low numbers and it is unlikely that the propose activity will impact on the recovery of these species in Australia.

CEE’s referral document that (CEE 2018 e), supplied to DAWE during referral) states: (Leatherback turtle) Adults live in ocean habitats and rarely come close to shore in Australia. Breeding occurs on tropical islands throughout the world. Leatherbacks found around Australia are understood to breed in the islands of Indonesia, Papua New Guinea, Torres Strait and Arnhem Land. The species is migratory, travelling thousands of kilometres between breeding and foraging areas. Leatherback Turtles feed mostly on pelagic invertebrates such as jellyfish and Bass Strait has one of the three largest concentrations of feeding Leathery Turtles in Australia. In Victoria, Leatherback Turtles are most commonly seen between April and May, when the waters of Bass Strait are warmest. Sightings and strandings have been recorded all along the Victorian Bass open coast, Port Philip Bay and the Gippsland Lakes (Figure 10). There are no records from Western Port, however there have been numerous sightings nearby, including around Port Phillip Head. The Leatherback Turtle is considered critically endangered worldwide, vulnerable under the EPBC Act and critically endangered in Victoria (DSE, 2007), though it is listed as threatened under the FFG Act. The key threat to the species, as for many turtles, is human disturbance of breeding habitats and harvesting of eggs. Leatherback Turtles do not nest in Victoria. Other threats include by-catch in commercial fisheries, and in Victoria the key by-catch threat is entanglement in cray

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 26 of 38 Expert Witness Statement Scott Chidgey Marine Biodiversity Impact Assessment pot buoy lines. Ingestion of marine debris is also a concern, particularly of plastics, as Leathery Turtles tend to feed along drift lines where debris accumulates. It is apparent from the information that we have presented that Leatherback Turtles, as a species or as an individual, face numerous threats during their long life and many thousands of kilometres of annual migrations. Shipping, and boats in general, over the range of their lifetime are one of those threats. In the context of these existing threats and the increasing number of vessels (boats and ships) over the large range of these impressive, threatened, long-lived animals, the incremental risk associated with ship strike by LNG tankers in Western Port is very small. See my response to “Mitigation measures to minimise the risk of adverse impacts to migratory species” below.

Reference to National Light Pollution Guidelines for Wildlife It should also be noted that while Chapter 1 – Matters of National Environmental Significance recognises the potential for light impacts, the document does not refer to the National Light Pollution Guidelines for Wildlife including Marine Turtles, Seabirds and Migratory Shorebirds. CEE provided reference to the “National Light Pollution Guidelines for Wildlife” in Section 7.10.5 of EES Appendix A: “The recently released Commonwealth Draft National Light Pollution Guidelines for Wildlife (DEE, 2019) provide discussion mostly specific to marine turtles, seabirds and migratory shorebirds.” We understand the Draft has been adopted as the Guidelines. … With reference to turtles the Guidelines state: “artificial light can disrupt critical behaviours such adult nesting and hatchling orientation, sea finding and dispersal, and can reduce the reproductive viability of turtle stocks”. As discussed above, none of the turtles that find their way into Western Port will be “sea finding” hatchlings or nesting. Hence the risk of light spill to turtles is covered by our risk category for marine biota of low.

Cetaceans The Draft Attachment MNES report correctly identifies that the Western Port area is not a known Biologically Important Area (BIA) for threatened or migratory cetaceans. However, it does not acknowledge that the waters adjacent to the proposed action area provide a known BIA for migrating and resting on migration Endangered Southern Right whales and a foraging area for Endangered Pygmy Blue whales. Although targeted cetacean surveys have not been undertaken to inform the referral it is understood that Humpback whales and individuals or pairs of SRW have previously been recorded in Western Port Bay. CEE’s referral document (CEE 2018) and EES Appendix A provide information and “Two Bays Project” map of humpback whale, southern right whale and killer whale sighting in Western Port from 2014 to 2017. We include the text “Humpback whales were the more frequently seen, followed by the Southern Right Whale and a few sightings of Killer Whales. Most sightings occur along the shipping channel in the Western Entrance. Only six sightings were recorded in North Arm between 2014 and 2017”. We also include: “Southern Right Whales intermittently pass along the central Bass Strait coast and may enter for short periods into Port Phillip and Western Port. They sometimes enter Western Port’s western entrance and have been observed near Crib Point, but the bay is not known to be an

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 27 of 38 Expert Witness Statement Scott Chidgey Marine Biodiversity Impact Assessment aggregation or breeding area for Southern Right Whales. These whales do rarely enter Western Port or are spotted around the entrance to the Bay.” Our reference to “aggregation and breeding areas” were based on those listed and mapped in the “Conservation Management Plan for the Southern Right Whale” (DSEWPAC 2012). We note that the Plan and SWIFT list “Biologically Important Areas” for Southern Rights in Victoria. DAWE’s reference to “the waters adjacent to the proposed action area provide a known BIA” refer to the nearest documented “emerging aggregation area”, which is Port Campbell located more than 160 km west of Western Port or about 200 km as the whale swims. The nearest established Southern Right Whale aggregation and breeding area is at Warrnambool, approximately 250 km west of Western Port. The entrance to the major shipping port of Port Melbourne is positioned between Western Port and both Port Campbell and Warrnambool. I therefore consider our description of the use of Western Port by Southern Rights as appropriately informative of its importance to this endangered whale. With respect to Pygmy Blue whales, I would firstly say that the term ‘pygmy’ is a misrepresentation of this subspecies. Although it is almost 7 m shorter than its northern hemisphere relative, at just over 21 m this ‘pygmy’ whale is 5 m longer than Southern Right and more than 7 m longer than humpback whales. Our true-Blue is the biggest animal to be seen in our nearshore waters, or on land for that matter, and is a very impressive whale in real life. I acknowledge that understanding of our blue whales in Victorian waters is rapidly increasing with the work of Peter Gill and his colleagues and it is likely that the more areas of its activity along the Victorian coast will be documented apart from the known feeding grounds in upwelling areas offshore from Warrnambool and westward. Blue whale carcasses occasionally appear on our beaches or floating offshore. The known range of our blue whales overlaps numerous existing major shipping routes which are increasing in volume as we have documented in Section 7.11.5. Overall, therefore, I conclude that the information we have provided is sufficient to support our risk assessment with respect whale strike to inform the Panel. Mitigation measures to minimise the risk of adverse impacts to migratory species The Department considers that further consideration of impacts to migratory species is required, including development of appropriate mitigation measures to minimise the risk of adverse impacts. We have provided a range of information on migratory marine turtles and mammals that provide context of the existing ranges and likelihood of representation of population of those species in the neighbourhood of the project and potential impact pathways (see Section 8 of my Witness Statement). We have provided context on the contribution of the project to existing risks to those species, which indicates the project will contribute little to the existing or future risks to these valued species and individuals. I agree with DAWE that appropriate mitigation measures to minimise the risk of adverse impacts with respect to ship strike requires development, and I believe that this will be required at a national level.

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 28 of 38 Expert Witness Statement Scott Chidgey Marine Biodiversity Impact Assessment Submission 4. Mornington Peninsula Shire

8. Marine Biodiversity Claimed deficiencies 8.2. In Council’s submission, the marine biodiversity impact assessment in the EES is significantly deficient in the assessment and management of risk, including in: 8.2.1. Failing to provide sufficient information to make a properly informed assessment of impacts As discussed in my Witness statement, I am satisfied that the predictions provided by the hydrodynamic, particle dispersion and tracer dispersion models in combination with the chlorine guideline value for 99% protection of marine ecosystems, the temperature differential value, entrainment/natural flushing loss guideline, the new information we collected during the EES investigations and existing information provide sufficient information for assessment of impacts of this proposal of marine biodiversity values. 8.2.2. Underestimating the risk (either likelihood, significance of consequence or both) of identified impacts; As discussed in my Witness statement, I am satisfied that the predictions provided by the hydrodynamic, particle dispersion and tracer dispersion models in combination with the chlorine guideline value for 99% protection of marine ecosystems, the temperature differential value, entrainment/natural flushing loss guideline in combination with the information on the distribution of habitats and associated marine ecological communities provide a realistic estimate of the likelihood (percentage), consequence (spatial and temporal extent of effect of guideline values) and ecological community (habitat and associated biota). These are clearly stated in the assessment and I consider them to be suitably conservative in the context of North Arm of Western Port as a Ramsar area. 8.2.3. Proposing inadequate mitigation measures to address potential impacts; and As discussed in mitigation measures in Section 9 of my Witness Statement.

