CC: The Hon. Peter Garrett, Federal Minister for the Environment, Heritage and the Arts;
Hon. David Alan Templeman MLA, WA Minister for the Environment, Climate Change

 

Premier.
State of Western Australia.
Hon. Alan Carpenter

 

Dear Mr Carpenter

I wish to register my strong opposition to Straits Resources Limited’s proposal for a solar salt operation on the eastern margin of the Exmouth Gulf in Western Australia, as outlined in the Environmental Review and Management Plan (ERMP). Exmouth Gulf is one of Australia’s most productive marine ecosystems and this unique natural asset would be placed at severe and long-term risk by the massive operation proposed in this ERMP.

The mangrove system on the eastern side of Exmouth Gulf is a vital nursery for crustaceans and fish, including species utilised by significant commercial and recreational fisheries established in the region.

The proposed 411 square kilometers of solar ponds and rock wall, as per Straits' original proposal, would extensively alter the natural “flood-out” drainage pattern and artificially redirect the flow of sediment and nutrients. The barrier could effectively starve the Gulf ecosystem of its vital natural resources.

The mangrove, seaweed and seagrass habitats of the eastern Gulf function like a battery, fixing and gradually re-supplying nutrients and energy after re-charge from the intermittent flood-out events.

The shallow water habitats on the eastern side of the Gulf are an important feeding ground for both adult and juvenile Green Turtles. The area is a major Dugong habitat and an important sheltered resting area for Humpback Whales which may be critical for the survival of young calves on the southward migration.

The Yannarie mangrove system on the eastern side of Exmouth Gulf has been universally recognised as requiring a high level of protection. It is completely closed to trawling and has been proposed as a marine conservation reserve under the Conservation and Land Management Act, as a fish habitat protection area under the Fish Resources Management Act and as an extension to a Ningaloo/Cape Range World Heritage Area.

Straits Salts’ proposal involves the extraction of huge quantities of seawater which would also remove vast numbers of prawn and fish larvae and post larvae fish from the Gulf ecosystem and the fisheries.

The proposal will involve the impoundment of vast quantities of toxic bitterns, the highly concentrated by-product of solar salt product. This material could then enter the Gulf ecosystem through seepage or wall failure, potentially killing vast numbers of marine creatures.

The company claims it will store the bitterns until such time as new technology becomes available to allow discharge to not occur. This is not an environmentally sustainable solution and equates to asking the regulatory authorities to ignore a vital component of their mission to protect the environment now for future generations.

There are many other major risks to the environment associated with this massive proposal that have not been adequately addressed in the proponent’s ERMP.

The excavated inland harbour may expose significant areas of acid generating sulphides as well as removing mangrove and algal mat habitat.

The silty bottom of the eastern Gulf is likely to be mobilised by repeated dredging operations smothering marine producer habitats. The Panamax Bulk Carriers, barges and service vessels are likely to increasingly disturb and disrupt the use of the area by megafauna such as Humpback Whales, Dugongs and Sea-Turtles. The international shipping may transport exotic marine pests from high-risk regions such as the coast of China.

Exmouth Gulf supports a long-standing sustainable prawn trawl fishery and the region is also home to a pearl oyster fishery and grow-out industry and an established recreational sports-fishery.

Both fishing and aquaculture are highly dependent on the maintenance of high water quality and of the natural ecological processes driving marine productivity. All these activities will be threatened by the proposed project.

Both commercial and recreational fisheries will potentially see a reduction in recruitment as a consequence of changes to habitat structure and foodwebs resulting from this proposal.

In closing, I wish to emphasise that the project being proposed by Straits Resources is of a size previously unheard of in Western Australia and could have massive impacts on an ecosystem scale.

Straits' ERMP fails to adequately examine the risks to the environment and does not alleviate in any way the numerous environmental, economic and social concerns surrounding this proposal.

Exmouth Gulf is one of the most productive marine environments in Australia – it is a precious natural asset that must be protected for future generations.

If anything went wrong with a project of this massive scale the effects would be irreversible and felt for generations to come – the risks are too great and it should not be allowed to occur.