Our concerns include:
- The level of environmental assessment chosen for the scuttling of the Ex–HMAS Adelaide; and
- Possible gaps in the environmental assessment ie. sand movement.
A Review of Environmental Factors (REF) was chosen in place of an Environmental Impact Statement (EIS). The difference between the two assessment processes is not necessarily in the content, but rather the legal requirements to obtain and address community concerns. For example, following publication of an EIS, it would go on display for 30 days. The public would have an opportunity to review the EIS and comment. The determining authority would then be legally required to address these comments and concerns.
An REF on the other hand, does not provide this platform for public comment. 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.
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.
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.
Once this ship is on the bottom, its there for good and there is no turning back, so lets get it right.