8.3 In Council’s submission, certain further information is required from the Proponent before the potential impacts of the Project can be assessed with any certainty. Specifically, Council considers the Proponent ought to be required to provide the following information before expert evidence is circulated and certainly, before the IAC hearing commences: I consider that there is adequate information EES Technical Appendix A, and my previous responses to agency submissions address most items suggested in this section 8.3 of MPSC submission. Responses to specific items in Section 8.3 are provided below. … 8.3.3. Collection and analysis of sediment samples in and surrounding the basin within any areas likely to be disturbed by discharge of water from the FSRU or associated with turbulence from tugs, LNG carriers etc. to determine the potential presence of toxic dinoflagellates in sediment; The phytoplankton sampling program identified that potentially harmful phytoplankton species are present in North Arm waters in low numbers. Analysis of all phytoplankton samples collected during thirteen months of monthly sampling consistently recorded “Levels of potentially harmful species were below aquaculture alert levels”. The specialist subconsultant report (appended to Annexure B of EES Technical Report A) advised that: “With the high level of mixing caused by tidal currents, and the (natural) disturbance of bottom sediments, it is unlikely that (dinoflagellate) cyst beds are present in the Lower North

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 29 of 38 Expert Witness Statement Scott Chidgey Marine Biodiversity Impact Assessment Arm. In fact, an early University of Melbourne survey of dinoflagellate cysts in Western Port failed to detect any cysts in samples from seven different sites (D.Hill pers. comm.).” Dinoflagellate cysts are widespread in the sediments of Port Phillip Bay and coastal waters of Bass Strait including northern Tasmania. Harmful algal events have occurred in Port Phillip, but have never occurred during or soon after dredging events. In view of: the low numbers of potentially harmful phytoplankton in North Arm • the high level of mixing in North Arm • the “unlikely” presence of “cyst beds” in Lower North Arm • the relatively high natural turbidity in Lower North Arm • the low nutrient status of Lower North Arm relative to Port Phillip, and • the small area of seabed disturbance by the FSRU discharge or movement of tugs at Berth 2 relative to natural and port related disturbance across the rest of Lower North Arm I consider the contribution likelihood of dinoflagellate levels in the water column increasing due to seabed disturbance by the FSRU discharge or movement of tugs at Berth 2 is low bloom resulting from seabed disturbance is very low.

8.3.4. Quantitative survey of fish and benthic invertebrates in basin with suitable replication at 4-5 sites within the Berth 2 basin and within 4-5 sites within at least two control locations; Fish communities in North Arm and more generally in Western Port have been described by Prof Jenkins Melbourne Water’s Understanding Western Port and Section 5.9 of EES Appendix A. Invertebrate epibiota are the invertebrate animals that live on the seabed. These are different from the invertebrate infauna that burrow in the seabed. Natural invertebrate epibiota and infauna communities are strongly influenced by the physical nature of the seabed (rock, gravel, sand, mud, dead shell, shell grit and so on), water depth, turbulence and seabed stability. Strong waves and currents may disturb the seabed and create an environment unsuitable for some biota, but suitable for others. In recognition of the importance of seabed character in determining epibiota and infauna characteristics, our major effort in documenting seabed epibiota and infauna in Lower North Arm focussed on mapping habitat in representative areas using towed video. (Technical Report A Section 5.7.3 and Technical Annexure D). Figures 5-32 shows that the dredged area appeared to be more homogeneous and flat for its size than other areas (Figure 5-32), probably because it is relatively flat following dredging in the 1960s. From our direct observations (including ghost shrimp surveys), the unconsolidated sediments in the dredged area appears to be a relatively shallow layer of fine and medium sand, with a relatively high proportion of shell over a stiff clay base. Lumps of clay are visible at the surface in some places. It is possible that the fine sand and shell resettled to the seabed from the dredge hopper “overflow” in this area during dredging. The tidal currents on the seabed are relatively strong, so epibiota need to attach to something solid on the seabed or take root in the seabed. It appears that the relatively consistent shell and shellgrit over the provides a consistent bed for some epibiota and infauna. Figure 5-38 shows that infauna were more abundant at Berth 2 compared with Berth 1 and reference sites (Figure 5-37). This may be due to a combination of more homogeneous and finer sediments than reference sites and lack of seabed disturbance due to shipping at Berth 2 compare with Berth 1, The presence of large, long-dead shell (relict mud oyster) and scattered coble sized rock also affected grab return efficiency between sites. Annexure D demonstrates that, while the seabed of North Arm is predominantly unconsolidated sediments as previously described, there is considerable variation in nature of the seabed between locations in the deeper channels, banks and shoals. These variations

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 30 of 38 Expert Witness Statement Scott Chidgey Marine Biodiversity Impact Assessment will result in differences in the composition of the infauna and epibiota found at those locations. However, the natural dispersion of biota and propagules by the tidal currents in Western Port ensures that there is continuity of species in similar habitat. Overall, we consider that the mapped seabed habitat and associated distributions provide a wider and more accurate representation of seabed biota distributional pattern in Lower Arm Western Port than the infauna grabs collected around Crib Point Jetty. Video tows and diver observations (ghost shrimp surveys, jetty pile surveys) and bathymetry show that there are no other habitat features present in the basin. The water column is turbid due to high turbidity in northern Western Port. Light levels are low, and the seabed is considerably greater than the photic limits of seagrass or most algae. Red algae are sparse. For these reasons, very few fish have been observed or noted in the basin. This information may be considered when monitoring programs are determined as described in Section 9 of my Witness Statement.

8.3.7. Reassessment of the proposed monitoring proposal and much more detail required in monitoring plan to be presented and provided to stakeholders. See Section 6 of my Witness Statement.

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 31 of 38 Expert Witness Statement Scott Chidgey Marine Biodiversity Impact Assessment Submission 5. Port of Hastings The Port of Hastings submission provides a valuable overview of the Port of Hastings. I have referred to aspects of this submission in Section 8 of my Witness Statement and responses to previous agency submissions. I recommend PoHDA’s submission to all stakeholders interested in the Gas Import Jetty and Pipeline Project. Submission 7. Submission Bass Coast Shire Council The Bass Coast Shire Council expressed concern for the Western Port Ramsar and UNESCO Biosphere values. The submission is concerned that a holistic approach to managing the project is required. I consider that there is adequate information EES Technical Appendix A, and my previous responses to agency submissions to address Bass Coast Shire Council’s concerns regarding the Projects potential impacts on marine biodiversity in the context of Western Port as a whole. Submission 12. Sea Shepherd The Sea Shepherd submission concerns the effects of shipping on whales, particularly the southern Right Whale. Sea Shepherd provides comment on the effectiveness of proposed mitigation measures to avoid shipstrike. These comments are applicable to all areas of shipping and provide added context for my comments in Section 8.1.1 of my Witness Statement and my response to DAWE’s Submission 3.

Submission 15. Victorian National Parks Association The Victorian National Parks Association (VNPA) submission includes concern over various effects of the project on marine biodiversity. 1 Chlorine VNPA’s concerns with respect to chlorine are addressed as follows CSIRO has provided a 99% Guideline Value for chlorine in the marine environment The hydrodynamic model has shown contours of the extent of the 99% guideline value exceedance for various operational scenarios. The contours show that the effect of chlorine is localised to the area of the existing shipping basin and does not extend to environmentally sensitive areas. Chlorine toxicity and accumulation has been addressed in my response to EPA’s submission. 2 Marine pest invasion This issue is addressed in Section 5.11 and 7.11.2 of the EES Technical Appendix A 3, 4 Matters of National Environmental Significance and listed species MNES are described in Section 5.11 and relevant marine species (whales, turtles, Australian grayling) are addressed individually in EES Technical Appendix A. Ghost shrimps and other FFGA listed species are addressed in Sections 5.7.3, 5.11.4, 7.6.16, 7.7.11 . Annexure F provides description of the detailed assessment of threatened ghost shrimps 5 Species Movement The position of the FSRU and modelled extent of discharges within the existing port facilities and shipping basin will not affect species movement or connectivity. We have addressed effect of entrainment on a range of ecosystem components in Section 7.5.1 and 7.6. 8 Western Port Bay Ramsar Values Addressed in Section 8 of EES Technical Appendix A

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 32 of 38 Expert Witness Statement Scott Chidgey Marine Biodiversity Impact Assessment Response to Public Submissions Common concerns regarding specific project impact on the marine ecosystem together with my response are listed below.

Ramsar values Many submissions were concerned that the project would affect Ramsar wetland values, including a range of marine ecological components from mangroves to fish and plankton.

Ramsar values were a most important focus of the EES. In relation to the marine environmental effects, we identified and described marine ecosystem values from our previous experience in Western Port, special investigations and scientific literature including: • Saltmarsh and mangrove • Mangroves • Intertidal mudflats • Intertidal and seagrasses and macroalgae • Subtidal epifauna and infauna • Plankton • Fish and fishing • Protected species and • Introduced species These are described in detail in Section 5 of our report, as well as annexures with particular detail on the microscopic plants and invertebrates in the water column, the fish larvae and eggs, the distribution of and nature of the soft seabed habitat and seabed biota in North Arm.

Through integrated field studies and modeling described in Section 6 of our report, we identified • the natural losses of plankton due to natural flushing processes; • the additional losses of plankton mortality due to entrainment through the FSRU, and • the effect boundaries of the FSRU discharge of chlorine oxidants and seawater temperature variation; • the various habitats and marine ecosystem components these boundaries encompass.

