PROPOSAL TO CONSTRUCT AND OPERATE A ...Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 8 Guidelines were

Environment Assessment Report

PROPOSAL TO CONSTRUCT AND OPERATE ASATELLITE LAUNCHING FACILITYON CHRISTMAS ISLAND

Environment Assessment Branch

Christmas Island Satellite Launch Facility ProposalEnvironment Assessment Report - Environment Assessment Branch – May 2000

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May 2000


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Table of Contents

1 INTRODUCTION.............................................................................................. 61.1 GENERAL ........................................................................................................... 61.2 ENVIRONMENT ASSESSMENT............................................................................ 71.3 THE ASSESSMENT PROCESS ............................................................................... 71.4 MAJOR ISSUES RAISED DURING THE PUBLIC COMMENT PERIOD ON THEDRAFT EIS ................................................................................................................. 9

1.4.1 Socio-economic...................................................................................... 101.4.2 Biodiversity............................................................................................ 101.4.3 Roads and infrastructure ..................................................................... 111.4.4 Other....................................................................................................... 12

2 NEED FOR THE PROJECT AND KEY ALTERNATIVES ...................... 142.1 NEED FOR THE PROJECT .................................................................................. 142.2 KEY ALTERNATIVES ........................................................................................ 17

2.2.1 Alternative Launch Vehicles and Technologies............................... 172.2.2 Alternative Space Fuels ....................................................................... 182.2.3 Alternative Orbits ................................................................................. 182.2.4 Alternative Launch Sites...................................................................... 182.2.5 Alternative of Not Proceeding with the Proposal ........................... 19

3 DESCRIPTION OF THE PROPOSAL......................................................... 203.1.1 General ................................................................................................... 20

3.2 TECHNICAL AND LAUNCH COMPLEX ............................................................ 203.2.1 Mission Control..................................................................................... 253.2.2 Administration and Residential Complex, Irvine Hill.................... 253.2.3 Roll-on Roll-off Facility........................................................................ 263.2.4 Facilities at Christmas Island Airport ................................................ 303.2.5 Infrastructure Corridors....................................................................... 303.2.6 Roadworks............................................................................................. 303.2.7 Launch Vehicles.................................................................................... 313.2.8 Fuel ......................................................................................................... 333.2.9 Flight Termination System .................................................................. 34

3.3 PROJECT CONSTRUCTION................................................................................ 343.4 PROJECT OPERATION ...................................................................................... 35

3.4.1 Employment .......................................................................................... 353.4.2 Launch Operations ............................................................................... 363.4.3 Drop Zones ............................................................................................ 363.4.4 Security................................................................................................... 383.4.5 Transport................................................................................................ 38

4 EXISTING NATURAL ENVIRONMENT .................................................. 404.1 GENERAL ......................................................................................................... 404.2 FLORA.............................................................................................................. 414.3 FAUNA............................................................................................................. 424.4 ISLAND ECOLOGY – FAUNA & FLORA INTERACTIONS .................................. 434.5 THREATS TO FAUNA AND FLORA ................................................................... 44


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4.6 PROJECT SITES ................................................................................................. 454.6.1 Flora ........................................................................................................ 454.6.2 Fauna ...................................................................................................... 464.6.3 Karst Habitats........................................................................................ 50

5 OVERVIEW OF SOCIAL AND ECONOMIC ENVIRONMENT .......... 535.1 HISTORY .......................................................................................................... 535.2 ADMINISTRATION ........................................................................................... 535.3 POPULATION AND CULTURAL DIVERSITY...................................................... 545.4 INFRASTRUCTURE............................................................................................ 55

5.4.1 Education............................................................................................... 555.4.2 Health ..................................................................................................... 555.4.3 Social Services ....................................................................................... 565.4.4 Housing.................................................................................................. 565.4.5 Electricity ............................................................................................... 565.4.6 Water....................................................................................................... 575.4.7 Sewage.................................................................................................... 575.4.8 Waste Management .............................................................................. 575.4.9 Policing................................................................................................... 575.4.10 Road........................................................................................................ 575.4.11 Off-Island Transport............................................................................. 57

5.5 BUSINESS AND INDUSTRY................................................................................ 585.6 SOCIAL FACTORS AND LIFESTYLE................................................................... 595.7 CULTURAL HERITAGE..................................................................................... 60

6 POSSIBLE IMPACTS UPON THE NATURAL ENVIRONMENT ANDIMPACT AVOIDANCE AND REMEDIATION. .............................................. 61

6.1 CONSTRUCTION HABITAT DISTURBANCE AND CLEARING ............................ 616.2 TRANSPORTATION IMPACTS ........................................................................... 64

6.2.1 Quarantine ............................................................................................. 646.2.2 Roadkills ................................................................................................ 656.2.3 Transportation of Hazardous Substances ......................................... 666.2.4 Use of Helicopters on South Point ..................................................... 73

6.3 IMPACT OF LIGHTING AND HIGH STRUCTURES ............................................. 746.4 LAUNCH ACTIVITY IMPACTS .......................................................................... 75

6.4.1 Vehicle and payload fuelling .............................................................. 756.4.2 Impacts on Christmas Island of a Normal Launch – Launch Plume

776.4.3 Impacts on Christmas Island of a Normal Launch – Launch Noise

796.4.4 Impacts of a launch vehicle accident on or near the launch pad... 906.4.5 Impacts of launch vehicle in flight ..................................................... 926.4.6 Drop Zone Impacts............................................................................... 946.4.7 Launch Impacts Upon Aircraft ......................................................... 100

6.5 CREATION OF ORBITAL DEBRIS..................................................................... 1016.6 IMPACTS ON CAVE SYSTEMS AND CLIFFS ..................................................... 1036.7 IMPACT OF SPILL AND WASTE WATER ON SOUTH POINT: .......................... 104


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7 POSSIBLE IMPACTS UPON THE SOCIAL AND ECONOMICENVIRONMENT AND IMPACT AVOIDANCE AND REMEDIATION.107

7.1 ACCESS TO SOUTH POINT AND CHINESE TEMPLE ....................................... 1077.2 ROLL-ON ROLL-OFF FACILITY....................................................................... 1097.3 IRVINE HILL RESIDENTIAL AND ADMINISTRATION COMPLEX .................... 1137.4 WASTE GENERATION AND HAZARDOUS MATERIALS. ................................ 1167.5 IMPACTS UPON INFRASTRUCTURE................................................................ 117

7.5.1 Power Supply & Sewage Treatment ................................................ 1187.5.2 Road use ............................................................................................... 1187.5.3 Water Supply....................................................................................... 1197.5.4 Education............................................................................................. 1197.5.5 Recreational Facilities......................................................................... 1207.5.6 Hospital................................................................................................ 120

7.6 EMERGENCY PROCEDURES............................................................................ 1217.7 SOCIAL IMPACTS............................................................................................ 121

7.7.1 Employee Education .......................................................................... 1237.7.2 Community Consultation.................................................................. 123

8 ENVIRONMENTAL MANAGEMENT..................................................... 1258.1 ENVIRONMENT MANAGEMENT PLANS ........................................................ 1258.2 REHABILITATION........................................................................................... 127

9 CONCLUSION............................................................................................... 13010 REFERENCES................................................................................................. 13211 GLOSSARY..................................................................................................... 136


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1 INTRODUCTION

1.1 GENERAL

This report assesses the environmental impact of a proposal by Asia PacificSpace Centre Pty Ltd (APSC) to construct and operate a satellite launchingfacility on Christmas Island, an Australian External Territory in the IndianOcean (Figure 1). In accordance with the Environment Protection (Impact ofProposals) Act 1974 (EPIP Act) the Minister for Regional Development,Territories and Local Government designated APSC as proponent in relationto his consideration of the environmental significance of decisions andapprovals to be made in relation to the construction of a satellite launchingfacility and ancillary operations on Christmas Island.

Figure 1. Location of Christmas Island

from Draft EIS

A second key nexus for government approvals is expected to be therequirements of the Space Activities Act 1998, under which a satellite launchfacility requires a space licence and each launch or series of launches requiresa launch permit. This legislation is administered by the Department ofIndustry, Science and Resources.

This assessment report reviews the draft Environmental Impact Statement(draft EIS), and the Supplement to the draft EIS which includes theproponent's responses to public comments on the draft EIS (the draft EIS plusthe Supplement constitutes the final EIS). In addition the assessment reporttakes into consideration the additional information provided by APSC on23 March 2000. It also relies on information, comments and advice providedby Groups within Environment Australia, other relevant Commonwealthagencies, Western Australian Government Departments which may be serviceproviders and/or administrators of relevant legislation in association with theTerritories Office, and previous studies undertaken on Christmas Island.


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1.2 ENVIRONMENT ASSESSMENT

Environmental impact assessment is predicated on defining adequately thoseelements of the environment that may be affected by a proposeddevelopment, and on identifying the significance, risks and consequences ofthe potential impacts of the proposal at a local, regional and national level.

The final EIS provides a description of the existing environment in the areaand the proposed operations and evaluates the environmental impacts andproposed mitigating measures to minimise the expected impacts.

This report will assess the adequacy of the final EIS in achieving the aboveobjectives, and will evaluate the undertakings and environmental safeguardsproposed by the proponent to mitigate the potential impacts. Furthersafeguards may be recommended as appropriate.

The contents of this report form the basis of advice to the Minister for theEnvironment on the environmental issues associated with the project.

1.3 THE ASSESSMENT PROCESS

Environmental assessment was conducted by the Environment AssessmentBranch of the Commonwealth Department of Environment and Heritage.

The launch facility proposal requires a range of decisions by the Minister forRegional Development, Territories and Local Government in relation to thetransfer of land and other matters. On this basis, and in view of the project’senvironmental significance, the proposal comes within the provisions of theCommonwealth’s EPIP Act.

The proposal was also potentially subject to impact assessment under appliedlegislation in the Indian Ocean Territories - the Environmental Protection Act(WA) (CI) (CKI) 1986 (EP Act). The Minister for Regional Development,Territories and Local Government issued a notice under Section 6 of the EPAct so that the project was not liable for assessment under that Act, but thatthe assessment should be carried out under the EPIP Act as the appropriateCommonwealth instrument.

In accordance with the provisions of the EPIP Act, APSC was directed toprepare a draft EIS by the Minister for the Environment on 15 May 1998.Guidelines for the preparation of the EIS were compiled by EnvironmentAustralia in consultation with the proponent, key Christmas Islandorganisations, and a number of individuals and groups with expertiseconcerning various aspects of the Christmas Island environment. The Final


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Guidelines were agreed to between APSC and Environment Australia inAugust 1998.

The draft EIS and Supplement to the draft EIS were prepared for APSC by theconsultants, Sinclair Knight Merz Pty Ltd of Queensland.

In accordance with the EPIP Act and Administrative Procedures, the draft EISwas made available for public review between 25 August and 6 October 1999.This period was extended until 15 October due to delays in the availability ofthe EIS. During this period more than ten meetings were held on ChristmasIsland with community groups and individuals. These meetings were heldby the Environment Assessment Branch to provide an alternative to writtensubmissions on the draft EIS. Over sixty people attended these meetings. Areport of notes on the issues raised in the public meetings were prepared andsubmitted to APSC for consideration in the revision of the draft EIS. Thisassessment report also notes some of the issues raised.

Thirty-one (31) submissions (including submissions from a number of WAagencies) as well as comments from Environment Australia were forwardedto APSC. APSC provided summaries of points raised in submissions atAttachment II of the Supplement.

In addition, Environment Australia commissioned ICF Consulting to providean independent technical peer review of the Draft EIS. ICF consulting hasextensive expertise and experience in reviewing environmental impacts oflaunch facilities, and has done so a number of times for the Commercial SpaceTransportation Branch of the Federal Aviation Agency of the USA. Theirreport was not available until some time after the close of the public reviewperiod and APSC chose to only consider ICF comments where they related tothe major issues addressed in the body of the supplement.

The supplement to the EIS was submitted to Environment Australia on31 January 2000. The Environment Assessment Branch of EnvironmentAustralia commenced preparation of this Assessment Report in consultationwith other areas of the Environment Portfolio on 1 February 2000. ICFConsulting was also commissioned to review how the document addressedpoint raised in their earlier report.

In examining the document it became apparent that on a number of issuesfurther information was required that was necessary for proper considerationof environmental impacts and a report being prepared for the considerationof the Minister for the Environment. With the authorisation of the Ministerfor the Environment and Heritage, the Head of the Environment ProtectionGroup wrote to APSC on 21 February 2000 seeking additional information asprovided by Paragraph 9.2 of the Administrative procedures of the EPIP Act.This action halted the 42 day assessment process, which was recommenced on


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24 March 2000 with the receipt of further information from APSC in responseto the request.

This Assessment Report and its recommendations has been prepared tosatisfy section 9.1.1 of the Administrative Procedures of the EPIP Act. Thereport is primarily for the consideration of the Minister for the Environment.After considering the Assessment Report, Section 9.3.1 of the AdministrativeProcedures requires the Minister for the Environment to:

“.... make any comments, suggestions or recommendations to the actionMinister and other relevant Ministers concerning the proposed action,whether or not contained in the report prepared by the Department underparagraph 9.1.1., including suggestions or recommendations concerningconditions to which the proposed action should be subject, that the Ministerthinks necessary or desirable for the protection of the environment ...”

The Minister for Regional Development, Territories and Local Government, asthe action Minister, is required to give all such directions and do all suchthings as can be given or done by that Minister for ensuring that the final EISand the suggestions or recommendations made by the Minister for theEnvironment are taken into account in matters to which they relate.

Similarly it is recommended that a number of issues and recommendationsraised in this report should be referred for the attention of the Minister forIndustry, Science and Resources in his capacity as the Minister responsible forthe Space Activities Act 1998.

1.4 MAJOR ISSUES RAISED DURING THE PUBLIC COMMENT PERIOD ON THEDRAFT EIS

Many stakeholders were critical of what they perceived to be a lack of detailand hard data regarding many aspects of the proposal. They said the draftEIS provided insufficient information on the potential for environmentalimpacts and contained many unsupported assertions rather than facts. Somepointed to the lack of public meetings during the public comment period.

There was widespread feeling that the rocket launch facility would effect theisland’s reputation as a peaceful haven and degrade the eco-tourismexperience. Of particular concern were noise levels associated with increasedair traffic and rocket launches. Some submissions suggested locating thelaunch site on an island with lower conservation value than Christmas Island.

A number of submissions were concerned about the potential impact of spills.The launch facility is located over cavernous karst. If a spill were to occur,fuel and other toxic substances could contaminate ground water and enter the


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cave system, and either be rapidly transported along the limestone/basaltinterface to the ocean, or alternatively be trapped in the anchialine systemwith severe environmental impacts.

Dr W.F. Humphreys of the Western Australian Museum submitted that theanchialine system on Christmas Island is barely known and no assessment ofthe subterranean fauna has been undertaken. For example, it is believedProcaris spp. (aytid shrimps) are confined globally to anchialine systems ononly a few islands.

1.4.1 Socio-economic

A number of stakeholders questioned the viability of the project and in turnthe estimated economic benefits to the island, citing a potential worldoversupply of rocket launch facilities. One stakeholder thought the projectmight be bankrupted leaving unpaid debts to island businesses. Others saidthat if the project proved to financially viable a percentage of APSC’s profitsshould be allocated to a Community Benefit Fund.

In contrast, some island and mainland businesses supported the facility, citingemployment and economic benefits arising from the project.

Some residents were concerned about the impact of a large number ofconstruction workers on their lifestyle and on the island’s infrastructure andfragile ecosystems (some thought foreign workers would have little respectfor the island’s natural environment). Others opposed accommodatingworkers at tourist facilities and questioned restrictions on access to theChinese temple on South Point.

A few submissions suggested the potential impacts of the project on the CocosIslands (APSC staff using the Islands for recreation and increased air traffic)warranted further examination.

1.4.2 Biodiversity

A major concern was the potential impact of the facility on endangeredspecies such as Abbott’s Booby. Abbott’s Booby is highly vulnerable todisturbance and phosphate mining was curtailed to protect the species. Somesubmissions claimed fauna and threatened species sections in the draft EISwere inaccurate and not comprehensive. For example, information on theChristmas Island Pipistrelle was said to be outdated and no concerted attemptwas made to sample for it. Researchers said the proposed wildlife monitoringprograms is inadequate but supported Parks Australia’s future involvementin monitoring programs.


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Questions were raised about the impact of construction and operationalactivities (including noise and burnt and unburnt fuel) on sea bird colonies,and increased traffic and security lighting on Christmas Island Hawk-Owlsand red crab migration and mortality. One stakeholder said that if securitylighting (which attracts birds) was essential, then any structures into whichbirds are likely to crash should be well illuminated.

Other concerns included; the impact of fire on rainforest and terrace forest;vegetation clearance associated with the facility resulting in a reduction in thenumber of nesting hollows and roosting sites for Hawk-Owls and Goshawks,and; long term effects on bird breeding;

Some stakeholders advocated more stringent quarantine activities to reducethe chance of pests being imported with materials for the project. Otherssupported APSC’s appointment of an environment officer and suggested thecompany should be required to pay a substantial environmental bond and toemploy a wildlife officer.

1.4.3 Roads and infrastructure

A major concern was the ability of the Shire of Christmas Island to meet thedemand for additional infrastructure, public facilities and services. Questionswere raised as to the ability of the consortium to fund road construction andmaintenance costs.

The proposed roll-on roll-off port facility is located near the main recreationalbeach and residential and commercial areas on the island and residents andtourism operators are concerned it would dominate the coastline, impactingon the tourism industry through increased traffic, parking problems and thepresence of ships and trucks for extended period of time. They claim thatunloading toxic chemicals at the site, which is prone to significant waveaction, shows a lack of understanding of local conditions by the company.Residents suggested investigating alternative sites for a port, imposing truckcurfews and constructing overtaking lanes. Thirty-one local residents signeda petition opposing the proposed port facility.

Stakeholders also expressed concern about: transport and storage ofhazardous and dangerous goods; the lack of commitment by APSC tominimise energy usage or to use alternative energy sources; insufficientinformation on water sourcing, water use and recycling, and; the need fordetailed water management, waste management and environmentalmanagement plans (including a soil and water management plan for buildingactivities).

Some residents said transportation of construction materials, fuel and rocketsections may interfere with local traffic. Whilst others were concerned that


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the facility may be used for military purposes or may become a militarytarget.

1.4.4 Other

Some submissions mentioned the potential for contamination of the marineenvironment and cited the lack of data to support the contention that spillswill dissipate and move out to sea. Others suggested discarded rocket stagesshould be recovered rather than be allowed to sink in the ocean.

The petroleum industry raised concerns about potential damage to itsfacilities on the North West Shelf and in the Timor Sea by spent rocket stagesand subsequent contamination of the marine environment. The open seadrop zones proposed in the Draft EIS pass very close to offshore petroleumproduction facilities. The industry also sought clarification regarding anylimitations the proposal may place on future petroleum exploration andgreen-field development.

Some stakeholders said the EIS lacked discussion on the spent rocket stagesdrop zones and the effect on air traffic in the areas along the flight paths.Planes may have to be diverted several hundred kilometres during launchoperations, adding to fuel costs for the airlines involved. It was suggestedthat further discussions were required with Indonesia on this matter.

Other issues included: the potential for accidents through failure of secondhand missile parts; no discussion of the environmental impacts of building,operating and maintaining of the 12 MW power station or the possibility ofhaving to extend the existing airport runway, and; the need for furtherconsideration of fire and emergency service requirements. One stakeholdersupported Parks Australia’s involvement as a monitoring agent.


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Figure 2. Project Location at South Point

from Draft EIS


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2 NEED FOR THE PROJECT AND KEY ALTERNATIVES

2.1 NEED FOR THE PROJECT

The Guidelines for the preparation of the EIS specifically required the needfor the project to be specifically examined. Information was provided inChapter 3 of the DEIS and supplemented by further information in Chapter 3of the Supplement. The para 9.2 request for further information included arequest for further detail on training opportunities to be provided on theisland.

APSC’s key argument for the need for the project is that such a project willmeet the growing demand for telecommunications, navigational and remotesensing satellites. The DEIS refers to studies that indicate that existing launchfacilities could not meet the growing demands of the commercial satellitetelecommunication market, although the Supplement makes reference to therecent decline in prospects for the low earth orbit market (for example, therecent financial failure of the Iridium satellite telecommunications networkleading to the potential de-orbiting of the network).

While the low earth orbit component of the market may not grow to theextent expected, APSC points out that the Christmas Island project is the onlyone of the current four proposed Australian launch facilities that will cater forboth the geostationary orbit and low earth orbit markets. This is due to thebenefits of Christmas Island’s location – enabling trajectories to the South andSouth East (Low Earth Orbits), while its proximity to the equator leads tobenefits for geostationary equatorial satellites (close proximity to the equatorenables maximisation of payload size).

On the basis of a twenty year period of operation with a capacity for 12launches a year (from year 6), the APSC estimates that company tax payablewill be of the order of $2 billion, while the Australian content of the capitalexpenditure for the project would be more than $300 million.

It is estimated that construction of the launch facility will employ an averageof 150-170 people, peaking at over 300 employees for approximately8 months. Operation of the facility would require about 290 staff directlyemployed, along with an estimated 150 people in support industries (onisland). A significant proportion of the operational staff would be employedon a fly-in fly-out basis and the majority would be likely to be foreign trainedexperts, with about 40% able to be recruited from mainland Australia orChristmas Island.


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A key issue of interest to Christmas Island residents was what jobopportunities and contracting and service provision opportunities wouldthere be for islanders, and whether APSC would be providing trainingopportunities for themselves and their children. APSC has not made aspecific commitment on these three issues. The additional information notesthat jobs of a more technical nature associated with launch vehicles andsatellites will naturally require people with many years of specialist training,but that “to the extent possible, APSC would wish to see Christmas Islandresidents fill as many positions as is practical”. The Socioeconomic impactMatrix states that APSC will seek to employ island residents whereappropriate (March 2000 additional information, Attachment 1, p36)

Training opportunities would be dependent upon the degree to whichservices and support activities were to be contracted out to local companies.The additional information states that APSC anticipates that it would be ableto provide apprenticeships or on-the-job training in vocational areas such aselectricians, plumbers, environmental management , auto mechanics etc.

