Smith Bay Wharf Environmental Impact Statement Response
Prepared by the Australian Ocean Lab
Copyright © The Australian Ocean Laboratory Limited (AusOcean) 2019. The information contained herein is licensed under a Creative Commons Attribution 3.0 Australia License (http://creativecommons.org/licences/by/3.0/au).
The information contained in this document has been prepared in response to Kangaroo Island Plantation Timbers Limited (KIPT) Smith Bay Wharf Draft Environmental Impact Statement assessment document. The latter is copyright Kangaroo Island Plantation Timbers Limited. Excerpts from the latter are included here under the Fair Dealing provisions of the Copyright Act 1968.
Photo: Smith Bay, facing east (source: Alan Noble).
AusOcean would like to acknowledge all of its amazing employees, volunteers and partners who made this report possible. In alphabetical order:
William Goh, University of Adelaide
Dr David Muirhead, Marine Life Society of South Australia
Dr Graham Short, California Academy of Sciences
Catherine Larkin, who was the author of AusOcean’s Smith Bay Marine Ecology Report (Larkin 2019), deserves a special mention.
We would like to acknowledge the contribution by Dr John Luick of Austides Consulting who graciously contributed the analysis on waves and currents.
Table of Contents
This document is in response to the Kangaroo Island Plantation and Timber (KIPT) Smith Bay Wharf Draft Environmental Impact Statement, dated January (2019) herein referred to as “the EIS”.
This document seeks to remedy inaccurate and/or misleading statements presented in the EIS, through a scientific and evidence-based assessment of the impact of the proposed development, based both on first-hand observations and the best-available science.
This document was prepared by the Australian Ocean Lab (AusOcean). AusOcean is a South Australian-based non-profit organisation and registered on the Commonwealth’s Register of Environmental Organisations (REO). AusOcean receives no public funding. AusOcean’s ABN is 34617043722.
Smith Bay is an open bay on the North Coast of Kangaroo Island approximately 4 km wide. Less than 5 km to the east is Dashwood Bay and a similar distance to the west is Emu Bay. The former is a location frequented by dolphins and the latter one is of the Island’s most popular beach holiday destinations. Smith Bay is increasingly recognised as a location of significance for whales, including the threatened southern right whale.
In this document we describe how the proposed development would undeniably damage the marine environment of Smith Bay. Adjoining marine areas would also be damaged due to the movement of sediments resulting from dredging and increasing levels of turbidity. Based on modeling by Austides Consulting, the tidal currents would transport sediments back and forth along the coast over a 7.2 km total range, twice a day, throughout the spring portion of the tide cycle. Furthermore, the subtidal currents during winter could carry sediments an additional 4.3 km eastward, reaching all of Dashwood Bay. This movement of sediments is unimpeded by any significant geographical barriers due to the open aspect of Smith Bay.
Suspended sediments in response to dredging and ongoing port use have a very high probability in driving the loss of diversity in Smith Bay. Less productive habitats monopolised by turf-forming algae are likely to replace the highly productive and diverse macroalgae and sponge habitat. Maintaining the connectivity of shallow water habitats is vital for healthy fish communities. Seagrass meadows within Smith Bay play a pivotal role in shaping fish assemblages and diversity in the wider marine environment. Destruction of this system will result in habitat fragmentation impacting the interconnectivity of shallow water areas that comprise the wider “seascape nursery”. Habitat loss and degradation are potentially the greatest conservation concerns for Australian coastal species, including species from the protected Syngnathidae family.
It should be noted that sediments are stirred up both as a result of the port construction, i.e., during “capital dredging”, and ongoing port usage. The EIS states that the dredging required to create the proposed berthing pocket area would completely clear approximately 10 ha of seafloor. Furthermore, every time a vessel berths, exposed sediments would be re-disturbed and, due to the aforementioned tidal flows, spread over an area orders of magnitude larger than the berthing area. Ongoing vessel traffic will continue to disturb the dredged area of seafloor, resulting in persistent large-scale sediment movements. The EIS report measures a range of sediment characteristics which falls short of understanding the full effects as they may move across the different zones.
