New South Wales
Generally, we are supportive of the Kamay Ferry proposal that will facilitate improved access between La Perouse and Kurnell, better assist in creating a Connection to Country between the headlands and improve the arrival experience to visitors accessing the National Park.
However, we object to the potential use of the Wharf for commercial tourism operations that are unrelated to the above-mentioned primary objectives. The proposal in its current form does not place any limits on the number of, or type of commercial vessels that can access the wharves.
La Perouse is already over-populated with tourists during summer periods, with significant traffic congestion and limited parking. New commercial operations should be limited to activities that have a direct connection to Aboriginal Culture, the “Meeting Place” concept and British / French arrivals. Commercial operations for unrelated tourist activities such as whale watching, deep sea fishing, jet boat joy rides, recreational cruises, etc. should be operated from other parts of Botany Bay where there is better access and parking.
The following sections detail our objections relating to tourism-related commercial operations, the risk of water pollution at La Perouse and the Noise assessment related to wharf operations.
EIS Chapter 5 Project Description
The project description notes that the wharves can be used by commercial vessels, but no details are provided in relation to type of, or number of commercial activities that will be permitted, or how these will be regulated.
“Tourism-related commercial vessels” is non-descriptive and could cover a range of activities including jet boating (for joy rides), whale-watching, deep-sea fishing, recreational cruises, etc. It is not clear how the environmental impacts (including noise and water pollution) can be effectively managed if there are no procedures in place for managing the number of and type of commercial operations.
We recommend that the project approval includes a condition that limits the number and type of commercial and recreational vessels that can access the wharves. For commercial operations, we recommend an approval process that requires minimum environmental performance limits related to noise levels, environmental emissions, and regular maintenance of vessels to minimise the risk of water pollution.
EIS Chapter 24 Hazard and Risk
This chapter addresses the potential risk of fuel / oil leaks from Ferries and notes that there will be a plan (for Ferries) that would include measures such as regular inspections of machinery and equipment for fuel or hydraulic fluid leaks to prevent leakages.
However, the risk assessment does not consider the potential risk of fuel / oil leaks from other commercial / recreational vessels that will access the wharves and how this risk will be managed.
Frenchman’s Bay Beach is frequented by many families with young children that are attracted to the calm waters that are mostly free from waves. The proximity of populated beach areas is very close to the wharf, and we are concerned about the risk of water pollution associated with non-regulated commercial / recreational vessels.
For commercial operations, we recommend an approval process that requires minimum environmental performance limits and regular maintenance of vessels to minimise the risk of water pollution. For recreational vessels, we recommend this installation of signage to encourage boat owners to regularly inspect and maintain their vessels to minimise the risk of water pollution.
Appendix O Surface Noise and Vibration Impact Assessment Report
Section 5.1.1 Ferry operations
• Table 41: The assumed sound power noise levels for recreational vessels (accelerating) are 14dB lower than assumed for the Ferry. This approach is not considered conservative, given that a range of difference commercial / recreational vessels could be allowed to use the wharf. A more conservative approach would be to assume that the noise levels associated non-Ferry vessels are equivalent to Ferries.
• Note 2 of Table 41 says that recreational vehicle loading noise levels are assumed to be 5dB lower than when accelerating. Either the stated sound power level of 98 dB is incorrect or Note 2 is incorrect as the idle noise level is 14 dB higher than the accelerating level.
• The assumed operating time of recreational vessels (7 minutes) is not conservative as the multi-user berth can cater for many vessels between 2 m and 20 m long per Chapter 5 of EIS. Other commercial vessels could include passenger noise, PA systems, horns, etc., but these are not included in the noise modelling assumptions.
• Figure 16 – The location of the eastern vessel berthing area is not consistent with the location described in the EIS (e.g., Figure 5-4 and Figure 5-6 of EIS).
Section 5.2 Ferry operations assessment
• At La Perouse, one public ferry and two recreational vessels are assumed to be berthing and departing in a worst-case situation (full capacity) 15-minute interval. As previously noted, the multi-user wharf can likely accommodate more than two recreational / commercial vessels in any given 15-minute interval.
• Table 44: The noise prediction result for PRC1 -Frenchmans Beach is 52 dB under enhanced weather conditions compared with the project noise trigger level of 48 dB, exceeding by 4 dB. It is not clear why this receiver is not shaded orange and identified as an exceedance in the table or following discussion.
Conclusion of noise assessment
• Some of the noise modelling inputs related to the number of commercial / recreational vessels accessing the wharf are not conservative, including the assumed source noise levels and number of vessels in the worst-case situation. More conservative assumptions will result in higher noise predictions.
• The noise model should include the correct location of commercial / recreational vessels.
• Discussion should be provided in relation to the potential impacts of the 4 dB exceedance at receiver PRC1 -Frenchmans Beach, noting that noise levels will be higher still with more conservative noise modelling assumptions.
• The report recommends “that a confirmation of our assessment be undertaken once a ferry operator has been appointed and details of the ferry sound power levels are made available”. We support this comment and recommend that this be included as an approval condition if the Project is approved.