The Christmas Island Tourism Association suggested that APSC considersponsoring a tourism officer trainee position for the visitor centre. APSC’sresponse (Supplement pII-17) was that it was anticipated that the increase intourism generated by APSC will also generate additional income to thebusiness community and flow through to the tourism industry overall.“APSC is keen to investigate the promotion and generation of tourism by anypractical manner”.

Some submissions and comments at community meetings expressed concernthat benefits may not flow to the Christmas Island community – citingnegative experiences with the casino resort (in terms of, employment andcontracting going to mainland Australians and debts left owing). Inresponding to this in the Supplement, APSC stated that “in a commercialproject there can be no guarantees of a certain level of benefit flowing to anyparticular section of the community, whether it be Christmas Island ormainland Australia. On this occasion, APSC Pty Ltd believes that theisolation of the Island could well act in favour of local cost structures and thecompany would be very surprised if significant economic benefits did notflow directly to the Island community. Already many Christmas Islandcompanies have approached APSC Pty Ltd with cost effective proposals forthe provision of goods and services”.

It is not necessarily correct that a commercial basis for a project restricts activedirection of benefits. A project may include the direction of specific benefitsto the community, and some public submissions raised that the Casino Resortdid include the creation of a community benefit fund. Responding to this inthe Supplement, APSC stated: “With regard to the transfer of profits from theCasino operations to a community benefit fund, APSC Pty Ltd does not


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support this approach and sees little commercial justification for such ascheme to be put in place. The range of benefits applying to Christmas Islandas a result of the casino or satellite facility will be substantial and will occur ina rational context rather than as a result of a bureaucratic decision”(Supplement PII-37). This is discussed further in Chapter 7.

In the Supplement (Ch 14, p84), APSC committed to the establishment of anindependent “Christmas Island Environment Foundation” to supportenvironmental research on the island. One million would be contributed byAPSC over 10 years, along with additional effort to seek other contributions(further discussed Chapter 8).

The supplement states that APSC considers that the overall benefits of thelaunch facility to Australia and Christmas Island far outweigh the overallcosts, but qualify this by noting that “naturally there will be some costs whichfall more heavily on some sections of the community than others”.

There is no doubt that economic and employment benefits will be derivedwithin Australia if the proposal proceeds. The level of these and in particular,where benefits will be directed is more open to uncertainty, and it should benoted that APSC has to date declined to reduce this uncertainty for theChristmas Island community in particular.

The EIS outlines other benefits as including:

Ø Spill-over benefits in technology based industry and related academicfields;

Ø The addition of another tourist attraction for the island (while launchfacilities such as the Kennedy Space Centre in Florida are significanttourist attractions, it is difficult to be certain to what extent a launchfacility on a relatively isolated island will attract tourists);

Ø APSC workers adding their spending power to the local economy;Ø Improvements to island infrastructure such as transport and

communications.

Acknowledged costs include:

Ø Precluding alternative development of South Point (it should be noted thatas a mining lease, Christmas Island Phosphates would be required torehabilitate the area with endemic plants at the end of the lease);

Ø Denial of access to the South Point area for a 24 hour period for eachlaunch;

Ø Audible (but brief and infrequent) launch noise for the community on theisland;

Ø Traffic disruption associated with transportation of large or hazardousloads;


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Ø Establishment of the roll-on roll-of facility may have specificdisadvantages for nearby residents;

There may also be other costs not covered in the EIS. In the social spherethese might relate to the disruption of a unique community with the arrival ofthe new workforce, particularly if integration is only a partial success.

In terms of cumulative impacts, the establishment of the launch facility on theisland may require that new water resources need to be found and accessed.

In terms of resource use conflict, the establishment of certain drop zones maycurtail future oil and gas exploration or production off the Western AustralianCoastline.

In terms of natural impacts, while the EIS process has answered many of thequestions relating to such projects, we are still faced with the unknown levelof impact upon the South Point Sea Bird colonies as a result of launches andthe potential for a launch vehicle explosion over the island. There are alsosome other uncertainties relating to impacts upon land based fauna, and thewater table. Further approval under the National Parks and WildlifeConservation Act 1975 will be required for the proposal to place the proposedwater pipeline from Jedda Cave to South Point through the national park.

These issues are all examined further in relevant sections of this report.

In finalising this assessment, the Department notes that the option of usingsolid fuel rockets, the specific nature of payloads, runway extensions and theuse of nuclear materials have not been assessed. If these matters are likely tohave a significant impact upon the environment, they would have to besubject to further environmental impact assessment if they were to beimplemented.

2.2 KEY ALTERNATIVES

Discussion of key alternatives can be found on P5-38 to 5-39 of the Draft EISand PII-30 to PII-31 of the Supplement.

2.2.1 Alternative Launch Vehicles and Technologies

APSC states that they are restricted in their consideration of access to otherlaunch vehicles due to reasons of national sovereignty and existing marketingrights. APSC notes that launch vehicle technologies are constantly improvingand states that APSC would wish to be at the forefront of their usage for bothcommercial and environmental reasons.


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In comparison to other known launch vehicles, the liquid oxygen/kerosenefuel used by APSC launch vehicles compares favourably to other vehicleswhich use UDMH for launch stages, while in comparison to launch vehicleswhich use solid fuel for all or some stages, there would be pluses and minusesenvironmentally. In relation to the expendable nature of the proposedrockets, there is no indication that the manufacturers of the ARS-3K vehicleare in the forefront of efforts to develop recyclable or reusable vehicles.APSC states that as new techniques become proven, these can be incorporatedinto the APSC operations. Given that APSC is primarily a purchaser of pre-designed rockets, this objective would be reliant upon the supplier’s abilityand willingness to comply with the objective.

2.2.2 Alternative Space Fuels

APSC states that there are currently no alternatives to the use of UDMH andNTO as storable space fuels for satellites, but that emerging technologies suchas electric thrusters have the potential to replace some of the fuel used.

2.2.3 Alternative Orbits

The launch trajectories proposed by APSC service the current major orbitmarkets for satellite launches. APSC does note that “doglegs” can be used toavoid areas such as operational oil production facilities if necessary.

2.2.4 Alternative Launch Sites

APSC argues that as an Australian company it is interested in developing thelaunch industry for Australia, but that Christmas Island compares veryfavourably with other potential and existing launch sites around the world.

In terms of alternatives within Australia, APSC notes that the criteria forlaunch sites capable of meeting market demands for geostationary and LowEarth Orbits are:

Ø proximity to the equator (within 15o), for efficient launch intogeostationary and low-inclination orbits;

Ø safe over-ocean flight paths for the major orbit segments;Ø existing infrastructure;Ø a benign climate, without extreme temperatures or winds; andØ a local geography and environment compatible with the launch

activities.

APSC has concluded that in comparison to other potential sites consideredover the past 14 years in Australia (including Woomera (SA), Temple Bay andWeipa (Cape York), and Gunn Point and Melville Island (NT), ChristmasIsland is superior to the other candidates. While perhaps from the


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proponents point of view this might be correct, in considering environmentalimpacts, the last criteria comes to the fore, and in that sense South Point andChristmas Island cannot be seen as having the environment most compatiblewith launch activities. The natural environment surrounding Woomera (asthe other area that has been assessed under the EPIP Act) would be morecompatible with launch activities. In contrast though, its overland flightpaths potentially raise both safety and some environmental problems.

APSC has simply stated its view regarding the suitability of Christmas Islandover other potential Australian launch sites, without providing an analysisagainst its own criteria. As such the conclusion reached has been presentedwithout its basis.

2.2.5 Alternative of Not Proceeding with the Proposal

APSC argues that without the launch facility, other developments would beneeded on Christmas Island to help support the existing economy as miningoperations wind down over the next 10-20 years. In relation to this, thelaunch facility proposal itself may only last for twenty years, thus closingdown around the same time as the mine.

APSC also states that Australia would lose a burgeoning high technologyindustry and that the satellites would be launched by other operators in othercountries, potentially with rockets using more harmful fuels. Given that thereare currently three other proposed launch facilities in Australia, this is notnecessarily the case.

The EIS neglects to consider that by not proceeding with the proposal, therewould also not be the range of potential impacts that the facility might causeto Christmas Island’s valuable natural habitat, and following on, to theIsland’s nature based tourist industry. Nor does it consider that without thelaunch facility proposal, the South Point site would be rehabilitated at the endof the mining lease, or could be used for another activity with less potential tosignificantly impact upon the environment.


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3 DESCRIPTION OF THE PROPOSAL

3.1.1 General

The objective of APSC’s proposal is the construction of a facility that will beable to assemble launch vehicles; receive and prepare satellites (or payloads);place satellites on launch vehicles and launch the assembly so that the satellitecan be placed in a geostationary or low earth orbit. The satellite payloads willbe owned by customers of APSC and will be designed to carry outcommercial functions including telecommunications and remote sensing.

The proposal would require the construction of a number of facilities atvarious locations on Christmas Island:

Ø Technical Complex, South Point;Ø Launch Complex, South Point;Ø Mission Control, South Point;Ø Temporary accommodation compound, South Point;Ø Residential and Administration Complex, Irvine Hill;Ø Roll-on Roll-off seaport Facility, Gaze Rd, Settlement;Ø Facilities at Christmas Island Airport;Ø Infrastructure corridors for communication, power, and water supply;

and,Ø Possible alterations to roads forming the transportation route from Dogs

Head to South Point.

3.2 TECHNICAL AND LAUNCH COMPLEX

These two adjoining complexes on South Point form the main focus of theproposal (Figure 3). Both would be located on a 85ha area of land currentlypart of Mining Lease 100 (ML100). In the Supplement (PII-3) APSC reportsthat at that time negotiations were taking place between APSC and theGovernment on the tenure arrangements for the APSC site. APSC expects tobe granted a 99 year lease over the site, with the lease converting to freeholdpossession once construction was finished and the space centre ready foroperations.

Launch site development and operations would be carried out in partnershipwith Moscow based “Design Bureau of General Machine Building” (KBOM)and “Design Bureau of Transport Machinery” (KBTM). The extent to whichthe technology, and expertise will remain with the Russian organisations isunclear.


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Figure 3. Project Components on South Pointfrom Draft EIS

The Draft EIS (S5.3) provides information on the construction materials to beused, the size and function of each of the buildings in the technical complex.The largest building in the complex, the Launch Vehicle Assembly (LV)Building, measures 110m x 50m x 25m high and as with other buildings onsite, construction would be similar to large industrial warehouse structureswith concrete footings and floor slabs, steel frames, and prefabricated wallpanels. The LV building would be used for unpacking, fitting out and testingthe launch vehicle components, assembling the components and joining themup with the satellite. This involves the use of overhead cranes, and floor railsto move components. The LV building would also support two five metrehigh receiving antenna systems to provide direct radio visibility of the launchvehicle.

Adjoining the LV building, the nose cone processing building is used to readythe adaptor that fits the payload to the launch vehicle, as well as the fairinghalves that encapsulate the payload, and for preparing the kick stage, if one isto be used (a kick stage is a rocket stage used to move the payload to its finalorbit).

The Payload processing building is probably one of the more complexstructures and is used for the assembly, preparation, testing and fuelling of


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the payload. The building would contain three high bays which would allowfor the simultaneous preparation of two payloads, and an airlock entry. Dueto the hazardous nature of the fuels used, the building would be designedwith drains and traps built into floor slabs in order to control spills. Thepayload fuelling area is physically isolated from the rest of the building, hasventilation and decontamination systems, gas detectors, escape exits and anon-water fire suppression system (discussed further in S3.4).

Operation of the facility requires a number of different types of fuels andtherefore fuel stores. Kerosene is required to fuel the types of rockets to beused, and would be stored in the containers approved by the InternationalStandards Organisation (ISO containers) that it would be shipped to theisland in. The additional information clarifies that the bunded volume for thisand other fuel storage facilities will at least equal that of the largest tank plusthe heaviest daily rainfall on a 20 year recurrence interval. The storage facilitywould contain five tanks each holding 110, 000 litres of kerosene. The ISOcontainers would be transported to the launch complex when required forfuelling.

Two separate storage facilities would be used for nitrogen tetroxide (NTO)and dimethyl hydrazine which are used to fuel satellites. Both storagefacilities are steel framed with a roof and open sides (for ventilation). Thefuels would be stored in the ISO containers they were transported in, whichwould be placed in storage racks. The facility would be bunded and the areadrain into a collection tank that would collect waste in the event of a leak.The stores would also have a gas detection system, a fire detection system anda manually operated misting sprinkler system. Due to the dangerous natureof these materials, the storage facilities must be positioned a specific distancefrom each other and from other dangerous materials as determined by WAregulations and Standards Australia so that an accident in one facility doesnot propagate an accident in another facility. The Draft EIS providesinformation on the safety and emergency facilities provided at each store(DEIS P 5-34).

The project also requires a diesel supply – both for the diesel fuelled powerstation, and the on site petrol station (which would only supply diesel). Thefuel farm will store 710,000 litres of fuel in three 200,000 litre and two 55,000litre tanks stored in an impervious compound. The petrol station is the onlyfuel facility proposed to involve below ground storage tanks.

A hazardous store would also be required to house and prepare pyrotechnicitems used for launch vehicles. These include small explosive devices foractivating mechanisms; explosive ribbon for separating components; and,small solid fuel rocket motors. These motors weigh up to 20 kg. They areused to separate stages during the flight of the launch vehicle. One launchvehicle may carry about 100kg of solid fuel rockets.


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The storage of fuels considered dangerous goods would be required to be inaccordance with Western Australian regulations and would need to becovered in inspection programs conducted by the Explosives and DangerousGoods Division of the WA Department of Minerals and Energy (as advised intheir comments on the Draft EIS).

The on-site diesel power station would have a maximum capacity of 12 MegaWatts, although this level of power would only be required for a period ofthree days surrounding a launch. APSC also proposes to have the capacity toaccess an additional 3 Mega Watts of power from the existing ChristmasIsland power station when required. This would require the establishment ofa 20km cable connection that would be trenched alongside existing roads andservice routes. The existing CI power station is diesel powered with acapacity of 12.5 MW, although current usage quoted in the draft EIS was 4.5MW.

The proposed launch vehicles also require liquid oxygen and a liquid oxygenplant is proposed to be located in the Technical Complex. The prefabricatedplant would include an electricity driven refrigeration system for liquefyingair, a distillation column, storage tank, pumps and control system. The plantwould be designed to run continuously and the liquid oxygen would betransported by truck to the Launch Complex for storage. Smaller quantities ofliquid nitrogen would also be produced for use on site.

The assembled launch vehicle is designed to be moved horizontally on a railvehicle. A rail system would link the Technical Complex with the LaunchComplex and would require a storage building for rail vehicles and relatedequipment.

It is estimated that within the Technical Complex, 20,000 m2 of roofed areaswill be available to harvest rainfall. A water storage area of tanks would beestablished with a volume of 38,000,000 litres. The reservoir would be belowground level with the surface area covered by a lightweight material toprovide protection from airborne pollutants and deter birds. When required,additional water would be sourced from Jedda Cave (a freshwater springalready used as a water supply resource for the township), via a new pipelineto South Point.

Additional facilities that would be required as part of the Technical Complexinclude:

Ø Fire station, to house two fire tenders, two spill clean-up trucks, portablefire fighting equipment and associated facilities;

Ø Vehicle maintenance and wash-down facilities;Ø Staff facilities;


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Ø Sealed roads;Ø Water, waste water, and power services;

The space separating the Technical Complex from the Launch Complexwould be largely vacant, but would be crossed by a corridor of road, rail,power and water services, and would also contain the tertiary sewagetreatment plant.

The Launch Complex would require an area of 30 hectares focusing on twolaunch pads. Launch pads are constructed of reinforced concrete and supportthe launch vehicle over a flame trench. The launch vehicle sits in a steelcradle system. Built into the launch pad are piping systems that transfer thefuel and refrigerants, and cabling and control systems. Below the adaptor is adeluge system, which at the moment of launch, emits up to 0.13 Megalitres ofwater which is designed to reduce the impact of noise upon the delicatesatellite payload, and also reduces general launch noise levels and helpsprotect the launch pad. Each pad will contain a large storage facility for thedeluge water, although this has not been made entirely clear. This assessmentreport is based on the assumption that a water deluge system would be usedand a decision not to use deluge water would have implications for the noiseimpacts of a launch.

The flame trench design directs gases upwards at 45° to the ground line to thesouth east. Atop each launch pad would be a service tower for staff access tolaunch vehicles, and an umbilical tower for connection to power and controllines (37m tall). Each launch pad would have two adjacent lightning towers,and three towers for high intensity lighting required for night launches, allabout 70 m high.

The rail system leads to each of the launch pads, as does the sealed roadsystem, which also links to the technical plants which would be positionedbetween the two launch pads. The technical plants provide the propellants,gases and other services to the launch pads. The area will be bunded tocontain liquid spills. Pipelines connect the technical plants to the launch pads(these pipelines are not bunded). The following liquids and gases are stored:

Kerosene – up to 250 t in three tanks (one reserved to assist in the caseof a rocket requiring de-fuelling) and associated pumps and valves.The tanks would be nearly empty at the time of launch.

Liquid Oxygen – up to 750 t. Storage vessels are vacuum insulated andwould be nearly empty at the time of launch.

Nitrogen (250 t), Helium (5 t), and compressed air (42 t) would becontained in the compressed gas facilities – with compressors, valvesand reservoirs.


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A refrigeration system would also be located in the technical plant area toprovide chilled water and gases for cooling parts of the launch vehicle andpayload prior to launch.

Staff facilities would be provided in a building that would also containcomputers and automatic control equipment for operating all launch systems.This would be unmanned during launch.

3.2.1 Mission Control

The Mission Control building would be located about 2.5 km to the north ofthe Launch Complex, within mining lease 101 adjacent to South Point Road.The complex would be single level buildings with an area of approximately1000m2. All antenna and tracking systems would be operated from MissionControl. Tracking of launched vehicles would be carried out from hereduring the early stages of the flight. Later stages may require relays fromother tracking stations. Power would be supplied from a trenched linefollowing South Point Road from the power station at the Technical complex.Water supply would also connect from the road, while a small “packet plant”would provide sewage treatment services.

3.2.2 Administration and Residential Complex, Irvine Hill

The Irvine Hill area is to the west of the airport and the Draft EIS notes thatthe Island Strategy Plan highlights the suitability of Irvine Hill for residentialand light industrial development. It is intended that accommodation beprovided for up to 300 personnel during the operational stage of the project.On the expectation that personnel would be predominantly transient (fly-infly-out, many foreign technical experts), the accommodation would be in theform of two person self contained serviced apartments. The complex wouldalso contain a communal dining facility and communal passive and activerecreational facilities (the active facilities would be available to other islandresidents). The Irvine hill area is sixty hectares in size, and it is expected that10 hectares would be required for the complex. Design information has notbeen provided for the residential and administrative complexes. Theadditional information (P53) states that the design and planning of thecomplex would be in complete cooperation compliance with the local andstate planning authority’s requirements and guidelines. APSC further statesthat design will be undertaken with due consideration and attention to theexisting prevailing site conditions (terrain, landscaping, orientation, climate)and that the use of energy efficient systems such as solar heating andrecyclable materials will also be considered where possible. Due to theproximity of this proposed complex to existing township areas, weunderstand that there would be minimal effort involved in connecting toexisting power, water and sewage disposal services.


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APSC also proposes to provide approximately ten individual residences forthe more permanent operational personnel (senior managers). These houseswould be located within existing residential areas and would be subject tonormal design and construction approvals.

3.2.3 Roll-on Roll-off Facility

Sea freight would be used for the delivery of most construction materials,kerosene, and space fuels, and launch vehicle stages. Diesel would also arriveby sea, but it is intended that it would be delivered via the current fuelfacilities at Smith Point.

The Draft EIS presented two options for the provision of offloading facilitiesfor project freight transported by sea. These were: the use of the existingSeaport at Flying Fish Cove with some upgrading; and the construction of aRoll-on Roll-off (RO-RO) facility on the shoreline opposite Gaze Rd, just to thewest of Temple Court (Figure 4).

The RO-RO facility would be designed for transport ships that allow freightto be retained on trailers whilst on the ship and are thus able to be offloadedwithout the need for cranes. As with most of Christmas Island’s shoreline,the shore along Gaze Road is bordered by sea cliffs (7m high at the originalproposed RO-RO). The proposal would involve cutting into the cliff toreduce the height to about 2m above sea level, and linking this point to Gazeroad by a sloping ramp.

The Supplement states that on further review of the alternative of utilisationof the existing port, APCS decided that because of reasons concerning sharedusage, strict and limited availability and the physical constraints of the site,use of the port for the project’s sea freight was not a viable option (althoughon occasion APSC might use the existing port for general freight of goods).

While deciding to proceed with the RO-RO facility, the Supplement describesan alternative location for the facility. This alternative location was proposedin response to public concerns relating to the proximity of the original facilityto the Temple Court commercial and residential area. Submission 3 was aletter of objection specifically directed only at that aspect of the proposal andcarried signatures of 30 residents of the Temple Court area.

The preferred site identified by APSC is located between the southern side ofthe Police Station and the Gaseng Tanks (See Fig 5). This is on the Gaze Roadforeshore and in effect relocates the Gaze Road entrance to the RO-RO facilityapproximately 125m to the north. The major difference is that due to the factthat the cliff face is higher at this point, the concrete ramp/road cutting wouldbe angled at 45 degrees to Gaze Road in order to allow for a suitable grade.


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The loading platform is therefore further to the east – approximately 60 mfrom the Police Station. A horizontal platform 30m long by 20m wide wouldcreate a wharf area at the base of the ramp for unloading and loadingoperations. The platform would be lit at night and berthing dolphins(mooring devices) would be required to absorb the berthing energy of thevessel. The supplement states that a level area for short term storage ofunloaded goods can be accommodated at the head of the ramp to Gaze Rd.Run-off would be diverted into a storm water drain.


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Figure 4. Location of Roll-on Roll-off facility as proposed in the Draft EIS

from Draft EIS

Figure 5. Location of Roll-on Roll-off facility as proposed in the Supplement


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3.2.4 Facilities at Christmas Island Airport

Air transport will be used for transportation of personnel, visiting officialsand satellites. The draft EIS listed a range of possible additions or alterationsthat might be required at the airport (P5-21). The supplement narrowed thisdown to the need for the addition of a new aircraft apron and taxiway on thesouth end of the existing runway. Plans were not provided. The Draft EISalso mentioned the possibility of using Cocos Island as a staging point for thetransport of satellites to Christmas Island (due to limitations of the ChristmasIsland runway). The additional information states that APSC does not intendto pursue that option.

