7.

0 Construction impact assessment

7.0 Construction

impact assessment

Synthesis of environmental effects

Volume 1

Environmental effects of Marine Structures

Volume 2

Environmental effects of Desalination Plant

Volume 3

Environmental effects of Transfer Pipeline

Volume 4

Environmental effects of Power Supply

Volume 5

Technical Appendix

Construction impact assessment

Chapter 7

Construction impact assessment

This chapter discusses the Projects potential environmental effects on the marine environment that may occur during construction. The environmental impact assessment for construction is based on specialist findings from the following reports: Bassett (2008) Underwater Noise (Technical Appendix 22) Biosis Research (20082) Assessment of Marine Mammals, Birds, and

Reptiles for the Desalination Project, Bass Coast, Victoria (Technical

Appendix 13) Biosis Research (20087) Cultural Heritage Existing Conditions and Impact

Assessment Report Plant site (Technical Appendix 45)

Consulting Environmental Engineers (CEE) (2008) The Desalination Project

Marine Biology (Technical Appendix 31)

Essential Economics (20082) Victorian Desalination Project Impact

Assessment (Technical Appendix 11)

GHD (20084) Invasive Marine Species (Technical Appendix 27) Maunsell Australia (Maunsell) (20085) Victorian Desalination Project

Environment Effects Statement-Social Impact Assessment Report (Technical

Appendix 56).

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Marine construction activities for the Reference Project, as detailed in Chapter 2 of this Volume, would build the Marine Structures by tunnelling under the dunes, beach and seafloor and would install the intake and outlet structures. Self-elevating platforms (SEPs) would conduct marine drilling. These temporary structures may be serviced (with materials and people) from land by marine vessels and helicopters.

7.1

Impact assessment

This section discusses the potential impacts of construction activities of the Marine Structures on the marine environment. Both the risk assessment and the impact assessment recognise that, like the Reference Project, the Project must comply with the Performance Requirements set out in Chapter 11 of Volume 1.

7.1.1

Risks assessed medium or above

The risk assessment was conducted for the Variations as well as the Reference Project and impacts on the marine environment are applicable to these Variations. Construction risks and potential impacts for the Variations multiple smaller conduits, passive screens at the intake head, pipeline diffuser and alternate locations for the Marine Structures (low profile reef or sand in deeper water) are considered to be similar to the Reference Project and are discussed below where applicable. Table 7-1 sets out the risks associated with construction of the Marine Structures which were rated medium or above. The risks are discussed in order of activity and likelihood with those most likely to occur discussed first.

Table 7-1 Construction risks assessed as medium or above

Consequence

Activity

Impact pathway

Likelihood

Seabed clearing

Removal or damage of reef habitat Removal or damage of sandy habitat Destruction of or disturbance to significant reef species

Moderate Minor Moderate

Certain Likely Likely

High Medium Medium

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Risk

Table 7-1 Construction risks assessed as medium or above

Consequence

Activity

Impact pathway

Likelihood

Generation of noise and vibration

Impact pile driving impacting on fish Use of air guns impacting on fish Use of air guns impacting on smaller toothed cetaceans, mammals and sea birds Geophysical surveys other than air guns impacting on fish

Moderate Moderate Minor

Likely Likely Likely

Medium Medium Medium

Minor Minor

Likely Almost certain

Medium Medium

Use of chemicals and hydrocarbons

Small chemical/hydrocarbon spill or incident impacting on marine biota and ecosystems Medium or significant chemical/hydrocarbon spill or incident impacting on water column, intertidal marine biota and marine ecosystems Medium or significant chemical / hydrocarbon spill or incident impacting on the marine park

Moderate

Unlikely

Medium

Major

Rare

Medium

Production of drilling spoil

Release of spoil at the drill site impacting on reef biota and ecosystems Disposal of spoil at a selected oceanic location impacting on marine biota and ecosystems

Minor

Likely

Medium

Minor

Likely

Medium

Movement of marine vessels

Increase in marine traffic impacting on fishing and recreational activities Introduction of flora and fauna marine pests from marine vessels impacting on marine species Increase in marine traffic impacting on public safety

Minor

Almost Certain

Medium

Major

Unlikely

Medium

Major Extreme

Rare Unlikely

Medium High

Use of construction divers

Introduction of abalone disease impacting on commercial viability of abalone diving industry in the Project area Introduction of abalone disease impacting on abalone communities

