18 December Abbot Point Port and Wetlands project Department of State Development, Infrastructure and Planning PO Box City East Qld 4002

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1 18 December 2014 Abbot Point Port and Wetlands project Department of State Development, Infrastructure and Planning PO Box City East Qld 4002 Dear Sir/Madam Re: Preliminary documentation for the Proposed Abbot Point Port and Wetland Project at the Port of Abbot Point, North Queensland (EPBC2014/7355) & Proposed Abbot Point dredging and onshore placement of dredged material at the Port of Abbot Point, North Queensland (EPBC2014/7356) (the Project). BirdLife Australia is a highly respected science-based conservation organisation with more than 10,000 members and more than 65,000 supporters. We have an extensive ongoing program of bird conservation research. This includes our Australian Painted Snipe Recovery Project developed to halt the rapid decline the species has undergone over the last 50 years, and our Shorebirds 2020 program, developed to address the ongoing decline of Australia s resident and migratory shorebirds. Australian Painted Snipe Recovery Project: Shorebird and wetland experts from across Australia and internationally have contributed to the program and its database includes all known records of the species dating back to The project aims to improve our understanding of the population trends and ecology of the species to provide best practice management advice to landholders in order to reverse the observed declines. Shorebirds Program: 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. Thank you for the opportunity to comment on the preliminary documentation for the Project. BirdLife Australia is strongly opposed to the Project on the basis that it will have significant, negative, long-term impacts on the nationally important Caley Valley Wetlands. Caley Valley Wetlands are widely acknowledged as: meeting many of the criteria for Ramsar listing as a Wetland of International Importance; providing internationally important habitat for the globally Endangered Australian Painted Snipe; providing nationally important habitat for Little Tern, Red-necked Stint, Sharptailed Sandpiper and Latham s Snipe.

2 BirdLife Australia believes that there is insufficient information in the preliminary documents for a full assessment of both the likely environmental impacts of the Project on Matters of National Environmental Significance and the effectiveness of proposed mitigation measures. It is highly likely that the Project will have significant, long-term deleterious impacts on one of Australia and Queensland s more important wetlands. We highly recommend that the Queensland Government considers other options for the disposal of dredge spoil, for example the disposal of dredge spoil at already degraded inland sites, or a long pier that would not require dredging and loss of wetlands. Please do not hesitate to contact this office should you require any further information, or clarification of the information presented in this letter. Sincerely, Samantha Vine Head of Conservation

3 Caley Valley Wetland value to bird life Caley Valley Wetlands are recognized in the Directory of Important Wetlands in Australia (Environment Australia 2001), meeting 5 of the 6 criteria for inclusion. The preliminary documentation states that Caley Valley Wetlands support at least 52 species of waterbirds, including 15 species of listed migratory shorebirds and 20 other listed migratory bird species. Around 48,000 birds were estimated to be using the wetland in March 2012, providing a strong indication of the importance of the wetland as a drought refuge for waterbirds. In the spring and summer the area is regularly used by a suite of migratory shorebirds (16 recorded) protected under international bilateral migratory bird agreements (CAMBA, JAMBA and ROKAMBA) and under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act). The Impact Assessment Study (Volume 2) states that the wetlands are known to provide internationally important habitat for Australian Painted Snipe and nationally important habitat for Latham s Snipe, Red-necked Stint and Sharp-tailed Sandpiper. Two other species occurred in nationally important abundances (>0.1% of the estimated population): Great Egret and Caspian Tern. Caley Valley Wetlands has been shown to provide habitat for more than 2.3% of the global population of Australian Painted Snipe and is considered to be of very high international significance for the species. The nomadic nature of the population and the species dependence on coastal wetlands as drought refuges emphasises the importance of the Caley Valley Wetland for the species throughout its life cycle. Poor knowledge base The most comprehensive study of the Wetlands (BAAM 2012) was limited in both extent and duration and alone is not a suitable basis for assessing either the longterm impacts of the Projects on Matters of National Environmental Significance (MNES) or the benefits of the proposed offsets to MNES. The limitations of our understanding of the bird life of Caley Valley Wetlands are evident in the results of the BAAM surveys in February, March and June of 2012 where successive surveys revealed new species found to be using the wetlands and increased estimates of the capacity of the wetlands to support bird life. These limited surveys were particularly important for our knowledge of Australian Painted Snipe. Caley Valley Wetlands is now known to support at least 2.3% of the global population of the species. While the Impact Assessment Study acknowledges that Caley Valley Wetlands provides important habitat for a number of species, it ignores the BMT WBM (2012) study which found a nationally important population of Little Tern in the southern section of the hypersaline zone. Little Tern is an EPBC-listed migratory species (and therefore a MNES) and is listed as Endangered under the QLD Nature Conservation Act Little Tern (Sterna albifrons) was observed feeding in an aggregation of approximately 300 birds within the Wetlands project area, as well as an additional 50 birds in adjacent wetland areas. The current estimate for the number of breeding birds in Australia is 3,000 (1998 figures) (DEWHA 2007). The 350 individuals recorded within the Wetlands may fulfil this criterion if 300 individuals or more are recorded within two more years of a five year period to 2014 (BMT WBM 2012)

