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.