John Gunn, Chief Executive Officer 6 August 2014 Northern Australia Taskforce Department of Prime Minister and Cabinet PO Box 6500 Canberra ACT 2600 Dear Sir/Madam The Australian Institute of Marine Science (AIMS) welcomes the opportunity to provide feedback on the Australian Government’s Green Paper on Developing Northern Australia (‘the Green Paper’). As a Commonwealth research agency based in northern Australia, and focused on the sustainable development of this region, AIMS commends the task force on their excellent work in pulling the Green Paper together. The Green Paper explores how best to create a policy environment that facilitates economic and social growth through private sector and local government investment into Northern Australia. At this high level, we suggest that a key element of any policy or investment strategy for the region (sub-regions) that targets growth across multiple sectors, should be a long-term vision of, and collective commitment to, securing triple bottom line benefits for all Australians. Opening up northern Australia to large-scale development, while enhancing social benefit and protecting regional environmental assets will be a challenge. However, we believe that lessons from our nation’s development (mistakes) over the last century, and advances in our ability to determine and predict the risks, impacts and trade-offs of future development, make it feasible to plan for sustainable multiple use at both local and regional scales. AIMS’ feedback on the Green Paper is provided from the perspective of a marine science agency with over 40 years’ experience working in tropical marine environments across Northern Australia and long-standing relationships with many of the industries that form the backbone of northern economies (offshore oil and gas, tourism, shipping and ports, and education). AIMS is not only acknowledged to be a world-leader in tropical marine ecosystems and their living resources, but a leading provider of the predictive models and support systems needed to inform ecologically sustainable development decisions. The Green Paper outlines a number of propositions and questions relating to Australia’s northern profile, opportunities, challenges and future directions. Building on our submission to the Joint Select Inquiry on Northern Australia earlier this year1 we would like to draw your attention to the following key issues and opportunities. Securing the knowledge base to support sustainable growth and development The Green Paper articulates a commitment to planning over two to twenty year timeframes and to engaging constructively with all stakeholders to secure shared ownership of and commitment to the Government’s vision, but does not fully explore the implications of these objectives and requirements for regional planning and ultimately development decisions. 1 Submission No. 106, available at: http://www.aph.gov.au/Parliamentary_Business/Committees/Joint/Northern_Australia/Inquiry_into_the_Developme nt_of_Northern_Australia/Submissions Planning for and managing sustainable “multiple use development” - across agricultural, mining, manufacturing/mineral processing, fishing and tourism sectors, in a region where traditional ownership of land is significant - will inevitably involve trade-offs between competing interests and goals. Without an adequate decision framework and evidence base to transparently assess risks, costs and benefits and make balanced decisions, there is a high risk of conflict and unintended consequences across economic, social and environmental dimensions. Development activities at local and regional scales will also all generally involve a balance between current benefit and future cost (e.g. environmental remediation, opportunity cost etc.). Lack of certainty regarding the scale and scope of social and environmental impacts and the capacity of ecosystems to ‘bounce back’ to good health from multiple stressors, again comes with a high risk of conflict and non-recoverable loss of valuable environmental ecosystems and their resources. These issues can present significant barriers to development, if not carefully managed, as evidenced by three current examples: Tourism on the Great Barrier Reef (GBR) contributes nearly $6 billion per annum to the Australian economy, yet the Reef’s condition has been shown to be in decline as a result of a combination of factors including the direct and indirect effects of run-off from catchments that have been highly modified as part of the growth of agriculture and grazing in north Queensland. Current efforts to reduce this impact and protect the economic, social and ecological values of the GBR are costly. Uncertainty about the cumulative impacts of different land-based activities (including aquaculture) has been reducing regulation effectiveness. Delays or abandonment of development proposals and the need for post-hoc efforts to regulate catchment-use are occurring at an unacceptably high frequency. More carefully planned development, based on deeper understanding of potential downstream impacts would have enabled more efficient and balanced economic growth that realizes the potential of both upstream and downstream activities. The Murray Darling Basin illustrates the economic and societal cost of broad scale development