Yannarie Solar Salt Environmental Review & Management Programme

Mr Wally Cox
The Chairman
Environmental Protection Authority
PO Box K822
PERTH WA 6842

Dear Mr Cox

Thank you for the opportunity to provide comment on the above document. Recfishwest is the peak body representing the interests of the estimated 788,000 (pg. 106, Department of Fisheries, Annual Report to Parliament 2005/06) recreational fishers in Western Australia. We are formally recognised by the Government in this role. Recfishwest places the highest priority on safeguarding the future of recreational fishing and the resource it depends on in Western Australia.

Exmouth Gulf is world renowned for its fantastic fishing with its fish rich shallow water, mangrove lined creek systems and numerous shoals and scatted reefs. The Eastern side of the Exmouth Gulf is one of the few remaining remote and pristine locations, attracting dedicated sports fishers because of its wilderness appeal.

The area is attractive to sportfishers due to the difficulty of access for various reasons including the long distance from roads and launching facilities. Access is limited by weather as it is exposed to frequent strong southerly winds.

The diversity of the Exmouth Gulf provides unique opportunities for recreational fishers. Within the Gulf there are many islands, shallow flats and reef that hold an array of different species and fishing opportunities. On the eastern side of the gulf are an abundance of pristine mangrove creeks that hold prized recreational sportfish such as barramundi, mangrove jack, giant herring and queenfish. The intertidal systems of the Gulf contain numerous important recreationally targeted species including trevally species, flathead, whiting and mud crabs. The deeper waters of the Gulf harbour prized demersal species such as coral trout, red emperor, blue-bone, north-west snapper as well as multiple species of rock lobsters. All of these species depend to some degree on juvenile recruitment from the eastern gulf.

The pelagic sports fishing opportunities of the Gulf are world renowned. Sailfish are plentiful in late spring as they feed on the tonnes of baitfish that congregate in the Gulf. Juvenile marlins have also been regularly encountered right up in the shallows.

The wilderness nature of Exmouth Gulf is appealing to the recreational anglers that fish the area and the eastern Exmouth gulf has been identified as a potential wilderness fishing area, to preserve that unique experience.

Summary of Major Concerns

Recfishwest comments are restricted to potential impacts of the proposal on issues affecting recreational fishing. Recfishwest has identified the following points as potential threats to recreational fishing in the Exmouth Gulf region;

• Impacts on recreational fish species from the modification / loss of nursery areas;
• Impacts on recreational fish species from water intake pumps particularly the entrapment of larval and juvenile finfish and crustaceans;
• Impacts on recreational fish species from potential future disposal of bitterns and/or the accidental release of bitterns through storm/cyclonic events;
• Impacts upon fish and the food webs that they depend upon from changes in marine and sediment quality;
• Impact on wilderness fishing experience following the development of this proposal.

Other concerns that Recfishwest have with the proposal are:

• Introduced marine pests and diseases from increased shipping activities due to the development;
• Impacts from barge harbour dredging / acid sulphate soils.
• Impacts from alteration of surface water flows in terms of loss of productivity of ecosystem and fisheries related by diversion of fresh-water runoff containing nutrients in heavy rainfall events;

Responses to Relevant ERMP Sections

Impacts on recreational fish species from the modification / loss of nursery areas

Exmouth Gulf forms an important nursery area for valuable commercial and recreational fish species. We believe that the Yannarie mangrove system on the eastern side of Exmouth Gulf is a vital nursery area for many forms of marine life including finfish and crustaceans. Many species using this area as a nursery are highly valued by recreational fishers. There are very few areas of mangrove systems and large changes to or the loss of an entire system could have ecosystem scale impacts.

Recreational fisheries are highly dependent on the maintenance of high water quality and the natural ecological processes which drive marine productivity. We believe that the Yannarie Salt Project proposal poses a significant threat to this unique area. We are concerned that the construction of the solar salt proposal could potentially see a reduction in finfish and crustacean recruitment through habitat structure changes and changes to foodwebs to a much wider area to which adults would take up residence. We are also concerned by the enormous numbers of larvae and juveniles will also be directly removed from the nursery habitat through the water intake pumps.