In section 7, we provide a schematic diagram of the Western Port ecosystem to guide identification of 53 marine ecosystem risks from the project. Mitigation measures are identified and described (see Witness Statement Item 9 and Section 7 of Technical Appendix). Each risk was systematically described and assessed on environmental evidence (documented environmental information), documented model prediction of stressor contours for various operational and environmental conditions (likelihood) and exceedance of guideline protection value for that stressor (consequence).

In Section 8, the risks of the project are assessed according to the Commonwealth Critical Components, Processes and Services Limits of Acceptable Change for Western Port Ramsar Values.

Overall, therefore, the risks of the project to the marine ecosystem with respect to the Western Port Ramsar Values has been comprehensively documented and assessed as very low (Section 8.3).

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 33 of 38 Expert Witness Statement Scott Chidgey Marine Biodiversity Impact Assessment Chlorine There has been widespread concern over the discharge of chlorinated seawater for its immediate toxic effect on marine biota and its potential accumulation in the food chain. This issue is addressed in Section 6.5 of our report, CSIROs specialist technical annexure and further discussed in my Expert Witness response to EPA. It is worth understanding that, unlike the freshwater environment, the marine environment contains a high concentration (around 35 parts per thousand) of dissolved salts. More than half of these salts, by weight, is chloride. The marine ecosystem has evolved in the ubiquitous presence of chloride and its related halogen, bromide. Chloride can readily be converted to chlorine by passing a weak electric current through seawater. Chlorine is a strong oxidant, which oxidises by removing an electron from susceptible atoms. In oxidizing the other atom, it returns to chloride salt. Saltwater contains a range of other salts that are rare in freshwater. A key salt related to chlorine is bromide. Because of its chemical properties, bromide in is rapidly oxidised to bromine by any chlorine present in seawater. This reaction is so strongly linked that chlorine and chlorine by-products only persist for minutes in the marine environment. Unlike the freshwater environment persistent toxicants such as chloramines are not formed for two reasons (1) chlorine prefers to oxidise bromine over ammonia and (2) ammonia concentrations in the marine environment are too low for bromine to form bromamines. Bromine is therefore the key oxidant or toxicant that results from electrolysis of seawater. It is a weaker oxidant than chlorine, but is effective in controlling unwanted biological growth in pipes and swimming pools. In a well-mixed marine environment, around 5 percent of bromine may bind with carbon during the oxidation process and forming simple bromo- methyl molecules, mostly bromoform. Bromoform is weakly toxic and naturally degrades in well mixed marine environments, like Western Port. An external current through seawater is not the only source of chlorine and bromine in the marine environment. It will be a surprise for most people to find that the largest source of bromoform in the world is the marine environment. A great many marine organisms manufacture a huge range of brominated chemicals. “From fewer than 50 examples of halogenated natural products that were known in 1968, the number today is more than 5000 and steadily increasing. A majority of these compounds are found in marine organisms and several recent reviews are available of marine natural products in general, in algae, in sponges, in invertebrates, in gorgonians, in bryophytes, in fungi, in cyanobacteria, in marine bacteria, and those cyano-containing marine triterpenoids” Gribble 2015. All halogenated by-products resulting from electrolysis of seawater are also produced by natural processes.

Marine life has evolved in a soup of chloride and bromide and the products. They naturally manufacture, regulate and metabolise all the chemicals produced by electrolysis of seawater as antibacterial, antiparasitic, antiviral, antitumor, anti-inflammatory, and antioxidant agents (Gribble). It is to be expected that these compounds do not biomagnify, or they would be present in toxic levels in natural marine ecosystems. As stated previously, CSIRO has recognized these processes resulting in chlorine produced contaminants are “non-persistent due to dispersion, volatilisation or degradation”. I accept CSIRO’s 99% marine ecosystem protection Guideline Value for chlorine concentration as appropriate to informing the assessment of risks of chlorine to the marine ecosystem of Western Port.

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 34 of 38 Expert Witness Statement Scott Chidgey Marine Biodiversity Impact Assessment Risk assessment As stated in my Witness Statement, CEE’s aim throughout the EES process was to provide clear, accessible, high quality, impartial and relevant environmental information collected from Western Port, known processes and process-based models so that the public and all other involved were equally informed of the environmental characteristics and processes that formed the basis of our assessment.

We also aimed to provide our risk and impact assessment reasoning as a clear and transparent process in public meetings and in our final document. This informed readers of the evidence and processes used by us to assess risks as experienced environmental scientists and engineers, and also to allow others to form their own conclusions based the same or additional information.

In assessing risk, I have considered the proposal in the context of the past, present and regulated future operations of the Port of Hastings as a shipping and related activities environment. The end-result of this was demonstrated in section 7, where we identified 53 marine ecosystem risks from the project. Mitigation measures were identified and described. Each risk was systematically described and assessed on environmental evidence (documented environmental information), documented model prediction of stressor contours for various operational and environmental conditions (likelihood) and exceedance of guideline protection value for that stressor (consequence).

I considered likelihoods and consequences of the integrated effects of these risks on ecosystem values and assigned risk ratings using five defined categories of very low to very high. I consider this fulfilled my aim for clarity and transparency in assessing the risk outcomes.

Many public stakeholders have taken a different approach to assessing the project based on a principle of no-risk.

My understanding is that our assessment of risks is part of the greater risk assessment elicitation process that is more generally known in Victoria as the EES process. That process includes consideration of submissions from public stakeholders and agencies; the Hearing before the IAC; the IAC’s assessment and their recommendation to the Ministers; the assessment of the relevant regulators and their recommendation to the Ministers, and, finally, the assessment and Decision by the Ministers. Each of these layers of assessment may use their own basis of risk.

Other common concerns Other common concerns in the public stakeholder submissions included: mangroves, Seagrasses, Fish, recreational fishing, rare species, ghost shrimp, whale strike and lighting. I consider that these have been adequately addressed in EES Technical Appendix A Marine Biodiversity Impact Assessment and its annexures and in my Witness Statement and earlier responses.

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 35 of 38 Expert Witness Statement Scott Chidgey Marine Biodiversity Impact Assessment Declaration I have made all the inquiries that I believe are desirable and appropriate and that no matters of significance which I regard as relevant have to my knowledge been withheld from the Panel.

Dated 24 September 2020

Scott S Chidgey

Scott Selwyn Chidgey

Gas Import Jetty and Pipeline Project Environmental Effects Statement Page 36 of 38

Scott Chidgey CV

CEE Pty Ltd

Environmental scientists and engineers

Unit 5 150 Chesterville Road Cheltenham VIC 3193 TEL 03 95534787 [email protected] SCOTT S. CHIDGEY B.Sc. (Marine zoology) University of Melbourne M.Sc. (Marine botany) University of Melbourne Commonwealth of Australia Commercial Air Diver and Supervisor (I and II) Coxswain (Unlimited)

Summary of Professional Experience 1977 Environmental scientist, Pancontinental Mining 1978 – 1983 Marine biological scientist, Caldwell Connell Engineers 1984 – 1990 Principal marine scientist, Consulting Environmental Engineers 1990 – present Director, CEE Consultants

Professional Experience Scott is a marine scientist with more than 35 years of consulting experience managing and conducting multidisciplinary environmental investigations for marine wastewater discharge projects around Australia and the South Pacific. In addition to his expertise in assessing marine environmental risks, determining impacts and developing mitigation measures, he is an experienced scientific diver (more than 30 years), taxonomist, ecologist, underwater videographer, mariner and open sea logistician. Scott has worked on marine environmental projects in all states of Australia as well as the South Pacific and Timor Sea, where his main professional activities include: ⚫ Assessment of discharge conditions against relevant environmental regulations, including the recently gazetted Victorian State Environment Protection Policy Waters 2018; ⚫ Marine ecological documentation, marine environmental issues identification, environment impact, values and risk assessments (state and commonwealth levels); ⚫ Development and assessment of integrated marine impact mitigation strategies; ⚫ Integration of marine science, environmental, engineering and planning processes; ⚫ A wide range of marine environmental licence compliance monitoring and environmental values assessment programs; ⚫ Marine environmental scientist representative at community consultation workshops.

Scott’s areas of technical expertise include a wide range skills including insitu measurement of intertidal and subtidal epifauna and flora, installation and monitoring artificial substrata, infaunal sampling around wastewater outfalls, sampling and assessment of contaminant levels, nutrient, light attenuation, stratification and colour, plankton monitoring, habitat mapping of benthic macrophytes using aerial scanning, towed video and acoustic methods (seagrasses and macroalgae). Scott has worked and continues to work on a wide range of marine impact and risk assessments. He maintains technical skills through this variety of project tasks as well as contact and liaison with a range of stakeholders, authorities, regulators, researchers and practitioners in other consultancies.