Major

Unlikely

Medium

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Risk 7-3

Table 7-1 Construction risks assessed as medium or above

Consequence

Activity

Impact pathway

Likelihood

All construction activities

Social impacts of construction of Marine Structures impacts on amenity Potential for reduced visitation and loss of business revenue due to perception that the Wonthaggi / Kilcunda coastline is becoming industrialised

Minor

Certain

Medium

Moderate

Almost certain

High

Construction exclusion zone Increased access to Williamsons Beach

Impacts on commercial fishing

Minor

Likely

Medium

People accessing Williamsons Beach impacting on threatened fauna

Moderate

Unlikely

Medium

The above risk assessment is based on accepted construction practices but does not take into account the mitigation measures embodied in the Performance Requirements. If the Performance Requirements are taken into account, both the likelihood and consequence of these risks may be significantly lower.

7.2

Seabed clearing

Some clearing of the seabed would occur to create a level platform for placement of equipment including SEP legs, anchors and cables that would be used to position and anchor the SEPs. This would likely disturb some biological habitats and affect the associated biological communities, although disturbance would likely be localised to around the SEPs. Benthic communities are most likely to be affected by seabed clearing. There may be localised damage to the seabed and the plants and animals that inhabit the affected areas. Generally, marine mammals are expected to avoid disturbed areas due to noise and vibration from construction activities, so it is unlikely that clearing activities would affect these species. Seabed clearing for the multiple smaller conduits and the pipeline diffuser Variations is expected to encompass a similar area as the clearing required for the Reference Project. Clearing for alternate Marine Structure locations (also a Variation in the Reference Project) would also be similar to the Reference Project as these locations would not be within marine sensitivity areas.

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Risk

The consequence of these activities are not considered to be significant as SEPs and associated infrastructure would be removed from the marine environment upon completion of construction of the Marine Structures and it is expected that these communities would recover to their original state after construction activities are complete. Secondary effects due to clearing (such as dispersal of sand from the seabed) would also only occur for a short period of time. Disturbed areas in the marine environment tend to be rapidly colonised by a succession of marine biota, usually resulting in a marine biological assemblage similar to the community that existed prior to disturbance (CEE 2008, Technical Appendix 31).

7.3

Generation of noise and vibration

Many marine mammals rely on sound as their primary method of communication. Some species may even use echolocation to determine the physical features of their surroundings. These animals communicate underwater at varying frequencies. Therefore, artificial sources of underwater noise may impact marine mammals by masking biologically important sounds. This could induce a behavioural response causing a temporary threshold shift (TTS) or permanent threshold shift (PTS) in hearing. Pile driving may be required during construction (based on geological conditions), depending on final siting of the Marine Structures. Pile driving, if required, would emit noise and vibration. The noise from pile driving is generally high level, low frequency and impulsive. The noise level from pile driving would depend on the pile diameter, local geology and bathymetry. Intense, impulsive signals such as those produced from pile drivers can affect fish, and noise levels of a smaller magnitude can cause behavioural changes. Damage to hearing by intense sound depends on the auditory threshold of the receiving species and would therefore vary from species to species (Bassett 2008, Technical Appendix 22). Noise from pile driving is expected to affect individual fish but not significantly affect species at the population level. Geophysical surveys (including the use of air guns) used to characterise the marine geology prior to construction have the potential to generate periodic underwater noise and vibration.

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Noise modelling was undertaken by Bassett (2008, Technical Appendix 22) using a software implementation of the Range-dependent Acoustic Model (RAM) to estimate geophysical survey construction noise and evaluate the consequence to marine biota. Modelling was undertaken for boomers and sparkers (used in geophysical surveys), which are mid-frequency sources used in seismic and hydrographic survey. These devices would likely be used for geophysical surveys for the Marine Structure tunnels. Figure 7-1 presents the noise modelling results for geophysical surveys. Results are presented between 16 hertz and 1 kilohertz. In order to provide a threedimensional picture of the noise, each individual figure shows the modelled noise propagation along a transect radiating from the noise source. The noise source can be seen at the left of each of the bathymetric tracks with red indicating high noise levels. The variable line indicates the seabed. The colour gradient shows the sound pressure level (SPL) expressed in decibels. The modelling estimates the potential for some species of fish to be impacted within two kilometres of geophysical surveys operating at a typical source level of 230 decibels (Bassett 2008, Technical Appendix 22). The impact on cetaceans, sea birds, mammals and reptiles is considered lower than the potential impact on fish. The soft start management procedure in the EPBC Act Policy Statement 2.1, which regulates seismic testing activities as they affect cetaceans, recommends a gradual increase of the geophysical source over a 30-minute period. This is expected to alert animals and enable them to move away from the disturbed area. Since this method would be required by the Performance Requirements, cetaceans, fish, sea birds, mammals and reptiles are not expected to be significantly affected by geophysical surveys including the use of air guns (Bassett 2008, Technical Appendix 22).