Our surveys suggest that much like the rest of Kangaroo Island, Smith Bay is an area of high biodiversity and home to many species of conservation significance. Any development at Smith Bay must be considered within the broader context of an interconnected marine environment. At the present time, the marine environment of Smith Bay and indeed the entire North Coast of Kangaroo Island, can only be characterized as pristine. If a port were to be built at Smith Bay it would irrevocably damage this environment. All of this considered, we suggest that Smith Bay is the wrong place for a port.
We would like to raise direct concerns with the following statements contained within the EIS.
AusOcean conducted three week-long expeditions to Smith bay documenting both fish and invertebrate assemblages at 10 different locations (Larkin 2019). We surveyed 91 species, comprising several species of conservation concern as described by the Conservation council, reef watch feral or imperil program (Reef watch 2019) and species protected under the Australian Commonwealth Environmental Protection and Biodiversity Conservation (EPBC) Act (1999) (Table 1).
Table 1: Species of conservation and commercial value known to frequent KI waters.
Western blue groper *
Southern rock lobster *
Southern blue devil *
Greenlip abalone *
Harlequin fish *
Long-snout boarfish *
Weedy seadragon *
Species from the Syngnathidae family (pipefish, seahorses) *
Giant Australian cuttlefish *
*denotes species surveyed in Smith Bay either by AusOcean or SEA Pty Ltd. as per KIPT’s marine ecological assessment.
Species of conservation significance surveyed in AusOcean’s marine ecology surveys appear in earlier documents pertaining to fish and invertebrate biodiversity assessments along the north coast of KI. Surveys noted 8 species of conservation significance over 7 locations (McArdle et al. 2015) and 9 species of conservation significance over 10 locations (Reinhold et al. 2013). As stated in the EIS, the rocky reef habitat along the north coast supports invertebrate communities that are generally diverse and extensive relative to those in other parts of the state. This statement is consistent with our survey findings. AusOcean’s marine ecology survey suggests that much like the rest of Kangaroo Island, Smith Bay is an area of high biodiversity and home to many species of conservation significance. These species are likely be impacted both during construction and ongoing port use.
AusOcean surveys discovered rocky reef shelves from 14-16m depth that supported an abundance of fish including the Southern blue devil and several species from the Syngnathidae family comprising Weedy sea dragons and three species of pipefish. Although the environment is somewhat fragmented, these unique pockets of varied topography are integral components of the wider marine environment and provide important refuges for fishes.
Three species of protected pipefish and a number of weedy dragons were observed in AusOcean’s marine ecology surveys of Smith Bay. An additional species of pipefish (Stipecampus cristatus) was noted in SEA Pty Ltd ecological survey (Table. 2).
The family Syngnathidae is protected under State and Commonwealth legislation (listed as threatened) by the Environmental Protection and Biodiversity Conservation (EPBC) Act (1999) and their export strictly controlled. Both leafy and weedy seadragons have been previously classified as Near Threatened in the International Union for Conservation of Nature (IUCN) Threatened Species Red List, with habitat loss partly contributing to the status (Browne et al. 2008). Syngnathid endemicity is high in Australia with 25% of syngnathid genera and 20% of species known only from Australian waters (Kuiter, 2000; Pogonoski et al. 2002).
Table 2: Species of Syngnathidae surveyed in Smith Bay (all photographs taken in Smith Bay).
Wide bodied pipefish
Mother of pearl pipefish
Ringed back pipefish
Source: SEA Pty Ltd.
Weedy sea dragon
As outlined in the EIS, the density of pipefish in seagrass meadows on the north coast of KI was found to be approximately one per 20 square metres (Kinloch 2009). Assuming the same densities in Smith Bay, the direct loss of seagrass due to dredging would result in substantial losses of critical syngnathid habitat. Distributions of syngnathids vary considerably. Some syngnathids are abundant in their preferred habitat type, but can occur sparsely in other habitats and in some cases species are restricted to specialised habitats (Browne et al. 2019). These differences make it challenging to predict the likely impacts on population numbers. Although only five species were noted throughout surveys it is likely that diversity is much higher.