creating unintended environmental impacts. Specifically, how insufficient knowledge regarding natural variability and downstream impacts on a critical environmental resource can lead to a significant future cost (in this case, in the form of water buy-backs from irrigators, complex ongoing management systems and reduced productivity to address the compounding impact of over-use). Recent north Queensland bulk commodity port expansions have illustrated how uncertainties regarding wider impacts of development and ongoing operations on the broader Great Barrier Reef can create a ‘high-risk’ investment environment for companies. In particular, these uncertainties contribute to extended approval processes and can lead to a loss of public confidence in the management decisions. These barriers need to be addressed if northern Australia’s potential is to be unlocked and secured; for both current and future generations. The best way to do this is through investment in a well-designed and continuously renewed scientific evidence base for northern Australia’s unique environmental values and their complex responses to human activities, and through the integration of this knowledge into both development decisions and ongoing development management frameworks. The level of scientific effort needed to support multiple use decision making across northern Australia is beyond the resources of any one organisation. Given the likelihood that project proponents will either lack the resources or incentives to engage in building the required bigger picture, regional evidence bases, and the anticipated pace, scope and sheer scale of development, Government intervention and leadership will be necessary. Thus, AIMS suggests that targeted action by the Government and other key stakeholders to build comprehensive evidence bases to support focused multiple use planning and management strategies should be a core element of the final White Paper. This could take the form of one or more strategic, collaborative research initiatives which build on or extend current capabilities and efforts. Attachment A provides case studies that illustrate the need and benefits of resolution for two priority development areas. These are: I. Removing Barriers to Commodity Port and Offshore Oil & Gas development in northern Australia. It highlights the need and benefits of reducing development risk though the availability of improved baseline environmental knowledge. II. The development of Australia’s two largest gulfs, the Gulf of Carpentaria and Joseph Bonaparte Gulf. It highlights the challenges as the focal point for major developments and population growth in future years shifts towards northern Australia’s coastal zones and the role that science can play in minimizing conflict, reducing investment risk and balancing development with downstream productivity and socio-cultural benefits derived from these regions. Balancing land-based and marine opportunities and challenges The Green Paper focuses almost exclusively on northern Australia’s terrestrial domains and issues, and in so doing underemphasizes the importance of the marine areas as drivers of economic growth, social value and ecosystem services. Australia has the 3rd largest marine estate in the world, with 3.14 million square kilometres (excluding the territories around Cocos-Keeling and Christmas Islands) occurring in the tropics. Our tropical marine estate is similar in area to our tropical land area. The total value of economic activity associated with Australia’s marine environment has doubled in the last 10 years; the most recent estimate puts its total value at $47 billion 2. This is projected to grow to $100 billion by 2025, driven primarily by expansion of industries such as oil and gas exploration and exploitation in northern Australia. Ports in northern Australia already handle the majority of Australia’s bulk exports and will only see further demand in the future, as Australia’s most direct shipping route to growing Asian markets. The majority of people in northern Australia live by the coastline and a large number of major development activities will be centred on coastal zones, highlighting the need for future policy and planning to consider not just options to improve the productivity of and optimal resource allocation on the land, but the intersect between land and sea. As noted above, this is particularly important in relation to management of coastal catchments and port expansions or developments, where changes to river discharges, agricultural runoff, dredging operations and spoil disposal respectively, can have negative impacts on important ecosystems such as the GBR and the Gulfs of Carpentaria and Joseph Bonaparte. Reducing Green Tape through improved understanding of environmental impacts and resilience A common message coming from discussions on enhancing the development trajectory of Northern Australia is that costly and complicated regulatory burdens cause unnecessary delays and cost over-runs for many development initiatives. While increased bureaucratic efficiency is an important goal, the cause of approval delays and additional regulatory hurdles is often rooted in genuine uncertainty regarding the nature, level and mechanisms of impacts from development activities on ecosystem