3 April 2017 Infrastructure Victoria Level 16, 530 Collins St Melbourne VIC 3000 Submitted via: yoursay.infrastructurevictoria.com.au/ports/submissions Re: Second Container Port Advice. BirdLife Australia is an independent science-based conservation organisation with more than 13,000 members and 100,000 supporters throughout Australia. We have an extensive ongoing program of bird conservation research and a range of citizen science projects that engage thousands of Australians. Our primary objective is to conserve and protect Australia's native birds and their habitat. We have an extensive ongoing program of bird conservation research, including our Shorebirds 2020 program, developed to address the ongoing decline of Australia’s resident and migratory shorebirds. Our Special Interest Group, the Australasian Wader Studies Group (AWSG) conducts and promotes shorebird research and conservation throughout Australasia. Through our Shorebirds 2020 program and the work of the AWSG, BirdLife Australia is recognised as a leading authority on the ecology and conservation of Australia’s shorebirds. BirdLife Australia has established a regular monitoring program for important shorebird sites throughout Australia including the Port Phillip Bay (Western Shoreline) and Bellarine Peninsula, and Western Port Ramsar sites. Both sites are recognised as providing internationally important habitat for waterbirds including a large number of migratory and threatened species listed under the Commonwealth Environment Protection & Biodiversity Conservation Act 1999 (EPBC Act). BirdLife Australia has a long history of involvement in recovery actions for the Critically Endangered Orange-bellied Parrot, including ongoing coordination of the mainland monitoring program for the species. As Australia’s leading bird conservation advocate, BirdLife Australia should be considered a key stakeholder in future planning for the location of Victoria’s second container port. Thank you for the opportunity to comment on the Second Container Port Evidence Base & Discussion Paper (the Study). Comments BirdLife strongly supports the strategy of maximising capacity at the Port of Melbourne prior to the construction of a second container port. BirdLife does not support the construction of the second container port in either Hastings or Bay West. These sites lie within sensitive, internationally important wetlands and the construction of a large scale port in either location presents an unacceptable risk to birdlife and other environmental values. We would strongly support studies of the feasibility of Geelong or Portland as alternative port sites. Port of Hastings expansion BirdLife Australia’s concerns about the proposed expansion of the Port of Hastings are well documented (see attached BirdLife report: Impact of proposed Port of Hastings expansion on the birdlife of Western Port). We find that the Study provides an accurate high level overview of the risks to birdlife from the construction and operation of a second container port at the Port of Hastings. In particular, we agree that such a proposal would present an unacceptably high risk to shorebirds and their habitat within Western Port. Future studies should further investigate risks to other waterbirds within Western Port, such as waterfowl, which have largely been overlooked in the Study. For example, this important group is absent from Table 1 of GHD’s ‘Second Container Port Advice Environment & Social Advice report. Bay West The Study provides a reasonably accurate high level overview of the risks to birdlife from the construction and operation of a second container port at Bay West, particularly with regard to potential risks to important bird habitat on the landward side of the Western Treatment Plant (WTP). However, we are concerned that the Study has not adequately considered the importance of Corio Bay as bird habitat beyond potential impacts on the intertidal zone. Corio Bay is known to provide internationally important habitat for the Critically Endangered Curlew Sandpiper and Sharp-tailed Sandpiper and Red-necked Stint. This gap must be addressed in future studies (see ‘Shorebirds’ below). As is the case for Western Port, future studies should further investigate risks to other waterbirds, such as waterfowl, associated with the Bay West proposal. These have largely been overlooked in the Study. For example, this important group is absent from Table 1 of GHD’s ‘Second Container Port Advice Environment & Social Advice’ report. Orange-bellied Parrot The Study correctly identifies that the WTP provides some of the last remaining mainland habitat for the Critically Endangered Orange-bellied Parrot. Future studies must examine the potential impact of the Bay West approval on foraging habitat