3.2.5 Infrastructure Corridors

The South Point components of the proposal would require provision ofcommunication, water and power infrastructure that are not currently presentat that end of the island.

While a power station would be constructed as part of the Technical Complexat South Point, APSC wishes to also be able to draw power from the existingChristmas Island Power Authority (up to 3 MW) as a contingency measure inthe event of a generator failure at the South Point power station during the 3day launch cycle when a full 12 MW will be required. A 20km power cablewould be trenched along existing roads and service routes. An optical fibrecommunications link would also be established between the township andSouth Point. APSC has stated that it would endeavour to install all servicesalong access corridors at the same time.

Additional water requirements would be sourced from Jedda Cave – afreshwater source in the central area of the island, that is already used as partof the town water supply. The Draft EIS proposed that the pipeline would beconstructed on low level concrete trestles above the ground, however theadditional information states that it is quite possible that the pipeline could beplaced below ground. This water supply would be used to supplement therainwater harvested at the technical complex and also serve as the watersource for the construction phase of the project.

3.2.6 Roadworks

Sealed roads would be constructed to service the South Point facilities. APSCis confident that the transport route across the island (made of crushed chalk)is of a sufficient standard for access and safety requirements and hascommitted to contributing to the upkeep of the road network due to expectedextra wear and tear. There may need to be alterations made at several points,including the roundabout near the wharf, the intersection of Murray road and


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Irvine Hill Road to accommodate the long haul vehicles required to move thelongest launch vehicle stages.3.2.7 Launch Vehicles

APSC propose to use Russian designed and manufactured launch vehicles.The vehicles would be transported to the island via sea. Transported acrossthe island by road and assembled at the Technical Complex.

The main launch vehicle that APSC proposes to use is the ARS-3K, designedby the Russian company, TsSKB Progress in Samara. The Progress plant isresponsible for the manufacture of the Soyuz family of launch vehicles.Soyuz vehicles are used for manned flights by the Russian Government.

The EIS notes that APSC is still negotiating to use other Russian launchvehicles. The most likely candidate is the new Angara range of rockets beingdeveloped by the Krunichev State Research and Space Production Centre(manufacturers of Proton Rockets) and being marketed by the LockheedMartin Corporation (USA). The supplement states that for the purposes ofenvironment assessment, the largest of the vehicles has been used as the basisfor impact assessment (Supplement p6).

The extent to which the technology, and expertise will remain with theRussian organisations is unclear at this time.

The ARS-3K launcher is a three stage launch vehicle with the following basicfeatures(See Fig 6):

3.2.7.1 First Stage

Four Strap-on “boosters are fixed around the central vehicle. These are firedon the ground and burn until fuel is exhausted (150-200 seconds, by which therocket has reach about 100 km). Each propulsion stage consists of a fuel tank,oxidiser tank, pressurisation system, rocket motor(s), steering system andother subsytems. At the end of stage 1 flight, the strap-ons are separated fromthe rest of the vehicle by explosive devices and fall to earth.

3.2.7.2 Second Stage

In the case of the ARS-3K, the second stage also ignites on the ground, butcontinues to burn after separation of the first stage. Once the fuel of thiscentral module is exhausted, it also separates from the remainder of thelaunch vehicle and falls to earth.

3.2.7.3 Third Stage


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The third stage of the launch vehicle takes the payload up into orbit. Launchvehicle flight computer and guidance systems are usually located in thisstage. APSC proposes to leave third stages in orbit on the basis that this iscurrent industry practice.

3.2.7.4 Kick Stage

A kick stage is sometimes used to manoeuvre payloads into a specific orbit.Kick-stages remain in orbit after disconnecting from the payload.

3.2.7.5 Payload

This is the satellite carried into orbit for APSC’s customer. The satellite isattached to the launch vehicle by a launch adaptor. APSC expects to launchthe following types of payloads:

Geosynchronous telecommunications satellites (main market);Low earth orbit communication satellites;Earth observation satellites;Scientific missions; and,Government sponsored payloads.

APSC has no plans for launching manned missions from Christmas Island.


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Figure 6. Typical Rocket Components (from APSC Draft EIS)

3.2.7.6 Payload Fairing

The visible nose of a rocket is actually a hollow casing which protects thepayload during flight. The fairing is explosively separated into two or threeparts once the rocket reaches heights where the air is thin enough andfrictional heating no longer poses a threat to the payload. The fairingcomponents fall to earth.

3.2.8 Fuel

Options for fuelling launch vehicles include solid fuels, hydrazine, keroseneand oxygen, and hydrogen and oxygen. APSC states that all launch vehiclesproposed to be used at the Christmas Island Launch Facility would be fuelledby kerosene and liquid oxygen. The Draft EIS indicates that both Kick stagesand payloads would be fuelled by di-methyl hydrazine and nitrogen tetroxide(P5-10 & 5-31). However recent advice from APSC indicates that APSC willnow use a kick stage fuelled with liquid oxygen and kerosene. The satellite


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fuels would be about 0.5%of the volume of launch vehicle fuels (APSC April2000). APSC does not propose to launch payloads that utilise nuclear fuel toproduce heat and electricity. This assessment is therefore set within thoseparameters.

3.2.9 Flight Termination System

APSC has not provided detailed information on all of the systems containedwithin a launch vehicle, nor would there appear to be any need for suchdetailed information to be provided for the purpose of environmental impactassessment. The flight termination system is of interest however, as it isinstrumental in determining how a malfunctioning launch vehicle is dealtwith. The flight termination system is located in the third stage of the launchvehicle. This is connected to components in each stage so as to enabledestruction of the rocket in the case of launch malfunctions such as deviationfrom the intended trajectory.

3.3 PROJECT CONSTRUCTION

APSC expects that construction would take eighteen months, and providedan indicative timetable of the construction program in Appendix E of theDraft EIS. APSC commits to full compliance with Australian standards interms of design and construction parameters and materials and equipment.Generally the proposal will be subject to building approvals under WesternAustralian legislation – through WA state regulatory authorities under serviceagreements with the Commonwealth Territories Office or by the Shire ofChristmas Island Council.

Construction would be a staged process, commencing with infrastructureupgrades (Roll-on Roll off facility, water pipeline, power supply and roadworks) prior to construction of the main South Point facilities.

Where possible, building components would be prefabricated prior toshipping to the island. Early shipments of materials would be delivered viathe current port facilities at Flying Fish Cove. Once the RO-RO facility is inoperation, shipments would switch to that facility, although the EIS alsoidentifies the option of transporting material directly to South Point using anoffshore barge and helicopter.

The EIS commits to the avoidance of unnecessary vegetation clearance and tono clearance of rainforest (there is a moratorium on the clearance of primaryrainforest on Christmas Island). It is estimated that construction at SouthPoint and Irvine Hill will require the disturbance of about 65 ha of land (thecondition of this land is discussed in the impacts section). The Draft EIS(p5-28) also states that about 20km of infrastructure corridors (along road


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borders) would be disturbed. With the power cable alone 20 km long, thismay be an underestimate.

As noted previously, the South Point facilities would be constructed onpreviously mined land. A feature of the earlier mining by hand of phosphateis that an odd landscape of sizeable limestone pinnacles has been left behind.This landscape can be found in some areas that would form part of theTechnical Complex and would have to be levelled and crushed andcompacted so that building platforms can be created. The Draft EIS states thatinvestigations to date have indicated that blasting would not be required forthe removal of limestone pinnacles (P9-1). Blasting impacts were thereforenot examined in the EIS, and have not been considered in this assessment.

It is expected that the construction workforce would be 150-170 people onaverage with a peak of 300 for about 7-8 months. The workforce would besourced from the Island where possible, with the bulk from the Australianconstruction industry. A number of Russian supervisors would also berequired. Some of the workforce would operate on a fly-in fly-out basis.

A temporary accommodation compound of demountable buildings would beestablished in the area between the proposed Technical and LaunchComplexes, and would be dismantled after use with the site rehabilitated.The compound would be fairly self contained – providing accommodation,dining and food preparation facilities for employees as well as fuel storage,maintenance workshop, vehicle and machinery parking and storage. Some ofthe support facilities such as catering, laundering, transport, cleaning andwaste disposal would be out-sourced to local businesses.

3.4 PROJECT OPERATION

3.4.1 Employment

APSC estimates that approximately 300 direct employees would be requiredfor the operational stage of the project. Of these about 50% would betechnical, 30% management and 20% support staff.

The specialist technical nature of much of the work (and possibly limitationson technology transfer) leads APSC to estimate that 60% of staff would beforeign trained experts, while the remaining 40 % could be recruited frommainland Australia and Christmas Island.

Satellite assembly and preparation would be handled by the satellite owners,and staff would visit the island for this purpose.


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The cyclical nature of the launch process would lead to variations inemployment levels, with some staff on the island for specific periodsassociated with a launch. While the normal operation of the facility wouldinvolve 12 launches a year, this will not occur until about the sixth year ofoperation, and there would be a corresponding rise in staff over that period.

3.4.2 Launch Operations

Launch vehicle assembly would begin 30 days prior to a scheduled launch.This involved unpacking stages, equipment installation, electrical andpressure testing, and installation of pyrotechnic (explosive) devices. Therocket stages are then joined together.

Satellite preparation can take up to 8 weeks. Once delivered by air, thesatellite undergoes a series of tests prior to fuelling. It is then transferred tothe hazardous processing bay for fuelling and the addition of pyrotechnicdevices and small solid rockets as required. Further tests are then conducted.

The satellite is joined to the adaptor and kick stage (if used) and is thenmoved across to the Launch Vehicle Assembly Building for assembly with thelaunch vehicle and fairing. The completed vehicle is then lifted onto aspecialised rail vehicle for transport to the launch pad.

The launch pad is prepared by checking all plumbing and connections. Thelaunch vehicle is taken slowly by rail (by remote control) from the TechnicalComplex to the Launch Complex. The launch vehicle is brought to an uprightposition and attached to the adaptor. The vehicle is then attached to theservice tower and umbilical tower.

The Draft EIS (P5-12) specifies weather conditions which may prevent alaunch. Prior to fuelling, the exclusion zone is evacuated. The fuelling iscarried our automatically and monitored from the Mission Control. Launchapproval is given by the launch safety officer subject to all conditions beingmet. These include the condition of the rocket, payload, and trackingfacilities, as well as weather conditions, clearance of local exclusion zones,and drop zones and flight path declared and cleared.

The ascent to a low earth orbit takes about ten minutes. During this time thelaunch vehicle is remotely monitored and the data is used to monitor the safeflight of the vehicle. Tracking will be carried out via satellite systems, existingdown range terrestrial stations, or by a down range ship.

3.4.3 Drop Zones


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APSC intends launching to the east, south-east and south (see figure 7). In thecase of south-east path, the exact direction may vary between 42 and 52degrees. Each launch will require the declaration of three drop zones for thereturn to earth of the first and second stages and the fairings. If the thirdstage was to be de-orbited, it too would require a drop zone.

The exact location of drop zones along the flight path will vary betweenlaunches depending on the payload size and model of launch vehicle. Dropzones can also be altered to avoid certain areas, although this may require alarger rocket for a given payload, or restrict the amount of fuel that can becarried by a payload. Drop zone ellipses are set at the 95 percent probabilitylimit (ie, 95% probability of the stage landing within the ellipse) .

The EIS provides information on the various notification procedures toinform shipping and aircraft of intended launches, flight paths and dropzones. During final launch preparation (3hrs before a launch and half an hourafter) aircraft using Christmas Island Airport will have to avoid a 5kmrestricted zone around the launch pad, while generally aircraft will be bannedfrom a 15km radius area around the launch site and extending 35 kmdownrange. From 30 minutes before a launch to 30 minutes after a launch allaircraft will be banned from drop zones. Sea exclusion zones will operate for4 hours before the launch until the all clear signal and will include the first 50km of the flight path as well as drop zones. These parameters may varyslightly, depending on the final decisions of the Space Licence and SafetyOffice.

Figure 7. Launch Directions from Christmas Island (note, some drop zones have been revisedin the Supplement)


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from APSC Draft EIS

3.4.4 Security

The Technical Complex and the Launch Complex would both be surroundedby security fences and a security check point would be located at the roadentrance to the Technical Complex.

APSC proposes that for a period of up to 24 hours before a launch, peoplewould be excluded from a land and sea exclusion zone in a 2 km radius fromthe launch pad. Viewing areas outside this radius would be established inconsultation with the Shire Council. The area would be secured by roadcheckpoints, patrols and light aircraft surveillance of the marine component.

Local notification of timing would include public notices (communitynoticeboards, boat ramps and roads crossing exclusion zone), radioannouncements, and newspaper advertisements. Local notices would be inall three Christmas Island languages.

3.4.5 Transport

Most transport associated with the proposal would be cross island – betweenvarious areas of the Dogs Head Settlement area and the South Point facilities.APSC anticipate that during the construction period, about 15 trips a month


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would be required to transport freight and construction materials across theisland. Personnel would be located at South Point during the constructionperiod, although they could be expected to visit the township. About 41 tripsper month would be required for rocket components and fuel during theoperational phase, as well as about 22 bus trips a day to transport personnelto and from the site.

Safety procedures for transportation of hazardous materials are discussed inthe Impacts Chapter.


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4 EXISTING NATURAL ENVIRONMENT

4.1 GENERAL

Christmas Island is located in the Indian Ocean, approximately 2,600 km westof Darwin , 2,600 km north-west of Perth, and 360 km south of Java. Theisland covers approximately 135 square km. The island has a typical tropical,equatorial climate with a wet season from December to April. The meanannual rainfall is 2109 mm.

The island is thought to have formed as a result of an undersea volcano thatrose to the surface, resulting in the formation of a coral atoll. The atoll latersubsided and then about 10 million years ago began to rise again – theterraced effect seen on the island today is a result of staged fringing reefdevelopment and erosion of sea cliffs prior to the next uplift. Soils arederived from either limestone sources, or in some areas basaltic extrusiverocks. The phosphate deposits found on the island are thought to be acombination of guano deposits and lagoon marine sediments.

Christmas Island can be viewed as a series of concentric terraces around anirregular plateau with lower terrace cliffs steeper and higher than the upperterraces. Deeper soils occur on the upper plateau and inland sides of terraces.

The immediate coastal zone is generally saline with thin soils. The zonedirectly behind that is also a harsh habitat for most plants, with Pandanus andsalt bush occurring in areas exposed to salt spray. Further inland, theenvironment becomes more sheltered and rainforest develops with structureand floristics determined by depth and type of soil. Coastal terrace forests aregenerally more open and drier than those on higher terraces (also dependanton the aspect, with SE coastal terraces being moist and closed), while theplateau rainforests possess a tall closed canopy with emergent trees to 45metres.

Other habitats include:

Ø limestone scree slopes, inland cliffs and pinnacles;Ø perennial springs and surface water (in areas where basalt comes to the

surface);Ø sea cliffs (average 10-20 m rising to 60 m);Ø karst formations (cave systems, overhangs, rock crevices and sinkholes);Ø Mangrove forest (50 m above sea level at Hosnie’s Springs – a Ramsar

site);Ø Minefields – often limestone pinnacles left after the removal of topsoil;Ø Beaches – coral and shell with a few sand beaches – Dolly and Greta

beaches providing turtle nesting habitat;


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Ø Shoreline rock platforms; andØ Marine – the shallow water area supporting corals and sand areas extends

50-100m out from land before the sea floor plunges deeper towards theJava trench.

Table 1. The following table lists threatened species listed under the Endangered SpeciesProtection Act 1992 and species of migratory wader which occur on Christmas Island, that arelisted under Japanese and Australian Migratory Bird Agreement (JAMBA) and the China andAustralia Migratory Bird Agreement (CAMBA),:

Type Scientific name Common name Listing* MB** RP†Mammal Crocidura attenuata trichura Christmas Island Shrew Endangered A

Pipistrellus murrayi Christmas Island PipistrelleBat

*

Bird Parasula abbotti (Sula abbotti) Abbott’s Booby Endangered J AAccipiter fasciatus natalis Christmas Island Goshawk Endangered FFregata andrewsi Christmas Island Frigatebird Vulnerable C FNinox squamipila natalis Christmas Island Hawk Owl Vulnerable FAnous stolidus pileatus Common Noddy C, JFregata minor minor Greater Frigatebird C, JPhaethon lepturus fulvus White-tailed Tropic Bird C, JSula leucogaster plotus Brown Booby C, JSula sula rubripes Red-footed Booby C, J

Reptile Chelonia mydas Green Turtle Vulnerable FEretmochelys imbricata Hawksbill Turtle Vulnerable FLepidodactylus listeri Tree Gecko VulnerableRhamphotphylops exocoeti Christmas Island Blind Snake Vulnerable

Plant Muellerargia timorensis EndangeredTectaria devexa EndangeredHuperzia phlegmarioides Vulnerable

* = potential candidate for listing under the ESP Act.** ‘MB’ Migratory Birds: ‘J’ = JAMBA; ‘C’ = CAMBA† ‘RP’ Recovery Plan Status: ‘A’ = Approved by the Minister; ‘F’ = Final Recovery Planprepared.Note: In August 1999 the status of the Christmas Island Goshawk was upgraded fromVulnerable to Endangered.

4.2 FLORA

There are 412 documented plant species on the island, with 17 endemic to theisland. Many of the plant species on Christmas Island can be found on theisland in a form and in habitat different to that with which they are usuallyassociated. Elsewhere they are found in open coastal habitats, whereas onChristmas Island, they can be found in elevated dense closed forests, formingpart of the canopy. There are also several plants which occur with verylimited distribution on Christmas Island.

The island has twenty five species of rare plants (Briggs and Leigh 1995), and,and two species are listed as endangered and one as vulnerable under theEndangered Species Protection Act 1992. The Draft EIS provides maps of known


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distributions for these species and short descriptions of the species andknown habitat. Table 1 shows endangered and vulnerable species.

4.3 FAUNA

The geographic isolation of Christmas Island has led to a high number ofendemic species and the development of unique natural history features ofthe native fauna. Of the 31 native vertebrate species that occur on ChristmasIsland, 20 species are endemic: five mammals, seven land and shore birds,three seabirds, and five reptiles.

Of the mammals, two rat species have become extinct since settlement, whilethe Christmas Island Shrew is listed as endangered and has not been sightedsince 1985. The Christmas Island Pipistrelle – a small insectivorous bat – hasdeclined markedly in the last decade for reasons not fully understood. Themain text of the Draft EIS (P6-26) fails to consider the most recent surveys andincorrectly states that the Pipistrelle “ … is well distributed over the islandand is also common”. The endemic Christmas Island Flying Fox iswidespread across the island.

Five of the six reptile species are endemic, and there has been a markeddecline of several species over the last decade. Opportunistic observationscarried out at various points on the island by Newsome and Bamford, whileconducting surveys for the EIS, noted this absence of native reptile fauna inareas where anecdotal accounts had them as common (Supplement Att V,P15).

Of the 11 native land birds (7 endemic) the Christmas Island Goshawk islisted as endangered, while the Christmas Island Hawk Owl is listed asvulnerable. The Island has been listed by the Birdlife International as a keyarea of bird endemicity.

Christmas Island is a world class seabird breeding colony. Three of the eightseabirds present are endemic to the island. The forest on Christmas Island isthe only remaining habitat for the endangered Abbott’s Booby; while theendemic and endangered Christmas Island Frigatebird is restricted to nestingin three areas in the north-east of the island. In discussing the third endemicbird – the Golden Bosun – Phaethon lepturus fulvus – the Supplement (p20)notes scientific debate concerning whether this bird is simply a colour morphof the more widely distributed White Tailed Tropic Bird, or actually a subspecies. While this has yet to be settled, it would be appropriate for thepurpose of this assessment to assume until proven otherwise that the GoldenBosun is a distinct subspecies restricted to Christmas Island. Six of theseabirds are listed under the Japan Australia Migratory Birds Agreement andsix are also listed under the China Australia Migratory Birds Agreement(see Table 1).


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The most striking feature of the invertebrate fauna are the 11 species of landcrabs including the numerous red land crab, the blue crab and the oncewidespread large robber crab which no longer occurs in most of its rangeelsewhere (due to deforestation and over-consumption). The Island’s landcrabs migrate to the ocean once a year to reproduce.

Less obvious is the internationally significant terrestrial and aquaticsubterranean fauna that occurs in the caves, crevices and groundwatersystems on the island and of which little is known. Fauna has been found inanchialine systems on the island. Anchialine habitats consist of bodies ofhaline waters, usually with a restricted exposure to open air, always withmore or less extensive subterranean connections to the sea, and showingnoticeable marine as well as terrestrial influences. They typically occur involcanic or limestone bedrock (Humphreys in press), and are vulnerable todisturbance. The Procaris species found on the island is one of only threespecies known from this genus – the other two are known from Hawaii andfrom Ascension Island in the south Atlantic. Information on thesubterranean fauna was provided in a submission by Dr W F Humphreys, asenior curator at the Western Australian Museum. Apart from anacknowledgment of comments on this issue in the supplement, the EIS didnot provide any details regarding subterranean fauna.

4.4 ISLAND ECOLOGY – FAUNA & FLORA INTERACTIONS

The EIS notes that the forest communities of Christmas Island are unusual inspecies composition because of the sparse vegetation cover in the understoreyand the occurrence in the closed forest of trees found elsewhere in opencoastal forests. These characteristics may be due in part to the presence of thered land crab found in abundance throughout the forest. Studies have shownthat the red crabs are a ‘keystone’ determinant of forest structure andprocesses (Green et al 1997 1998 1999), largely determining rates of seedlingrecruitment and litter decomposition.

The resulting forest provides important nesting habitat for a number ofseabirds including the Abbott’s Booby in the plateau forests. The terracerainforest supports the Christmas Island Frigatebird, while the shore Terraceforests are the breeding grounds for the Red Footed Booby.

The Christmas Island Fruit Bat, and a number of the land birds are importantfor pollination and seed distribution, while the land crabs may also beimportant for seed distribution.