The life history traits of syngnathids make them particularly susceptible to decline (Foster & Vincent 2004; Martin-Smith & Vincent 2006). Studies have shown that most individuals in common with leafy seadragons, have limited home range sizes of <1 ha (Sanchez-Camara & Booth 2004). Species with juveniles that have limited dispersal are vulnerable to local extinction, especially if their habitats are fragmented (Fagan et al. 2002; Foster & Vincent 2004; Cushman 2006). Furthermore, some species of pipefish are particularly susceptible to habitat modification due to increased water temperature, silt and pollutants (Borum 2003; Foster & Vincent 2004). It has been suggested that habitat loss and degradation are potentially the greatest conservation concerns for Australian coastal species, including syngnathids (Australian State of the Environment Committee 2001).
Indirect effects due to sedimentation and increasing levels of turbidity have the potential to negatively impact syngnathids. Research has demonstrated the effects of turbidity on sexual selection in several species of pipefish (Sundin et al. 2010; Sundin et al. 2016). This evidence suggests that mate choice is environmentally dependent and that increasing levels of turbidity may affect processes of sexual selection through an impaired possibility for visually based mate choice. Therefore, ongoing environmental perturbations such as increasing levels of turbidity may have detrimental consequences.
Due to their limited mobility and small home range sizes, loss of critical habitat due to dredging is likely to result in the loss of substantial numbers of syngnathids. In the event that individuals can move away from the construction zone, environmental perturbations such as increasing levels of turbidity may have ongoing negative consequences.
The effects of sedimentation in temperate rocky reef systems has been well documented (Airoldi and Virgilio 1998; Gorgula and Connell 2004; Balata et al. 2007; Connell et al. 2008). The devastating effects of human induced disturbances (i.e. sedimentation and eutrophication) in conjunction with natural disturbances has driven the widespread loss of kelp canopies along Adelaide’s metropolitan coastline (Connell et al. 2008). The expansion of turf-forming algae and excessive sedimentation are key drivers in this process. Research suggests the localities most vulnerable to these ecosystem shifts are those associated with conditions that enhance sediment deposition (e.g. dredging and intensive land use) or excessive sediment accumulation (Connell et al. 2008). Loss of macroalgae habitat can result in ecosystem shifts from complex and productive habitat to less productive, homogeneous systems dominated by turf-forming algae. These altered conditions can persist under high nutrient and sediment loads (Gorgula and Connell 2004). In some cases, these shifts may not be reversed over several generations of canopy-forming taxa (Benedetti-Cecchi et al. 2001; Eriksson et al. 2002).
Suspended sediments in response to dredging and ongoing port use have a high probability in driving the loss of diversity in Smith Bay. Less productive habitats monopolised by turf-forming algae are likely to replace the highly productive and diverse macroalgae habitat. The EIS report measures a range of sediment characteristics which falls short of understanding the full effects as they move across zones.
Figure 1: Canopy forming macroalgae forests (left) have been replaced with turf-forming algae dominated reefs (right) along the Adelaide metropolitan coastline (Connell et al. 2008).
Shallow water habitats contribute globally to fisheries productivity and maintenance of biodiversity (Ramos et al. 2015; Nordlund et al. 2018). These systems are vital for healthy coastal areas. Species that utilise multiple habitats (i.e. rocky reef and seagrass meadows) are heavily influenced by the connectivity and structure of the seascape as whole (Pittman et al. 2007; Staveley et al. 2017). It is important to consider habitat connectivity and its role in ecosystem functioning for many reasons. Fish connect habitats via larval dispersal, daily movements and exchanges of biomass and energy via ontogenetic migrations (Perry et al. 2018). Additionally, many coastal fish species utilise multiple habitats during different life stages (Gillanders et al. 2003). Research has demonstrated the importance of seagrass habitat as nursery areas with higher species richness and abundance of juveniles and subadults compared with larger adults (Gullström et al. 2008; Berkström et al. 2013). Furthermore, nursery species often prefer the clearer water and the complex habitat of seagrass meadows over turbid waters that occur in unvegetated sandy areas (Nagelkerken and van der Velde 2004).