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Expert Witness Statement Scott Chidgey Marine Biodiversity Impact Assessment Scott has played a key role in environmental investigations, monitoring and licensing of all wastewater discharges to the marine environment for Barwon Water, Wannon Water, Melbourne Water, City West Water, Esso LIP, Western Port Water, South Gippsland Water and Victorian Desalination Project. Scott Chidgey recent relevant experience Review of SEPP ‘Waters’ 2018, Water Plan 4 and Ecological Risk Assessment in relation to South East Outfall Impacts and monitoring requirements Report and presentation to South East Water 2018/19 Review of SEPP ‘Waters’ 2018, Water Plan 4 and Ecological Risk Assessment for Warrnambool Ocean Outfall including ongoing monitoring program Report and presentation to Wannon Water. 2018/19 Marine environmental monitoring and Ecological Risk Assessment of Baxter’s Beach effluent discharge including ongoing monitoring program Report to South Gippsland Water 2018/2019 Marine environmental monitoring and Ecological Risk Assessment of Geelong’s Black Rock effluent discharge including ongoing monitoring program Report to Barwon Water 2019 Review of SEPP ‘Waters’ 2018, Water Plan 4 and Ecological Risk Assessment for Warrnambool, Lorne and Apollo Bay Ocean Outfalls 2018/19 Presentation to Barwon Water 2018/2019 Marine ecological monitoring program gradient design, implementation and reporting for Darwin’s East Point Outfall Reports to Power and Water Corporation, NT. 2017 to 2019 Marine ecosystem monitoring and mapping Boags Rocks outfall for Melbourne Water Reports to Melbourne Water. 2000 to present Calculation of ecosystem protection guideline values for discharge of toxicants from PNGLNG plant Report to Exxon Mobil, Presentation to PNG EPA 2016 Direct toxicity assessment of effluents at 10 Victorian wastewater outlets Reports to water agencies 2010 to present Marine environmental studies for Victorian Desalination Plant EIS 2008, Pilot plant (2009) Design (2011), Ongoing Monitoring 2016 to present

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AGL GAS IMPORT JETTY PROJECT MARINE SPECIES INTRODUCTION

Prepared for:

CEE Pty Ltd Melbourne

2019 Version 1.0

ES LINK SERVICES PTY LTD ABN 76 088 414 037

PO Box 10, Castlemaine VIC 3450

Linking sustainable economic returns with environmental and social outcomes

AGL Gas Import Jetty Project – Marine Species Introduction

AGL GAS IMPORT JETTY PROJECT MARINE SPECIES INTRODUCTION

Prepared for:

CEE Pty Ltd Melbourne

2019 Version 1.0

Prepared by:

John A Lewis Principal Marine Consultant ES Link Services Pty Ltd

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AGL Gas Import Jetty Project – Marine Species Introduction

Abbreviations

Abbreviation Description

BWTS Ballast Water Treatment System

CCIMPE [Australian Government] Consultative Committee on Introduced Marine Pest Emergencies

DAWR [Australian Government] Department of Agriculture and Water Resources

EPA Environment Protection Authority

FSRU Floating Storage Regasification Unit

IMO International Maritime Organization

IMS Invasive Marine Species

MEPC Marine Environment Protection Committee [of IMO]

NIMS Non-Indigenous Marine Species

NMS [Australian Government] National Monitoring System

RIS Regulation Impact Statement

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Table of Contents

Executive Summary ...... 3

1 Introduction ...... 5 1.1 The Project ...... 5 1.2 Invasive Marine Species ...... 5 1.3 Terminology ...... 5 1.4 Australia’s Marine Pest Lists ...... 6

2 IMS in Western Port ...... 7 2.1 Present State of Knowledge ...... 7 2.2 Vectors & Origins ...... 8

3 IMS Regulations ...... 8 3.1 Ballast Water ...... 8 3.1.1 International ...... 8 3.1.2 Australia ...... 9 3.2 Biofouling ...... 10 3.2.1 International ...... 10 3.2.2 Australia ...... 10

4 Project Risk ...... 11 4.1 Scenario ...... 11 4.2 Colonisation ...... 12 4.3 Translocation ...... 13 4.4 Transfer ...... 13 4.5 Colonisation ...... 13 4.6 Establishment ...... 13

5 Conclusions ...... 14

6 Recommendations ...... 14 6.1 FSRU ...... 14 6.2 Delivery Vessels...... 14 6.2.1 Ballast Water Management...... 14 6.2.2 Biofouling Management ...... 15 6.3 Marine Pest Monitoring ...... 15

7 References ...... 16

Appendix 1 - ...... 19 Australian Target Species Lists ...... 19

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EXECUTIVE SUMMARY

AGL Wholesale Gas Limited (AGL) is proposing to develop a Liquefied Natural Gas (LNG) import facility, utilising a Floating Storage and Regasification Unit (FSRU) to be located at Crib Point on Victoria’s Mornington Peninsula. AGL selected Crib Point Jetty in Western Port as the preferred location for the Project as it is an established, operating port.

The project, known as the “AGL Gas Import Jetty Project” (the Project), comprises: • The continuous mooring of the FSRU at the existing Crib Point Jetty, which will receive LNG carriers of approximately 300m in length; • The construction of ancillary topside jetty infrastructure (Jetty Infrastructure), including high pressure gas unloading arms and a high-pressure gas flowline mounted to the jetty • and connecting to a flange on the landside component to allow connection to the Crib Point Pakenham Pipeline Project.

The FSRU will be continuously moored to receive LNG cargos from visiting LNG carriers, store the LNG and re-gasify it as required to meet demand for high pressure pipeline gas. The frequency of visitation by LNG tankers has not been defined but is somewhere between weekly and monthly. Regasification involves the heating of LNG using the ambient heat of seawater in Western Port. A daily volume up to 450,000 kL (450 ML/day) of seawater from Western Port will be pumped at a rate of 5.2 m3/s through heat exchangers in the FSRU.

The introduction of non-indigenous species has been commonly quoted as one of the greatest environmental and economic threats and, along with habitat destruction, the leading cause of extinctions and resultant biodiversity decreases worldwide. Similarly, alien marine species have claimed to be one of the top five threats to marine ecosystem function and biodiversity, and of increasing threat to maritime industries.

This report assesses the risk of introduction of invasive marine species to Western Port by vessels arriving at the Crib Point facility and measures to minimise any risk.

Nineteen non-indigenous marine species (NIMS) have been reported from Western Port and these represent a subset of the NIMS found elsewhere in Victoria and, in particular, in Port Phillip Bay. The highest risk of introduction of NIMS and IMS to Western Port is considered to be by domestic movements of vessels and aquaculture equipment, with Port Phillip Bay the most likely source. Evidence from past introduction of IMS to Australia on vessels from overseas suggest this to be a rare event but, once a species is established, spread within Australia is likely and difficult to manage.

Although the risk of IMS introduction on vessels arriving from overseas is deemed to be low, measures can be taken to further minimise this risk. Management of ballast water and biofouling in accord with IMO regulations and guidelines can achieve this, as will attention to the preparation and selection of vessels arriving in Western Port and limitations on the time delivery vessels spend in both export ports and when discharging cargo.

The risk of species arriving in ballast water is considered low because delivery vessels are required to comply with Australian and international ballast management requirements. These require either the deep-sea exchange of ballast water taken up in foreign ports or operation of a ballast water treatment system to render all entrained organisms non- viable. This is irrespective of the delivery vessels being more likely to need to take up, rather than discharge, ballast water in Western Port to compensate for cargo discharge.

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Although to be confirmed for this project, LNG carriers generally utilise good biofouling management practices as they are high activity vessels that operate on-line trades which require high ship efficiency to meet sailing schedules.

Recommendations are:

• For the FSRU, as a long-stay vessel, that it should be dry-docked, cleaned of marine growth, antifouling systems renewed or restored, and inspected by a qualified Australian biofouling/IMS inspector before departure from the last port of call before arrival in Australia. The antifouling coating system applied should be suited to long periods of inactivity in inshore waters. The vessel should also depart for Australia as soon as possible after hull maintenance is completed, preferably within 7 days of refloating and/or inspection.

• Delivery vessels must manage ballast water in accord with Australian and international ballast water management requirements by either deep sea exchange or, preferably, operation of an approved BWTS to treat any ballast water to be discharged in Australian waters.

• Biofouling on delivery vessels should be managed in accord with the IMO biofouling management guidelines, including each vessel having a ship-specific biofouling management plan and biofouling record book that are followed, maintained and regularly updated. Port stays in both the export and import ports should be minimised, and arrival-on-time logistics practised to avoid queuing prior to loading or unloading.

• Delivery vessels should not have been laid-up or idle for extended periods in overseas locations prior to entering this trade. Should this occur, the tankers should be dry-docked for cleaning and maintenance or, at the least, inspected for freedom from potential IMS prior to sailing for Australia.

• Given the low risk of IMS introduction by project vessels, particularly if the above management measures are adopted, and the high risk of introduction of NIMS and IMS by domestic vessels, aquaculture and fishing activities, a project-specific marine pest monitoring program in Western Port is not considered to be warranted nor justifiable.

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1 INTRODUCTION

1.1 The Project

AGL Wholesale Gas Limited (AGL) is proposing to develop a Liquefied Natural Gas (LNG) import facility, utilising a Floating Storage and Regasification Unit (FSRU) to be located at Crib Point on Victoria’s Mornington Peninsula. AGL selected Crib Point Jetty in Western Port as the preferred location for the Project as it is an established, operating port.