within the WTP and movement corridors for the species, which may include areas directly affected by the construction of road, rail and administrative facilities. Shorebirds The Study highlights the importance of the Western Treatment Plant for migratory shorebirds and have identified noise and light pollution as potential risks. While the Study identified a number of key threatened species present at the WTP, we note several threatened species have been completely overlooked and the importance of the area for other migratory species has not been identified or is generally understated. Species listed under the EPBC Act which have been overlooked include; - Curlew Sandpiper, nationally listed as Critically Endangered. Curlew Sandpipers occur along this stretch of Port Phillip Bay and in the WTP in numbers far exceeding the 1% flyway population threshold for international significance. - Great Knot, nationally listed as Critically Endangered - Red Knot (subspecies rogersi), nationally listed as Endangered - Bar-tailed Godwit (subspecies Baueri), nationally listed as Vulnerable. Several additional shorebird species listed as Migratory under the EPBC Act also occur in internationally significant numbers. As such this coastline and general area would unquestionably qualify as Important Habitat for these species based on the Commonwealth EPBC Act Policy Statement 3.21: Industry guidelines for avoiding, assessing and mitigating impacts on EPBC Act listed migratory shorebird species and the Wildlife Conservation Plan for Migratory Species (2015). Migratory species occurring in numbers far exceeding their 1% flyway population threshold that have not been identified in the assessment include; - Sharp-tailed Sandpiper - Red-necked Stint - Double-banded Plover In addition, there are several potential impacts with varying degrees of severity which have not been considered. These include; - Permanent disruption to tidal flows and sediment transport leading to changes in coastal hydrogeology and a degradation of intertidal habitat quality; - Potential for spills – fuel, oil, and those washing up onto WTP foreshore; - Impacts from increased wash – erosion and destabilisation of intertidal system and mudflats; - Disturbance of sediment from movement of vessels in and around the port facility leading to decreased water quality and impacts to existing seagrass beds and benthic macroinvertebrate diversity; and - Potential to introduce new/ alien invasive species from ship ballast. Impact of proposed Port of Hastings expansion on the birdlife of Western Port Dr Jenny Lau March 2014 Report prepared for the Victorian National Parks Association BirdLife Australia BirdLife Australia (Royal Australasian Ornithologists Union) was founded in 1901 and works to conserve native birds and biological diversity in Australasia and Antarctica, through the study and management of birds and their habitats, and the education and involvement of the community. BirdLife Australia produces a range of publications, including Emu, a quarterly scientific journal; Australian Birdlife , a quarterly magazine for all members; Conservation Statements; BirdLife Australia Monographs; the BirdLife Australia Report series; and the Handbook of Australian, New Zealand and Antarctic Birds. It also maintains a comprehensive ornithological library and several scientific databases covering bird distribution and biology. Membership of BirdLife Australia is open to anyone interested in birds and their habitats, and concerned about the future of our avifauna. For further information about membership, subscriptions and database access, contact BirdLife Australia 60 Leicester Street, Suite 2-05 Carlton VIC 3053 Australia Tel (Australia): (03) 9347 0757 Fax: (03) 9347 9323 (Overseas): +613 9347 0757 Fax: +613 9347 9323 E-mail: [email protected] © BirdLife Australia This report is copyright. Apart from any fair dealings for the purposes of private study, research, criticism, or review as permitted under the Copyright Act, no part may be reproduced, stored in a retrieval system, or transmitted, in any form or by means, electronic, mechanical, photocopying, recording, or otherwise without prior written permission. Enquires to BirdLife Australia. Recommended citation: Lau, J., 2014. Impact of proposed Port of Hastings expansion on the birdlife of Western Port. Unpublished report prepared for the Victorian National Parks Association by BirdLife Australia. This report was prepared by BirdLife Australia under contract to the Victorian National Parks Association. Disclaimers This publication may be of assistance to you and every effort has been undertaken to ensure that the information presented within is accurate. BirdLife Australia does not guarantee that the publication is without flaw