Jane MacDonald - Save Ralphs Bay

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There is clearly a relationship between the nature of a risk that confronts a particular place and the need for society to take steps to manage the risk. As the likelihood and consequence increase, the need for more restrictive provisions on land use will increase. 4.2 Potential impacts on aquaculture The Scope Guidelines for the IIS cover hydrology, water circulation patterns, water quality and impacts on aquaculture in sections 5.2.1 (13) (page 38); 5.2.5 (1) and (3) on page 40, 5.2.9 (5) on page 42. However, these matters do not appear to have been considered at all. The matter of potential impacts on aquaculture was raised on pages 31‐32 of Part B of the Save Ralphs Bay submission on the DIIS. I hope that the Commission considers carefully any submissions on the DIAR which raise this topic for consideration. 4.3 The Lauderdale tip The “Panel conclusions ‐ Contamination” on page 59 of the DIAR and the “Panel conclusions – Groundwater” on page 34 both indicate significant concerns regarding the Lauderdale tip. In the light of these concerns, I request that the issue of the Lauderdale tip is added to the list of, “Other risks and uncertainties” in the draft recommendations. 4.4 Noise impacts on marine wildlife On page 28 of the DIAR it is stated, “Fish and marine mammals would likely be driven from Ralphs Bay, and possibly the Derwent Estuary, for at least the five year period of civil construction work. Immobile and site dependent species such as the endangered Spotted Handfish could be subject to considerable long‐term behavioural and physiological stresses.” However, in the Panel’s conclusions on noise, dust and odour on page 31, it is stated, “The Panel is satisfied on all the evidence that vibration and underwater noise is probably unlikely to affect terrestrial and marine wildlife to a point of concern.” It is difficult to see how the Panel could be unconcerned by the level of impact described on page 28, especially in the light of the considerable public interest in the return of whales to the Derwent and the enjoyment derived by many from watching dolphins in Derwent waters. I suggest this is another factor which should be listed as an, “additional matter militating against approval”, or at the very least, another addition to the list of “risks and uncertainties.” 4.5 Contamination Jane MacDonald, submission on DIAR Page 16
Based on the evidence presented, I do not support the Panel’s conclusion on page 59 of the DIAR that, “the proposal is generally acceptable in terms of potential contamination and water quality”. Dr. Appleyard’s concerns regarding the high level of problems associated with Monosulfidic Black Oozes (MBO’s) should not be dismissed lightly, given his credentials and experience. Dr. Larsen’s comments regarding the manageability of MBO’s should be checked very carefully with Dr. Appleyard. My understanding is that “managing” MBO’s is enormously difficult and expensive. On page 50, I suggest the term “removing” is more apt in the description of denitrification than, “consuming”. (3 lines above the bold italic heading in the middle of the page). At the beginning of the second paragraph on page 54, it appears that the words “metals in” should be added, so that the sentence reads: “Dr Eriksen acknowledged that metals in Derwent Estuary sediments were tightly bound under normal conditions.” (However, it is difficult to know what ”normal conditions” means in this sentence). In the section on Stormwater on page 56, I suggest that, “loss of” needs to be added, to give the following sentence: “Prevention and, or, mitigation procedures include reduced nitrogen input, protection against loss of denitrification and overall river flow management to minimise stagnant periods.” 5. References ‘Climate Change Risks to Australia's Coasts’, Australian Government Department of Climate Change, released November 14 2009 Nyrstar 2008‐09 EMP Annual Review Nyrstar Triennial EMP 2007‐08 Jane MacDonald, submission on DIAR Page 17
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Jane MacDonald - Save Ralphs Bay

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