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Submission on Environmental Impact
 


Potential Issues with the Proposal to Develop a  Coal Port at Dudgeon Point

Air Pollution
• The community of Louisa Creek is less than one kilometer southeast of a Dudgeon Point port site and less than a kilometer northwest of the Hay Point and Dalrymple Bay coal ports. It would be subject to coal dust deposition from both sides. Long-term impacts from coal dust deposition on human and environmental health at low concentrations are not known. This dust from Hay Point and Dalrymple Bay ports requires constant cleaning of housing as far north as the Mackay Marina apartments, 20km as the crow flies northwest of these ports. Most prevailing winds throughout the day are from the southeast. An additional coal port at Dudgeon Point would add to coal dust deposition over Mackay from the Harbour and across south, east and west Mackay. McEwan’s Beach community would also be affected. Communities further south would also be affected when the northerly winds blow, but to a lesser extent.

As all ports are increasing their capacity this would add further to coal dust deposition in the region. While the ports try to keep coal dust onsite, the smaller particles are harder to manage. Fine particles less than 2.5 microns cause more damage to human lungs because they penetrate deeper into the lungs than larger particles. Queensland has no legislation that addresses pollution from these small particles.

Dredging
• Hay Point and Dalrymple Bay coal ports have almost exhausted the capacity of the off-shore dredge spoil disposal site. Dudgeon Point is within a higher erosion prone area with EPA mapping much larger zones of Control Management Districts for erosion. This suggests that there will need to be more dredging for a port at Dudgeon Point. Where will the additional spoil go?
• An increase in dredging would mean a reduced supply of coastal sand replenishment to McEwan’s Beach and north to the Pioneer River mouth. The eastern part of the Mackay Airport has a planned runway extension into a high erosion prone area (400m wide) at Shellgrit Creek mouth in South Mackay. Changes in the regional supply of beach replenishment sands as a result of dredging at Dudgeon Point for a port should be carefully studied for their erosion implications. The region faces a one to two meter rise in sea levels by 2100 because of climate change impacts (thermal expansion of seawaters and glacial meltwaters).

Flora and Fauna
• The wetland and coastal ecosystems complex from Dudgeon Point to Baker’s Creek contains 505 plants and animal species. Of these 415 are native and the rest are naturalised introduced species. 187 are bird species. 27 of the 35 migratory bird species that visit Australia are recorded here. There are 74 Marine species of birds (EPBC). Four of the bird species are Rare; one species is Vulnerable and one is Rare (NCA); There are six mammal species and ten reptile species including two turtle species the flatback turtle and green turtle (Appendix I). This habitat complex is mapped as State Significant (terrestrial habitats) and State and Nationally Significant (wetlands).
• At least 160 bird species and one (flatback) turtle species use Dudgeon’s Point to rest, feed and/or breed.
• Dudgeon’s Point is an internationally significant part of the East Asian and Australasian flyway for migratory birds as some species are there in internationally significant numbers e.g. Sand Plovers >1% of the flyway population.
• All levels of government in Australia have the responsibility under the EPBC Act and international agreements to protect migratory waders, turtles and their habitat e.g.
Japan & Australian Migratory Bird Agreement (JAMBA);
China & Australian Migratory Bird Agreement (CAMBA);
Republic of Korea and Australian Migratory Bird Agreement (ROKAMBA); “Bonn Convention”–the Convention on the Conservation of Migratory Species
Federal Environmental Protection & Biodiversity Conservation Act 1999 (EPBC)
• Migratory waders feed and roost along Ballykeel beach and any loading
jetties should be kept well away from this area as well as other sites off
Sandringhanm Bay, the saltpans and Mt Hector.
• The proposed Dudgeon Point port boundaries proposed by Ports Corporation QLD in 2003 are mostly adjacent to or within Essential Habitat for Threatened Species and remnant ecosystems as mapped by EPA in their Remnant Ecosystems map. It would not always be possible to contain contaminated runoff from a coal port facility, especially during storms and cyclones. There is a high risk of adverse impacts on threatened species.
• The southern half of the proposed 2003 Dudgeon port site contains “Not of Concern” remnant regional ecosystem 8.12.22. This ecosystem has low representation in the Protected Area Estate (PAE). Any clearing or adverse impacts on this ecosystem would need to be offset by purchasing and placing another area containing this ecosystem within the PAE.

