Reading the comprehensive material that’s appearing on the No Ship At Avoca website, I’ve been interested to learn of the technical problems inherent in the environmental review process that has been used to assess the environmental implications of exHMAS Adelaide’s planned scuttling, a mere 1.7 km off Avoca Beach. The website makes it clear that the environmental assessment process was most limited.
I’m amazed that no Environmental Impact Statement (EIS) has been prepared. All that’s been undertaken is a Review of Environmental Factors (REF).
The preparation of an EIS is a far more thorough process and one that inherently values and elicits a public response. When completed an EIS must be put on public display for a period of at least 30 days so that all interested parties may comment.
An EIS must also meet the following requirements, it must:
- give a detailed analysis of all potential areas of concern in relation a development;
- be written in accessible language that’s easy to understand; and,
- contain material that alerts lay people and specialists to the problems inherent in carrying out an activity.
An REF on the other hand, provides no platform for public comment. It’s a far more limited instrument and I’m very suspicious about why it’s been used in this case.
The No Ship At Avoca website explains that
The REF for the scuttling of the Ex–HMAS Adelaide was posted on their website only 2 weeks ago. Prior to it being posted, we were denied access to this report and we were told by the state government that without compromise, the vessel would get scuttled on 27th March, 2010 regardless of what any of us had to say.
The website they’re referring to is the HMAS Adelaide website. The No Ship At Avoca website goes on the explain some of the developments leading up to this now critical situation.
Many people have said to us “why have you left it so late to complain”. Even if we were investigating this last year when forums were being conducted, the REF was not available to comment on. It is very difficult to raise concerns about the level of environmental assessment, if the assessments themselves have either not been conducted or are unavailable for review. So technically, this is the first opportunity that we have had to raise concerns regarding the potential impacts of the proposal.
What caught my attention, in all of this was not only the failure of consultation, the closed nature of the REF process and the static out dated tools that have been used to assess the REF. There doesn’t appear to have been sufficient dynamic modeling of impacts and as the following excerpt from the No Ship At Avoca website makes perfectly clear, the assumption about sand movement simply don’t seem to be informed by contemporary science.
We are concerned that the REF may not have covered the issue of sand movement sufficiently. Recent research out of Macquarie University has demonstrated that sand movement occurs down to 40 metres, however the Coastal Processes Report prepared for the REF is based on an old belief that sand movement does not occur below 30 metres. As such, the REF may not have adequately considered the impact of the ship on beach replenishment. Councils are already faced with the issues and costs of beach re–nourishment and as sea level rise continues to occur, this is only going to get worse. We need to be certain that placing 138 metres of ship on a unique sand deposit off Avoca Beach, is not going to trap or redirect sediment, thereby preventing the natural sand movements between the beach and the lower shoreface.
Now is the only time the community at large has to stop this coastal vandalism. I, for one, will be at the meeting on Saturday.