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4.5 THREATS TO FAUNA AND FLORA

Historically island ecosystems around the world have been particularlyvulnerable to damage and degradation as a result of human settlement. Mostother islands in the Indian Ocean and the South-East Asia region are losinghabitat to expanding human populations and associated habitat destructionand degradation. Christmas Island possesses a relatively intact ecosystem,but, as indicated by the list of endangered and vulnerable species, it has andstill does experience a range of threats.

Phosphate mining operations have resulted in about 70 clearings in theplateau rainforest, adding up to a total of 32 km2 out of the 137 km2 island(25% of the island and 30% of the plateau area). The removal of soil hasdeterred regrowth, enabling the establishment of weed species. Gaps in therainforest canopy has also increased wind turbulence in adjacent areasimportant for the returning Abbot’s Boobies. Weed species have beenaccidentally introduced as hitchhikers on sea and air transport and freight, aswell as being deliberately introduced as food or garden plants. To date mostweed invasions have occurred in mined, disturbed or marginal rainforestareas. While generally this clearance has reduced habitat for species, some ofthe areas cleared and mined at the turn of the century have become valuablehabitat in itself, and some introduced species such as the Japanese Cherry areimportant food sources for the Imperial Pigeon and the Christmas Island FruitBat. There is currently a moratorium on the clearing of primary rainforest onthe island and the Christmas Island Rainforest Rehabilitation program isworking to rehabilitate mined areas.

Of the introduced vertebrates, the Black Rat may have been responsible forthe extinction of the native rats (via disease), while feral cats are numerousand widespread. There are five introduced reptiles – the South-East AsianWolf snake being of particular concern as it may possibly be having anegative impact upon the endemic Pipistrelle bat and native reptiles.

The introduced animal of most concern is the Yellow Crazy Ant, Anoplolepsigracilipes, which was accidentally introduced early this century. Recently thepopulation has exploded and formed multi-queened “supercolonies” atseveral locations. The ant sustains very high densities and systematicallywipes out red crabs, robber crabs, blue crabs and reptiles where supercolonieshave become established. Drs Green and O’Dowd and Professor Lake, havebeen studying this problem, and in their submission noted that the ant is alsoassociated with a sap-sucking scale insect and causing extensive canopydieback. The submission by Birds Australia notes that a forthcoming reviewof the status of Australian birds by S.Garnett will recommend that all endemicChristmas Island birds be listed as critically threatened as a consequence ofthe threat posed by Yellow Crazy Ants.


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The removal of land crabs already appears to have led to an increase inunderstorey vegetation in supercolony areas, while canopy dieback couldhave a direct impact upon seabird nesting areas. These are profound changesin the island’s ecology with unknown long term consequences. A three yearant Action Plan has been developed to better understand the ecology of theants and to trial and implement suitable control techniques to manage theirpopulations.

4.6 PROJECT SITES

4.6.1 Flora

The site of the proposed Technical and Launch Complexes at South Point ison a higher terrace separated from the surrounding coastal terrace by steepslopes and cliffs which are broken by an intermediate narrow terrace in someareas. The site itself is within the boundaries of a mining lease – ML100 – andhas been subject to mining for phosphate. Some areas have also beenpreviously used for phosphate processing, and for tailings ponds fromprocessing. The resulting landscape includes the dried tailings pondsurfaces, high areas of limestone pinnacles in the northern section, and morerecently and currently mined areas in the southern section. Apart from thecurrent and recently mined areas, the site is covered by a combination ofregrowth and weed species. The north and north west border is fringed byprimary rainforest and adjacent regrowth, while to the north-east, a fragmentof primary rainforest remains within the ML100 lease (adjacent to theproposed Technical Complex). The southern area is adjacent to cliff-sidevegetation.

The survey conducted for the EIS did not find any threatened or endangeredspecies within this area, although five of the island’s endemic species werefound within or adjacent to the area. Of the 96 plant species recorded on theAPSC site, 54 are known to have been introduced. The flora survey focusedon identifying the presence of rare and endangered flora and in our view didnot extend to a thorough examination of the habitat value of regrowth on thesites that may be cleared as a result of construction of the Technical andLaunch Complexes.

Based on current information, we do not support the conclusion in the DraftEIS that “This regrowth vegetation generally consists of colonising speciesand weeds, and is therefore of limited conservation value” (DEIS p9-8). APSCalso is of the view that current vegetation on the site is likely to be removedthrough proposed future mining activities prior to construction of APSCfacilities (DEIS p9-9). Christmas Island Phosphates (CIP) EnvironmentalCoordinator has informed us that:


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“CIP does not intend to clear any areas within ML100 that wouldinvolve clearing secondary regrowth or mature rainforest trees. Weare currently conducting secondary mining in this area which consistsof mining between pinnacles that were mined in previous years. Togain access to some area we have cleared vegetation, but only of theweed species Leucena” (Lynch, pers com 1999).

Similar concerns apply to the level of information available on vegetationcoverage of the proposed Irvine Hill Residential and Administrative area(which is covered by secondary regrowth and patches of primary rainforest)and any areas that may need to be cleared for additional airport facilities (theflora survey noted that some secondary regrowth in that area was graduallybeing replaced by trees associated with primary rainforest).

Recommendation 1: APSC, in consultation with the Christmas IslandConservator, should establish a comprehensive baseline by identifying areasof vegetation on the proposed Launch and Technical Complex that are ofimportant habitat value.

Recommendation 2: APSC, in consultation with the Christmas IslandConservator, should establish a comprehensive baseline by conducting floraand fauna surveys of the Administration and Residential Complex, and anyareas to be disturbed during construction of additional airport facilities.

4.6.2 Fauna

Fauna Surveys of South Point were carried out for the EIS in April 1999 (DEISApp l) and July 1999 (Supplement Att V). Fauna surveys were not conductedfor the Irvine Hill site. The surveys included systematic observations forbirds and reptiles, but only opportunistic observations for mammals.Fourteen sites spread across South Point were the focus of the original survey,with an additional four sites to the NW of the proposed South Point facilitiesadded in the second survey. Survey techniques used were:

Ø Opportunistic observations;Ø Fixed point census for Seabirds from points on the coastal terrace, and

cliffs overlooking the coastal terrace;Ø Area search for land birds. Searches were over an area of about 20 ha for

20 minutes and were located in each of the main vegetation types;Ø Hand searching for reptiles. Searches at three sites during daylight and

two sites at night. The report noted that conditions were not good forobserving reptiles with heavy cloud and frequent rain.

We believe that there are a number of issues that restrict the reliability of thesurveys conducted for the EIS:


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The survey found no Pipistrelle bats “despite driving at night just aftersunset, when the species is reported to be most active”. The submission on theDraft EIS by Dr Lindy Lumsden (one of the authors of a report on 1998 surveyresults) stated that the level of survey conducted for the EIS was inadequateand that ultrasonic detectors should have been used. The 1998 survey, whichmade use of ultrasonic detectors, detected 44 bat passes at a site very close tothe proposed Technical and Launch Complexes on South Point. In othercorrespondence Dr Lumsden has stated “While population densities arelower in the South Point area than they are in the west of the island, as thespecies is currently in decline and classified as Endangered, it is important toconsider all populations of the species. To comprehensively investigate thedistribution and abundance of the pipistrelle in this area further survey workwould be required, using ultrasonic detectors so that the data was comparableto our results. To determine how the species is using the area and the likelyimpact of the space station, it would be necessary to locate roost sites andforaging areas by radiotracking” (Lumsden pers com, March 1999). It shouldbe noted that in discussing APSC’s proposals for conducting surveys for theEIS, Environment Australia did advise that ultrasonic detectors should beused to detect Pipistrelles.

The final version of the Natural Impact Matrix (P30) submitted as part of theMarch 2000 additional information concludes that no commitment is requiredby APSC in relation to the Pipistrelle, as no bats were found in the faunasurveys.

Recommendation 3: APSC should establish a comprehensive baseline for theChristmas Island Pipistrelle Bat by conducting surveys of its distributionusing ultrasonic detectors, and where appropriate, radio tracking, in order toestablish the distribution and abundance of the bat on South Point. Thesurvey should be completed prior to the commencement of any constructionactivity on South Point by APSC and the survey design should be approvedby the Environment Australia.

The survey for reptiles was very limited, and none of the survey sitesidentified occur on the area to be disturbed by the proposal. The additionalinformation provided in March 2000 responded to a request for additionalinformation on this issue and explained that although none of the surveypoints shown on the map are within the project area, the map points are onlyindicative and that surveys at the points nearest the project area did indeedcover the site itself. While accepting this, we still view the level of effort insearching for reptiles on or near the project area as inadequate. The sitesearched that probably included parts of the Technical Complex was searchedfor 40 minutes on one evening by torchlight. The site searched closest to theLaunch complex was searched for one hour on one day. As noted in thegeneral discussion on fauna, there has been a marked decline of severalspecies of endemic reptiles over the last decade. The report for the April 1999survey by Newsome and Bamford (DEIS App l) noted that the Blue Tailed


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Skink, which was not found at all during a 1998 reptile survey of the island,has been reported from the artificial environment of pinnacle fields elsewhereon the island, and that it is therefore possible that it may be found in thepinnacle fields on South Point.

Recommendation 4: APSC should establish a comprehensive baseline, byundertaking a survey of the occurrence of endemic reptile species should becarried out in the areas that would be disturbed during the construction andoperation of the Technical and Launch Complexes on South Point. Thesurvey should be completed prior to the commencement of any constructionactivity on South Point by APSC and the survey design should be approvedby Environment Australia.

Some aspects of the approach used to survey seabirds were questionable (forexample, there were no surveys from the ground on the eastern coastalterrace), although, the surveys were sufficient to confirm previouslydocumented seabird distribution. Substantial improvements in the surveydesign will need to be made if a credible baseline is to be established formonitoring purposes. This is discussed further in the Natural ImpactsChapter.

Apart from these issues, the EIS provides a general picture of the occurrenceof fauna on South point, based on both the surveys and previous information.As with most other parts of the island, red land crabs were found in mostenvironments, other than in areas along the western coastal terrace wherecrazy ants were found. The Draft EIS assumes that on available data, allnative reptile species would be present in their preferred habitat on SouthPoint, but that activities on the areas proposed for the Technical and LaunchComplexes would be unlikely to directly affect any species other thanpossibly the Blue Tailed Skink. Two introduced reptile species were foundduring the surveys.

Christmas Island Fruit Bats were observed at several points along the WesternCoastal Terrace (note that ground surveys were not conducted on the EasternTerrace). A male, female and juvenile Christmas Island Goshawk weresighted on the eastern terrace less than 1km from the proposed LaunchComplex, as were relatively large flocks of the Christmas Island ImperialPigeon. A Christmas Island Hawk Owl was heard calling during a nightsurvey of the western terrace, and the surveyors conclude that given a totalisland population of 600 pairs, it is likely that a “reasonable” populationoccupies the south point area

Nine species of land bird and six species of seabird were recorded during theinitial survey. Of these, the Christmas Island Goshawk is endangered, theChristmas Island Hawk Owl is vulnerable, as is the Christmas IslandFrigatebird (although these were only seen in flight and are unlikely to neston South Point). During the second survey one Abbott’s Booby (endangered)


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was sighted in flight at a new survey site to the NNW of the project area. Thesurvey report noted that this may indicate that a pair nests in the area,although it may also have been a bird from the nearest Abbott’s Boobycolonies which are about 5 km from the South Point project area.

While the seabirds known to nest at South Point are not endangered orvulnerable, the seabird colonies on South Point are some of the mostimportant on an island that is itself recognised as an important seabirdbreeding site. In response to comments that the draft EIS did not fullyconsider this aspect, the Supplement provided further information on thisissue (P20).

The Supplement notes that while the actual proposed South Point site for theproject may represent less than 1% of the island, the development is on apeninsula and within a few kilometres of roughly 5% of the island’s terracerainforest. This may be an underestimate given that South point incorporatesapproximately 16% of the island’s coastline. The actual number of seabirdsestimated to nest on the coastal terraces of South Point are much higher thaneither 5% or 16% of the Island’s population.

Based on evidence from previous surveys, the 6000 pairs of Red FootedBoobies that nest on South Point make up 50% of the total Christmas Islandpopulation, while there are estimated to be a further 1,400 to 5000 pairs in therest of Australia. The Draft EIS recognises that the Christmas Islandpopulation is one of the largest in an estimated global population of onemillion.

In addition, South Point is a breeding area for 20% of the island’s BrownBoobies, 20% of the Red Tailed Tropic Birds, 25% of Golden Bosuns(subspecies endemic to Island), 40% of Common Noddys and 40% of GreaterFrigatebirds. In relation to the significance of the Red Footed Booby andGreater Frigatebird populations, the supplement notes that while these maybe significant in the Australian regional context, “The widespread distributionof these birds, however, and their occurrence in many protected areas, isreflected in their secure and stable global populations” (Supplement p19).

Apart from the estimates of global population numbers, no evidence isprovided to support this assertion. Contrary to this are reports of evidencethat across the globe “ … many seabird populations have become endangeredowing to the rapid acceleration of certain activities by man in marine areas…” (Nettleship et al 1994). In the case of Indonesia “Records from before 1960and the results of surveys carried out in 1981, 1987 and 1989 reveal thatIndonesian seabird populations are declining rapidly” (De Korte, 1991).Whilst these seabird species may be widespread, so are the effects of humanexploitation. Unless documentation is provided showing otherwise, it mustbe assumed that the seabird colonies on Christmas Island, and that on South


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Point are highly significant regionally, if not globally, and are currentlycomparatively secure from negative human impacts.

4.6.3 Karst Habitats

No attempt was made to determine whether subterranean fauna occurred incave systems or groundwater systems under South Point. The Supplement(p82) notes that reports and studies on Christmas Island cave systems havefocused on accessible caves in the north and central part of the island. Noobvious cave systems are known to exist on South Point. Cave systems haveoften been found on Christmas island through detection of sea cave openings.The remoteness of the South Point area and the commonly rough conditionson that side of the island have discouraged this practice.

Figure 8. Upper level chamber in Daniel Roux Cave, Christmas Island (this cave is not on South Point)

Photo courtesy of Rauleigh Webb

APSC notes that drilling work carried out as part of geotechnicalinvestigations for the project did not reveal any large cave systems beneaththe proposed facility. APSC’s position is that “At this time, APSC considersthat there is a possibility that cave systems do exist beneath South Point andhas structured its impact response accordingly”. APSC commits to discussingwith Parks North “ … the possibility of carrying out investigations over thenext several years into the presence or otherwise of cave systems beneath


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South Point and whether these are stable or contain valuable flora and fauna”(Supplement P83). Prior to this, during early launches, monitoring locationswould be set up within the nearest known cave systems.

The report on Geotechnical Investigations by ARUP Geotechnics for APSC(May 1999) was not provided to Environment Australia until after the requestfor additional information was made in March 2000. The document reportsthat investigations found that narrow, near vertical, open joints wereencountered in a number of boreholes including some in the area proposedfor the launch pads, while two larger cavities were encountered in boreholesin the vicinity of the proposed technical complex. The maximum amount offree space encountered in each borehole was around 10m, at the base of whichwas a loose bed of sandy gravelly debris up to a depth of 6m. The cavitiesbegan at 10 and 12 metres depth. The Geotechnical report concluded withrecommendations including that:

“ … further investigation must be carried out once the final designlayout of the Space Base has been determined. The purpose of theinvestigations will be to confirm that there are no large cavities, cavenetworks or adverse structural features in the rock … In particular,further investigation should aim to resolve the following issues:Whether the location of sinkholes between BH108 and BH109 and theoccurrence of deep open cavities in both of these boreholes represents apossible cave network in this area.”

While the focus of the geotechnical survey was on determining whetherappropriate bearing stratum existed for the proposed structures, the resultsindicate that there may be a potential cave system in the area, thus posing aquestion as to the occurrence of subterranean fauna. We are of the view thatAPSC’s commitment to consider further investigations in a few years time isinadequate given that insufficient data is currently available to gauge theimportance of the area to subterranean fauna, and that the geotechnicalsurvey clearly indicates that it is possible to obtain further information on anycave systems.

Recommendation 5: APSC must develop a proposal to conduct a survey forpossible cave systems and subterranean fauna on South Point focusing on theproposed site of the Technical and Launch Complexes and using nondamaging techniques such as ground probing radar. This plan is to beapproved by Environment Australia prior to the survey taking place. Areport on the survey results must be provided to Environment Australia andshould be taken into account in the development of the EnvironmentalManagement Plan for the project.

A final point in relation to the environmental value of the project areas onSouth Point relates to a comment made by Newsome and Bamford in theApril survey report (Appendix l p14) of the Draft EIS: “It is difficult to


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establish the significance of the South Point area to the endemic land birdsthat occur there because much of the original habitat has already been lost”.It should also be noted that a condition of mining leases on Christmas islandis that rehabilitation must occur prior to the end of the lease. Actions andcommitments by the proponents need to be contrasted not just against thecurrent environment, but also against what future improvement in the naturalenvironment may be forgone.


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5 OVERVIEW OF SOCIAL AND ECONOMICENVIRONMENT

5.1 HISTORY

Christmas Island was originally sighted and named by a British East IndiesCompany Captain William Mynors on Christmas Day 1643. The firstrecorded landing was by William Dampier in 1688 (Adams 1993), howeverthe island was not settled until 1888 following the discovery of indications ofrich phosphate deposits by the Challenger Oceanographic expedition. Mostof the workforce were indentured labourers recruited from China, Malaysia,the Cocos-Keeling Islands, Singapore and India. These workers sufferedisolation, low wages, difficult and dangerous working conditions, socialsegregation and inequality of rights in contrast to the Europeans on theisland.

The island was occupied by Japanese forces from March 1942 to August 1945,after which the island was administered as part of the Colony of Singapore.In 1958 sovereignty was transferred to Australia. It was not until 1981 thatAustralian residents status was available to residents of Christmas Island, andWestern Australian law only replaced Singaporean law in 1992.

Continuing poor conditions for labourers led to the formation of the Union ofChristmas Island Workers in 1975, and hunger strikes in Canberra in 1979which finally led to pay and conditions equivalent to those on the mainland(Curl 1997). The government operated mine closed in 1987, and attemptswere made between 1976 and 1989 to depopulate the island through a seriesof redundancy schemes for mine workers and government employees -causing many people to leave the island. The mine was reopened after twoyears with the workforce as majority shareholders.

The island economy diversified into tourism with the opening of theChristmas Island Resort Casino in 1993, but has suffered since the casinoclosed in 1998 with debts of almost two million Australian dollars. It wasrecently announced that the casino and hotel buildings are to be sold toAPSC.

5.2 ADMINISTRATION

Christmas Island is an Australian External Territory, with the responsibilityfor service coordination and delivery resting with the Commonwealth


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Department of Transport and Regional Services through the Territories Office.Services are provided by either:

Ø Christmas Island Administration (the on-island component ofTerritories Office);

Ø Christmas Island Shire Council (established in 1992 and operatingunder the Local Government Act 1995);

Ø Via Service Delivery Agreements with Western AustralianGovernment Departments; or,

Ø Through other Commonwealth departments and agencies.

The EIS provides details of the allocated responsibilities, and a range ofrelevant Commonwealth and Commonwealth/Western Australianlegislation.

A town plan was developed in 1994 in an environment of optimism regardingthe economy of the island, and earmarked several areas for expansion of thetownship. The decline in the economic outlook has since led to a revision ofthe plan. The submission from officers of the WA Ministry for Planning inOctober 1999 noted that the Shire of Christmas Island Town Planning SchemeNo.1 has previously been advertised for public comment and is soon to bepresented to the Minister for Territories for final approval. “The Scheme iscurrently being held in abeyance pending discussions between the Counciland the Commonwealth Island Administration regarding, among otherthings, the proposed release of sites for residential development”.

5.3 POPULATION AND CULTURAL DIVERSITY

There have been significant fluctuations in the island population over the pastdecade. The 1991 census recorded 1272 persons, in 1994 the population wasestimated at 2100 persons, while the 1996 census recorded a residentialpopulation of and estimated 1793 persons. The Draft EIS estimated thecurrent population at approximately 1700, while population projections in theMarch 2000 additional information worked from an existing population baseof 1400. Much of the change has been due to the changing fortunes of theresort and casino.

By ethnic groups, the community make-up is about 65% Chinese, many ofwhom are Buddhist, 20% Malay, most of whom are Islamic, the remainderCaucasian (Johnson, 1988(a)). In 1996, 60% of the population were classifiedas speaking languages other than English compared with 13% Australia-wide.Chinese languages were recorded as being spoken by 40% of the populationwhile 10% of the population listed Malay as the language spoken in the home.The diversity in languages creates a need for organisations such as the ShireCouncil and Christmas Island Administration to use interpreters.


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The strong cultural diversity of the island is visible through over a dozenTaoist and Buddhist shrines and temples located around the island. TheMuslim community focuses around the Kampong area where the Mosque islocated. The ethnic communities are also recognised through communityorganisations such as the Chinese Literary Association, the Islamic Council,the Buddhist Society and temple committees.

In 1996 only 5% of the population were aged over 55 years, while 32% wereunder the age of 15 years. The lack of educational opportunities past gradeten at the school results in low numbers of people in the 15-24 age group, witha lack of employment opportunities on the island discouraging people fromreturning after completing their education.

5.4 INFRASTRUCTURE

5.4.1 Education

The Christmas Island District High School caters for students from preschoolto year ten. Children are expected to board on the mainland for their finaltwo years of education at a subsidised cost. About 80% of the school childrenare from non-English speaking backgrounds. Chinese and Malay reading andwriting classes are offered on a voluntary basis and Mandarin is formallytaught at the school from year three. A Muslim primary school is located inthe Kampong.

There are no technical and further educational facilities currently available onthe island. Vocational training is provided by Indian Ocean Group Trainingwhich provides employment opportunities through traineeships andapprenticeships, short courses, Skillshare services, and by providing acoordination point for employers and potential trainers on Christmas andCocos Islands.

5.4.2 Health

Christmas Island has a well appointed, 9 bed hospital staffed by trainedmedical personnel. The island has two general practitioners. Residents haveaccess to the Patients Assisted Travel Scheme if they require specialisttreatment in Perth, and medivac facilities are also available in emergencies.