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Figure 7-1 Noise modelling results for geophysical survey at the intake location

Bassett 2008

7.4

Use of chemicals and hydrocarbons

Chemicals and hydrocarbons would be used for marine construction, largely for vessel and equipment fuelling. These chemicals would not be placed in the marine environment, but accidental spills could occur. Accidental spills of hydrocarbons may affect: marine biota and ecosystems water column

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the intertidal community the marine parks in the region.

The level of impact is dependent on the types of chemical used and their toxicity. The risk process identified that accidental small chemical or hydrocarbon spills would be almost certain to occur during the construction phase, but are likely to have only minor effects on any communities or ecosystems because quantities of chemicals stored and used would generally be small. Medium or significant spills are considered unlikely to occur. The PRs require development and implementation of methods and management systems to limit on-vessel storage and/or use of hazardous substances and dangerous goods, which would reduce the risk of spills. If a spill were to occur, it is expected to only affect individual marine biota, rather than entire populations and any effects, though moderate, are likely to be temporary and localised. The risk of an accidental spill affecting the neighbouring marine park was rated as low because the quantity of any spill is likely to be small and the marine parks are located at a sufficient distance from the Project area to minimise the impact. Accidental spills are not likely to have any significant or long-term effects on any population of marine mammal, sea birds or reptiles (Biosis Research 20082, Technical Appendix 13).

7.5

Production of drilling spoil

Spoil will be generated from tunnelling and drilling for the Marine Structures. Based on the Reference Project, if a suitable marine spoil disposal site can not be identified, most of the drilling spoil will be collected on the jack-up barge and later taken to land for disposal. Any impact on the marine environment is expected to be minimal as the Performance Requirements specify disposal of any spoil from marine construction in accordance with EPA Best Practice Guidelines for Dredging and the National Ocean Disposal Guidelines.

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7.6
the shore.

Movement of marine vessels

Marine traffic would be largely from the movement of vessels to the SEPs from

7.6.1

Increase in marine traffic

It is possible that the movement of marine vessels could disturb recreational users in the Project area, especially fishing activities and affect public safety. Any disruption is expected to have a minor effect on recreational and fishing activities because the duration of the impact would be limited to the construction period. The construction exclusion zone would limit interactions between construction vessels and the public such that any impact would be from the exclusion zone rather than marine traffic. The exclusion zone is designed to protect public safety and would ensure that no public safety impacts arise from increases in marine traffic.

7.6.2

Introduction of pests and disease

Movement of construction and support vessels and discharge of ballast waters by vessels arriving from international and domestic locations have potential to spread marine pests if not properly managed. Marine pests and disease could also be transported via attachments to the hulls of ships (biofouling). The spatial and time scale over which the transplant of an introduced species may affect the marine environment is difficult to predict; however, the movement of introduced species into areas where there are no natural controls may have widespread ecological effects. The translocation of some pests can cause changes to biodiversity in the immediate affected area. Compliance with Commonwealth and State legislation requirements for ballast water would likely reduce the probability of pest species translocations and standard operating procedures have been developed in recognition of the risk that marine industries pose in translocating marine pests. The movement of vessels to and from the Project area poses no greater risk than any other marine industry in introducing marine pests. However, the Performance Requirements require development and implementation of a marine pest risk management process (including monitoring) to further reduce the risk of the introduction, spread and establishment of marine pests (GHD 20084, Technical Appendix 27).