4 The study found that the wetlands provide Important foraging and roost habitat for resident and migratory shorebird species, including the threatened Little Tern. It is not clear why the findings and recommendations of this study were not incorporated into subsequent assessments. A thorough assessment of the potential impacts of the Project requires long-term information on the diversity and abundance of bird species using Caley Valley Wetlands under a range of seasonal and climatic conditions. We do not know how habitat availability varies throughout the year or between years for a range of species. We cannot offset the impacts of the Project on values we do not understand. Recommendation Further surveys are required to determine the diversity and abundance of bird species using the Caley Valley Wetlands prior to Project approval. This must include a more detailed study of how birds (in particular, Australian Painted Snipe) use the wetlands for foraging, roosting and breeding under a range of hydrologic and climatic conditions. We recommend that comprehensive monthly surveys of the entire wetland (incorporating threatened species survey techniques as described in DEWHA (2010)) are undertaken for at least three years, with further, ongoing surveys (as a minimum two during the wet season when migratory shorebirds are likely to be present and two during the dry season). The Proponent must assess the risk from the Project to Little Tern (a MNES) and any other MNES found to exist in the Caley Valley Wetlands and disclose plans for effective mitigation and offsetting strategies for these species. Potential impacts of the Project on MNES. The Impact Assessment Study (Volume 2) calculates that the Project will result in the loss of ha of foraging habitat and the indirect loss or degradation of an estimated 16.4 ha of habitat due to increased activity and noise. This estimated loss has been applied to migratory shorebirds and Australian Painted Snipe (MNES) On this basis, the Proponent has estimated that the Project will result in the direct loss of ha of habitat, which will require offsetting. The offset requirement has been calculated as ha composed of 38.2 ha of freshwater wetland habitat and ha of saline-influenced habitat. The Proponent is proposing to offset these impacts by protecting and enhancing 1409 ha of habitat elsewhere in the Caley Valley Wetlands. We have a number of serious concerns about this approach. 1. It is not clear how the EPBC Act Environmental Offsets Calculator was used to determine the total offset requirement for the residual impact on important habitat for Australian Painted Snipe, listed migratory shorebirds and other migratory birds (MNES). The Proponent has not disclosed the assumptions made and values used for the offset calculation. 2. The Proponent has not accounted for the impacts of the construction of the rail embankment on the outer, north-western section of the Caley Valley Wetlands, either in terms of direct habitat loss or indirect impacts on the section of the

5 wetland that will become disconnected from the main wetland, which will significantly alter the hydrology of the area. 3. The Proponent has made no attempt to determine how the Project will impact on individual MNES (Australian Painted Snipe, migratory shorebirds and other migratory birds); all are lumped together as though all species have similar foraging and roosting requirements. By lumping all of these species together, the Proponent has ignored the different habitat requirements of individual species. Migratory shorebirds are specialised to feed in different parts of the wetland system. Australian Painted Snipe requires very shallow (< 50mm), vegetated-freshwater habitat which is typically found along the margins of the wetland. The habitat optimisation proposal includes reinstating tidal influence to a section of stranded claypan. While this will create habitat for some of the more versatile marsh species, Painted Snipe are unlikely to use the area due to salinity constraints and a net loss of habitat will still be present for the species. By way of example, the habitat requirements of some of the species known to use freshwater, ephemeral areas of Caley Valley Wetlands are given in Table 1. It is clear that even within this group of birds, species differ in their habitat requirements. 4. Although this submission primarily considers the effects the proposal will have on the Caley Valley Wetland, near coastal turbidity caused by dredging will ultimately have detrimental effects on foraging opportunities for migratory shorebirds. Increased turbidity and sedimentation in the intertidal zone (in this case seagrass meadows) precludes light penetration and is likely to cause a habitat phase shift to the detriment of the existing mudflat flora and fauna. The loss of seagrass equates to a loss of local biodiversity a 40-fold difference exists between biodiversity in seagrass and bare-sand communities (Fox et al. 2007). The absence of seagrass meadows and an increase in nutrients on intertidal mudflats encourages colonisation by mats of Sea Lettuce Ulva lactuca and other algae. Sea Lettuce is well-known nitrogen scavenger, and if dense algal mats are able to become established they can have catastrophic effects on the underlying invertebrate assemblages through deoxygenation of sediment (Raffaelli & Hawkins 1999; Mackenzie 2000). Such a decline in benthic prey will have catastrophic effects on intertidal foraging species, particularly of coastal obligates, such as Eastern Curlew (EN EPBC) and Grey-tailed Tattler who cannot supplement their diet by feeding in nearby wetlands and will consequently abandon the site.