Habitat Concerns
• In the past year most major wetlands of national significance and adjoining coastal ecosystems and communities in Central Queensland have been under threat from mining and port development e.g. Abbot Point port expansion plus the declared Abbot Point State Development Area which will impact the adjacent Caley Abbot wetland aggregation; proposed commercial scale oil shale mining and processing within the Goorganga floodplain adjacent to the Goorganga Wetlands and south of Proserpine; a coal port next to the Mackay Harbour wetlands in Mackay; Dudgeon Point coal port next to Sandringham Bay wetlands and ongoing expansion at Hay Point and Dalrymple Bay near Louisa Creek and McEwan’s beach communities; and Shoalwater Bay north of Byfield National Park. Short-term economic gains for the coal mining industry are prioritised over social and environmental needs along the Queensland coast. This contravenes the legal requirement for a triple bottom line approach.
• Salt pan off Ballykeel which is part of the mangrove environment is fed by
tidal waters and is protected habitat. It would need to be well buffered
• The Dudgeon Point coal port terminal would be next to Louisa Creek and its mangroves. The Louisa Creek mangroves have been identified as some of the healthiest in the Mackay/Sarina area. All mangroves should be completely buffered from any likelihood of contamination as they are vital marine nursery habitats, and are potential habitat for the false water rat (mangrove mouse) listed as Vulnerable under the QLD Nature Conservation
Act (NCA) and EPBCAct.
• The 375ha site to the south and south-east of Timberlands should not be part of the coal port and should be well protected from adverse impacts as it is primarily remnant vegetation classified as “of Concern” under the Vegetation Management Act and “Endangered” for Biodiversity i.e. Regional Ecosystem 8.3.5.

Areas of State Significance
• Natural Resources: Significant coastal dune system, wetlands, and coral reef
• Conservation Park: Painted rocks
• Scenic Coastal Landscapes: Sandringham Bay coastal wetlands
• Beach and Foreshore habitat: Turtle nesting habitat & shorebird habitat
• Terrestrial Habitat: “Of Concern” remnant vegetation and “Endangered” for biodiversity

Economic Climate
• At this time (October 2008) the global economy faces an economic downturn that may deepen into a depression lasting some years. Australi’s main coal buyers are Japan and China. China is predicted to far better than Japan, with its growth rate slowing to six percent from the current nine percent. The full impacts of this economic downturn will not be known until next early year when Australian coal companies enter into price negotiations for its coal exports, but can be expected to decline. At that time port expansion demand may well slow down considerably. There may also be a backlash against the use of more coal as countries work out their climate change mitigation strategies. It is therefore premature to hastily expand the number of coal ports in Queensland. Abbott Point is expanding from 15 Million tonnes (Mt) a year to 110 Mt a year by 2010. Other ports such as Hay Point and Dudgeon Point are also expanding. That capacity may well be sufficient as global demand recedes. Future predicted demand should be revised in light of the current world economic situation.
• Expansion of the coal industry can also not be justified given its contributions to climate change, especially the increasing acidification of the world’s ocean and the Great Barrier Reef from growing uptake of carbon dioxide into the oceans. Marine animals have not evolved in more acidic environments and this process if it continues will destroy many of the oceans’ marine ecosystems. Carbon dioxide concentrations are increasing to levels not seen on Earth since the Permian Age 250 million years ago when they were implicated in a massive extinction of many life forms on land and water, including coral reefs (Veron. “A Reef in Time” 2008).
Zoning
• Re-zoning of Dudgeon Point from Rural to Industrial would also be necessary to establish the coal port. It would mean the loss of good quality agricultural land as well as increased air pollution over the surrounding region for at least a 20km radius. If associated heavy industry was also established near the port heavy metals and other pollutants would predominantly blow over Louisa Creek, McEwan’s Beach and Mackay.

Infrastructure
• Dudgeon’s Point lacks all infrastructure necessary for a port. The road in is unsealed for its entire 10km length. Additional power supply would be needed. Water supply would also be another issue.

Alternative Options
• Given the high number of State Significant values associated with Dudgeon Point and the surrounding region especially in Sandringham Bay and its coastline, the most appropriate long-term sustainable use would be for a low impact use such as ecotourism, possibly some permaculture agriculture and as a climate change buffer zone. Revegetation works should also be carried out to restore degraded land within the north end of the port site impact zone.

Betty Hobbs
Coalport Community & Recreation Assoc.
Ph: (07) 4956 3256

Patricia Julien (on content of this information packet)
Mackay Conservation Group 9th October, 2008
pajulien@orion-online.com.au Ph: (07) 4966 8025

Refer: Draft Mackay Whitsunday Regional Coastal management Plant 2007. Online on EPA website at http://www.epa.qld.gov.au/environmental_management/coast_and_oceans/coastal_management/regional_coastal_management_plans/mackaywhitsunday_coast/

and

Ports Corporation QLD. Development of Land Holdings at Dudgeon Point, March 2003 (CD)



 
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