While the medical services are regarded as being of a high standardcompared to similar areas on the mainland, it should be noted that thecommunity does not have access to services in a nearby centre, or even a


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centre which could be reached by car. Medical evacuations have a turn-around time of twelve hours. Some inadequacies noted by the island’s socialworker (Johnston, L. 1998(a)) were:

Ø The need for one general practitioner position to be designated for afemale doctor;

Ø Absence of an overall health promotion and awareness strategy;and,

Ø Lack of structures to address social health factors of the community.

5.4.3 Social Services

The island has a full time social worker and a welfare assistant (one day aweek). Centrelink provides a part time agency service, while the WA LegalAid Commission provides a paralegal service two days a week and a visitingsolicitor every few weeks. Johnson (1998(a)) notes that NGO social servicesnormally expected in Australia such as disability services, meals on wheels,living skills, mental health services, youth services, emergency foster care,respite care, carer supports, community legal services, drug and alcoholservices etc are not present on Christmas Island. This is attributed to theisland’s ineligibility for traditional sources of NGO funding through Stategovernment and Commonwealth sources, and Lotteries Commission funds.

The Christmas Island Women’s Association has an unstaffed safe housewhich is used by an average of one family a month.

5.4.4 Housing

The population of Christmas Island is concentrated in the north eastern partof the island known as Dog’s Head. Five main residential areas make up thetownship – located on the coastal terrace and several higher terraces. There isa total stock of residences of about 750 units. The majority of these are flats,units or apartments. The standard of housing has been criticised asinadequate, and there has been efforts to upgrade the standard in the pastdecade. The Christmas Island Administration has commenced a program ofupgrading the existing stock of housing and building new public housingunits. Excluding the Island Resort staff accommodation, the currentoccupancy rate is over 95%. Housing costs are high, with rents ranging from$180 to over $500 a week. There is no equivalent of a state housing authorityand home loans tend to be more expensive due to bank’s concerns with thefragility of the island’s economy (Johnson 1998(a)).

5.4.5 Electricity

The diesel power station at Drumsite has a capacity of 12.5 MW, with currentusage of about 4.5 MW.


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5.4.6 Water

Because of the porosity of the soil, the presence of surface water is restrictedto a number of springs emerging where basalt flows intersect with thesurface. Drinking water is pumped and treated from a number of springs andunderground streams. Flow rates vary according to levels of rainfall. Shortterm storage is provided by above ground tanks with a capacity of 4.5 ML. In1995 water usage was four to five times higher than metropolitan Australia –possibly due to losses due to a degraded system.

5.4.7 Sewage

The town sewage treatment plant has a capacity of 4000 equivalent persons.The casino resort has an independent plant.

5.4.8 Waste Management

The island has one landfill site on the plateau with an adjacent second siteunder development. Difficulties with waste management on the islandinclude the high cost of removal of waste from the island, the need to protectthe groundwater, difficulty in disposing of oil wastes and the limited supplyof topsoil available to cover the landfill.

5.4.9 Policing

Police services are provided by the Australian Federal Police. At the time ofthe Draft EIS, there were eight permanent police officers, seven specialconstables and two administrative personnel. The AFP is also responsible forcustoms and immigration, while there is one full time officer from theAustralian Quarantine and Inspection Service on the island.

5.4.10 Road

There are about 140 km of road on the island. Urban roads are generallysealed with bitumen, while the main roads outside the urban area aresurfaced with chalk. Five organisations have responsibility for roads on theisland, with the Shire Council acting as a central road authority. The islandhas a limited bus service for the school, while cycling is limited by the steephills and distances between the sections of the township. There is a high levelof vehicle ownership.

5.4.11 Off-Island Transport

The seaport at Flying Fish Cove has facilities for bulk handling and containerships. A separate handling facility for diesel fuel shipments is at Smith Point.


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The port can be closed for several days at a time during an annual period ofheavy swells. The draft EIS refers to the longest closure having been 54 days,however the March 2000 additional information states that the maximumperiod is 10 days. Phosphate shipments are now 700,000 tonnes a year withabout 130 ships a year using the facilities (McGovern pers com 1999). Airflights are on a weekly (or more frequent in school holidays) basis from Perth(also servicing Cocos Island), and on a weekly basis to and from Jakarta via acommunity charter organised by local businesses. The airport is a 24 hour,sealed, all weather runway, capable of taking heavy aircraft.

5.5 BUSINESS AND INDUSTRY

Phosphate mining has been the basis of the Christmas Island economy formuch of its history, although its importance has declined recently to someextent. In 1997 the mining lease held by Christmas Island Phosphates coveredabout 20 square kilometres, at which time Christmas Island Phosphatesnegotiated with the Commonwealth to extend the mining lease for a further21 years from February 1998. The mine employs about 140 people.

During the period when the casino resort was operational (1993-98), tourismbecame an important component of the island economy. The resort itselfemployed about 325 people, of whom 110 were locally recruited. Someattendees at the community meetings held for this assessment commentedthat the actual number of people locally employed and contractingopportunities offered to local businesses was less than had originally beenexpected. In 1995 the resort attracted 30,000 visitors. The injection of wagesand business opportunities associated with the resort and increased touristnumbers was a significant boost to the island economy. In addition, anagreement between the resort owners and the Commonwealth required theowners to pay 1% of gross casino profits to a Community Benefit Fund everyquarter. The fund was administered by an advisory committee on behalf ofthe Minister for Transport and Regional Services. The funds were used forprojects such as building upgrades and sport and recreational facilities, withsome money also directed to identified at-risk groups (Johnson 1998(a)).

The close of the resort casino had a significant impact upon the communityand the economy. Apart from the direct reduction in employment, there wasalso a significant reduction in the population; higher cost and very reducedair services; businesses affected by the decline in tourists and population(leading to more unemployment); and the loss of community assets such as achildcare centre closed due to a reduction in the number of working parents.

The unique natural features of Christmas Island still attract a number oftourists who are catered for by several small accommodation establishments.


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The island also has a range of small businesses including supermarkets, cafesand restaurants, diving and fishing charters, and speciality shops.

Christmas Island Administration, the Department of Education and the ShireCouncil are also major employers on the island.

5.6 SOCIAL FACTORS AND LIFESTYLE

Johnson (1998(a)) describes Christmas Island as a safe, open and genuinelymulticultural, welcoming, community. There are numerous and active anddiverse community organisations with events open to all. The active andvibrant nature of the community is reflected in the contents (oftenmultilingual) of the Christmas Island Newsletter, and the events noticeblackboard at the roundabout. The range of active faiths on the island is quitevisible and brings an added dimension to the community probably unique inAustralia.

The official crime rate is quite low given the risk factors such as isolation,cheap alcohol, unemployment, and racial mix present. Residents regularlyleave their houses and cars unlocked as part of the relaxed lifestyle on theisland. A small increase in minor property offences was noted while thecasino was operating (Spence pers com 1999). The isolated nature of theisland discourages large property offences.

Johnson (1998(a)) suggests that the official crime rate might conceal a muchhigher rate of unofficial or unreported crime that may be dealt with internallywithin sectors of the community. Issues such as domestic and family violenceand alcohol and drug abuse may be regarded as internal problems.

A number of attendees at the community consultation meetings stressed thevalue of the lifestyle on the island and were cautious of anything that mightthreaten this.

Johnson is of the view that some features of the resort casino and its closurehad negative impacts upon the community. Apart from the economicimpacts, other impacts included:

Ø Damage to some important community alliances;Ø An increased sense of insecurity and some loss of belief in the

future of the island; and,Ø An increased sense of isolation and conflict , pointing to a shift

toward social dysfunction.

“The impact of the Resort’s closing has been dramatic for several reasons.First, the Resort did not integrate well with the island community, and it did


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not sufficiently consider local perspectives in its decision making. As a result,when it closed and the operators left the island owing money, it wasexperienced by the community as a betrayal.

Secondly, there is a sense that the Resort owners came to the island promisingemployment, training and a better quality of life, then left the people and thecommunity worse off.”

5.7 CULTURAL HERITAGE

The Draft EIS provides an overview of Christmas Island’s built culturalheritage. Most of the island is listed on the Register of the National Estate as aNatural Area, while there are a number of items listed for historic valuesincluding building groups and precincts representing different aspects ofcolonial, industrial and Asian architecture, in some cases very different fromanything found on mainland Australia.

Of particular interest to this proposal is the listing of the South PointSettlement Remains – the settlement on South Point was used to house manyof the labourers working on the mine between 1914 and 1974. The residentialarea was demolished in 1977 to allow for mining beneath the location of thebuildings. Apart from ruins of the railway station and other structuralremains, the key feature of the area today are the Chinese South Point Templeand two small shrines, still in active use and important to the Chinesecommunity on the island.

The second particularly relevant listing is the Settlement Services Precinct.The buildings and streetscapes in this area are representative of architecturederived from the British experience in Singapore and Malaya, as well asChinese terrace houses, all with historical significance. The proposed Roll-onRoll-off facility would be located within the Settlement Services Precinct,which has now become a key commercial area on the island (and also hassome residential areas ).


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6 POSSIBLE IMPACTS UPON THE NATURALENVIRONMENT AND IMPACT AVOIDANCE ANDREMEDIATION.

6.1 CONSTRUCTION HABITAT DISTURBANCE AND CLEARING

As noted in the project description, APSC estimates that about 65 ha of land ofvarying condition would be directly disturbed during the construction of theproposal. Information regarding the extent of proposed clearing in the DraftEIS was at times inconsistent. In response to a request for clarification, asummary of measures relating to clearing, rehabilitation and revegetation wasset out in the additional information provided in March 2000. In relation toconstruction activities, the proponent included undertakings to:

Ø Locate and describe significant species and their populations andhabitat – map and estimate extent of significant species on site forbaseline and monitoring;

Ø Avoid all unnecessary vegetation clearance;Ø Mark and protect all threatened flora species during construction

and operation – install protective fencing around identifiedthreatened species;

Ø Monitor significant species on site and avoid disruption to anyenvironments deemed to be significant habitat.

As noted in the existing environment section, further work needs to becompleted on vegetation surveys and habitat identification. The loss of largeareas of vegetation due to the negative impacts of past activities on the islandhas meant that degraded habitats and secondary regrowth may currently beimportant for the survival and recovery of populations of some species (suchas the Imperial Pigeon and Blue Tailed Skink, Christmas Island GlossySwiftlet and Christmas Island Goshawk). It may therefore be necessary forthe layout of buildings and infrastructure to accommodate the retention ofimportant disturbed habitat and secondary regrowth.

The Draft EIS explained that cleared vegetation would be burnt. Both ParksAustralia and Christmas Island Administration suggested that clearedvegetation could be mulched rather than burnt. In response, APSCcommitted to assess the options for mulching lighter vegetation as part of siteclearing and explained that large logs and trunks would be scattered over thesite to provide habitat where not a safety hazard (Supplement PII-52).Mulching of vegetation already occurs on the island (eg, by Parks AustraliaNorth) and obviously produces a more desirable product.

Layout plans have not been provided for the proposed residential andadministrative facilities at Irvine Hill. The additional information states that


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the Irvine Hill area is 60 ha in size, or which 10 ha will be required. APSCproposes to wait until the location of the 10 ha development has been decidedbefore a fauna survey is undertaken. This approach bypasses consideration ofenvironmental considerations in deciding which area to develop.

Construction of the Roll-on Roll-off facility will most likely cause somedisturbance to the immediate sea floor. The EIS notes however that the seafloor adjacent to that area of cliffs has already suffered degradation due to thepresence of a number of stormwater outfalls in the area. The condition of thesea floor communities past the “drop-off”, where the level falls away quickly,is less certain and no information on surveys is provided.

While power and communications infrastructure would be placedunderground, it is proposed that the water pipeline be placed above groundon low trestles. An underground pipeline would generally have less of animpact upon areas it passed through in terms of appearance and lowermaintenance requirements. The towns main water pipeline from Jedda cave toDrumsite tank is currently being put underground.

The route for the water pipeline from Jedda Cave to South Point passesthrough an area of national park, which would require specific approvalunder the National Parks and Wildlife Conservation Act 1975.

The EIS commits APSC to rehabilitation of areas as soon as possible afterconstruction activity has ceased in a given area. The Flora and FaunaManagement Plan indicates that revegetation would be with native, lowgrowing shrubs in conjunction with native grasses where low vegetation isrequired. While it is appreciated that areas immediately adjacent tobuildings, and within areas required to be empty for safety purposes mayrequire any vegetation to be low growing, other areas such as the large emptyarea between the Technical and Launch Complexes should be able to berevegetated with the object of creating habitat as close as possible to the area’snatural state. Rather than simply discussing rehabilitation and landscapingprograms with Parks Australia North (as stated p44 of AdditionalInformation), it would be appropriate for these plans to be approved byEnvironment Australia as part of the overall Environment Management Plan.

Recommendation 6: The layout of buildings and infrastructure in all areas ofthe proposal must be designed as far as possible (without compromisingsafety requirements) to avoid necessitating the clearance of importantregrowth habitat during construction. Project layout and construction mustnot involve the clearance or damage of primary rainforest. Buffer zones atleast 20m in width, consisting of regrowth vegetation or rehabilitated areasmust be left between primary rainforest and project areas. Clearedvegetation must not be burnt and should be mulched where possible. APSCmust obtain the approval from Environment Australia for vegetationclearance prior to construction commencing.


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Recommendation 7: Rehabilitation and landscaping plans must be developedas part of the Environment Management Plans to be approved byEnvironment Australia.

Recommendation 8: The water pipeline from Jedda Cave to South Pointmust be placed underground. Placement of the pipeline through a section ofnational park will require separate consideration under the National Parksand Wildlife Conservation Act 1975 or Environment Protection andBiodiversity Conservation Act 1999.

Clearance and construction activity may result in the spread of weeds, edgeeffects (such as increased levels of predation by native or introducedpredators), and the spread and/or dislocation of feral animals. APSC hascommitted to the monitoring of weed infiltration, eradication of weeds andthe design of road and infrastructure corridors to prevent weed infiltration.In relation to the potential dispersal of exotic fauna, the Natural ImpactMatrix (p22) states that APSC will cooperate in any eradication programsproposed by Parks Australia North, while the Flora and Fauna ManagementPlan states that the responsibility for eradication of feral animals from the sitewould be the responsibility of APSC Environmental Officer in conjunctionwith Parks Australia North.

Earthmoving equipment could be a transport vector assisting the proliferationacross the island of the Yellow Crazy Ant. This is particularly significant withthe construction of water pipelines and underground infrastructure requiringthe excavation and transportation of soil. The EIS does not consider the needfor sterilisation or decontamination of earth moving equipment for eithercrazy ants or harmful soil micro-organisms.

Recommendation 9: The cost for control of feral animals on project sites andferal animals dispersed to adjacent areas as a result of construction activitymust be met by APSC. Control techniques must be approved by ParksAustralia.

Recommendation 10: A strategy for the prevention of transportation of theYellow Crazy Ant and soil micro-organisms through the movement ofearthmoving and construction vehicles must be developed and implementedas part of the Environment Management Plan.

In planning the construction activities, APSC will also need to be mindful ofthe requirements of Part 3 of the Regulations of the National Parks and WildlifeConservation Act 1975, which makes it an offence to injure, kill or interferewith wildlife unless the wildlife is unprotected. Similar regulations areanticipated for the Environment Protection and Biodiversity Conservation Act1999.


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6.2 TRANSPORTATION IMPACTS

6.2.1 Quarantine

The proposal involves the creation of at least two if not three new entry pointsto Christmas Island:

Ø Roll-on Roll-off Facility, settlement;Ø South Point landing of construction materials by helicopter

(temporary 2-3 months);Ø Additional offloading area at airport (uncertain).

Both the construction and operational components would involve periods ofsignificant increases in traffic onto the island. As noted in the description ofthe existing environment, introduced plants and animals have had andcontinue to have a significant impact upon the environment of ChristmasIsland. The Draft EIS (P9-8) notes that construction materials will be derivedfrom existing quarry sources on the island, or imported from mainlandAustralia. Although this narrows down the range of possible introductions,the possibility of, for example, phytopthera being introduced to the islandwith a load of sand is a good reason for strong enforcement of quarantinecontrols. The Draft EIS also notes that a mosquito vector for Dengue Fever –Aedes albopictus – is present on the island, although the disease itself is not.Increases in the number of visitors to and from Asia (for example, projectworkforce travelling on leave) could increase the chances of establishment ofdengue fever on the island.

In relation to comments on the new entry points, the Supplement (PII-59)states that this issue will be discussed with the Australian Quarantine Service.In relation to the possible increased risk of disease introduction, the NaturalImpacts Matrix (P31) concludes that no commitment is required by APSC asalthough there may be potential, severe, long term impacts on the health ofthe island population, this risk is no higher than that associated withincreasing tourism. A more active approach by APSC would involveinclusion of awareness of quarantine procedures and requirements inintroductory training for all employees and contractors.

The submission on the draft EIS by the Manager of Operations of the WesternAustralian Region of the Australian Quarantine and Inspection Serviceexplained that a Quarantine Officer was supplied on Christmas Island on a100% cost recovery basis arrangement with the Department of Territories andRegional Services, although this arrangement was under review with thepossibility of quarantine services being supplied by trained and auditedresident(s) of the island. The submission observed that “Provided thatsuitable facilities are available to undertake inspections and treatments ofimported cargo, containers and adequate suitably trained inspection staff are


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available, it is not anticipated on the information available that there wouldbe any significant environmental impact on the island”.

Recommendation 11: APSC must include awareness of quarantine proceduresand requirements in introductory training for all employees and contractors.

Recommendation 12: APSC, in consultation with the Australian Quarantineand Inspection Service, must construct appropriate quarantine facilities atall new points of entry to Christmas Island that are established as part of theproposal.

Recommendation 13: Territories Office must ensure that adequate levels ofsuitably trained inspection staff are available to undertake quarantineinspections and treatments of the expected increased levels of cargo andcontainers arriving on the island as a result of the proposal.

6.2.2 Roadkills

The annual migration of land crabs to the sea gives the issue of roadkills aparticular significance on Christmas Island. However, even at other times ofthe year vehicle collision with animals have an impact upon land crabs andother animals such as the Christmas Island Hawk-Owl. The submission fromBirds Australia notes that road-killed owls are regularly found in areas ofhigher traffic density and suggests that a marked increase in the island’shuman population might limit the population density of owls in settled areaswhere traffic density was highest. Safety requirements involving separationof facilities can increase the use of motorised transport within a launchfacility. Wildlife studies at Kennedy Space Centre in Florida have noted theimpact of road mortality and the potential for measures such as culverts andunderpasses to provide corridors for movement (Breininger et al 1994).

The possible increase in red crab road mortality was an issue raised by severalpublic and government agency submissions.

Measures APSC proposes to take that may decrease the level of impactinclude:

Ø Design of the security fencing at the Technical and LaunchComplexes to exclude all crabs (including young crabs);

Ø Bus transport for staff to reduce cross-island road use;Ø Cooperation with Parks Australia North during the period of crab

migration to minimise impacts to ensure that sections of the roadsexperiencing high crab migration numbers are avoided or trafficminimised;

Ø Making use of flexibility in bringing fuels and components to theisland and flexibility in timing of transportation across the island;


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Ø Use of the most appropriate roads between Settlement and SouthPoint;

Ø Driver education program for all employees;Ø Use of low growing shrubs to break up large grassed areas that

may attract birds.

The Fauna and Flora Management Plan (Supplement Att IV ) states that APSCwill “support installation of crab tunnels along newly constructed roads” andwill audit the effectiveness through “estimates of crab migration numbers inareas with and without crab tunnels”. However the Supplement itself (PII-53)is less certain about this, stating that “There appears to be little informationabout the cost effectiveness of existing crab crossings as a means to reducecrab mortality during peak migration periods”, and going on to list measuresthat APSC consider more appropriate (see above).

The Christmas Island National Park Draft Plan of Management (p74) lists theprovision of crab tunnels under roads to have proved effective, althoughmore cost effective designs need to be found .

Recommendation 14: In addition to APSC’s commitments in the EIS, APSCshould record instances of significant avifauna road mortality, both on theSouth Point project area and during cross-island transportation and reportinstances to the Conservator (monthly). Modification of transport activitymay have to be made if Environment Australia determines that levels of roadmortality may endanger or further endanger native species. APSC shouldinstall crab tunnels under new and existing roads at points to be determinedby the Conservator, and should contribute to the maintenance of existing crabtunnels.

6.2.3 Transportation of Hazardous Substances

APSC estimates that the following fuel delivery trips will occur between portfacilities and South Point each month:

Ø Kerosene: 15 trips over five days;Ø Diesel fuel: 16 trips over eight days;Ø Unsymmetric di-methyl hydrazine (UDMH) and Nitrogen

Tetroxide (NTO): One trip (one UDMH trip every three months,two NTO trips every three months).

The Draft EIS provides details of vessels in which Kerosene, UDMH and NTOare transported in, properties of the fuels, methods of road transport andassociated safety procedures. Further information on transport routes andanalysis of impacts arising from the transportation of fuels (including spills)was provided in the Supplement (P40-47).


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In response to requests for information regarding transport of diesel fuel, theSupplement (PII-23 & II-13) explained that diesel fuel would be delivered as itis currently on the Island via the facility at Smith Point, pumped to the fueldepot adjacent to the existing power station from where it would betransferred to a road tanker (carrying 12.5 kL) for delivery to South Point.Consideration of the risks and impacts associated with the transportation andstorage of diesel fuel has not been supplied by APSC.

The EIS explains that rocket propellant kerosene is similar to aviation turbinefuel, used commonly by jet aircraft. The fuel will be offloaded at the Roll-onRoll-off facility in large ISO approved containers, similar to those currentlyused to transport jet fuel to the airport. The possible environmental impactsof kerosene have not been effectively discussed in the EIS. In response to arequest for additional information on this, APSC responded in the March 2000additional information report (P41) by referring back to chapter 8.4.1 of theSupplement. While the supplement describes how an uncontained spillcould, in a worst case scenario of a large spill (1000+ litres), pass through theporous soil and enter the groundwater supply where many of the toxiccompounds tend to persist and recovery “will be virtually impossible”, thereis no description of how the presence of kerosene in soils and groundwatermay impact upon flora, fauna and the human population. Without thisinformation, we must assume that in such a worst case scenario, there will bea significant negative impact.

