What you may not have known about the EPA Report on the Ocean Reef Marina development

It is interesting, although rather brain numbing, to read through the EPA report that ultimately approved the building of the Ocean Reef marina precinct. In light of that, we have taken out a few of the ‘stand out’ admissions from this report, that outline the environmental damage this marina will create. The EPA must do due diligence when assessing a proposal, however they do not have the final say, and their role is to highlight issues and approve suggestions to mitigate these issues.  They are not required to solve these issues, and clearly, when reading this report, there is no suggestion anywhere that this proposal will not impact severely on the environment. The suggestions are merely to lessen the impacts and as you will read below, and they are not at all sure that what they are suggesting will work.

What we have attempted to do is highlight statements made by the EPA about the problems associated with building this Marina.

First the design brief used in this assessment was the 2015 plan, rather than 2018 plan, even though this report was issued in 2019. 

The new plan is quite different. However, it must be noted that the EPA chose not to assess the Bush Forever site. The EPA did not deem an environmental report on the terrestrial component (including the Bush Forever site) was necessary and therefore did not assess. Highly unusual in itself when there is a Bush Forever site involved.

Essentially the coastal dune system has not been assessed by the Environmental Protection Authority. 

Straight off the bat they outline the potential impacts and acknowledge that the proponents (Development WA) can only provide a best estimate. A best estimate? This was cause for a pause when reading.

In making the recommendations EPA Chair Dr Tom Hatton said the proposal represented challenges for the local marine environment, “specifically the loss of sensitive reef habitat. that support diverse marine life and abalone,” 

 That statement alone should have halted this development.

The report then outlines the key Environmental factors’

Marine Environmental Quality – impacts to water quality due to increased turbidity and the release of nutrients and contaminants in sediments;

  •  Benthic Communities and Habitat – direct and indirect impacts due to permanent loss of communities and habitat and altered sediment and water movement and flows;
  •  Coastal Processes – construction and operation of the marina may cause alteration of wave dynamics and sediment transport and may trap algae and seagrass wrack; and 
  • Social Surroundings – impacts to the abalone fishery (commercial and recreational) associated with direct and indirect impacts to abalone.

Significant Impacts to marine environmental quality 

This statement is repeated in varying forms throughout the assessment. They are not sugar coating it, they are clearly stating there will be significant environmental impacts as this marina is both constructed and operated.

So, they set about assessing the during construction and operational phases. We have not included the many issues during construction, although needless to say this process will be an ongoing problem for both nearby residents and beach goers for many years. We have included the link to the report for those who would like to know what they will be facing during construction.  

However here are some statements about the long-term effects once the Marina is up and running.

Operational Phase After completion, the proposal may have the following potential impacts:

  • reduced environmental quality within the marina from elevated nutrient levels and excessive algal growth, low dissolved oxygen levels and leaching of metals and antifoulants;
  • changes in the quality of adjacent marine waters caused by the outflow of marina water;
  • pollution from incidents (such as accidental spills and leakages) and increased boat usage; and
  • changes in water quality associated with maintenance dredging.

Maintenance dredging will be required periodically.

And here is the read between the lines moment.

The EPA acknowledges the proponent’s confidence in the modelling undertaken to predict long-term water quality in the marina, however, notes that model outputs can only provide a best estimate, often with limited confidence. The EPA is aware that other marinas along the Perth metropolitan coast with similar flushing levels have Ocean Reef Marina Environmental Protection Authority 17 recorded higher measured concentrations of phytoplankton than has been predicted for this proposal.

Clear as day. They are admitting that they have no real confidence in the modelling and from the other marinas they know it is woefully underplayed.

They then move onto what they do know about the current marina and its effect on the marine park.

This nearshore reef system is the dominant influence on nearshore coastal processes as it significantly affects the rate and magnitude of longshore transport, wave energy hitting the shoreline and ocean currents. In addition to the influence of the reef, the existing Ocean Reef Boat Harbour creates an impediment to the movement of waves, currents and sediment along the coastline. The proposal is for the upgrade and expansion of this.