The project, known as the “AGL Gas Import Jetty Project” (the Project), comprises: • The continuous mooring of the FSRU at the existing Crib Point Jetty, which will receive LNG carriers of approximately 300m in length; • The construction of ancillary topside jetty infrastructure (Jetty Infrastructure), including high pressure gas unloading arms and a high-pressure gas flowline mounted to the jetty • and connecting to a flange on the landside component to allow connection to the Crib Point Pakenham Pipeline Project.

The FSRU will be continuously moored to receive LNG cargos from visiting LNG carriers, store the LNG and re-gasify it as required to meet demand for high pressure pipeline gas. The frequency of visitation by LNG tankers has not been defined but is somewhere between weekly and monthly. Regasification involves the heating of LNG using the ambient heat of seawater in Western Port. A daily volume up to 450,000 kL (450 ML/day) of seawater from Western Port will be pumped at a rate of 5.2 m3/s through heat exchangers in the FSRU.

1.2 Invasive Marine Species

The introduction of non-indigenous species has been commonly quoted as one of the greatest environmental and economic threats and, along with habitat destruction, the leading cause of extinctions and resultant biodiversity decreases worldwide. Similarly, alien marine species have claimed to be one of the top five threats to marine ecosystem function and biodiversity, and of increasing threat to maritime industries.

1.3 Terminology

An array of terms has been used to categorise species introduced beyond their range of native occurrence. To differentiate between species that do or do not cause harm in the new environment, an invasive marine species (IMS) is a non-indigenous marine species (NIMS) whose introduction does, or is likely to cause, economic or environmental harm, or harm to human health. IMS are therefore a subset of NIMS that cause harmful impacts. A NIMS is more broadly a species introduced by humans, either intentionally or accidentally, outside of its natural past or present distribution.

The Australian Government Marine Pests website1 states that “marine pests are plants and animals that are not native to a particular region”, that “can be introduced by human activity”, and “once here, they can harm our resources, marine industries, and the natural environment”. In this sense, “marine pests” are equated to IMS.

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1.4 Australia’s Marine Pest Lists

Lists of marine species considered to pose an invasive risk have been assembled to assist in the prevention, control and management of invasive marine species in Australia. The first of these, the CCIMPE1 Trigger List (Appendix 1, Table 1), was developed as a list of species agreed to warranting concerted management action should they be detected in Australia for the first time, or beyond their known range for species established in Australia but not widespread. The currency of this list expired and will be replaced by the Australian Priority Marine Pest List that has been recently endorsed by the National Biosecurity Committee or the purposes of planning preparedness, surveillance and response.

The list includes three established (introduced species that have established sustaining populations in Australia) and six exotic species (those not known to be present in Australia). a. The established marine pests of national significance on the list are: • Asterias amurensis (northern Pacific seastar) • Carcinus maenas (European shore crab) • Undaria pinnatifida (Japanese kelp). b. The exotic marine pests of national significance on the list are: • Eriocheir sinensis (Chinese mitten crab) • Mytilopsis sallei (black-striped false mussel) • Perna canaliculus (New Zealand green mussel) • Perna perna (brown mussel) • Perna viridis (Asian green mussel) • Rhithropanopeus harrisii (Harris mud crab).

In 2010 a species targeted, ongoing National Monitoring Strategy for marine pests was agreed by Australian governments. The list of target species agreed for monitoring was an augmented CCIMPE List (Appendix 1, Table 2).

The State of Victoria has declared 20 marine species considered priority marine pests as noxious, which means people must not bring these species into the state, or take, hatch, keep, possess, sell, transport, put into any container or release them into any protected waters (unless otherwise authorised by permit)2. The Fisheries Act requires people to report the possession, existence and location of any noxious aquatic species and provides powers to allow authorised officers to seize, remove and prevent the spread of noxious aquatic species. The species listed are: American slipper limpet (Crepidula fornicata) Aquarium Caulerpa (Caulerpa taxifolia) * Asian bag mussel (Arcuatula senhousia) ** Asian basket clam (Corbula amurensis) Asian green mussel (Perna viridis) Asian paddle crab (Charybdis japonica) * Asian shore crab (Hemigrapsus sanguineus) Black striped false mussel (Mytilopsis sallei) Brown mussel (Perna perna) Chinese mitten crab (Eriocheir sinensis) European fan worm (Sabella spallanzanii) ** European green shore crab (Carcinus maenas) **

1 Australian Government Consultative Committee on Introduced Marine Pest Emergencies 2 http://agriculture.vic.gov.au/agriculture/pests-diseases-and-weeds/marine-pests/a-z-marine-pests

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European or basket clam (Corbula gibba) ** Harris’ mud crab (Rhithropanopeus harrisii) Japanese seaweed (Undaria pinnatifida) ** Japanese softshell clam (Mya arenaria) New Zealand green mussel (Perna canaliculus) New Zealand screwshell (Maoricolpus roseus) ** Northern Pacific seastar (Asterias amurensis) ** Rapa or veined whelk (Rapana venosa)

* known from Australia ** known from Victoria

2 IMS IN WESTERN PORT

2.1 Present State of Knowledge

The Australian Government Marine Pests website3 lists four known pests from Melbourne: Asian date or bag mussel, European fan worm, European green crab, Japanese seaweed, and the Northern Pacific seastar. The only other Victorian port with marine pests listed is Portland, where Asian date mussel and Mediterranean fan worm are also known. The port of Western Port is not included on this marine pest map.

In 1997, as part of a program to survey for exotic marine pests in Australian ports, a survey was undertaken in the Port of Hastings (Currie & Crooks 1997). 355 species were collected, of which seven were confirmed as introduced: European green crab, European clam, Asian date mussel, Asian semele (Theora lubrica), and the bryozoans Bugula dentata, B. neritina and Watersipora subtorquata. Broccoli weed (Codium fragile ssp. fragile) was subsequently found at Newhaven on Phillip Island in March 1998 (Campbell 1999). Bay-wide surveys, but with a focus on minor wharves, marinas and aquaculture sites, were subsequently undertaken in late 1998 and 1999 (Cohen et al. 2000) reported an additional four NIMS in the bay: the solitary ascidians Ascidiella aspersa, Ciona intestinalis and Styela plicata, and sea lettuce Ulva lactuca. European fan worms and the solitary ascidian Styela clava¸ were also found, but only on mussel ropes transferred into Western Port from Port Phillip Bay. Presence of the previously observed Pacific oyster (Magellana gigas) on Phillip Island was also confirmed. Three toxic microalgal species, the dinoflagellates Alexandrium tamarense, A. minutum and A. catenella, are known and were considered likely to have self-sustaining populations in Western Port (Parry & Cohen 2001). A small aggregation of Japanese kelp was found growing on discarded abalone shells at Flinders in 2000/2001 (Parry & Cohen 2001). These were removed and there have been no reports of this seaweed in the Bay since.

In 2008, a project was undertaken to determine if Pacific oysters (Magellana gigas) were present or absent from Westernport Bay around Phillip Island (Dugdale et al., 2008). Four sites were surveyed, Rhyll Inlet, Rhyll foreshore, McFees Road and Newhaven, and M. gigas was found at all four sites. Specimens collected represented a range of size classes, suggesting a range of different ages and therefore recruitment events. A live M. gigas was photographed at Crawfish Rock in March 2009, and the species has been observed to be common on wharf piles in Hastings in recent years (J. Watson, pers. comm.).

3 https://www.marinepests.gov.au/pests/map

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2.2 Vectors & Origins

The movement of marine species across natural biogeographic boundaries has been facilitated by human activity through the opening of canals, introductions for aquaculture, inadvertent transfer with aquaculture stock, release from aquaria, and shipping both in ballast and as attached biofouling. In many ports, harbours and embayments, the introduction of the majority of NIMS can be attributed to biofouling. However, for IMS, the strength of biofouling as a vector is far less. Species imported for aquaculture (e.g. Pacific oyster), associated with aquaculture imports (e.g. broccoli weed), in ballast water (North Pacific sea star, toxic dinoflagellates), and releases from aquaria (Caulerpa taxifolia) have been more invasive with greater impacts than the majority of biofouling species, most of which are opportunistic colonisers of disturbed and artificial habitats.

In southern Australia, the origins of most IMS is in the warm temperate latitudes of the northern hemisphere, mostly Europe and the north-west Pacific, with tropical and sub-tropical waters providing the historical barrier to natural dispersion. IMS originating in Europe include the European green crab (pre-1900, dry ballast), Mediterranean fan worm (1965, biofouling) and European clam (1987, ballast water), and, from Asia ,Pacific oysters (1947, aquaculture), the North Pacific sea star (early 1980s, ballast water), Asian date mussel (early 1980s, ballast water/biofouling), broccoli weed (1985, aquaculture) and Japanese kelp (1988, ballast water/biofouling). Dates of first detection of these IMS indicate, not only the long history of invasions, but also the rarity of the events. One notable feature is the apparent increase in events in the 1980s, and the probable role of ballast water as the vector for introduction. Increasing trade with countries in the north-west Pacific also appear significant.