The supplement does provide information on how a surface spill might becontained, contaminated soil treated, and how contaminated groundwatermight be pumped to the surface and treated.

The Draft EIS provides an outline of the hazardous nature of NTO andUDMH (P5-31 and P5-36) and Appendix B contains the “Statement ofHazardous Nature: Hazardous According to Worksafe Criteria”. Furtherinformation regarding the persistence of the chemicals in the environmentand the likely environmental impacts was provided in Chapter 8 of thesupplement. Environment Assessment Branch sought further informationfrom the Hazardous Substances Unit of the National Occupational Health andSafety Commission (Mazurski pers com Feb 2000).

UDMH is a highly toxic substance classified as a dangerous good under the“Australian Code for the Transport of Dangerous Goods by Road and Rail”.Classification by the National Occupational Health and Safety Commissiondescribes UDMH as a substance that is highly flammable, may cause cancer,is toxic by inhalation and if swallowed, and causes burns. Dr Mazurski sumsup its hazardous nature as follows:

“As such UDMH would be classified as hazardous because of its carcinogenicity atconcentrations of 0.1% or more. In the Exposure Standards for AtmosphericContaminants in the Occupational Environment [NOHSC:1003 (1995).UDMH is listed


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with an atmospheric exposure standard of 0.01ppm with a carcinogen and skinnotation. Since only a handful of chemicals have lower exposure standards in thislist, it may be considered a highly hazardous chemical, particularly in terms ofchronic atmospheric exposure.

Patty's Industrial Hygiene and Toxicology (1998) report several incidents of humaninhalation exposure to UDMH have occurred. Symptoms of exposure includedrespiratory effects, nausea, vomiting, neurological effects, pulmonary edema, andincreased serum glutamic pyruvic transaminase (indicates liver damage).

The NAERG (North American Emergency Response Group) classifies UDMH asfollows:TOXIC;· May be fatal if inhaled, ingested or absorbed through skin.· Inhalation or contact with some of these materials will irritate or burn skin and eyes.· Fire will produce irritating, corrosive and/or toxic gases.· Vapors may cause dizziness or suffocation.· Runoff from fire control or dilution water may cause pollution.

With respect to fire safety concerns NAERG (North American Emergency ResponseGroup) classifies UDMH as follows:HIGHLY FLAMMABLE:· Will be easily ignited by heat, sparks or flames.· Vapors may form explosive mixtures with air.· Vapors may travel to source of ignition and flash back.· Most vapors are heavier than air. They will spread along ground and collect in low

or confined areas (sewers, basements, tanks).· Vapor explosion and poison hazard indoors, outdoors or in sewers. Some may

polymerize explosively when heated or involved in a fire.· Runoff to sewer may create fire or explosion hazard.· Containers may explode when heated

NAERG (North American Emergency Response Group) recommends for UDMH,when a spill or leak occurs the area is to be immediately isolated for at least 100 to 200meters in all directions on public safety grounds. If a tank is involved in a fire, isolatefor 800 meters in all directions; also, consider initial evacuation for 800 meters in alldirections.”

Nitrogen tetroxide is an extremely poisonous, oxidising and corrosive gasclassified as a dangerous good under the “Australian Code for Transport ofDangerous Goods by Road and Rail”. NTO exposed to air rapidly formsnitrogen dioxide (a noxious and toxic gas). Reaction with water will producehighly corrosive nitric and nitrous acids, which are sever irritants to skin,lungs and eyes. This may later produce nitrates. Dr Mazurski sums up itshazardous nature as follows:

“NTO is classified in the List of Designated Hazardous Substances as follows

ClassificationVery Toxic (T+)R26 Very toxic by inhalation.Corrosive (C)R34 Causes burns..


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As such NTO would be classified as hazardous because of its inhalation toxicity atconcentrations of 0.1% or more. With respect to its industrial use NTO (or NDO, see below)are used in the manufacture of other chemicals (e.g., nitric acid and ammonia fertiliser), aschemical manufacturing intermediates, nitrating agents, oxidising agents, as polymerisationinhibitors for acrylates, and as catalysts. In air, nitrogen tetroxide liquid vaporises anddissociates to form gaseous phases of nitrogen tetroxide, nitrogen dioxide (NDO), and nitricacid (mist). NTO is a thick, heavy, greenish liquid that is very volatile (its vapor pressure isabout 50 times that of water and 5 times that of acetone). Its yellowish to reddish brown vapor,which is due to the nitrogen dioxide (NO2) resulting from the N2O4--NO2 equilibriummixture, has a pungent odour similar to bleach. Because of the rapid formation of NDO fromNTO in air the atmospheric exposure standard for NDO is relevant to NTO use. In theExposure Standards for Atmospheric Contaminants in the Occupational Environment[NOHSC:1003 (1995)]. NDO is listed with an exposure standard of 3ppm.

Patty's Industrial Hygiene and Toxicology (1998) report that mild exposure intoxication mayinduce transient nonspecific symptoms, including cough, dyspnea, headache, nausea, vertigo,fatigue and somnolence, which typically dissipate over the following hours to days, but maypersist up to 2 weeks without pulmonary abnormalities detectable by clinical examination.More commonly described in the industrial medical literature is a multiphasic course ofdisease that can be fatal if untreated. An individual may experience a variety of acutesymptoms, including cough, dyspnea, wheeze, chest pain, heart palpitations, weakness,sweating, nausea, vomiting, headache, and eye irritation during or shortly after exposure.

The NAERG (North American Emergency Response Group) classifies NTO as follows:

TOXIC· May be fatal if inhaled or absorbed through skin.· Fire will produce irritating, corrosive and/or toxic gases.· Contact with gas or liquefied gas may cause burns, severe injury and/or frostbite.· Runoff from fire control may cause pollution.

With respect to fire safety concerns NAERG (North American Emergency Response Group)classifies NTO as follows:· Substance does not burn but will support combustion.· Vapors from liquefied gas are initially heavier than air and spread along ground.· These are strong oxidizers and will react vigorously or explosively with many materialsincluding fuels.· May ignite combustibles (wood, paper, oil, clothing, etc.).· Some will react violently with air, moist air and/or water.· Containers may explode when heated.· Ruptured cylinders may rocket.

NAERG (North American Emergency Response Group) recommends for NTO, when a spill orleak occurs the area is to be immediately isolated for at least 100 to 200 meters in all directionson public safety grounds. If a tank is involved in a fire, ISOLATE for 800 meters in alldirections; also, consider initial evacuation for 800 meters in all directions.

By bringing these fuels to the island and transporting them across the island,the proposal will create a number of possible scenarios which could causeharm to the environment and/or human health:

6.2.3.1 Spillage into marine environment

Spillage could occur while containers are offloaded onto the island. TheSupplement (P45) states that kerosene is moderately to highly toxic to aquaticlife (dependent upon the type of kerosene). A kerosene spill would float onthe surface and would evaporate and disperse within 24 hours. Spills ofUDMH or NTO could have a locally severe impact resulting in the death of


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marine organisms in the immediate vicinity. The Draft EIS (p9-4) states that“No long term ecosystem damage occurs as no harmful residual materialsremain in the environment”. While there may be no residual chemicals, anydeath of coral could be considered an impact in the medium term.

6.2.3.2 Spillage in the vicinity of the township

Fuel will be landed and transported through a number of areas of thetownship where residences line the road to be used. In the case of NTO andUDMH the roads will be temporarily closed for about 10 minutes and thegoods will be accompanied by a spill clean-up truck (the Draft EIS does notmention the use of a spill clean-up truck for kerosene transport, however theMarch 2000 additional information (p41) in discussing kerosene spills,mentions that an emergency spill team will be present). Householders wouldbe advised of shipments in advance. A spillage in these areas could pose adanger to human health and necessitate evacuation of an area surroundingthe shipment. The Supplement (p46) lists potential impacts of a spill ofUDMH or NTO in a populated area as follows:

Ø Severe burns to eyes, skin, and lungs of people that come intocontact with the compounds;

Ø Noxious fumes are blown into dwellings;Ø Severe damage to fauna and/or fauna that come into contact with

the compounds; andØ Temporary contamination and closure of spill area.

The supplement notes that in the USA these chemicals are transported alongpublic highways using a security escort. APSC states that NTO is bannedfrom transport in the USA without a permit (March 2000 additionalinformation p54) while advice from ICF consulting is that NTO is prohibitedfrom highway transport in the USA and that a specific exemption is required(ICF Dec 1999).

There is some confusion in the Supplement regarding possible transport routealternatives. PII-7 states that APSC has already investigated the possibility ofalternative road routes to transport goods from the offloading facilities toSouth Point, but that the only practical route is that which has been proposed.However, P46 states that in responding to an event involving the release ofUDMH or NTO during transport through a populated area, APSC wouldinvestigate alternative transport route options through less populated areasand goes on to list three options. In responding to this discrepancy, APSCstates in the March 2000 additional information (p19), that it has investigatedalternative road routes and that the only practical option is that which isproposed and in addition “APSC is willing to investigate the viability of


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alternative routes on a commercial basis where benefits to the community andthe Spaceport can result from a combination of resources from APSC, PRLand the Commonwealth”. It is uncertain whether the benefit to thecommunity referred to would include improved road infrastructure or onlybe the removal of a hazardous substance transport route from their frontdoor. The March 2000 additional information also notes that no detailedrouting analysis has been undertaken (p54).

6.2.3.3 Spillage in areas of natural habitat/ areas allowing groundwater access

Kerosene exposed on the surface (including in a marine environment) readilyevaporates and is broken down by sunlight. Of particular concern is thepossibility of a kerosene spill entering an anchialine groundwater systemwhere the light fuel may become trapped and not disperse to the marineenvironment.

As noted in the human impact section, direct exposure of fauna and flora inthe immediate vicinity of a spill of NTO or UDMH would result in severedamage and death, as would exposure to the resulting nitrogen dioxide cloudfrom a NTO spill. The occurrence of rain, or the use of misting with water asa spill containment mechanism for an NTO spill could create nitrates thatcould enter the water table. The March 2000 additional information (P22)provides information on current nitrates levels in island groundwater (verylow) and concludes that the quantities of nitrates that could be formed as aresult of a spill would be insignificant in contributing to nitrate levels ingroundwater. No reasoning as to why a small increase in nitrates levelswould be insignificant is given. The Supplement (p44) does however notethat APSC’s response to such a spill would include determination of whethersampling of groundwater is warranted. While UDMH is not a persistentcontaminant, the Supplement notes that movement through some soils canslow decomposition but concludes that available data suggests a spill ofUDMH onto open ground would not readily migrate to groundwater.UDMH can also remain in water for up to 9 days depending on water purity.The Supplement states that “If UDMH did make it to the groundwater, then itwill continue to mix and dilute, adsorb to soils and breakdown” (P43).

Apart from the possibility of immediate death or injury to humans, flora andfauna, the key potential impact is the release of hazardous substances into thegroundwater system. This is because of the central role groundwater plays onChristmas Island as the only human water supply, a source for fresh watersprings, and a habitat in itself. The nature of the groundwater system is notfully understood. The Draft EIS (P9-3) explains that groundwater is thoughtto flow in a radial direction from the centre of the island. Comments byEnvironment Australia noted that if this was the case, then it was of someconcern that the hazardous material transport route would appear to be on


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the landward side of groundwater flow to areas that included the Hosnie'sSpring Ramsar site, a number of town water pumping sources and naturalsprings that formed habitat essential to the survival of species such as thegrey crab. The March 2000 additional information (P40) states “fromdiscussions with Tony Falkland it would appear that it is highly improbablethat a spillage from a road accident could effect Hosnie's Spring. This isbecause it would require the spill to occur in such a way that it happened nearaccess to a currently unknown fissure which also had a connection withHosnie’s Spring, a highly improbable set of circumstances” (Tony Falkland ofEcowise Environmental Ltd has 15 years experience in relation to ChristmasIsland water supply issues and recently prepared the draft WaterManagement Plan for the Island). These comments could be seen toemphasise the unknown characteristics of the groundwater system.

While the results of such an accident could be highly significant, APSC hasoutlined a range of safety measures to both minimise the chance of a spill andto enable rapid detection, clean-up and isolation of a spill in many cases. Themeasures proposed for the transport of these goods will also require approvalin accordance with relevant Western Australian regulations. The Draft EIS(P11-3) provided the following Road accident probabilities:

Ø Kerosene – one in 33069 years;Ø UDMH – one in 595239 years;Ø NTO – one in 283447 years.

These probabilities are derived by applying a UK study on hazardousmaterials transport. The Supplement (p40) also refers to US Department ofTransport 1996 statistics which showed that the probability of oil shipmentaccidents was one in 244,000. ICF Consulting (April 2000) concluded that thestudies appeared to provide reasonable point estimates of accidentprobability, but noted that there had been no detailed modelling of theprobability of releases in the event of an accident, the consequences of release,or damages associated with releases of UDMH or NTO. ICF suggests that “Ata minimum, it would be desirable to model the impacts of worst case releasesof NTO and UDMH in inhabited and ecologically sensitive areas of the island.This would at least demonstrate if such releases exceed a threshold of concernand would also help in the formation of spill response strategies.”

Recommendation 15: APSC must present the results of a routing analysis(including the landing of materials onto the island) describing and evaluatingall options for the transportation of Kerosene, Diesel fuel, Unsymmetric di-methyl hydrazine and Nitrogen Tetroxide, so that the Minister for theEnvironment and Heritage can provide additional advice on the preferredroute in relation to his responsibilities under the Environment Protection(Impact of Proposals) Act 1974.


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Recommendation 16: APSC must produce a report modelling the impacts ofworst case releases of Unsymmetric di-methyl hydrazine and NitrogenTetroxide in inhabited and ecologically sensitive areas of the island andprovide it to the Minister for Environment and Heritage no later than theprovision of the routing analysis.

6.2.4 Use of Helicopters on South Point

APSC proposes that during the construction period, larger goods andprefabricated components would be transported to South Point via largeseagoing barges and heavy lift helicopters on a monthly basis for the first 2-3months, then once every 2 months for the duration of the construction period(Supplement pII-27). Each unloading period would take 5-7 days dependingon weather conditions.

Chapter 6 of the Supplement documents a range of past research on noise andaircraft impacts upon birds. In relation to helicopter flights it states:“Considerable uncertainty surrounds the prediction of helicopter flights,lights and noise impact on birds. If prediction by analogy is used as a guide,then depending on species, location and situation, there are impacts in somecases and no discernible impact in others” (P23). Table 6.3 refers for the needfor monitoring and a management strategy, although there is no reference tothis in the draft environmental management plans. The Supplement alsorefers to a 1997 review of impacts of aircraft on seabirds by GBRMPA thatconcluded that the response of birds to aircraft will depend on the species,location, history of experience, aircraft type and aircraft activity. Because ofthe uncertainty surrounding aircraft impacts on different species GBMPArecommended that helicopters should not be permitted to land near surface ortree nesting seabirds.

North Keeling Island, which is another Australian external territory with alarge Red Footed Booby colony, has a Notice To Airmen that no aircraftapproach within one nautical mile of the island and must maintain at least2,000ft in altitude above the island. This is in response to an instance where anavy aircraft was observed by Parks Australia staff to pass over the island at500ft, causing thousands to rise in the air, and possibly some deaths.

The proposal is questionable both in terms of the potential negative impactupon the seabird colonies, and possibly in terms of aircraft safety.

Recommendation 17: APSC should not use helicopters as a means oftransporting construction material to South Point. If APSC believes that ithas no alternative to the use of helicopters, then a trial should be carefullydesigned and approved by Environment Australia (and other relevantauthorities). After approval, the trial should be carried out with appropriatemonitoring to determine the reaction of seabird colonies to helicopter


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disturbance. After considering the outcomes of the trial, the Minister for theEnvironment may provide further recommendations.

6.3 IMPACT OF LIGHTING AND HIGH STRUCTURES

The South Point facilities would possess low level security lighting at night.In the 24 hours leading up to a launch, and during a night launch (aninfrequent event), high intensity lighting will be used The Draft EIS (p9-12)and the March 2000 additional information (p32) note that the Red FootedBooby may be attracted to lights when returning from feeding at night, whilethe Greater Frigatebird is known to be active at night. The Christmas IslandHawk Owl is known to be attracted to street lights in the Township area andthe Birds Australia submission states that lighting would be very likely toattract the Hawk Owl. Lighting might also attract the Pipistrelle bat.

Lighting can be a problem for birds when combined with tall structures. TheBirds Australia submission gives the example of migrating shorebirds whichare regularly attracted to lighthouses and then killed in collisions with unlitstructures such as cables or walls. Kennedy Space Centre also experiencesbird strikes as a result of tall structures. There will be a number of highstructures around each launch pad: a 37m service tower, two 70 m lightningtowers, and three 70 m lighting towers. The additional information states thatlighting design will include the use of downlights rather than upwardpointing lights and that APSC will provide shielded lighting to minimise theglare and visibility from outside the facility area. Efforts will be made todesign or mark high, but less visible, structures such as powerlines so as toreduce the likelihood of bird collisions.

Another approach would be to minimise the number of tall structures by, forexample, combining the lighting with lightning towers (at Kennedy SpaceCentre the lightning rod is actually on top of the service tower, however thedesign of Soyuz launch pads would most likely not allow this).

Some submissions on the Draft EIS also raised concerns about the possibleimpact of lighting upon red crabs and sea turtles. The red land crab is knownto be attracted to existing light sources on the island (potentially interruptingforaging). APSC states that the use of shielding to minimise light throw willreduce this effect. The intention to make security fencing crab proof will alsohelp.

Greta and Dolly Beaches are known nesting sites for Green and Hawksbillturtles (both vulnerable). The nearest beach is about five kilometres from thelaunch site. Newly hatched turtles head towards the nearest lights (generallythe light sky over the sea) and can be severely impacted by artificial lighting.If the intensity of lighting is such that a glow in the sky at South Point can be


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seen at Greta and Dolly Beaches, then this would be likely to impact on thehatching turtles. The Draft EIS dismisses this due to the elevation anddistance between the lights and the nesting areas. The Natural ImpactsMatrix (p30) states that lighting will be designed to not be an attractor fromthe sea, ie by the use of appropriate shielding.

Kennedy Space Centre and Cape Canaveral have both experienced problemswith launch pad lighting disorienting hatching marine turtles (Breininger et al1994), and have worked in consultation with the US Fish and Wildlife Serviceto address the problem (for example, through the use of low pressure sodiumvapour lights). Launch facilities at these bases do however occur much closerto nesting areas than the South Point complex would.

Recommendation 18: Lighting facilities must be designed in such a mannerthat light from the South Point facilities must not be visible in the sky overGreta or Dolly Beaches.

Recommendation 19: Strategies for lighting design and the minimisation oflighting and tall structure impacts and for the monitoring of impacts andsubsequent management responses must be approved by EnvironmentAustralia as part of the Environmental Management Plan.

6.4 LAUNCH ACTIVITY IMPACTS

The launch cycle has a number of potential impacts upon the environmentassociated with various stages within the launch cycle:

Ø Vehicle and payload fuelling;Ø Impacts on Christmas Island of a normal launch – noise and launch

plume;Ø Impacts of a launch vehicle accident on or near the launch pad –

shockwave, fireball, plume, debris;Ø Impacts of launch vehicle in flight – drop zone impacts and sonic boom

footprint;Ø Impacts of launch vehicle failure in flight.

6.4.1 Vehicle and payload fuelling

Fuelling processes and fuelling facilities for the payload and launch vehicleare outlined in the project description chapter and described in more detail inthe EIS (DEIS p5-35, 8-12).

In relation to the fuelling of the launch vehicle, ICF Consulting remainsdissatisfied with the level of discussion of the hazards associated with theproduction, storage and use of liquid oxygen. Liquid oxygen is dangerouslyexplosive in fires and in contact with materials that can be oxidised.


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Refrigerated oxygen can also cause frostbite on contact with skin. ICFrecommended that the management of hazardous substances should includeconsideration of liquid oxygen and discuss safety systems for refrigeration. Aquantity distance analysis would also need to be conducted for all propellantsto see whether catastrophic failure at storage areas or a launch failure on thepad would create conditions that damage more flammable/toxic vessels,creating even more catastrophic conditions.

Recommendation 20: The management of liquid oxygen must be addressed inthe Hazardous Material Contingency Plan.

The Draft EIS estimated that up to 10 tonnes pa of UDMH and 20 tonnes pa ofNTO would be required by the facility. This may now be an overestimategiven that we have recently been informed by APSC that they now intend touse kick-stages fuelled by kerosene and liquid oxygen.

The DEIS states that fuelling activities would be carried out by Astrotech,described as the leading commercial satellite contractor in the USA. The DEISstates that an experienced team of US engineers from Astrotech would fuelthe satellites. If a release of UDMH or NTO occurred, the situation is dealtwith by staff in full suits with self contained breathing apparatus. Positiveventilation would remove the fumes via special filters and floor drains woulddirect liquid to a waste container in a sump. Any waste liquid would betransported to a hazardous materials treatment facility on the Australianmainland. Normal fuelling operations could produce a small amount of fueldiluted in water to a safe level. The transportation of hazardous wastes willneed to be considered in the Waste Management Plan.

The Draft EIS (p11-2) states that the risk of spillage of space fuels is highestduring satellite pre-processing, but concluded that the risk of a spillage wasvery small and accidents and consequences would be confined to the fuellingfacility and its personnel. The Draft EIS concluded that there wasinsignificant risk to the public. The Supplement (pII-28) outlined the resultsof a safety analysis of Astrotech’s facilities in Florida, which included ananalysis of fires. The analysis concluded that for realistic toxic gasconcentrations and durations, there would be minimal risk to humans locatedat the facility boundary 60 metres away.

It should be noted that the 1990 safety evaluation of Astrotech’s Floridafacility by the US Environment Protection Agency and Office of CommercialSpace Transportation states that the payload customer is responsible for andperforms all hands-on work related the assembly, processing and fuelling ofthe spacecraft, while all hazardous operations performed at Astrotech aredirectly supervised by the Astrotech safety officer. The report notes thatAstrotech safety requirements include such things as training and certificationof propellant handling teams.