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7.7

Use of construction divers

The disease of greatest concern is the ganglioneuritis virus that affects abalone. This disease appears to be spread by several vectors, including through the action of ocean currents, the use of abalone as fishing bait and by attaching to diving equipment and boats. Divers may be used to assist with sub-surface construction. This disease was detected in the wild in western Victoria in May 2006 and has now currently spread approximately five kilometres from the Twelve Apostils Marine National Park eastern boundary (CEE 2008, Technical Appendix 31). Although it is considered unlikely that this disease would be introduced to the Project area, the consequence of this introduction would be serious as it may have significant implications for abalone commercial fishing and the areas abalone population. Additionally, experience from the infection site in western Victoria indicates that the disease can infect large areas after introduction (CEE 2008, Technical Appendix 31). The PRs require specific risk management processes to limit the risk of introduction of this abalone disease in the Project area (see section 7.11).

7.8

Construction affecting social Amenity

Collectively, construction activities are expected to affect the visual amenity of the local area, as the Project may interrupt the quality of coastal views in some areas. The coastal area is valued for its significant scenic landscape created by the intersection between the coast and the Strzelecki foothills. The community also values the views across to Phillip Island and east to Gippsland and the scenic quality of the undeveloped tourist route near Phillip Island. Any effect on amenity from construction is expected to be minor as construction activities would be restricted to a small section of the coast and would only extend for the temporary construction period (Maunsell 20085, Technical Appendix 56).

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The community consultation for the Project identified a concern that the Project would contribute to a general industrialisation of the Wonthaggi coastline, which could generally change the perception of the area and lower tourist visits. Most tourism in the area occurs in and around Philip Island and well away from the Project area. While a moderate impact on visitation and eco-tourism is expected in the immediate area of Wonthaggi during construction, the construction activities, as such, are of limited duration and are not expected to appear to industrialise the area.

7.9

Exclusion zone

A construction exclusion zone would be required to ensure health and safety of the general public. The temporary exclusion zone would preclude all marine activities including commercial fisheries and recreational uses within this zone in order to prevent the interaction between construction activities and other public and commercial activities. The construction area is frequently fished for rock lobster and abalone nearshore and less frequently for shark and squid offshore (CEE 2008, Technical Appendix 31). According to ABS census data (Essential Economics 20082, Technical Appendix 11), there are 30 to 40 jobs out of a population of around 10 000 that are associated with the commercial fishing industry. The aquaculture and fishing industries are very small with respect to total business and employment (less than one per cent) in the area. Since the exclusion zone would only preclude commercial fishing from a small area (approximately two kilometres by two kilometres) and any reduction of commercial fishing would affect only a small percentage of the population for only the short construction period, the exclusion zone would only have a minor effect on commercial fishing and it is not expected to have any long-term effects on commercial fishing in the local area.

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7.10

Increased access to Williamsons Beach

Construction activities would increase the number of people working in the Project area and this could result in more people wanting to access the adjacent beach area. People can disturb nesting Hooded Plovers nesting in the beach area by flushing adults from active nests, which can increase the predation risk to eggs. In general, Williamsons Beach, which currently only has a car park and no associated amenities, has lower patronage than other beaches in the area (Maunsell 20085, Technical Appendix 56). Since the Victorian Hooded Plover population has been estimated to be between 334-538 birds, disruptions to the breeding success of this species would have a moderate effect on Hooded Plovers as any loss of individuals may lead to reductions in the viability of the population in the local area or region (Biosis Research 20082, Technical Appendix 13). Field surveys conclude that there are likely to be three Hooded Plover breeding pairs resident in the coastal area near the Plant site. It is for this reason that the PRs require the implementation of methods and management systems to ensure no adverse effects on the dune system, beach and intertidal zone from Project activities to minimise the loss of individuals of significant species. In particular, the PRs require collaboration with Parks Victoria and DSE to achieve additional protective measures such as fencing off portions of the beach used by nesting Hooded Plovers to exclude people, uncontrolled dogs and increased fox and cat control.

7.10.1 Risks assessed as low

The risk assessment for the Reference Project explored a comprehensive list of potential environmental effects in order to identify the priority areas for management and mitigation. The following risks have been assessed as and are expected to have a minor or negligible effect on the environment with generally a rare or unlikely probability of occurrence.

Release of grout to marine environment

The grout used to facilitate sub-surface construction rapidly solidifies and the tunnels would largely be drilled deep below the seabed, so it is highly unlikely that grout would be released to the marine environment.

