Shani Tager
Climate and Energy Campaigner
Greenpeace Australia Pacific
Level 2, 30 Mountain St,
Ultimo NSW 2007
20 October 2014
By email to: epbc.referrals@environment.gov.au
Dear Minister,
Comment on referral: EPBC 2014/7355 – ABBOT POINT PORT AND WETLAND PROJECT
The summary of our recommendations to you regarding this referral are:
1. Request a re-referral of the two Abbot Point referrals as one;
2. Include additional matters of national environmental significance as controlling provisions;
3. Require an EIS or PER to adequately assess the impacts on matters of national
environmental significance.
Re-referral
As Minister, you should exercise your powers under s74A of the EPBC Act and request that this
referral and EPBC referral 2014/7356 Abbot Point Dredging and Onshore Placement of Dredged
Material be re-referred as a single project.
The same proponent is proposing to carry out both actions at Abbot Point. It is highly unlikely that
either action will be undertaken without the other. It appears that the construction in the wetland
in this proposal is unnecessary without the approval of the dredging referral (2014/7356). There is
no compelling reason for the delineation of the two actions when they have the same proponent
and are reliant on each other. They are two parts of the same project and the assessment of their
impacts should be approached as such, as was done with the existing Abbot Point capital dredging
approval which included dredging and dumping in the same referral.
Leaving the two Abbot Point referrals as separate proposals could mask the cumulative impacts
that they will have. The Great Barrier Reef Strategic Assessment highlights “the need for pointsource impacts to be assessed at a scale that takes into consideration the influence of other
human-related activities and ecological processes operating in the region.”1 A clear step towards
achieving this would be to assess the proposals as one project.
Matters of National Environmental Significance
The referral has failed to recognise that this proposal will have, or is likely to have, an impact on a
1
Great Barrier Reef Marine Park Authority 2014, Great Barrier Reef Region Strategic Assessment: Strategic
Assessment Report, GBRMPA, Townsville, page 6-66.
number of matters of national environmental significance. Notably absent are the impacts on the
Great Barrier Reef's outstanding universal value (OUV), the environment in the Great Barrier Reef
Marine Park, which can still act as a controlling provision for an action outside the Marine Park,
and the environment in a Commonwealth marine area.
The EPBC Act referral guidelines for the Outstanding Universal Value of the Great Barrier Reef
World Heritage Area outline known and potential threats to the OUV which include the following
that are relevant to the current proposal:
 land use change that contributes to sediment run-off;
 modification of natural coastal and riverine processes;
 poor water quality and pollution, for example dredging;
 altered aesthetic environment;
 increased human presence; and
 the potential effects of climate change.2
They go on to state that Port developments have a high risk of significant impact.
The proposal in this referral is to significantly alter the Caley Valley Wetlands. The Great Barrier
Reef Marine Park Authority recognises wetlands as vital to the Great Barrier Reef for a number of
reasons, including filtration and fish habitat.3
Given the Caley Valley Wetlands are in close proximity to the Great Barrier Reef World Heritage
Area, and it is clear that this proposal has the potential to cause significant impacts on the marine
environment, the controlling provisions should reflect this and be extended accordingly.
Assessment Approach
The need for a robust assessment approach is clear with the referral identifying a number of
information gaps and areas which are being examined under ongoing investigations. These include:
 “the design and management of bi-directional flows through the embankment will be
based on a detailed assessment of water quality requirements and ecological values of the
Caley Valley Wetland” at page 8;
 “further studies are underway to inform specific aspects of the proposed action. The results
from these studies will feed into detailed project design and further impact assessment
along with post approval management” at page 12;
 “further studies are currently underway to examine environmental matters specifically
related to the proposed action, these studies include: hydrological processes and surface
water; groundwater; terrestrial ecology; aquatic (wetland) ecology; noise; and dust” at
page 43;
Further information gaps in the referral include:
 No assessment on the impacts on the wetland to hydrology and groundwater
 No assessment of the scale of the impact on endangered species
 No assessment of acid sulphate soils from the dredged spoil that will be placed in the
2
3
EPBC Act referral guidelines for the Outstanding Universal Value of the Great Barrier Reef World Heritage Area,
Commonwealth of Australia 2014. Accessed at: http://www.environment.gov.au/system/files/resources/e8e475085ea4-457b-adef-b9c1364e9bec/files/referral-guidelines-great-barrier-reef_0.pdf, p 12.
Great Barrier Reef Marine Park Authority, http://www.gbrmpa.gov.au/managing-the-reef/how-the-reefsmanaged/coastal-ecosystems/fresh-water-wetlands-and-associated-floodplain-ecosystem
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holding ponds and how contamination will be avoided
No analysis of the impact that coal dust from trains and stockpiles will have on the
wetlands
No details on how much spoil and water the holding ponds will contain and how overflow
will be prevented during cyclones and extreme weather events
No evidence to establish that this will be a “beneficial” reuse of dredge spoil and how the
rail embankment will improve and protect the wetland
Finally, the assessment of “onshore disposal options” related to the PER for EPBC Act Approval
(EPBC 2011/6213) were minimal and not rigorous. It is insufficient to rely upon this decision to say
that the impacts of the current proposal have been assessed.
It is clear that the two Abbot Point referrals are part of the same project and should be assessed as
such. Furthermore, it is unclear why the proponent has limited the controlling provisions and we
recommend that you include the additional matters of national environmental significance that the
proposal will likely have a significant impact on as controlling provisions. The scale of potential
impacts which are currently unknown mean that this referral ought to go through a rigorous
assessment, either by EIS or PER.
Yours sincerely,
Shani Tager
Climate and Energy Campaigner
Greenpeace Australia Pacific