Once established in the new hemisphere, climatic barriers to latitudinal spread are less extreme, and arrivals to Australia of both Japanese kelp and broccoli weed may have been via New Zealand, where these species were first detected in 1987 and 1973 respectively. Once in a new location, this can provide a node for regional spread via natural dispersal, small vessel movements, or fishing and aquaculture activities.

For Western Port, high risk sources of NIMS are where these species are already established to the east and west of the Bay. The high numbers of NIMS in Port Phillip Bay make this a high-risk source, but movements of the non-indigenous algae Codium fragile ssp. fragile and Grateloupia turuturu into Victorian locations to the east of Western Port indicate translocation across Bass Strait.

None of the IMS currently reported from Western Port are likely to represent new introduction to Victoria, let alone Australia, with introductions via coastal trading ships, small boats, or aquaculture transfers.

3 IMS REGULATIONS

3.1 Ballast Water

3.1.1 International

As a result of concerns raised by Australia and Canada in the late 1980s, in 1991 the International Maritime Organization (IMO) Marine Environment Protection Committee (MEPC) adopted the non-mandatory International Guidelines for preventing the introduction of unwanted aquatic organism and pathogens from ships’ ballast water and sediment

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discharges. This led to, in 2004, adoption of the legally binding International Convention for the Control and Management of Ships’ Ballast Water and Sediments (“the BWM Convention”) on 13 February 2004 (IMO, 2009).

The BWM Convention included a two-stage introduction of management measures; ships were first required to meet a ballast water exchange standard (Regulation D-1) then, after this, to meet a ballast water performance standard (Regulation D-2). Regulation D-1 required ships on international voyages to exchange ballast water taken up in ports with open ocean water with an efficiency of at least 95 per cent volumetric exchange. Regulation D-2 requires ships to have a ballast water treatment system (BWTS) installed that will ensure that ballast water discharged contains: • Less than 10 viable organisms per cubic metre greater than or equal to 50 microns in minimum dimension; • Less than 10 viable organisms per millilitre less than or equal to 10 micrometres in minimum dimension; and • Indicator microbes concentrations as a human health standard of: o Toxicogenic Vibrio cholera less than 1 colony-forming unit (cfu) per 100 millilitres; o Escherichia coli less than 250 cfu per 100 millilitres; and o Intestinal Enterococci less than 100 cfu per 100 millilitres.

The BWM Convention entered in to force in September 2017. Entry-into-force requires ships not already fitted with a ballast water treatment system to do so by 2021.

3.1.2 Australia

Australia, in 2001, introduced mandatory ballast water management requirements for all international shipping which required that vessels do not discharge high risk ballast water in Australian ports or waters (AFFA, 2001). The requirements were enforced under the Quarantine Act 1908 and administered by the then Australian Quarantine Inspection Service (AQIS). Options for the treatment of high-risk ballast water were: • No discharge of ballast water to occur in Australian ports or water, • Tank to tank transfer to prevent the discharge of high-risk ballast water in Australian waters, or • Undertake a full ballast water exchange at sea prior to arrival in Australian waters using either or a combination of, the sequential, flow-through, or dilution method. The method was required to achieve at least 95% volumetric exchange.

The Biosecurity Act 2015 (Australian Government 2015), which superseded the Quarantine Act 1908 in 2016, included ballast water provision that implemented and aligned with the BWM Convention. Under the new Act, vessels had the option of managing their ballast water by either ballast water exchange or by use of a Type Approved ballast water system. However, in line with the implementation schedule of the BWS Convention, ballast water exchange would be phased out in favour of a method compliant with the D-2 discharge standard (DAWR 2017). The new Act extended ballast water management requirements to vessels sailing between Australian ports as well as international vessels arriving in Australian seas.

Within Australia, the State of Victoria enacted the Waste Management Policy (Ships’ Ballast Water) in 2006 “to minimise the introduction of marine pests into Victorian State waters from high-risk domestic ballast water discharge” (EPA Victoria 2008). Ships’ masters were required to assess the risk status of any domestic ballast water through use of an on-line risk assessment tool. The risk assessment tool performed a biological risk assessment to predict if harmful aquatic organisms and pathogens could be in the ballast water in each tank. Management options for high risk ballast water were retention onboard/tank to tank transfer, ballast water exchange outside of Victorian waters (at least 12 nm off the Australian coast), or treatment by an approved method.

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3.2 Biofouling

3.2.1 International

Guidelines for the control and management of ships’ biofouling to minimize the transfer of invasive aquatic species were adopted by the MEPC in 2011 (IMO, 2012a). These guidelines were developed to address concerns that biofouling was a significant vector for the transfer of invasive aquatic species, and that “ships entering the waters of States may result in the establishment of invasive aquatic species that may pose threats to human, animal and plant life, economic and cultural activities and the aquatic environment”.

The objectives of the Guidelines were to provide practical guidance on measures to minimise the risk of translocating invasive aquatic species in biofouling through the implementation of biofouling management practices, including the use of antifouling systems, to keep the ship’s submerged surfaces and internal seawater cooling systems as free of biofouling as possible. They were intended to provide a globally consistent approach to the management of biofouling. The Guidelines propose that every ship should have a Biofouling Management Plan and a Biofouling Record Book. The plan would detail procedures for effective biofouling management and consider measures including the selection and application of suitable antifouling systems, identification of hull locations susceptible to biofouling, schedules of planned inspections, repairs, maintenance and renewal of antifouling systems. The Biofouling Record Book would contain details of the biofouling management measures and systems undertaken, including details of the antifouling systems, dates and locations of dry-dockings or slippings, in-water inspections and inspections and maintenance of internal seawater systems, and the work completed.

Sections of the Guidelines provide guidance on antifouling installation and maintenance, choosing the antifouling system, installing, re-installing, or repairing the antifouling system, in-water inspection, in-water cleaning and maintenance, and design and construction (IMO, 2012b).

The Guidelines are just that, guidelines, and their uptake on international shipping is encouraged, but not mandatory. There are also no current proposals for the IMO to develop a convention, or other mechanism, to mandate biofouling management measures, although governments in New Zealand and California have done so.

In addition to the Guidelines, the IMO Marine Environment Protection Committee also circulated guidance for minimizing the transfer of invasive aquatic species as biofouling for recreational craft (IMO, 2012b). This provides guidance on the selection of antifouling coating systems, minimisation of biofouling in niche areas, and in and out of water cleaning.

3.2.2 Australia

The Australian Government is proposing to introduce requirements for the management of biofouling on international ships entering Australian waters, but the form of these has yet to be finalised. A Consultation Regulation Impact Statement (RIS) is currently out for public comment4. The RIS outlines three policy options: the status quo, a species- based approach, and requirement for effective management practices (DAWR 2019).

The preferred DAWR option is a requirement for effective management practices. This option would require vessels to implement effective and vessel-specific biofouling management practices consistent with the direction set by the IMO.

4 https://haveyoursay.agriculture.gov.au/biofouling-mgt-requirements

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To obtain a low-intervention status, arriving vessels would be required to have a Biofouling Management Plan and a Biofouling Record Book to demonstrate effective biofouling management practices. These would need to be: • Consistent with the IMO Biofouling Guidelines; • Vessel specific and effective (suited to the operational profile of the vessel, its maintenance schedule, and the vessel’s voyage within Australian territory; and • Regularly maintained and updated to represent best practice.

National Biofouling Management Guidelines, which predated the IMO Guidelines, were earlier developed for different maritime sectors, including commercial vessels, non-trading vessels, and petroleum production and exploration vessels (Australian Government 2009a, 2009b, 2009c).

The State of Western Australia (WA) imposed Ministerial Conditions on oil and gas development projects within the state that required vessels arriving from overseas or other Australian states to be free of marine pests. In part this required vessels to be inspected by a WA approved biofouling inspector in the last overseas port of call before mobilising to WA to ensure freedom from marine pests. A list of more than 70 alien species considered of concern, and that could be spread by biofouling or ballast water, underpinned this requirement (Appendix 1, Table 3).

Within the states of Australia, environmental management plans are commonly developed and adopted for inshore projects, such as port dredging and construction, that include invasive marine species management requirements. These commonly require a biofouling/invasive marine species risk assessment of all vessels mobilising to the project, from outside or within Australia, that demonstrate measures to minimise the risk of marine pest introduction.

4 PROJECT RISK

4.1 Scenario

The gas import jetty scenario is for the FSRU to be continuously moored at Crib Point to receive LNG cargos from visiting LNG carriers. Vessel arrivals will therefore include initial arrival of the FSRU, then LNG delivery tankers with a frequency of somewhere between weekly and monthly.

The risk of any vessel translocating and introducing a NIMS is determined by the risk of each of the following events occurring:

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4.2 Colonisation

Factors influencing the colonisation of a vessel by a potential IMS are the presence of the species in the port or ports of origin, propagule presence in the environment, and the availability of suitable substrates on the vessel or processes for entrainment.