Impact on wilderness fishing experience following the development of this proposal

Recfishwest questions the mitigation measure of allowing recreational fishing access to the first concentrator ponds as a compromise for the potential destruction of fish nursery habitat as a result of the proposed salt production facility.

We believe that the promotion of access to the first concentration pond as incentive for recreational fishers support should be viewed with scepticism. Existing solar salt projects in Western Australia have gone down that path and at this time all prohibit access for recreational fishers within their mining lease citing occupational health and safety requirements.


Impacts on recreational fish species from potential future disposal of bitterns and/or the accidental release of bitterns through storm/cyclonic events

The impounding of large quantities of toxic bitterns presents an unacceptable risk to this sensitive environment. Straits Resources have made no assurances in the ERMP that the bitterns resource recovery strategy will be adopted, rather stating that a feasibility study will be carried out.

It is stated that a final assessment of the technical and economic options for resource recovery from the bitterns will be completed within ten years of the commissioning of Stage 1. We believe bitterns discharge should have been assessed in the current ERMP. Waiting until the project is fully operational before applying to discharge bitterns is unacceptable. Any release of bitterns into Exmouth Gulf could be catastrophic for the marine environment particularly in terms of the quantity that will be potentially will be stored by this proposal.

The impoundment of bitterns is not without risk. Potential seepage or wall failure as result of extreme weather events such as cyclones and storms are realistic threats to the proposed solar salt mine. The escape of toxic bitterns into Exmouth Gulf could potentially kill vast numbers of marine creatures and have a catastrophic impact on food webs.

We believe that the ERMP does not adequately address contingency measures for storing bitterns in the event of natural disasters such as cyclones.

Impacts upon recreational fishing from changes in marine and sediment quality

The eastern shoreline of Exmouth Gulf is one of the largest embayments on the Western Australian coast and its extensive sand flats, seagrass meadows and mangrove lined tidal creeks function as highly productive nursery areas. These habitats function as important nursery grounds for finfish and crustaceans important to recreational and commercial fisheries. The pumping of large quantities of sea water is likely to modify salinity and/or flow in the Gulf, which could have significant consequences for primary productivity and hence recruitment of finfish and crustaceans important to the recreational fishing sector.

Introduced marine pests and diseases from increased shipping activities due to the development

It is estimated that at peak production 150 bulk carriers will visit the Gulf each year to export salt. The impact of dredging and intake channels to facilitate these large ships could give rise to increased turbidity resulting in shading or smothering of benthic primary producers thereby affecting water quality. Dredging may lead to the destruction of natural habitat.

International shipping also opens up the threat of translocation of exotic marine pests from high-risk regions. An outbreak of a marine pest species has the potential to cripple many commercial and recreational fisheries in the region.

The increase in large ship traffic also posses a safety threat in terms of visibility of the small recreational fishing craft (invariably four to five metres in length) that frequently use the Gulf.

Conclusion

Recfishwest believes the risks posed by the proposed salt mine are too large considering the environmental and financial values of the area. The importance of Exmouth Gulf as a nursery habitat for many valued recreational finfish and crustacean species should not be compromised by the development of a solar salt mine. We believe that the important environmental concerns such as the storage of bitterns and their potential discharge in the future are inadequately addressed in the ERMP.

Should you require any further information or clarification on issues raised, please do not hesitate to contact me at our office on 9246 3366.

Yours sincerely





Frank B Prokop
Executive Director

12 March 2007


CC Hon David Templeman MLA, Minister for the Environment
Hon Jon Ford, Minister for Fisheries
Peter Milligton, CEO, Department of Fisheries
Doug Bathgate, Chair, Exmouth RRFAC


 





This page last updated on 13 March 2007.