features and processes. In the absence of accurate impact thresholds and predictions of the spatial extent of impacts, conservative limits are often set, and increased information sought on wider range of variables over a much larger area than might be needed if there was greater certainty about the way in which activities impact the environment. Coordinated pre-development baseline resource surveys and targeted impact and threshold studies conducted to address industry-wide impact issues are a much more effective way to reduce uncertainty than placing individual regulatory burdens on each development proposal. The development and implementation of regional, issue-oriented research strategies to build the knowledge base needed to reduce environmental uncertainties and reduce unnecessary green tape would require strategic collaboration between government and relevant industry sectors, but would yield significant cost and time savings to industry and promote certainty for investors, and thus the likelihood of economic growth. Demonstrating leadership in the tropical region The Green Paper also outlines the growing influence of Asian economies on northern Australia; in particular, Asia’s role as a demanding consumer of northern economies’ goods and services (for example, minerals and energy, food, and provision of education and health services) and relevance to Australia’s security agenda. It gives comparatively little attention however to the potential for northern Australia to play a leadership role in supporting neighbouring developing nations to address the unique challenges confronting tropical regions across the globe. Coastal marine environments and their resources (in particular, coral reef systems) are central to the economies of many nations in the tropics, but are currently under threat from a range of human and global stressors which may see the collapse of key industries (for example, fisheries, reef-based tourism). Northern Australian universities, management authorities and research agencies, such as AIMS, have considerable expertise and experience in monitoring 2 The AIMS index of marine industry, June 2014; http://www.aims.gov.au/publications.html and assessing such threats and implementing strategies to promote resilience, which could be better promoted and shared in future regional engagement strategies. Should any of these points require further clarification, please contact AIMS General Manager, David Mead on xxxxxxxx or xxxxx. Yours sincerely Signature Removed John Gunn Chief Executive Officer ATTACHMENT A Case Example # 1: Removing Barriers to Commodity Port and Offshore Oil & Gas development in Northern Australia The following case example illustrates where Government Leadership and investment is required in order to remove barriers within the commodity ports and offshore oil and gas sectors. Development Potential: Offshore oil and gas activities and bulk commodity port developments and expansions will both be crucial to the prosperity of Australia’s northern economies over the medium term. The tropical north west of Australia was the focus of capital investment valued at $130 billion in 2012 and the majority of new production of LNG (projected to increase from 12 million tonnes per annum in 2005 to 94 million tonnes per annum in 2016) will be delivered from offshore projects in northwest Australia. Ports in tropical regions of Australia now handle the majority of Australia’s exports. As production of commodities (minerals, gas, agricultural products) grows in response to regional and global demand, the number of ports across this region and the size of existing ports are projected to expand. Problem Statement: This development/growth comes with some risk to the environment, which must be managed in accordance with state, territory and federal government environmental regulations and controls. The absence of adequate, readily accessible data and integrated knowledge to support assessment of these risks presents a significant barrier to development and operations. The current Abbot Point expansion provides a good example of this issue for the commodity ports sector, with current uncertainties regarding the broader Great Barrier Reef impact of the redevelopment and ongoing operations resulting in significant concerns across the full spectrum of stakeholders (industry, public, investors, etc.), investment delays and loss of public confidence in development decisions (the ‘social license’ to operate). Projected economic growth across northern Australia will only compound these issues. Solution: Government intervention and leadership is required to break this cycle – being played out across Australia - of the rate of development outstripping the knowledge base needed to balance competing values and to ensure that growth does not incur untenable future cost (for example, through loss of ecosystem-function and the high value industries dependent on healthy ecosystems, such as tourism and commercial fishing). Specifically, a program to a) centrally aggregate all existing baseline environmental data (including that held by industry), b) analyse this data to improve current knowledge (extracting the full value of existing data), c) identify knowledge gaps, and d) filling of critical gaps, is recommended. AIMS has