6 Table 1: Habitat requirements of some shorebird species recorded at Caley Valley Wetlands. Common Name Latham's Snipe Water Depth Upper Limit (mm) Water Depth Lower Limit (mm) Salinity Upper Salinity Lower Salinity Optimum 60 0 <18g/L freshwater freshwater Roosting Req (Description) Preferred roost is amongst vegetation in freshwater swamps, sometimes at edge or in the open, rarely in water Marsh Sandpiper g/L freshwater <18g/L Roosts near low saltmarsh or on edges of waterbodies e.g. swamps Pacific Golden Plover Red-necked Stint Sharp-tailed Sandpiper g/L freshwater 18-30g/L g/L freshwater g/L g/L freshwater 110g/L Sandy beaches, spits and islands with other plovers and sandpipers, rocky reefs, in saltmarsh sometimes under vegetation Roosting in flocks on sheltered beaches, spits, banks or islets. Often amongst vegetation e.g saltmarsh. Roosts on wetland edges in single species or mixed flocks either on bare areas or amongst sparse vegetation

7 5. The Proponent has assumed that the proposed offset area is equally suitable for all species, for both foraging and roosting, and that all of offset area will provide habitat for these species. This is not the case. The majority of the offset area is closed marsh which is unsuitable for Australian Painted Snipe and migratory shorebirds because it is 1. too deep and 2. fringed by vegetation. 6. BirdLife Australia has serious concerns that the Project will lead to a net loss of habitat for MNES and ongoing degradation of the remaining wetland that forms the basis of the offset (see below). The underlying principles of offsetting (achieving zero impacts or a net gain) cannot be demonstrated under the existing Proposal. An offset must be demonstrably likely to achieve a gain of ecological equivalence, in both kind and magnitude, to the values lost. An offset must provide direct benefit for the population(s) being affected by the impact, meaning the protection, restoration and/or rehabilitation and management of equivalent habitat to fully counterbalance the calculated impact on population(s). 7. The Proponent has not accounted for the indirect loss of habitat and other impacts brought about by the altered hydrology, sedimentation patterns and increased pollution in the wetlands. Construction of the railway embankment, removal of the existing bunds and construction of the bunds for the dredge spoil dump and the sourcing of the borrow for the embankment and bunds will alter the hydrology of the wetlands and impact on both foraging and roosting habitat for all bird species, including MNES. The existing modelling of impacts to the wetland uses a two-dimensional hydrodynamic model for which there are few input data, no calibration and assumptions and extrapolations made about the bathymetry which are considerably uncertain. Construction of the rail embankment and associated pipes is described as being designed to protect and enhance the wetland. However we are not confident that this has been adequately assessed and consider that the works may in fact degrade the wetland and suitability of habitat for the Australian Painted Snipe and other shorebirds. While it is possible to manipulate a wetland to increase bird diversity or abundance, having one or more coal haul rail lines around more than half of the perimeter is an impediment. Similarly, removing one of the shallow arms of the wetland which is likely to be some of the best Suitable Habitat for Australian Painted Snipe also has the potential to have significant negative impacts. We are very concerned that the discharge may affect less disturbed freshwater/hypersaline wetlands fringing Upstart Bay. The infrastructure is likely to increase sedimentation and erosion and we would like to see robust modelling on potential impacts to the ephemeral habitat. In particular, the report addresses the construction phase in relation to the rail embankment and regulation of water flows, identifying the planned development of a stormwater management plan and sequencing of construction activities to limit impacts on the existing hydrological regime to the extent possible (undefined). However we would like to see further detail about this, including investigation on the potential impacts of this construction, the close proximity of the rail line to significant habitat, as well as the regulation of flows through the pipes. The proposal for pipes with flow valves could significantly affect hydrological conditions to the detriment of the habitat.