As anthropogenic disturbances continue to fragment and in some cases destroy important coastal habitat understanding the importance of habitat connectivity is pivotal. “Seascape nursery” is a conceptual model that defines a mosaic of coastal habitats that are functionally connected (Nagelkerken et al. 2015). This concept implies that the existence of structure (regardless of type) is essential if shallow water habitats are to function as nursery grounds (Heck et al. 2003). Therefore, the combination of habitat structures (i.e. reef, sponge and seagrass meadows) and linkages between may be a key driver in improved species abundances observed in vegetated areas (Pittman et al. 2004; Gullström et al. 2008). The loss of marine structural habitats often results in reduced habitat functional connectivity. This is an area of concern, particularly for species with limited mobility which are expected to suffer more so than migratory species as a result of habitat fragmentation (Caldwell and Gergel 2013).
Maintaining the connectivity of shallow water habitats is important for healthy fish communities (Perry et al. 2018). Seagrass meadows within Smith Bay likely play a pivotal role in shaping fish assemblages and diversity in the wider marine environment. Destruction of this system will result in habitat fragmentation impacting the interconnectivity of shallow water areas that comprise the wider “seascape nursery”. Therefore, Smith Bay should be considered an integral component of a highly diverse and interconnected marine environment.
This chapter was prepared by Dr John Luick of Austides Consulting, Adelaide, in response to “Smith Bay EIS - Coastal Process Impact Assessment, Reference: R.822454.005.02.Coastal Process.docx, Date: December 2018”.
It represents his views in relation to Appendix G (Coastal Processes) of the KIPT EIS (“the BMT report”). It is in no way meant to be exhaustive.
Dr John Luick has no financial or other connection or interest in the KIPT Smith Bay development, for or against. The following are his own professional opinions.
I was unable to find in the BMT report the time period for which data was obtained. Most of the wave statistics that are presented (significant wave height, peak wave period, and return periods) are not relevant to the main questions I would have regarding potential impacts on enterprises located to the east of the dredging. For my questions, I would need to know the statistics for peak wave height, direction, wavenumber, and frequency, and I would want them separately for a summer and a winter period. These would enable computations of “Stokes Drift”, the phenomenon by which waves transport sediment (in this case sediment from the dredging process).
Figure 2.7 of the BMT report shows a scatterplot including data from mid-winter to early summer. As with the waves, it would have been useful to also have two plots (July/August for winter and one for the final month to represent summer). Also, the plots also do not seem to distinguish between tidal and residual (or “subtidal”) currents. The tidal currents sweep back and forth twice a day, like an “AC current”, whereas the subtidal currents (nontidal component) are like the DC part of an electrical current. The same also seems to apply to BMT’s Figures 2.8 and 2.9. This makes it difficult for me to make meaningful estimates of the alongshore drift, which is what I take to be the key issue.
The subtidal eastward currents in winter are correctly attributed by BMT to the effect of south-westerlies driving water in a series of storm surge-like events. These same events cause coastal currents to flow to the north along the Adelaide shoreline.
In the figures below, I show what the tidal and subtidal currents look like (see Figures 1 and 2). Note the different scales between the vertical axes of the two plots. The tidal current scale (Figure 1) runs between ± 30 cm/s, whereas the range on the subtidal currents (Figure 2) is ± 6 cm/s.
If the east-west tidal currents are integrated over a six-hour eastward (positive) flow period during “spring tides”, the result is the eastward distance tides can carry suspended particles. On 17 March, for example, this distance turns out to be over 3600 metres (3.6 km) over the six-hour period, prior to reversing.
The oscillating tidal currents are superimposed on the mean eastward flow (during winter) which is often more than 4.3 km/day.
Figure 1. Tidal currents (east-west component).
Figure 2: Subtidal currents (east-west components).
The preceding comments emphasise the importance of distinguishing between the season, as well as the tidal and subtidal currents when discussing the potential for transport of disturbed sediments. While the BMT report discusses the tides and mean currents, it does not explicitly present the difference in the key graphics.