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Chapter 7 Construction impact assessment

Tunnel collapse
It is highly unlikely that any tunnel collapse would affect the marine environment, as tunnelling would occur 15 metres below the seabed. However, if this did occur, only a small area of the seabed would likely be affected resulting in some disturbance or destruction to seabed habitat. Any disturbance would only be temporary and the seabed would likely fully recover (CEE 2008, Technical Appendix 31).

Release of bentonite
The tunnel-boring machine (TBM) that would create the tunnels for the Marine Structures could use bentonite as a drilling fluid to lubricate and cool the drillcutting head. A malfunction of this machine may result in bentonite being released into the marine environment. However, only in rare circumstances would accidental release occur and any release of bentonite is expected to only have a moderate effect on marine biota. These water-based drilling fluids have low toxicity and any localised impact could be due to temporary seabed blanketing.

Drilling noise affecting fish and marine mammals

Underwater noise that would be generated from drilling for the intake and outlet risers has been assessed through noise modelling and this is considered to be a low risk to marine biota (Bassett, 2008 Technical Appendix 22). The rate of diminishing noise for drilling at the intake and outlet would be slightly less than for seismic activities (discussed above) and drilling noise is generally low level, low frequency and continuous with most energy concentrated below 1 kHz. Since this is a level in which most whales have reduced hearing sensitivity, only in rare circumstances would drilling affect cetaceans, and it is considered unlikely that drilling would affect and fish and other vertebrate species (Bassett 2008, Technical Appendix 22).

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Helicopter noise
Helicopters may be used for transportation between the shore and the SEPs during the construction period. Noise impacts from helicopters may be a source of disturbance to birds, especially the beach-nesting species, the Hooded Plover. Helicopters could also affect other marine biota. It is likely that there would be some noise disturbance from this activity, but since helicopter movements are not likely to be frequent and would only occur during the construction period, the effect on Hooded Plovers and other biota is expected to be negligible (Biosis Research 20082, Technical Appendix 13).

Lighting
Artificial lights may also have deleterious effects on birds, especially on seabirds. Many seabirds fly or migrate at night. Artificial lighting can be disorienting and may trap large numbers of birds within a pool of light. Lighting impacts associated with construction activities are expected to only affect individual birds rather than an entire population. This impact would be contained in the local area, and would only occur during the period of construction (Biosis Research 20082, Technical Appendix 13).

Underwater noise affecting recreational activities

Although it is possible that underwater noise generated by construction activities could affect recreational activities, any impact would be temporary with no lasting effect on recreational use of the area. Marine activities that generate noise and vibration that may affect recreational users (e.g. helicopters) would only occur during the construction phase during a short time period (approximately 24 months) and then would cease. Therefore, it is considered unlikely that noise and vibration from construction would affect the overall recreational use of this area (Maunsell 20085, Technical Appendix 56). Additionally, the PRs require minimising exposure of marine recreational users to underwater (continuous) noise levels greater than 145 dB re 1 PA.

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Exclusion zone affecting recreational activities

It is also possible that the exclusion zone would preclude some recreational activities (such as diving). However, any impact on recreation would likely be minor because construction would only limit recreational activities in a small area for a short period of time.

Tourism and visitation

Penguin and seals are the main wildlife visitor attractions in Bass Coast Shire, although there is also some bird watching and occasional whale spotting. Although it is possible that adverse effects on the penguin population and other marine life from Project construction activities could affect long-term visitation and eco-tourism activities in the region, with adoption of the PRs, the Project is unlikely to have an impact on penguins, seals and other wildlife attractions (Biosis Research 20082, Technical Appendix 13). Therefore, it is unlikely that the eco-tourism industry would be adversely affected by the construction activities and eco-tourism operators are not likely to experience a downturn in business due to the Project. Any effects of the Project on eco-tourism would most likely be restricted to the Project area with no effect on operators on Philip Island who are responsible for the larger amount of employment and economic activity (Essential Economics 20082, Technical Appendix 11).

Maritime heritage
Construction activities are not expected to affect maritime heritage in the Project area. A systematic search of the Project area using the sidescan sonar and multibeam data did not detect any areas of heritage interest within the areas proposed for the Marine Structures. Therefore, any disturbance to the seabed in this area is unlikely to affect any maritime heritage assets (Biosis Research 20082, Technical Appendix 13).

Marine vessel emissions

Emissions generated from the movement of marine vessels during construction are unlikely to be sufficient to affect human health and interactions between the public and construction vessels would be restricted by the exclusion zone (Maunsell 20085, Technical Appendix 56).