The presence of potential IMS of risk to Western Port in a port is a function of the geographic distribution of that species, and the environmental and seasonal conditions conducive to organism reproduction. Species that pose a risk would be from ports in cool to warm temperate waters in both hemispheres and within and outside of Australia. Risk would be highest in ports or locations where IMS are known to be established, either in the environment or on other nearby vessels.

Colonisation of the vessel is regulated by the measures in place for ballast and biofouling management. Operational ballast water management treatment systems (BWTS) prevent the survival of marine organisms in water taken up, and effective biofouling management measures limit the availability of surfaces suitable for settlement. The risk of infection also increases with time spent alongside or moored within an inshore location, and the cumulative time since the last renewal and/or maintenance of the biofouling control systems. The IMO ballast water management requirements and biofouling guidelines address vessel infection, and adherence to these will proactively minimise vessel risk.

For this project, the residence time of vessels in potential donor ports would be likely highest for the FSRU, whether previously operating in another location or, for a new or modified vessel, the time alongside during fit-out. Operational LNG tankers are likely to have short stays of less than days in export ports, limited to the time taken for loading. Longer times are only likely if the vessel enters service after a period of lay-up or other inactivity.

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4.3 Translocation

Successful translocation of a potential IMS depends on environmental conditions through a voyage remaining tolerable to the species. Crossing through diverse physico-chemical environments, such as crossing through, or out of, tropical waters, would significantly reduce the possibility of survival of species, and voyage duration would be inversely related to survival.

Entrainment in ballast tanks can moderate external environmental variability and increase the likelihood of survival. For vessels not fitted with a BWTS, open ocean ballast water exchange will minimise this risk.

4.4 Transfer

Effective transfer of a species from a vessel into the recipient environment requires release of viable organisms or propagules which can be through reproductive maturation and sporulation or spawning, dislodgement of organisms, migration of mobile organisms off the vessel, or discharge of ballast water containing live organisms.

If living species are present on a vessel the risk of transfer increases with time, as time enables reproductive maturation of organisms and the likelihood of suitable environmental conditions for propagule release to occur. As for colonisation risk, should viable IMS populations be present, transfer risk would be higher for the FSRU than delivery tankers due to the long residence time. Residence time for the delivery tankers would be expected to be less than 2 days; the time taken for unloading. This can increase if the tankers need to queue to unload, which can be avoided by “arrival on time” logistics.

Untreated ballast water from high risk ports should not be discharged, to prevent the release of risk species.

4.5 Colonisation

Colonisation requires conditions that enable viable propagules to move from the vessel to suitable settlement sites. This includes hydrodynamic conditions that retain or return spores, larvae competent to settle, or mobile organisms to cross the water barrier between the ship and the settlement site, and colonisation space within the recipient community.

In the report on exotic species in the Port of Hastings (Currie & Crooks 1997) it was noted that authors considered that rapid tidal currents around the commercial shipping berths may prevent local settlement of larvae released in ballast water, instead transporting larvae to other areas. Tidal currents at Crib Point are likely to similarly reduce the likelihood of settlement. Healthy, stable ecosystems are also resilient to invasions with invasions often a secondary impact to environmental disturbance or modification. Any modifications or extensions to the Crib Point jetty would provide surfaces for opportunistic colonisation by NIMS, but such colonisers are most likely to be of species already established in Australia and spread by natural dispersal or small vessel movement.

4.6 Establishment

Establishment of a potential IMS is dependent on ongoing environmental conditions suitable for survival, growth, maturation, propagation and dispersal of the species. These conditions could be influenced by the FSRU operation, but not by vessel movements.

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5 CONCLUSIONS

The highest risk of introduction of NIMS and IMS to Western Port is considered to be by domestic movements of vessels and aquaculture equipment, with Port Phillip Bay the most likely source. Evidence from past introduction of IMS to Australia on vessels from overseas suggest this to be a rare event but, once a species is established, spread within Australia is likely and difficult to manage. The NIMS currently reported form Western Port are a subset of NIMS found elsewhere in Victoria, and particularly in Port Phillip Bay.

Although the risk of IMS introduction on vessels arriving from overseas is deemed to be low, measures can be taken to further minimise this risk. Management of ballast water and biofouling in accord with IMO regulations and guidelines can achieve this, as will attention to the preparation and selection of vessels arriving in Western Port and limitations on the time delivery vessels spend in both export ports and when discharging cargo.

The risk of species arriving in ballast water is considered low because delivery vessels are required to comply with Australian and international ballast management requirements. These require either the deep-sea exchange of ballast water taken up in foreign ports or operation of a ballast water treatment system to render all entrained organisms non- viable. This is irrespective of the delivery vessels being more likely to need to take up, rather than discharge, ballast water in Western Port to compensate for cargo discharge.

Although to be confirmed for this project, LNG carriers generally utilise good biofouling management practices as they are high activity vessels that operate on-line trades which require high ship efficiency to meet sailing schedules.

6 RECOMMENDATIONS

6.1 FSRU

As a long residence vessel, the FSRU should be dry-docked, cleaned of marine growth, antifouling systems renewed or restored, and inspected by a qualified Australian biofouling/IMS inspector before departure from the last port of call before arrival in Australia. The antifouling coating system applied should be suited to long periods of inactivity in inshore waters. The vessel should also depart for Australia as soon as possible after hull maintenance is completed, preferably within 7 days of refloating and/or inspection.

6.2 Delivery Vessels

6.2.1 Ballast Water Management

Delivery vessels must manage ballast water in accord with Australian and international ballast water management requirements by either deep sea exchange or, preferably, operation of an approved BWTS to treat any ballast water to be discharged in Australian waters.

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6.2.2 Biofouling Management

Biofouling should be managed in accord with the IMO biofouling management guidelines, including each vessel having a ship-specific biofouling management plan and biofouling record book that are followed, maintained and regularly updated.

Port stays in both the export and import ports should be minimised, and arrival-on-time logistics practised to avoid queuing prior to loading or unloading.

Delivery vessels should not have been laid-up or idle for extended periods in overseas locations prior to entering this trade. Should this occur, the tankers should be dry-docked for cleaning and maintenance or, at the least, inspected for freedom from potential IMS prior to sailing for Australia.

6.3 Marine Pest Monitoring

Given the low risk of IMS introduction by project vessels, and the high risk of introduction of NIMS and IMS by domestic vessels, aquaculture and fishing activities, a project-specific marine pest monitoring program in Western Port is not considered to be warranted nor justifiable.

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7 REFERENCES

Australian Government. 2015. Biosecurity Act 2015. No. 61, 2015. Authorised Version C2015A00061. Federal Register of Legislation (https://www.legislation.gov.au)

Australian Government. 2009a. National Biofouling Management Guidelines for Commercial Vessels. January 2009. Commonwealth of Australia, Canberra, ACT.

Australian Government. 2009b. National Biofouling Management Guidance for Non-Trading Vessels. April 2009. Commonwealth of Australia, Canberra, ACT.

Australian Government. 2009c. National Biofouling Management Guidance for the Petroleum Production and Exploration Industry. April 2009. Commonwealth of Australia, Canberra, ACT.

Campbell SJ. 1999. Occurrence of Codium fragile subsp. tomentosoides (Chlorophyta: Bryopsidales) in marine embayments of southeastern Australia. Journal of Phycology 35, 938-940.

Cohen BF, McArthur MA, Parry GD. 2000. Exotic marine pests in Westernport. Marine and Freshwater Resources Institute Report No. 22. Marine and Freshwater Resources Institute, Queenscliff, Vic.

Currie DR, Crookes, DP. 1997. Exotic marine pests in the Port of Hastings. Marine and Freshwater Resources Institute Report No. 4. Marine and Freshwater Resources Institute, Queenscliff, Vic.

DAWR. 2017. Australian Ballast Water Management Requirements. Version 7. Australian Government Department of Agriculture and Water Resources, Canberra, ACT.

DAWR. 2019. Australian biofouling management requirements for international vessel arrivals. Consultation Regulation Impact Statement. RIS ID: 12793. Biosecurity Animal Division, Australian Government Department of Agriculture and Water Resources, Canberra, ACT.

Department of Fisheries. 2014. Western Australian Prevention List for Introduced Marine Pests. June 2014. Government of Western Australia, Department of Fisheries, Perth, WA.

Dugdale T, Clements D, Sagliocco J-L. 2008. Pacific oyster (Crassostrea gigas) survey September 2008 – Phillip Island. Department of Primary Industries, Frankston, Vic.

EPA Victoria. 2008. Protocol for Environmental Management: Domestic Ballast Water Management in Victorian State Waters. EPA Victoria, Southbank, Vic.

IMO. 2009. Ballast Water Management Convention and the Guidelines for its Implementation. 2009 Edition. International Maritime Organization, London.

IMO. 2012a. Guidelines for the Control and Management of Ships’ Biofouling to Minimize the Transfer of Invasive Aquatic Species. 2012 Edition. International Maritime Organization, London.

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IMO 2012b. Guidance for minimizing the transfer of invasive aquatic species as biofouling (hull fouling) for recreational craft. MEPC.1/Circ. 792. 12 November 2012. International Maritime Organization, London UK.