So this is where  upgrade versus expansion comes in.  The existing marina has already impacted the marine ecosystem, and yet the plan is to extend that impact. And the loss of the dune system has not even been considered here. That impact is unknown.

Here is what is known

The existing Ocean Reef Boat Harbour creates an impediment to the movement of waves, currents, wrack and sediment along the coastline. The proposed breakwaters extend significantly further (than the existing breakwaters) into deeper water and across the active surf zone (wave breaking) where intensive sediment transport occurs. As a result, additional blockage/impact to sediment transport and wrack movement is expected.

And here is the uncertainty again. And here, hidden amongst this uncertainty, is the reference to the continued need to move sand North and South of the marina.

Although the proponent is confident in its predictions, the EPA notes that there is always a level of uncertainty in modelling sediment transport and wrack movement.

The EPA notes that the proponent estimates that 10,000m3 to 20,000m3 will be required to be moved to the north of the marina every five years. Sand bypassing would likely be completed by excavating accreted beach sand from the shoreline south of the proposal, loading into trucks and transporting the material to the northern shoreline. If this management is not possible, the proponent has committed to sourcing alternative sources to supplement the sediment deficit in the northern littoral system.

So, we hope like us, you are feeling a little unwell at what is clearly indicated in this assessment. It gets worse. 

The proponent has predicted a 100% permanent loss of Benthic Communities and Habitat within the development envelope to allow for the construction of the marina waterbody and breakwaters.

It is important to note here the importance of Bethnic communities.

Benthic communities are largely composed of macroinvertebrates, such as annelids, mollusks, and crustaceans. These organisms inhabit the bottom substrates of estuaries and play a vital role in maintaining sediment and water quality.

The proponent has also predicted that changes in hydrodynamics and suspended sediment in the waters surrounding the marina during construction is likely to result in smothering of the underlying habitat. The proponent has predicted that this ‘halo effect’ may extend up to 70m beyond the marina breakwaters. The predicted total impact to all types of Benthic Communities and Habitat including within the development area is 45.9 ha .

Altered sediment and water movement caused by the breakwaters is expected to increase sedimentation rates in the waters surrounding the marina which is likely to result in further smothering of the underlying habitat. As a result, the EPA considers it unlikely that the Benthic Communities and Habitat within the 70m halo, lost as a result of construction impacts described above, will recover. The EPA considers it appropriate, therefore, that the development envelope, which includes the indicative proposal footprint and a 70m halo, is determined to be a Zone of High Impact within which there will be irreversible loss of Benthic Communities and Habitat.

At this stage it is hard to read on and there is certainly no suggestion that these reefs and abalone can be moved or replaced. If this was a viable option, it would have been suggested here. The only suggestions are continued monitoring and monetary compensation.

We expected to see that if the worse case scenarios were observed ( although we’re not sure what they might be monitoring in regards the  reef ecosystem since it will be gone) that construction would halt but this is not an option entertained by the EPA.

And here it is again.

The EPA notes that the proponent has predicted 100% loss (approximately 46 ha) of Benthic Communities and Habitat within the development envelope which includes a 70m ‘halo-effect’ zone (development envelope) surrounding the proposed marina caused by increased sedimentation associated with construction activities and hydrodynamic changes. The EPA also notes that due to the altered sediment and water movement caused by the breakwaters this loss is expected to be irreversible.

So, with all these effects, what is the plan suggested by the proponents and accepted by  the EPA ?

Fund research, monitor the destruction and put money in education? 

The proponent has proposed an Offset Strategy, which broadly consists of the following: 

1) funding for research and investigations into threats and pressures; 

2) monitoring of habitats and water quality; and 3) support for an education and interpretation program.

We hope to have the stomach to read the Bush Forever and loss of a coastal dune system report that was not even environmentally  assessed by our state environmental body and bring that to you soon.