The tidal currents will transport dredged-up materials back and forth along the coast over a 7.2 km total range, twice a day, throughout the spring portion of the tide cycle. On top of that, the subtidal currents during winter could carry it an additional 4.3 km. The prevailing Stokes Drift would push the material onshore and to the east.
My estimates are based on an operational hydrodynamic model of the two Gulf region, which was calibrated and validated inside and outside the Gulfs, but without Smith Bay data. However, as far as I can tell, my results agree with the very limited data and analysis in this report. On the basis of this BMT report alone, a full understanding of the littoral drift is not possible.
Due to not separating the two time and two frequency domains of variability, an important connotation is ignored, which is that the negative impact of the dredging could be minimised by dredging only during summer, and only during neap tidal periods. To make this argument, impact estimates for those periods and frequency bands would have to be separately calculated.
I would expect the dynamics of the littoral drift of sand and dissolved substances at Smith Bay to be similar to those observed over many years along the Adelaide metropolitan beaches. There, the alongshore drift is caused by the same sort of subtidal flow during winter, with tidal currents primarily acting as “turbulence” keeping suspended particulates from sinking, and the process reinforced by Stokes Drift due to the waves. The only difference will be that at Adelaide, drift is to the north (not east). Since the analogue is so similar and obvious, I would have expected the developer to be required to show how the dynamics would differ, if they are claiming that their activities will not negatively impact their neighbours. I was unable to find any substantive discussion or data in the BMT report comparing the Smith Bay to the well-known Adelaide dynamics.
Dr John L Luick, Austides Consulting
Principal, Austides Consulting, Adelaide
Adjunct Senior Lecturer, College of Science and Engineering, Flinders University
Visiting Scientist, South Australian Research and Development Institute, Adelaide
Expert Adviser, Tridel Engineering LLC (Dubai)
As noted, the construction of a causeway and the dredging of the berthing pocket and approaches would result in the direct loss of about 10 ha of mixed habitat (rocky reef, sponge and seagrass), comprising the seagrasses Posidonia sinuosa, Amphibolis antarctica and Amphibolis griffithii, and associated invertebrate and fish communities. This loss of mixed habitat would supposedly be offset by providing financial support to optimise fertiliser use in the Cygnet River catchment that in turn would encourage the recovery of seagrass.
Despite the wide range of functional roles performed by sponges they are often overlooked in monitoring and conservation programmes (Bell 2008). Important functional roles of sponges include; habitat provision, stabilisation of sediments, nutrient recycling and water filtration (Wulff 2001). Hence, sponges are considered important components of marine benthic communities throughout temperate habitats. The composition of mixed habitat (seagrass, sponges and rocky reef) should be taken into account when determining appropriate environmental offsets. As marine systems are unique, novel approaches to offsets are required (Bell 2016). Any exclusion of sponges from monitoring and conservation programs is concerning, particularly because they have the potential to exert a major influence on overall ecosystem functioning (Bell, 2008).
Deciding on the biodiversity value to be offset is a fundamental part of the offset process as it must be representative of the inherent value of the ecosystem (Bell 2014). Furthermore, the environmental offset program is intended to ensure “equivalence of conservation benefits”. Although we understand this type of offset is industry standard, the proposal doesn’t take into account the extensive loss of rocky reef habitat and sponges which are integral components of the wider marine environment. In conservation benefit terms, it is not clear that an equivalent acreage of seagrass can compensate for the loss of the latter. We suggest that restoration efforts should centre on improving water quality and restoring habitat and associated biodiversity where the damage has occurred, i.e. at Smith bay.
Discharged ballast water can result in the introduction of invasive species (marine pests) (Gollasch et al. 2018). The proposal suggests that conventional ballast water management practices are adequate to manage the risk of biosecurity hazards. However, to date, international shipping has resulted in the introduction of over 200 introduced marine species into Australian waters (Mcennulty et al. 2001).
In contrast, no introduced species were recorded in Smith Bay during either of the marine surveys conducted by SEA Pty Ltd. (Wiltshire & Brook 2018). The introduction of marine pests would therefore have a profoundly negative impact. Once marine pests established themselves on Kangaroo Island, their removal would be challenging.