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In the request for additional information, APSC was asked whether thepayload fuel tanks would be required to satisfy at least the same containmentstandards as the ISO cylinders that the space fuels were transported andstored in. APSC’s response in the March 2000 additional information (p38)was that the fuel tanks would be designed differently to satisfy theirhandling, filling and usage requirements. The tanks a designed to be light,but are inherently rugged, as they are designed to withstand high pressuresonce in space, and so on the ground have a high strength reserve. Thepayload and launch vehicle would be accompanied by an emergencyresponse unit on its rail journey to the launch pad.

As noted in the proposal description, fuelling of the launch vehicle in thelaunch pad is an automatic process, and is carried out after the launch padarea has been cleared of personnel. Payload and launch vehicle telemetrysystems will be in operation, providing information on the status of fueltanks. If at any stage a launch is aborted while the vehicle is still on thelaunch pad, the launch vehicle fuel tanks are able to be drained, and thelaunch vehicle returned to the assembly building.

Recommendation 21: All UDMH and NTO storage and transport containers(including payload fuel tanks) must be approved as safe for use under therelevant Western Australian legislation. The payload processing facility, itssafety features and certification of fuel handling teams must also beapproved under relevant Western Australian legislation. Where suchregulation does not currently exist, it must be developed to match or exceedworld’s best practice prior to any operation involving these fuels proceeding.

6.4.2 Impacts on Christmas Island of a Normal Launch – Launch Plume

The proposed launch facility would conduct launches up to twelve times ayear. As the launch vehicle ascends, it remains over Christmas Island for thefirst 25 seconds of flight. After that time it passes over the shoreline and thefringing reef and out to sea.

The launch plume from combustion of kerosene and liquid oxygen in therocket engines produces water, carbon dioxide, carbon monoxide, smalleramounts of hydrogen, nitrogen and oxygen, as well as some ions (at rocketexhaust and in the upper atmosphere). In addition approximately 500 tonnesof deluge water is combined with the exhaust either as steam or clouddroplets. This combination passes through the ground cloud and is added tofor the first approximately 460 metres of flight (15 seconds).

APSC based their conclusions regarding emissions from a combination ofRussian data, measurements from other launches and theoretical adjustments.The 33 tonne ground cloud produced in the first 15 seconds begins to mixwith surrounding ambient air (thereby diffusing), and also rises due to


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buoyancy. The Supplement (P60) concludes that humans and animals will besafe from the effects of the launch exhaust plume at a distance of 30 metresdownwind, but notes that the impact of heat and noise will be greater.

The March 2000 additional information provides information on the groundcloud temperature (p43). APSC’s estimated impacts are shown in thefollowing table:

Distance DownwindFrom Pad

DilutionRatio

CloudTemperature

Effect on Flora andFauna (estimated)

15 m 28 240°C Severe45 m 36 195°C Severe85 m 100 91°C Severe150 m 420 45°C Mild or nil180 m 600 40°C Nil

This would indicate that flora and fauna beyond the fenced security areawould be at risk of harm from the heat impacts of the ground cloud, as bothlaunch pads are closer than 180 m to the security fence in some directions.The western launch pad is about 50 m from the nearest perimeter of theLaunch Complex and areas beyond the mining lease to the south and south-east that may be of habitat value (Figure 5.3 of the Draft EIS identifies thisarea as rainforest). The eastern launch pad is about 75 m from the nearestperimeter fence to the north. The nearest area of National Park is 770 m fromthe nearest launch pad, with the required wind direction only occurring 12%of the time. The prevailing SE wind (67%) would blow the cloud over thezone between the Technical and Launch Complexes (presumablyrehabilitated) and beyond to other mined areas of mining lease 100. Theflame trenches would be designed to direct the gas and steam to the south-east, although upward at forty-five degrees (Supplement pII-13). Given theprevailing winds, the ground cloud has more of a potential impact upon theland birds such as the Christmas Island Goshawk, and Imperial Pigeon, andthe land crabs and reptiles than for harming sea birds, although the March2000 additional information (P4) notes that during the 1999 surveys a clusterof about 20 red-footed Booby nests were noted approximately 300m from thesite of the proposed launch facility.

Apart from redesigning the launch pad area to create a wider buffer zone, it isdifficult to envisage how this potential impact could be reduced. In contrast tothe short distance from the launch pads to natural habitat and the 770m to thenearest area of national park, it should be noted that the Technical Complex(which would be evacuated during launch, thus only leaving property indanger) is separated from the Launch Complex by a distance of 1.4km.

Recommendation 22: APSC must monitor the impact of the ground cloud inthe first five launches. Monitoring reports must include measurements on the


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cloud composition, temperature, dispersal and area of harmful impact.Surveys for impacts on fauna and flora must be conducted at a number ofsites spaced downwind of the launch pad concerned (100m, 300m, 600m, 1km,2km). Reporting arrangements and possible management responses will bespecified in the Environmental Management Plan.

Recommendation 23: APSC must investigate and report on alternativeconfigurations which would allow for a wider buffer zone between the launchpads and areas of natural habitat. Comment should be sought from theMinister for Environment and Heritage on the alternatives prior to the finalsiting decision being made.

The EIS stresses that some alternative rocket fuels create emissions thatpotentially have a greater effect than that of kerosene and liquid oxygen. Forexample, solid fuel rockets (such as the boosters used on the Space Shuttle)produce hydrochloric acid and aluminium oxides, while launch vehicles thatuse NTO and UDMH produce ammonia and oxides of nitrogen. This isworth noting in terms of the possibility that some public concern relating tothe impacts of a launch facility may be based on awareness of impacts ofanother launch vehicle entirely.

6.4.3 Impacts on Christmas Island of a Normal Launch – Launch Noise

Launch Noise has the potential to be the launch impact of most concern inrelation to successful launches. The Draft EIS provided a noise contour mapof the noise levels estimated from a rocket at 50 m in height (See Fig 9). Thiswas based on NASA and Russian data scaled to the largest rocket proposed tobe launched by APSC (the Angara-5). The Draft EIS did not providesufficient technical information with which to verify APSC’s estimates. Theinformation was provided in the Supplement (p31), allowing ICF Consultingto verify that the acoustical analysis calculations were technically accurateand the approach was verifiable (ICF April 2000).

As the largest rocket was used for the modelling, many launches would beexpected to produce lower sound levels. APSC states that the ARS-3K launchvehicle would produce noise levels 5 dB less than the Angara.

Figure 9. Noise Contour Map (rocket at 50m – worst case scenario)


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from APSC Draft EIS

In relation to direct human impacts, the Draft EIS states that the LaunchComplex is located a minimum of 14 km away from areas of humanhabitation. The March 2000 additional information acknowledges that twopeople reside at Grant’s Well, approximately 8 kilometres from the launchfacility. The research station is located a little closer and is intermittently usedas accommodation for visiting researchers. Noise levels at Grants Well areestimated to be 86 dBA (APSC compares this to a food blender), while thetownship area would experience 78 dBA on higher terraces (compared to acar travelling at 100 km/h at 8 metres) and 75 dBA lower down near theshoreline (living room music).

The EIS estimates that rocket noise would last for up to 45 seconds (with agradual build-up). Launches occur up to twelve times a year. Given theinfrequent occurrence and expected advance notice of the event, this wouldnot appear to be an unacceptable impact upon the human population.

Fauna of course occurs much closer to the site. Of particular concern is theseabird nesting colonies at South Point, and possibly territorial land birds thatoccur on South Point – the Christmas Island Goshawk (endangered) andChristmas Island Hawk Owl (vulnerable). The area of South Point within a1.5 km radius of the launch site(110 dBA or greater) includes sites where anadult pair and juvenile Goshawk were sighted and important seabird nestingareas along the eastern coastal terrace. Part of the western coastal terrace


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seabird nesting area also occurs within this zone, while a larger portion fallswithin the zone subject to between 100 and 110 dBA.

The Draft EIS recognised the possibility that launch noise may have someimpact on the fauna on South Point and committed to long term monitoringof the effects. The draft referred to background literature on the subject whichpresented varied and conflicting views and findings on the matter of noiseimpacts on wildlife. The Draft did not make any definite commitment as towhat would be done if a significant negative impact was detected, nor did itprovide sufficient detail of the proposed monitoring. In response tocomments on the Draft EIS, further information on potential impacts and longterm monitoring was provided in the Supplement, while information on theshort term monitoring associated with each launch was provided in theMarch 2000 additional information.

It should be noted that the rocket launch event has some specific characteristicthat can influence the noise impact: the noise will last for about 45 seconds,and will vary in level during that time; associated with the noise for somespecies will be the visual stimuli of the launch vehicle rising from the launchpad; and, the noise will only occur up to twelve times a year.

The noise levels given above are expressed in units (dBA, or A-weightedsound level in decibels) that are filtered to the approximate response of ahuman ear. It is unlikely that the various species of fauna exposed to thelaunch noise have hearing similar to humans. This issue was taken intoaccount in analysing the behavioural and auditory responses of Harbor Sealsto Titan IV launches from Vandenberg Air Force Base in California (Thorsonet al 1998), and it was found that as amphibious mammals, harbor seals havehad to compromise their in-air hearing in relation to their underwaterhearing. At the frequency at which the seals can detect the faintest sound,their sensitivity is about 30 dB less sensitive than humans (at their bestsensitivity). Their decreased sensitivity most likely reduces the amplitude ofsound that they perceive from a rocket launch. In contrast, domestic cats canhear much better than humans. For the purposes of studying the response ofthe seals to rocket launches, the researchers developed a “seal” weightedsound filter to accurately represent the sound level perceived by seals and sobetter gauge likely impacts on them.

Recommendation 24: APSC must carry out and report on measurements oflaunch noise for the first launch of each model of rocket so that the predictednoise levels may be verified. Distances at which noise levels are measuredshould be determined in consultation with Environment Australia andappropriate noise regulation authorities under applicable Western Australianlaw.

Recommendation 25: APSC must develop weighted sound filters for a rangeof target species to be agreed with Environment Australia.


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6.4.3.1 Seabirds

The Draft EIS provided information on an experimental blast (measuring138 dB) detonated in the vicinity of breeding Red Footed Boobies (P9-6).APSC concluded that there was no discernible behavioural reaction by RedFooted Boobies, however Parks Australia North staff present observed thatbehaviour of chicks in nests changed from generally somnolent to highlyvigilant, which may have been associated with elevated heart rates andincreased metabolic rates. The supplement included a statement that “APSCPty Ltd recognises that this did not simulate a rocket launch, nor is a singleexperiment significant, but that it did give some indication of a possible birdresponse to noise”.

General effects of human disturbance according to the “Guidelines forManaging Visitation to Seabird Breeding Islands” (GBRMPA 1997) are listedbelow in order of their occurrence during the normal breeding cycle of nestestablishment, egg laying and incubation, hatching, brooding and feeding ofchicks, fledging and survival to breeding age:

• changes to ideal breeding habitat characteristics;• deterrence from settling to breed;• desertion of colony site by all or part of a breeding population;• increased destruction or predation of eggs;• increased mortality of young chicks from predation, exposure,trampling ordisorientation;• reduced number of young birds fledging; and• reduced fledging weight, contributing to lower juvenile survival.

Launch activity sound could effect the seabird colonies on South Point in thefollowing ways:

Ø Harassment as a result of flushing of the colony in response tolaunch noise (potentially causing increased heart and metabolicrates and decreased food search capacity,);

Ø Nests left temporarily unattended – leaving chicks or eggs exposedto weather and/or predators;

Ø Individual nests permanently abandoned – loss of chicks or eggs;Ø Injury or death of juveniles or adults due to startle responses (may

be particularly an issue with tree nesting birds such as Abbott’sBooby and Red Footed Booby which are not adept at manoeuvringamongst trees. Individual Greater Frigatebirds or Abbott’s Boobiesthat fall to the ground are not able to become airborne again andgenerally die unless given human assistance);

Ø Abandonment of nesting colony by one or more species.


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These responses could lead to a decline in reproductive output, reducedfledging weight, contributing to lower juvenile survival, a reduction in thenumber or density of birds, a reduction in the diversity of species using theSouth Point area, and the possibility of birds forced to nest in other lessoptimal nesting habitats. The infrequent nature of the event would in someways reduce the potential magnitude of the impact, but may also prevent theseabirds from becoming habituated to the disturbance (as do some species ofbirds that nest near military and civilian airbases).

As noted in the supplement, the same species of birds may react differently indifferent situations. Reference is made to varied responses of seabird tohuman disturbance at different colonies. In some cases the birds appearedvery sensitive, with frigatebirds and Red Footed Boobies flying at anapproach within 50 m at some sites, while at another site it was reported thatthe Red Footed Booby could be touched while on the nest.

Seabirds are generally more sensitive to disturbance in the early parts of thebreeding cycle. If complete abandonment of nests occurs, it generally happensin the early part of the breeding cycle, thus indicating that this is generally themost sensitive time for many species. Regular disturbance at this time canprevent a significant portion of a colony from establishing (GBRMPA 1997).The success of seabird nesting colonies will also fluctuate for natural reasons,thereby making it difficult to gauge the impact of human disturbance, as wellas meaning that human instigated losses can combine with natural losses toproduce an even greater effect.

In some situations identification of such periods of particular sensitivity mayenable the avoidance of impacts by avoiding launches during that time. It isunlikely that this will be possible with South Point. Table 6.2 in theSupplement shows that the breeding seasons of species relevant to theproposal range occur in varying periods from February to June (Abbott’sBooby season extends to July). The Golden Bosun (White-tailed Tropicbird)may breed in all months. In addition, the period of incubation and parentalcare is particularly lengthy for some seabirds. The Red Footed Booby requires45 days incubation, over 100 days of care to reach fledgling stage and 190days of post fledgling care. The Greater Frigatebird requires 55 daysincubation, up to 161 days to reach fledgling stage, and 15-18 months of postfledgling care.

After reviewing available data, APSC concludes that uncertainty remains asto how seabirds, such as Red-footed Boobies and Greater Frigatebirds, wouldreact to periodic and very loud noise events (Supplement P18). APSCsuggests that in attempting to predict the impacts of rocket launch events onthe seabirds at South Point, the following points need to be taken intoconsideration:


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Ø “The reaction of seabirds to disturbance varies between species andbetween sites for the same species;

Ø A greater severity of impact has been observed when there is aconsistent disturbance at the start of the breeding season;

Ø Chick mortality/stress as a result of adult birds leaving the nest islikely to be highest during the hottest times of the day;

Ø The scope for habituation and instances where no impact has beendetectable; and,

Ø There are no data to give any indication as to how seabird colonies,such as those on Christmas Island, will react to periodic rocket blastevents.” (Supplement P19).

As noted previously, habituation is unlikely to be an issue with the proposal.In relation to the last point, there have been some studies of the impacts ofrocket launch activity upon birds. Some public comments on the Draft EISrequested that APSC provide information on the environmental impacts ofexisting launch facilities, however no information was provided in responseto these requests.

Kennedy Space Centre and the adjoining Cape Canaveral launch facilities areperhaps the most well known launch facilities in the world. Kennedy SpaceCentre covers 570 square kilometres and contains the Merrit Island WildlifeRefuge (566 square kilometres). The landscape provides habitat for more than330 species of birds, 31 mammals, 117 fishes, 65 amphibians and reptiles and1000 plant species. The refuge supports 21 species of wildlife listed asendangered or Threatened on either Federal or state lists, which is more thanany other single wildlife refuge in the United States. At 135 squarekilometres, the entire area of Christmas Island is less than one quarter ofKennedy Space Centre. Unlike seabirds, many other species are not colonialnesters, and can therefore be distributed more evenly across their preferredhabitat. The endangered Florida Scrub Jay is a territorial bird, and studies ofthe impact areas of Titan launch pads have found that reproductive successand mortality are comparable to areas on the Centre that are not subject tolaunch effect (Breininger et al, 1994). A closer comparison could be made withthe colony of endangered Wood Storks (colonial waterbirds; 5 to 25 pairs willoften nest in a single tree) that began nesting within two kilometres of one ofthe space shuttle launch pads in 1988. Video observation revealed a startleresponse of wading birds during launches when the birds briefly took flightfrom their nests and returned within minutes (providing the opportunity forsome loss or damage to eggs or nestlings, or predation). Pre and post launchstudies suggested that no mortality of nestlings occurred from launches andthe number of breeding pairs increased between 1988 and 1990. The colonywas abandoned prior to the first launch in 1991 – most likely as a result of


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rising water levels and degradation of the mangrove nesting trees caused byfreezes (unusually cold weather).

Vandenberg Air Force Base is 398 square kilometres in area and extends along56 kilometres of Californian coastline. It is used for ballistic missile testing,and the launch of unmanned government and commercial satellites into orbit.A colony of endangered Californian Least Terns nest within about 650 metresof one of the launch pads at Vandenberg. Because of concerns regardingpossible launch impacts upon the colony, each launch that occurs during thenesting season is monitored for impacts upon the Least Terns. The US Fishand Wildlife Service has issued an Incidental Take Statement in relation to thelaunch activity, requiring that there be a take of only:

“1. A maximum of eight (8) adult California least terns and eight (8) adult westernsnowy plovers in the form of direct mortality or injury per calender year, as a resultof predation or launch vehicle malfunction.

2. A maximum of ten (10) California least tern nests and ten (10) western snowyplover nests as a result of indirect launch effects per calender year. Examples ofindirect effects include, but are not limited to, abandonment, predation, or exposureto weather. The annual loss of ten California least tern nests is not expected to exceedten (20) chicks or eggs. The annual loss of ten western snowy plover nests is notexpected to exceed thirty (30) chicks or eggs.

3. All nesting individuals in the project area through harassment as a result offlushing during seven (7) flushes of nesting western snowy plovers and five (5)flushes of nesting California least terns per calender year without signs of nestabandonment, death, or injury. No numerical estimate is possible because of theuncertainty regarding the number of nesting birds that may be present.

4. All non-breeding western snowy plovers, California least terns, and brownpelicans and all American peregrine falcons and southern sea otters in the projectarea through harassment. No numerical estimate is possible because of theuncertainty regarding the number of individuals of each species that may be present.

5. No (0) American peregrine falcons, brown pelicans, or southern sea otters areexpected to die or be injured as a result of implementing the proposed project .”

A study of a launch on July 1997 found that Least Tern losses directlyattributable to the launch included 4-5 nests containing 7-9 eggs and one nestthat contained 2 chicks. At the time of the launch the colony hadapproximately 20 adult Least Terns (Schultz 1997). The study also concludedthat the severe disturbance of the launch combined with predation attemptsby owls were the factors likely to have affected an early seasonal departurefrom the site by the remaining adult least terns.

Based on the information provided in the EIS and the additional informationabove, it would appear to be a real possibility for launch noise at South Pointto have a significant negative impact upon the nearby seabird colonies. In


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addition, the breeding behaviour of some of the seabird species does notprovide them with the ability to rapidly recoup losses beyond natural lossesto which they have adapted. However, it cannot be certain that such negativeimpacts will occur, or if they will be of a magnitude to have an ongoingresulting decline in seabird populations nesting on South Point.

APSC proposes to monitor the seabird populations on South Point todetermine whether there is a negative impact as a result of launch noise orother activities associated with the APSC facilities. APSC proposes toestablish baseline information of bird population numbers based on data fromthe two existing surveys as well as three to four surveys per year until 2004.Future survey programs would also include surveys of a number of controlareas elsewhere on the island, so as to provide a comparison to areas notdirectly exposed to APSC facilities on South Point. After the baseline hadbeen established and interpreted in consultation with Environment Australia,APSC proposes that the surveys continue in order to monitor any impacts.

The March 2000 additional information provided details of launch specificmonitoring which would measure short term responses and impacts bygathering data before, during and after launches. This would involve pre andpost launch surveys of South Point baseline survey sites, monitoring ofspecific nest trees (including at the nearest Abbott’s Booby nest site), anddirect and indirect video observations during the launch.

There are a range of uncertain aspects of the monitoring program outlined inthe EIS that require further attention. These include:

Ø During the proposed baseline monitoring period, APSC proposes toconduct 11 launches. Construction activity would also occur,however this could be comparable to mining activity that alreadyoccurs on South Point.

Ø Some survey methods, such as counts from cliff-top vantage points(ie, looking down upon trees the birds are nesting in) may not bereliable means of conducting consistent surveys;

Ø Other methods such as counting piles of droppings under treesduring the breeding season, to survey breeding seabirds, are basedon questionable assumptions about the behaviour of the seabirds;and,

Ø The absence of any reliable approach to the monitoring of breedingsuccess rates and distinguish launch activity induced changes fromother changes.


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If the proposal is to proceed, a full monitoring program would need to bedeveloped and approved as part of the Environmental Management Plan.Because of the importance of the Seabird colonies and the possibility ofnegative impacts, it would be appropriate for the monitoring program to bedeveloped in consultation with scientists that have expertise in relation toboth the seabirds concerned and expertise in the development of monitoringtechniques.

Recommendation 26: A full seabird monitoring program be developed andtested as part of the Environment Management Plan to be approved by theMinister for Environment and Heritage. The seabird monitoring programmust include the collection of baseline data for at least three years prior tothe first launch. The monitoring program must be developed in consultationwith Environment Australia and scientists recognised as having expertise inrelation to both the seabirds concerned and expertise in the development ofmonitoring techniques.

In order for the monitoring program to be of value, it must be associated witha feedback mechanism whereby negative impacts detected by the monitoringcan be addressed through changes to the management regime. APSCproposes the following options for alterations to the launch regime if asignificant impact can be linked to launch events (Supplement p21):

Ø Minimise night launches (reducing light impacts and disturbance tonocturnal and roosting birds);

Ø Avoid launches during the middle part of the day if birds aredisturbed and seen to fly from their nests in response to a launchevent (reducing impacts of high temperatures on unattended nests);

Ø Conduct launches in a manner that minimises impacts during peakperiods of courtship and egg laying (thought to be the period whenbirds are most susceptible to disturbance).

These responses would not be able to address all potential launch impacts.For example, while not launching in the middle of the day may avoidtemperature impacts, it would not necessarily avoid predator impacts upontemporarily abandoned nests. As noted previously, some of the seabirds carefor their young for over a year, making it difficult to avoid disturbance if anyare found to be particularly sensitive. There is a particular concern with nightlaunches given that it would be difficult or impossible to determine the shortterm responses of fauna to the launch. Environment Australia is of the viewthat it is possible that in some circumstances, the only means of addressingsignificant negative impacts upon seabirds or other fauna would be to ceaselaunches at South Point.