8 8. The Proponent has not considered the cumulative, long-term impacts of coal dust on the wetlands and the impacts this will have on the health of the entire wetland, including the invertebrate prey of birds using the wetlands. 9. There are no details about the proposed enhancement of the wetlands. Therefore it is not possible for us to assess the cost/benefit of this to birdlife. It is difficult to remediate such a pristine wetland to the quality of its natural state. To ensure that an enhanced wetland is kept in good condition would require plans for significant and ongoing management. For example, the report refers to degraded, hypersaline land several times. It is highly likely that the degraded, hypersaline condition is the natural state in the dry season and dryer cycles. Marine plain wetlands depend on the drying of algal mats and resting to fuel their huge productivity. The phrase enhanced wetlands can suggest deepened waterbody which is likely to result in a lower diversity of bird species in the Caley Valley Wetland. The ecosystem may become more suited to species such as Black Swan Cygnus atratus and some ducks, but will lose value for many of the numerous species of shallow water using migratory shorebirds which are subject to State, Federal and International protective agreements. The report hints at allowing for differing water levels, but needs a more strategic plan. For example, the available wetland resources for migratory waders on the Autumn Northward journey are extensive, but in dry spring seasons, the suitable wetlands in the tropics can be very limited. Management could aim to retain extensive shallow muddy areas at this time, then drying into the summer in all but the wettest years. In regards to Australian Painted Snipe, the report surveys show Australian Painted Snipe recorded in the summer season; this is probably a result of very wet years allowing wetlands to persist beyond spring. Managers could use this as a tool in some years, but wetlands only support Australian Painted Snipe for long periods if there is a continuum of drying muddy edges. As Caley Valley Wetland has a small local catchment, careful attention should be paid to retaining local rainfall inflows to support the marginal Australian Painted Snipe habitat, and also sustaining the freshwater, tidal (High Water Spring Tides) connection. The fresh/saltwater interface, correctly managed, will also assist lifecycle maintenance of other catadromous species such as barramundi and estuarine crustaceae. 10. We are opposed to the offset area becoming a Nature Refuge as this does not provide in perpetuity protection to the wetland from all potential threats (e.g. mining). If this is found to be a suitable offset site, we recommend reservation as a National Park. Recommendation Detailed studies are required to determine the extent and quality of habitat for each MNES in areas to be directly and indirectly impacted by the Project. In particular, how the Project will impact on the hydrology, chemistry and sedimentation patterns in the wetland, how this will change the bathymetry and productivity of the wetland and ultimately, how this will affect the extent and condition of foraging and roosting habitat available to the full suite of bird species that use the Caley Valley Wetland under a range of hydrological and climatic conditions.

9 This will require direct measurement and subsequent modelling of a number of wetland variables, including but not limited to salinity, bathymetry, chlorophyll, invertebrate sampling and dissolved oxygen, to improve our understanding of wetland functioning and how this impacts on bird habitat. These studies must also include modelling of the likelihood of flood, tidal penetration given bund breach, salinity of inundated area given bund breach, primary production, respiration, and ecosystem metabolism prior to, during and after construction of the Project. The proposed offset area should be examined to determine the extent and quality of foraging and roosting habitat available to each MNES, modelled under a range of hydrological and climatic conditions prior to, during and after construction of the Project. Any offsetting and wetland enhancement projects must have input from a technical reference group composed of independent scientists with expertise in the fields of wetland ecology, hydrology and shorebird and waterbird ecology. Other concerns BirdLife Australia objects to the use of a Community Reference Group composed largely of industry and tourism representatives to guide the wetland enhancement program. These representatives are unlikely to have the required expertise in wetland rehabilitation and management. Reference Garnett, S.T., Szabo, J.K. and Dutson, G. The action plan for Australian Birds CSIRO Melbourne (2011) BMT WBM (2012) Kaili (Caley) Valley Wetlands Baseline Report. Report prepared for the Office of the Coordinator-General, Department of State Development, Infrastructure and Planning. Fox, D.R., Batley, G.E., Blackburn, D., Bone, Y., Bryars, S., Cheshire, A., Collings, G., Ellis, D., Fairweather, P., Fallowfield, H., Harris, G., Henderson, B., Kämpf, J., Nayar, S., Pattiaratchi, C., Petrusevics, P., Townsend, M., Westphalen, G. and Wilkinson, J. (2007) Adelaide Coastal Waters Study. CSIRO Report prepared for South Australian Environment Protection Authority, Adelaide. Mackenzie, C.L. (2000) The abundances of small invertebrates in relation to Sea Lettuce, Ulva lactuca, mats. Bulletin of the New Jersey Academy of Science 45, Raffaelli, D.G. and Hawkins, S.J. (1999) Intertidal Ecology. Kluwer Academic, Dordrecht, The Netherlands. Department of the Environment, Water, Heritage and the Arts (2010) Survey guidelines for Australia s threatened birds - Guidelines for detecting birds listed as

10 threatened under the Environment Protection and Biodiversity Conservation Act 1999.