developed a specific proposal designed to address this development barrier (Remove barriers to the development of key northern Australian industries by addressing knowledge gaps associated with commodity ports and oil and gas development), a copy of which can be provided if required. Benefits of Proposed Approach: Intervention would eliminate market failures which currently act as deterrents to private sector investment in building a broad-based and integrated knowledge base. For example: Data sharing between companies is seen as loss of competitive advantage (commercial loss) and spill-over benefits to other companies. Integrated assessment of cumulative impacts of development activities occurring over appropriate regional scales is well beyond the capability of individual companies to undertake or support. The proposed actions would lead, with a comparatively modest level of investment, to several significantly improved outcomes: Full value from the data already collected across these sectors. Development of standards and a framework for future investment. Improved regulator decisions derived from higher quality, more comprehensive data. Fewer regulatory restrictions due to greater certainty of likely impacts from industry activities. Improved public confidence in development activities. Case Example # 2: Achieving balanced economic growth by supporting multi-use decision making in Northern Australia Yours sincerely The following case example illustrates where Government Leadership and investment is required in order to ensure balanced and sustainable development. Development Potential: The coastal zones of Australia’s two largest gulfs – the Gulf of Carpentaria (GoC) and Joseph Bonaparte Gulf (JBG) – are central to northern economic development, for example: Significant new agricultural/irrigation projects are planned in the catchments of both Gulfs. John Gunn Both CEO AIMSGulfs sustain important prawn and other fisheries. Coastal industries are forecast to develop rapidly in the area. Shipping will increase in both water bodies as a result of growth in the resources sector (particularly oil and gas developments in JBG and increased mining activities adjacent to GoC). Ports are currently undergoing expansion or are predicted to do so. There is significant unrealised marine tourism potential in the area. The area is highly valued by indigenous communities (to the extent of declaring IPAs – Indigenous Protected Areas). Problem Statement: There is a lack of scientific knowledge to quantify and manage environmental risks associated with projected areas of development. It is not possible to articulate the trade-off and optimum combination of uses for optimum, sustainable development. There is also a lack of essential baseline information about the condition of the coastal environments and their resilience to local and remote development activities. For example, changes to catchments have an impact on runoff and river flows, which often result in poorly understood, but potentially significant impacts on coastal marine industries and livelihoods. Risk Created: There are a number of risks associated with these knowledge gaps, including: i) conflict between users regarding the appropriate balance of usage activities and protection of environmental and cultural values; ii) delayed or foregone development opportunities due to perceived, but unproven risks; and iii) the need for expensive (and productivity reducing) reparation in response to major unanticipated impacts. Solution: What is needed to address these risks are science-based decision support tools built on a clear and comprehensive mapping of coastal assets, environments and areas of cultural significance. These tools would transparently illustrate the trade-offs between development and downstream productivity and socio-cultural benefits derived from the regions. This requires the development of a scientific knowledge base around key ecosystems, how they function and their ability to absorb changes. The best way to deliver these tools is through collaborative research efforts focused on mapping what is important to stakeholders, documenting areas of highest value and most vulnerability to the impacts of development, plugging knowledge/information gaps, and developing scenario models to assess what constitutes the best balance of competing uses. Such efforts currently exceed the ability and resources of any one organisation to undertake alone. Their ‘public good nature’ (extending beyond the interests and responsibilities of individual project proponents) moreover, further implies that without Government intervention and leadership, traction will not be achieved. AIMS has developed a specific proposal designed to address the Gulf of Carpentaria opportunity (Achieving balanced economic growth by supporting multi-use decision making in Northern Australia), a copy of which can be provided if required. Benefits of Proposed Approach: The net cost-benefit equation associated with action is compelling. In brief: Reduced investment risk; More transparent, effective and timely decisions; Reduced conflict amongst users; Improved public confidence in the rigor and long-term impacts of management decisions; Reduced risk of non-sustainable economic development in northern Australia.