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7.11

Performance Requirements during construction

Performance Requirements (PRs) have been developed to provide an environmental framework for management of potential impacts during construction of Marine Structures. The PRs are focussed on the environmental outcomes that the State wishes to achieve through Project delivery. The PRs relevant to the management of construction impacts of the Marine Structures are set out below. The full suite of PRs for the Project is provided in Volume 1 Chapter 11 as part of the overall Environmental Management Framework. As part of the environmental impact and risk assessment process relating to construction of Marine Structures, CEE (2008, Technical Appendix 31), Biosis Research (20082, Technical Appendix 13; 20087, Technical Appendix 45), GHD (20084, Technical Appendix 27) and Bassett (2008, Technical Appendix 22) have identified a range of suggested management measures that could be implemented to manage potential impacts. These suggested management measures have been formulated in response to the Reference Project and relevant Variations for the Marine Structures. In effect, the suggested management measures demonstrate how the Reference Project and relevant Variations can achieve the PRs. These detailed management measures have formed an important input to the PRs for the Project. The management measures suggested by CEE (2008), Biosis Research (20082, 20087), GHD (20084) and Bassett (2008) for the mitigation of impacts associated with the construction of the Marine Structures address the following matters: managing the introduction of aquatic pests and diseases potentially introduced by the transfer of equipment and construction vessels to the construction site by ensuring:
-

all international vessels comply with Australian Quarantine and Inspection Service (AQIS) requirements all interstate vessels comply with State requirements a pre-entry risk assessment procedure is considered, determining the likelihood of any vessel associated with construction of the Desalination Plant introducing marine biofouling pests of concern to the Project bioregion

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minimising the effects of the self elevating platform (SEP) and associated equipment on the marine environment by:
-

positioning the SEP, jack-up legs, anchors and cables to avoid areas of high relief reef

minimising or avoiding the interaction between fishing operators, fishing gear and the marine construction site by:
-

consulting with the fishing operators and advising them of the nature of construction activities and timing, possible exclusion zones and the risks to their fishing gear and catches taking particular care when construction vessels are moving through fishing grounds between the construction site and home ports limiting vessel movements to daylight hours to and from the construction sites

managing potential impacts of seismic survey on cetaceans by:

-

ensuring compliance with the measures prescribed in the EPBC Act Policy Statement 2.1 Interaction between offshore seismic exploration and whales minimising the generation and propagation of impulsive and/or repetitive noise, such as from offshore impact pile driving underwater ceasing drilling activities, where practicable, if a baleen whale, larger toothed whales such as the killer whale or false killer whale, or leatherback turtle is spotted within 50 m of activities

managing the physical and ecological integrity of the Williamsons Beach, the dune systems and the intertidal zone by:
-

minimising project personnels access to these areas during Project activities banning dogs from the construction site and consult with Parks Victoria to determine further measures in the protection of Williamsons Beach and Kilcunda-Harmers Haven Coastal Reserve educating project personnel about conservation and exclusion zones monitoring the locations and breeding success of resident Hooded Plovers along Williamsons Beach at least monthly until the plant is in routine operation developing measures that manage injured sea birds if impacted by construction activities.

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The PRs proposed for the marine environment are outlined in Table 7-2.

Table 7-2 Performance Requirements

Timing Subject D&C Coastal processes O&M Protect coastal processes. Minimise impacts on sand movements, wave patterns and currents. Comply with the Performance Criteria. Demonstrate through modelling of hydrodynamic processes such as tides, currents, winds and sand movements, that the Project will have no adverse effect on coastal processes. Monitor and report the effect of Project Activities on coastal processes. Detail the measures proposed to address the results of the monitoring undertaken to achieve compliance with the Performance Criteria. Coastal integrity Protect the physical integrity of the dune system, beach and intertidal zone. No surface disturbance of the dune system, beach and intertidal zone. No measurable loss to the integrity of the coastal assets including the dune system, beach and intertidal zone. Comply with the Performance Criteria. Develop and implement methods and management systems designed to ensure no adverse effect on the dune system, beach and intertidal zone from Project Activities including: Induction programs for Project personnel Minimise access outside public access pathways Monitor and report the effect of Project Activities on the dune system, beach and intertidal zone. Coastal flora and fauna Protect the ecological values of coastal habitat. No reduction in habitat values for significant species. Minimise loss of significant species individuals. No removal of coastal vegetation. Comply with the Performance Criteria. Develop and implement methods and management systems designed to ensure no adverse effect on the dune system, beach and intertidal zone from Project Activities including: Induction programs for Project personnel Implement management measures to minimise access of construction personnel to Williamsons Beach and foreshore reserve, particularly during Hooded Plover breeding season (August to February) Collaborate with Parks Victoria and DSE to achieve additional protective measures such as fencing off portions of the beach used by nesting Hooded Plovers to exclude people, uncontrolled dogs and increased fox and cat control Ensure that external lights are kept to a Objective Performance Criteria Performance Requirements