Parry GD, Cohen BF. 2001. Exotic species established in Western Port, including an assessment of the status of the exotic species Corbula gibba, Alexandrium spp, Gymnodinium spp and Undaria pinnatifida. Marine and Freshwater Resources Institute Report No. 45. Marine and Freshwater Resources Institute, Queenscliff, Vic.

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Appendix 1 -

Australian Target Species Lists

Table 1. CCIMPE ‘Trigger List’

A. Non-Indigenous Species to Australia (Not Yet Know to Occur in Australian Waters)

No. Scientific name/s Common name/s 1 Eriocheir spp. Chinese Mitten Crab 2 Hemigrapsus sanguineus Japanese/Asian Shore Crab 3 Crepidula fornicata American Slipper Limpet 4 Mytilopsis sallei Black Striped Mussel 5 Perna viridis Asian Green Mussel 6 Perna perna Brown Mussel 7 Corbula (Potamocorbula) amurensis Asian Clam, Brackish-Water Corbula 8 Rapana venosa (syn Rapana thomasiana) Rapa Whelk 9 Mnemiopsis leidyi Comb Jelly 10 Caulerpa taxifolia (exotic strains only) Green Macroalga 11 Didemnum spp. (exotic invasive strains only) Colonial Sea Squirt [=D. vexillum] 12 Sargassum muticum Asian Seaweed 13 Neogobius melanostomus (marine/estuarine Round Goby incursions only) 14 Marenzelleria spp. (invasive species and Red Gilled Mudworm marine/estuarine incursions only) 15 Balanus improvisus Barnacle [= Amphibalanus improvisus] 16 Siganus rivulatus Marbled Spinefoot, Rabbit Fish 17 Mya arenaria Soft Shell Clam 18 Ensis directus Jack-Knife Clam 19 Hemigrapsus takanoi/penicillatus Pacific Crab 20 Charybdis japonica Lady Crab

B. Established Non-Indigenous Species in Australia (Known to occur in Australian waters, but not widespread)

No. Scientific name/s Common name/s 21 Asterias amurensis Northern Pacific Seastar 22 Carcinus maenas European Green Crab 23 Varicorbula gibba European Clam 24 Musculista senhousia Asian Bag or Date Mussel 25 Sabella spallanzanii European Fan Worm 26 Undaria pinnatifida Japanese Seaweed 27 Codium fragile spp. fragile Green Macroalga 28 Grateloupia turuturu Red Macroalga 29 Maoricolpus roseus New Zealand Screwshell

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C. Holoplankton Alert Species (For notification purposes, eradication response from CCIMPE is highly unlikely)

No. Scientific name/s Common name/s 30 Pfiesteria piscicida Toxic Dinoflagellate 31 Pseudo-nitzschia seriata Pennate Diatom 32 Dinophysis norvegica Toxic dinoflagellate 33 Alexandrium monilatum Toxic dinoflagellate 34 Chaetoceros concavicornis Centric diatom 35 Chaetoceros convolutus Centric diatom

Table 2 National Monitoring System Target Species List

A. Species additional to those on the CCIMPE Trigger List

No. Scientific name/s Common name/s 1 Acartia tonsa Calanoid copepod 2 Alexandrium catenella Toxic dinoflagellate 3 Alexandrium minutum Toxic dinoflagellate 4 Alexandrium tamarense Toxic dinoflagellate 5 Balanus eburneus Ivory barnacle [= Amphibalanus eburneus] 6 Beroe ovata Comb jelly 7 Blackfordia virginica Black Sea jelly 8 Bonnemaisonia hamifera Red macroalga 9 Callinectes sapidus Blue crab 10 Caulerpa racemosa [var. cylindracea ?] Green macroalga 11 Crassostrea gigas Pacific oyster 12 Gymnodonium catenatum Toxic dinoflagellate 13 Hydroides dianthus Tube worm 14 Limnoperna fortunei Golden mussel 15 Pseudodiaptomus marinus Asian copepod 16 Rhithropanopeus harrissii Harris mud crab 17 Siganus luridus Dusky spinefoot 18 Tortanus dextrilobatus Asian copepod 19 Tridentiger bifasciatus Shimofuri goby 20 Tridentiger barbatus Shokohazi goby 21 Womersleyella setacea Red seaweed

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Table 3. Government of Western Australia, Department of Fisheries Western Australian Prevention List for Introduced Marine Pests* (June 2014)

* Species on this list were declared as Noxious Fish under the Fish Resources Management Amendment Regulations (No. 6) 2014.

Biofouling species, and species that may be associated with biofouling.

Group Synonyms Common name Genus/Species Macroalgae Bonnemaisonia hamifera Bonnemaison’s hook weed; Pink cotton wool Caulerpa taxifolia Exotic strains only Aquarium weed; Feather alga; Killer alga Codium fragile fragile Codium fragile tomentosoides Dead man's fingers; Oyster thief; Broccoli weed Fucus evanescens Brown macroalga; Wrack Grateloupia turuturu Devil’s tongue weed; Asian red seaweed Sargassum muticum Japweed; Wireweed; Strangle weed Undaria pinnatifida Japanese kelp; Wakame Womersleyella setacea Polysiphonia setacea Red polysiphonous macroalga Sponges Gelliodes fibrosa Gray encrusting sponge Cliona thoosina Boring sponge; Sulfur sponge Gastropod Molluscs Crepidula fornicata Slipper limpet; Atlantic slipper snail Maoricolpus roseus New Zealand screwshell Rapana venosa Rapana thomasiana Asian rapa whelk; Veined rapa whelk Bivalve Molluscs Anadara transversa Anadara demiri Transverse arc clam Arcuatula senhousia Musculista senhousia Asian bag mussel; Asian date mussel Brachidontes pharaonis Variable mussel

Corbicula fluminea Asian clam; Asiatic clam Potamocorbula amurensis Corbula amurensis Asian clam; Amur River clam; Overbite clam; Brackish-water corbula Corbula gibba Varicorbula gibba Basket shell; European or basket shell clam Crassostrea ariakensis Suminoe oyster; Asian oyster

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Crassostrea virginica American oyster; Eastern oyster Crassostrea gigas Giant oyster; Pacific oyster; Japanese oyster; Miyagi oyster Dreissena bugensis Freshwater Quagga mussel Dreissena polymorpha Freshwater European zebra mussel; Wandering mussel Ensis directus Jack-knife clam Geukensia demissa Ribbed mussel Limnoperna fortunei Golden mussel Monia nobilis Anomia nobilis Jingle shell; Saddle oyster Mya arenaria Soft-shell clam; Long-neck clam; steamer Mytella charruana Charru mussel Mytilopsis leucophaeata Dark false mussel; Conrad's false mussel Mytilopsis sallei Black-striped mussel Perna canalicula Perna canaliculus New Zealand Mussel; New Zealand green-lipped mussel; greenshell mussel; kuku; kutai Perna perna Brown mussel Perna viridis Asian green mussel Potamocorbula amurensis Corbula amurensis Asian clam; Amur River clam; Overbite clam; Brackish-water corbula Polychaete Worms Hydroides dianthus Serpulid tube worm, limy tube worm Marenzelleria spp. Invasive species and marine / Red gilled mudworm estuarine incursions only Polydora nuchalis Spionid polychaete Sabella spallanzanii European fan worm Crustaceans - Barnacles Amphibalanus eburneus Balanus eburneus Ivory barnacle Amphibalanus improvisus Balanus improvisus Bay barnacle Balanus glandula Common acorn barnacle; White buckshot barnacle Chthamalus proteus Atlantic barnacle, Caribbean barnacle Solidobalanus fallax Warm-water barnacle Crustaceans - Shrimps, etc. Dikerogammarus villosus Killer shrimp Crustaceans - Crabs Callinectes sapidus Chesapeake blue crab; Atlantic blue crab; Blue crab

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Carcinoscorpius rotundicauda Mangrove horseshoe crab Carcinus maenas European green crab; European shore crab Charybdis japonica Lady crab; Asian paddle crab Eriocheir sinensis Chinese mitten crab Eriocheir spp. Mitten crabs Hemigrapsus penicillatus Grapsus (Eriocheir) penicillatus Hairy-clawed shore crab Hemigrapsus sanguineus Asian shore crab; Japanese shore crab Hemigrapsus takanoi Brush-clawed shore crab Pachygrapsus fakaravensis Polynesian grapsid crab Rhithropanopeus harrisi Harris mud crab; White-fingered mud crab; Zuiderzee crab Echinoderms – Sea Stars Asterias amurensis Northern Pacific seastar Ascidians – Sea squirts Didemnum perlucidum White sea squirt Didemnum spp. Exotic invasive species only. Colonial sea squirt; colonial ascidian Didemnum vexillum Colonial sea squirt Fishes Neogobius melanostomus Round goby Siganus luridus Dusky spinefoot Siganus rivulatus Marbled spinefoot; rabbit fish Tridentiger barbatus Shokihaze goby

Tridentiger bifasciatus Shimofuri goby

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