Smith Bay and nearby Dashwood Bay are regularly frequented by whales and dolphins (Cribb et al. 2018), including southern right whales which are listed as endangered under the EPBC act.
The impact of anthropogenic noise on marine mammals is an area of increasing concern. Ocean noise pollution is of particular concern to cetaceans as they are highly dependent on sound as their principal sense (Weilgart 2007). Most noise in the ocean comes from commercial shipping which has been the main contributor to increases in ocean background noise over the past century (Parks et al. 2007). The long term impacts of increasing levels of noise are not well understood. However, recent studies on the Southern right whale (Eubalaena australis) show alterations in both short and long term behaviours as a result of increasing low frequency noise (Park et al. 2007).
Whales communicate from 30 Hz to about 8 kHz (Cranford et al. 2015) and dolphins from 20 Hz to about 150 kHz (Turl 1993). Commercial ships produce underwater noise with peak spectral power in the range 20 Hz to 200 Hz, extending at least to 100 kHz (Veirs et al. 2016), directly overlapping with frequencies essential to cetacean communication and navigation.
Construction and ongoing ship activities would make Smith Bay and adjoining areas much noisier than they are today, adversely impacting these iconic and protected marine mammals. As sound travels efficiently underwater, potential areas of impacts can be thousand of square kilometres or more (Weilgart 2007).
The proposed development includes wood chip storage areas on land adjacent to the shoreline. It is not clear how the proponent intends to prevent strong southerly winds from blowing wood chips into the bay. Tannins leach out of wood, forming so-called “leachates” (Tao et al. 2005). These react to form water-soluble substances, such as gallic acid and protocatechuic acid (Svensson et al. 2012). Ocean acidification, albeit caused by CO2 absorption, is known to be highly detrimental to marine life (Dupont et al. 2009). Acidification caused by leachates is therefore likely have a similar detrimental effect.
Although the primary purpose of this document has been to address the environmental impact of the proposed port, we would also like to comment on the following claims made by the proponent.
The proponent claims that Smith Bay is the “closest practicable sheltered north coast site” and “has deep water relatively close to the shore”. In reality, Smith Bay is neither sheltered year round nor is deep water located particularly close to shore.
In order to achieve sufficiently deep water (after significant dredging) the vessel berthing pocket would be ~500m offshore. Technically, the proposed berthing area would not lie within the confines of the bay. Such a location would therefore be highly exposed to Kangaroo Island’s violent winter storms, in particular, gales from the northwest. Mount Marsden, only 14 km away, is one of the windiest locations in South Australia, and Kingscote is the state’s third windiest town (BoM 2018).
The EIS does not mention the environmental impact of vessels or berth infrastructure potentially damaged or run aground by storms.
The proposal conflates not proceeding with the proposed port development as the “do nothing option” [sic]. There are other uses for the timber that do not require construction of a port, notably the use of the timber biomass for energy production. Energy production can take the form of either power generated by combustion and fed into the grid, or biofuel production, such as biodiesel, through hydrothermal liquefaction (Elliott et al. 2015). Biofuels that are produced in such a way are carbon neutral, i.e., there are no net carbon emissions produced when the biofuel is consumed. In particular, Tasmanian blue gum (Eucalyptus globulus) which comprises the bulk of KIPT’s plantings, is already considered to be fuel wood, and deemed a fire hazard for this reason.
In 2018 Kangaroo Island Council commissioned a report (EEA 2018), which detailed how timber biomass could be used for power and fuel, enabling the Island to achieve energy security in a manner consistent with its clean, green brand.
We therefore suggest that alternative business models for utilising the Island’s timber resources should be considered. Over time, cleared timber forests could be returned to their former state, e.g., farm land or native vegetation, without degrading Kangaroo Island’s natural environment.
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 By way of comparison, $5M has been spent to date to restore 20 ha of shellfish reef at Windara Reef (The Nature Conservancy 2019, personal communication, 25 May).
 Mariners also deem Smith Bay to be an unsuitable anchorage. Of the several dozen Kangaroo Island anchorages listed in “Anchoring and Anchorages in South Australia” by James Cowell, Smith Bay is not mentioned.