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Timing Subject D&C O&M minimum, that they are positioned as low to the ground as is practicable and that they are shielded to avoid light spill upward and toward the foreshore, beach and sea Implement a program of monitoring the locations and breeding success of resident Hooded Plovers along Williamsons Beach to measure the impact of Project Activities and inform opportunities for mitigation. This should continue at least monthly from prior to construction until the plant is in routine operation. Implement a program of monitoring for the Orange-bellied Parrot from March to September prior to and during construction activities and inform opportunities for mitigation. Marine flora and fauna general Protect marine flora and fauna. No significant impact on Bunurong Marine National Park and on the protected values of marine parks. Minimise to the extent practicable the impacts on marine flora and fauna from Project Activities. Limit impacts on ecology of continuous high relief reef. Develop, implement and maintain methods and management systems to protect marine flora and fauna. No construction in the designated areas, which creates a long-term impact, presented in Figure PR Sensitivity Area Marine Area, in Technical Appendix 5. Trenching is not permitted in the designated areas presented in Figure PR Sensitivity Area Marine Area, in Technical Appendix 5. Manage any geotechnical investigation program to avoid significant impacts on the high relief reef in the designated area and marine fauna in general. Any spoil from marine construction to be disposed of in accordance with EPA Best Practice Guidelines for Dredging and the National Ocean Disposal Guidelines for Dredged Material. Marine amenity recreational Minimise disruption to marine recreational activities. Outside any marine exclusion zone (for diving safety) no significant impact on diving, surfing, recreational fishing or marine boating activities. Limit disruption to divers outside construction exclusion zones. Comply with the Performance Criteria. Develop and implement methods and management and systems to minimise disruption to recreational activities. Turbidity or colouration impacts from the outlet should not be visible from the shoreline. Objective Performance Criteria Performance Requirements

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Timing Subject D&C Commercial fishing and marine tourism O&M Minimise disruption to the commercial fishing industry and marine tourism. Minimise restrictions on commercial fishing and marine tourism activities. Comply with the Performance Criterion. Develop and implement methods and management systems that seek to achieve effective consultation and communication with the commercial fishing and marine tourism industry in relation to potential restrictions and disruptions during construction. Marine pests Avoid the introduction, spread and establishment of marine pests. Compliance with the Commonwealth and State legislative requirements for Ballast Water. Comply with the Performance Criterion. Develop and implement a marine pest risk management and monitoring process (including a process directed to addressing the risks of introducing pests by vessels and equipment). Develop and implement a risk management process specifically for limiting risk of abalone disease. Underwater noise and vibration ecological Protect cetaceans. Compliance with EPBC Act Policy Statement 2.1 Interaction between offshore seismic exploration and whales. Underwater noise and vibration marine diving activities Protect marine diving activities from underwater noise and vibration. No significant impact outside any marine exclusion zone on marine diving activities. Comply with the Performance Criterion. Conduct geophysical survey of Project Activities in accordance with the procedures outlined under the EPBC Act Policy Statement 2.1 - Interaction between offshore seismic exploration and whales. Comply with the Performance Criterion. Outside any exclusion zone, minimise exposure of marine recreational users to underwater (continuous) noise levels greater than 145 dB re 1PA. Develop, implement and maintain methods and management systems that ensure effective consultation and communication with marine divers in relation to marine noise and vibration. Marine navigation Protect coastal access on marine waters for vessels. Minimise impact on safe passage of non-Project vessels along the coast. Comply with the Performance Criterion. Identify and implement any requirements for notifications for vessel movements by Marine Safety Victoria. Objective Performance Criteria Performance Requirements

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