APSC has proposed a regime of “adaptive environmental impact assessment”where when set indicators are reached, APSC would respond at a certain level(Supplement P24, Table 6.4). Such an approach would be necessary, however,


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if the level of response to the indicators proposed by APSC is insufficient.APSC has only recognised that there may be a need to respond with a delayin the launch program, and this would only be in the case of extreme eventssuch as “abandonment of the site” (only 10% of original baseline conditionsremain at 30% or more of study sites, while control sites remain stable), or a20-50% decline in the breeding success and numbers occupying nests sites ofthe nearest Abbott’s Booby nesting sites. Lesser impacts such as monitoringshowing a continual reduction in population size at 60% or more of studysites would at the most result in a modification of the launch protocol. Adecline in the reproductive output, or numbers of one or more species at 15-30% of study sites would only result in increased monitoring, investigations,and an examination of the possibility of modifying the launch protocol.

Recommendation 27: The adaptive response management regime must berevised as part of the Environment Management Plan to be approved by theMinister for Environment and Heritage. The revised regime must bedeveloped in consultation with Environment Australia and scientistsrecognised as having expertise in relation to the seabirds concerned andexpertise in monitoring techniques. A significant impact upon the seabirdcolony such as a decline in reproductive output of seabirds at 15-30% or moreof sites monitored on South Point (without a corresponding decline at controlsites) must result in a suspension of the launch regime while the possiblecauses are investigated by a panel of avian experts appointed by the Ministerfor Environment and Heritage, until such a time that the panel hasdetermined whether further launches are possible without bringing aboutfurther decline or preventing recovery of numbers.

Recommendation 28: For any night launches conducted, APSC must carryout the monitoring program to ensure effective monitoring of short termimpacts.

6.4.3.2 Other Fauna

In addition to the presence of the endangered Christmas Island Goshawk andvulnerable Christmas Island Hawk Owl, the assessment report also notedlarge numbers of endemic Imperial Pigeons and Christmas Island GlossySwiftlets in the vicinity of the project area. Further surveys will be requiredbefore the presence of vulnerable reptiles such as the Christmas Island TreeGecko and Blind Snake can be determined, as well as other reptiles such asthe declining Blue Tailed Skink. The Christmas Island Fruit Bat was noted asbeing present on the western Terrace (it was not searched for on the easternside), and the presence of the Christmas Island Pipistrelle bat will need to beascertained through further survey work. The land crab fauna is also presentat South Point. Each of these species will be exposed to a range of possibleimpacts dependent upon their behaviour and use of the surrounding habitat.These may include startle responses, territory abandonment, breeding failure,


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and hearing impairment (which may be a particular issue with the Pipistrelleand Glossy Swiftlet, which both use echolocation).

APSC proposes to monitor land birds with an area search technique in eachvegetation type on a range of sites on South Point and in control siteselsewhere on the island (March 2000 additional information p6). This wouldinvolve the assembly of baseline data, before and after surveys for launchesand continuing long term monitoring of baseline survey areas.

More intensive monitoring would be conducted for the Goshawk and Hawk-Owl. APSC proposes that as many pairs of the Goshawk be located aspossible, which would be checked upon each field trip – the disappearance ofseveral pairs being an indication that a decline was taking place. APSCproposes that the Hawk-Owl be monitored by listening for calling Hawk-Owls at several points in the South Point area to gain some measure of theirabundance. This proposal differs with the Natural Impact Matrix (P28) whichrequires no commitment of APSC as no Hawk-Owl nests were found in thesurveys, which is not surprising given that they were not systematicallysearched for. Given that both these species are listed under the EndangeredSpecies Protection Act 1992, additional monitoring such as location of nests andnon-intrusive video monitoring of nests during launches would beappropriate.

Apart from commitments in relation to lighting impacts, there is littleindication of recognition of the importance the occurrence of the Goshawkand Hawk-Owl on South Point. Given that the total population of theChristmas Island Goshawk is estimated to be 100 to 200 mature individuals,the removal of the territory of just one breeding pair (such as the pair notedby surveys near the proposed launch facility area) should be considered asfurther endangering the species.

Other species such as the Christmas Island Gecko, Christmas Island BlindSnake, and Christmas Island Pipistrelle have been dismissed as requiring nocommitment by APSC based on surveys that Environment Australiaconsiders are inadequate (see Natural Impacts Chapter). The Natural ImpactMatrix (p30) considers that no commitment is required in relation to theChristmas Island Fruit Bat on the basis that the bats were only found on thewestern terrace, which would not be exposed to launch accidents. Inresponse to a comment that there had been no surveys for fruit bats on theeastern terrace, the March 2000 additional information stated that “on thecompletion of survey of eastern terrace, no populations were found”. It isuncertain what survey this is referring to given that the second surveyreported on in Attachment V of the Supplement did not systematically surveyfor mammals and, as with the first survey, did not occur on the eastern coastalterrace.


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Recommendation 29: Monitoring proposed in the EIS for land fauna must besignificantly revised in consultation with Environment Australia in thepreparation of the Environment Management Plan.

Recommendation 30: An adaptive management regime must be developed forall endangered and vulnerable species present on South Point, as well as forspecies for which significant populations have been found in the vicinity ofthe launch area. The management regime must take into account recoveryplans prepared for endangered and vulnerable species. The managementregime must be included in the Environment Management Plan to beapproved by the Minister for Environment and Heritage.

6.4.4 Impacts of a launch vehicle accident on or near the launch pad

The Draft EIS states that the companies providing the launch vehicles forAPSC have an overall success rate of approximately 97%. The launch vehiclewill only be on or over the island for the first 25 seconds of flight. APSCstates that space insurance statistics suggest that there is a one in five hundredchance of an accident of any sort occurring during that 25 seconds (Draft EISp8-14). The Supplement (p61-62) provides further information based onhistorical failure statistics of all available launch vehicles and flights for thelast 25 years (excluding solid rocket booster failures). Based on thisinformation, APSC concludes that the probability of a failure over the APSCsite is one in 909 flights, while the probability of a failure over the terraces isone in 6670 flights. Specific data is not available for the ARS-3K and Angaralaunch vehicles because they are both new vehicles without a launch history(although the ARS-3K is based on the reliable Soyuz launch vehicles whichare used for Russian manned space flights).

No launch vehicle flight paths are intended to be directed towards thetownship on Christmas Island. Given the distance from South Point to theTownship, and the launch safety procedures undertaken, APSC concludesthat there would be no possibility of damage to the housing, structures orpeople in the Dogs Head area (Draft EIS p11-4).

During the first 13 seconds of flight, the rocket rises over the launch pad, sothat if there is a failure, debris will fall back over the launch pad and


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surrounding area. Between 13 and 25 seconds, the launch vehicle continuesto rise and moves across the terraces, before crossing the reef and moving outto sea. A launch vehicle explosion would cause:

Ø Shock wave – causing death or physical injury to fauna up to 500mradius and considerable damage to exposed structures up to 900m;

Ø Fireball – with heat hazardous up to 250m radius;Ø Smoke Plume- with a hazardous ellipse of 200 m by 400 m (which

would rise rapidly and move down wind, or, later in the flight,remain at altitude above 1000 m);

Ø Debris thrown up to 500m, possibly including some fuel notconsumed in the fireball.

Figure 10. The envelope of potential impact calculated by APSC

from APSC Draft EIS

While there is a low chance of such an explosion occurring, given thesignificance of the surrounding environment and the expected 200 or solaunches of the 20 year lifespan of the project, the impacts of such an eventmust be considered. An explosion over the island would cause damage to anarea of vegetation, would kill nearby wildlife (or those in the path of fallingdebris) and startle those further away, and has the potential to cause a fire.While the first 13 seconds (or 19 seconds in the Supplement) of flight will beover the launch pad area, as noted previously, some of the borders of thelaunch pad security zone are within 50 m of the western launch pad, and thuseven an explosion at this stage will result in shockwave, fireball, launchplume and debris effects beyond the boundary of the complex. This is


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another reason for a revision of the buffer zones surrounding each launch pad(see recommendation 23).

ICF Consulting was satisfied with the shockwave calculations (ICFConsulting April 2000).

The nature of Christmas Island vegetation currently means that a fire wouldbe unlikely to spread. However the likely impacts resulting from theintroduced Yellow Crazy Ant such as increased forest floor leaf litter anddenser understoreys may alter this in the future. Given the ruggedness of theterrain on the eastern coastal terrace, APSC states that small mobile firefighting units with individuals on foot would be required to contain a fire.Parks Australia officers with experience on the island find it difficult toimagine firefighters on foot able to safely deal with a fire on the coastalterraces.

There is also a small possibility of the payload not being totally destroyed bythe accident and falling to earth with fuel tanks still containing space fuels.While unlikely, this has happened once with a Delta III rocket. Space fuel thatwas released on the island terraces could have impacts upon the fauna in thevicinity (see S6.2.3).

APSC has committed to recovering all debris from a launch accident that fallson the island or the surrounding reef, and have committed to therehabilitation of all areas affected by a launch anomaly with native floraspecies as soon as practical following devastation of an area by fire (NaturalImpact Matrix p19). APSC has also committed to conducting a site inspectionprior to launching to remove any robber crabs or other significant fauna fromthe vicinity of the rocket blast (Natural Impact Matrix p24). As mentionedabove, given that some of the 500 m radius will be areas of natural habitat, itmay be difficult to carry out an effective search.

Recommendation 31: The Environment Management Plan must include aplan for how APSC will respond to the environmental impacts of a launchaccident over the island. The plan must include a survey of impacts uponflora and fauna, and immediate, short term and longer term responses tominimising and remediating impacts.

6.4.5 Impacts of launch vehicle in flight

6.4.5.1 Impacts on the atmosphere of APSC rocket exhaust gases

Exhaust gases from liquid-oxygen-kerosene rockets consist mainly of carbondioxide and water, plus carbon monoxide at high altitudes, with traces ofother components (elemental gases H2, N2, O2 and ions OH- and H+). At highaltitudes, the expansion of the exhaust cools the rocket exhaust gas


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immediately, so no further reactions occur. At low altitudes (below about 50km), the gases remain hot for a few seconds until they mix with air. APSCstates that the global removal rate of removal of about 2 billion tonnes perannum, means that exhaust carbon monoxide will not accumulate in theatmosphere. Any remaining carbon monoxide will be removed by naturalprocesses involving the hydroxyl radical, with a lifetime of about 3 months.

APSC states that the project is expected to provide a net reduction in exhaustgas generation on a global basis, by attracting business from competingrockets (existing and planned) which use solid or toxic propellants and havegreater impacts on the environment. The rocket burns about 70 tonnes ofkerosene while in the atmosphere which APSC states is equivalent to one fuelload for one flight of a mid-size jetliner, and APSC says the emissions andenvironmental effects are similar (in reviewing the EIS, ICF Consulting notedthat the basis for this analysis had not been provided). In addition, mostcommercial rockets are launched at higher latitudes than APSC, requiringmore fuel to change plane at the equator.

The deposition into different parts and layers of the atmosphere is governedby the length of the active plume and how long the LV spends traversing thelayer, as determined by the trajectory. Once the rocket is above 300 metres,the exhaust gases will form a trail of increasing altitude along the flight path,leaving the atmosphere after 170 km over the Indian Ocean. APSC states thegases will mix with and be diluted by the global atmosphere.

APSC failed to analyse the potential impacts of the launch vehicle exhaust onthe ozone layer and instead in the Supplement (p57) refers the reader to theEnvironmental Assessment for the SeaLaunch Project, (which was prepared forthe U.S. Department of Transportation in 1999) in regard to the impacts ofliquid-oxygen-kerosene rockets on the free troposphere, stratosphere andmesosphere

According to this report the impact of rocket exhaust emissions on theatmospheric boundary layer (up to 2 km) would only last for a few hours.Emissions would be dispersed by winds and local turbulence caused by solarheating.

Models predict a substantial, temporary reduction in ozone levels in theexhaust trail of liquid propellant rockets. However, recovery to nearbackground levels occurs within a few hours. The atmosphere being capableof replacing the destroyed ozone by migration and regeneration.

The effects of rocket launches on total global ozone are less well understood.It is possible that solid particles in the exhaust might provide surface area forheterogenous chemical reactions that might lead to the destruction ofstratospheric ozone, however this area has not been adequately studied.


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Rocket launches contribute to less than 0.034% of annual global ozonedestruction. Rocket exhaust components that play a role in ozone destructionin the stratosphere are chlorine compounds, nitrogen compounds andhydrogen compounds. Chlorine is the largest contributor to ozonedestruction. APSC rockets will not be releasing chlorine or chlorinecompounds.

The high speed movement of the rocket and the re-entry of stages after theiruse may impact stratospheric ozone. Shock waves caused by the high speedmotion of the rocket or re-entry components enhance the formation of NOx

which in turn contributes to ozone destruction, however this effect isconsidered to be relatively small. In addition, the heating of the rocket or re-entry components may cause the production of chemical compounds thatmay play a role in ozone destruction. Even though the chemistry andsignificance of these processes is uncertain, the SeaLaunch report concludedthat the impact of after burning and re-entry of the Launch Vehicle is likely tobe minimal.

6.4.5.2 Sonic Boom Impacts

Launch vehicles produce sonic booms in flight which may be experienced in a“footprint” along the flight path. The sonic boom footprint for launches fromSouth Point would be out to sea, however there has been concern at otherlaunch sites about the impact of sonic booms upon marine mammals(Thorson et al 1998). This has not been properly discussed in the EIS,however the marine notification procedures set out in the supplement (p69-70) include the checking by aircraft of the sonic boom footprint area foraquatic mammals such as whales. The EIS does not specify whether a launchwould be delayed if marine mammals were spotted.

Recommendation 32: APSC must delay launches when aircraft surveys detectthat marine mammals are present within the sonic boom footprint. APSCmay comply with this condition by demonstrating to the satisfaction ofEnvironment Australia that launch vehicle sonic booms do not causesignificant impacts upon the species of marine mammals found in the waterswhere sonic booms can be expected as a result of the proposal.

6.4.6 Drop Zone Impacts

The first and second spent rocket stages and the fairings fall in predetermineddrop zones. The components have a mass in the range of 1 to ten tonnes anda length of up to 28 tonnes. Launch stages are composed of aluminium alloys,titanium, and stainless alloys. Fairings may be composed of metal or ofcomposite materials containing carbon and glass fibres in a resin matrix. Eachfairing segment is about 0.8 tonnes with dimensions 19 x 4 x 2 metres. TheDraft EIS notes that all of these materials are commonly used in boats.


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The first and second launch stages will contain residual kerosene in the fueltanks when they fall into the ocean. While some of the kerosene would havebeen vented to the atmosphere during descent, APSC estimates that themaximum volume of kerosene released at any one location would be 0.35tonnes, while the average total volume per launch would be one tonne. TheSupplement (p44) does however refer to an initial model of the Angara whichwould release 3.3 tonnes of kerosene per launch, with 1.1 tonnes at any onelocation. APSC contrasts this with referenced estimates of the amount ofhydrocarbons released into the marine environment via land based andtanker spills, and natural seepage (Supplement p45).

Kerosene is moderately to highly toxic to aquatic life dependent upon thetype of kerosene and aromatic compounds present. Kerosene does howeverreadily evaporate, and APSC refers to studies that have shown that in anopen environment, 95% or more would be lost to evaporation within a fewhours. The remainder is dispersed by turbulence and consumed viaphotochemical oxidation and microbial degradation within several days.

While covering the surface, waves and wind would break up the spill intopatches, reducing the likelihood of contact with marine mammals andreptiles. APSC refers to studies that show that marine mammals and fishactively avoid oil spills in open water. The potential impact of such spills donot appear to be significant.

The kerosene slicks would not reach land from any of the planned dropzones, however, in the case of an explosion soon after launch, kerosene spillsmight impact upon coastal Christmas Island communities. Kerosene wouldadhere to rock faces along the coast, potentially smothering and killingorganisms it came into contact with. Wave action would rapidly degrade thekerosene. On exception would be if the spill reached one of the few sandybeaches along the east coastline. The kerosene could be adsorbed by the sandand protected from degradation by sediments. Given the importance of thesebeaches to nesting sea turtles, such an impact would not be acceptable. Thesupplement refers to responses according to a spill response plan.

Recommendation 33: APSC’s spill response plan must include effectivemechanisms that prevent the contamination of Christmas Island beachesfrom fuel spills.

The deposition of spent stages upon the ocean floor may be of concerndepending upon the benthic life on the ocean floor. The Draft EIS proposed adrop zone in the Timor sea which was of concern for a number of reasonsincluding the occurrence of shallow banks and shoals, some of which supportcoral reefs. The Supplement proposed a revised drop zone to the west wherethe shallowest water is 1800m (see Figure 11).


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The supplement also demonstrates that the proposed drop zones do notoverlap with the MOU 74 zone which allows for traditional Indonesianfishing within an area of the Australian Fishing Zone. The rocket flight willcross over routes to and from the zone and presumably such fishing activitywould take place in other areas within Indonesian waters. APSC states that itwill “undertake, where appropriate, to notify such fishermen of drop zones

Figure 11. Drop Zones in Timor sea area on the path to Geostationary Transfer Orbit

from APSC – March 2000 additional information.

and impending launches at their home ports”. Some comments on the DraftEIS expressed concern regarding the repercussions of the close proximity ofthe proposed flight path to Indonesia. APSC notes that Australia andIndonesia have agreements in place which provide for reciprocal notification(Supplement pII-56). This issue is considered to be beyond the scope of theEnvironment Assessment Process.

Some concern also remains in relation to the composite fairings, which theSupplement explains will break up, gradually become waterlogged andeventually sink within a period of weeks or years. The concept of fairingsweighing up to 0.8 tonnes floating for years does not appear to be desirablefor safety or environmental reasons.

Recommendation 34: APSC should investigate means of ensuring thatfairings sink soon after impact.


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Over 600 rocket stages and fairings would be dumped into the ocean over theexpected twenty year lifespan of the launch facility. The apparentwastefulness and potential resulting environmental degradation attractedcriticism in a number of public comments. APSC has stated that this iscurrently world practice and in the General Impact Matrix (p4) commits toinvestigating the recovery of debris components from the ocean in the futureshould this become international practice.

Although not operated on a commercial basis, the space shuttle solid fuelbooster rockets are currently retrieved from the ocean and re-used, whilefuture plans may include a change-over to liquid fuelled boosters that wouldfly back to the launch site (Brown 1988), the commercial Kistler proposal forWoomera involves a new (untried) vehicle with recyclable stages that returnvia parachute for collection, and the Russian Krunichev Angara family oflaunch vehicles (some models proposed to be used by APSC) may include aversion with a winged recoverable first stage that would use two jet enginesto fly back to an airfield for recovery (Wade, M. 2000).

Obviously this is an area of practice currently undergoing change. Ratherthan simply committing to investigating keeping up with internationalpractice, it would be appropriate for this proposal and other proposals forAustralian based launch facilities to keep up with international best practice.

Recommendation 35: APSC should develop and implement recoveryprocedures for rocket stages as this becomes international practice for othercommercial launch operations.

Another concern raised in public comments related to both the original dropzone A6 (no longer to be used) and the proposed drop zone B3 (see Figure12). Submissions from Woodside Energy, Australian Petroleum Productionand Exploration Association Limited (APEA), and Western AustralianDepartments of Minerals and Energy and Environment Protection allregistered concerns about the proximity of oil and gas installations in theTimor Sea and the North West Shelf to the proposed drop zones. Concernswere also expressed regarding possible impacts upon associatedtransportation operations and future exploration activities. Since the publiccomment period, correspondence (either to Environment Australia or theMinister for Environment and Heritage) has also been received from APPEA,Woodside Energy, the Petroleum and Electricity Division of theCommonwealth Department of Industry, Science and Resources, WADepartment of Ministry and Cabinet, and Esso Australia regarding this issue.

In the Supplement (p67 – 71) APSC responded to these concerns by providingfurther information regarding the determination of drop zones, theirfrequency of use and flexibility. By making adjustments to the launchtrajectory and incurring a small payload penalty, as noted above, the A6 drop


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zone was moved beyond environmentally sensitive areas and further from oiland gas installations. The number of potential B3 drop areas was alsoexpanded in order to increase opportunities to select a drop zone dependingon both the mission and location of oil and gas facilities at the date of alaunch. In the March 2000 additional information, APSC summarised itscriteria for selection of drop zones (p30). This included commitments thatdrop zones would not include present fixed assets, and would be adjusted toavoid any future such assets. APSC states that consultation with oil andshipping companies would occur to enable mobile assets to avoid drop zoneareas on launch dates.

Figure 12. Inclined Drop Zone B3 Options

from APSC – March 2000 additional information.

The A and B trajectories do still pass over petroleum industry areas, the Btrajectory also passes over sparsely populated areas of Australia and the Atrajectory flight corridor will pass over small inhabited islands includingMelville and Croker Islands and pass over an area of Papua New Guinea forsix seconds at an altitude of 200 km. There is a possibility of launch vehiclefailure along its flight path, bringing debris down upon what is known as theinstantaneous impact point. APSC provided initial calculations of theCasualty Expectation analysis which indicated that in all instances the hazardis well within the accepted value of 30 x 10-6. ICF Consulting was of the viewthat further casualty expectation should be calculated for each populationarea crossed (ICF Consulting Feb 2000). APSC notes that the Space Licenceand Safety Organisation (SLASO) will be required under the Space Activities


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Act 1998 to provide independent assessment of acceptable risk and safetyparameters and all launch permits are likely to be require a detailed casualtyexpectation analysis. Environment Australia agrees that final responsibilityfor safety analysis should rest with SLASO.


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The petroleum industry remains concerned in relation to:

Ø The EIS does not provide estimates of the potential economic andenvironmental consequences of an incident due to a launch vehicleaccident;

Ø The EIS does not consider the value of petroleum industry assets inthe North West Shelf ($12 million according to DISR) or thepotential value of the petroleum industry;

Ø The potential for revised drop zones to affect any future oil and gasexploration and development in those areas.

In relation to the potential for future conflicts, APSC notes the possibility ofperforming dogleg manoeuvres to avoid future operations (at a payloadpenalty cost), and the potential for the development of a collaborativeresponse to the use of the relevant areas over the next few years beforepotential conflicts may occur (Supplement p70).

This issue is of relevance to the environment assessment process both in termsof:

Ø the potential for a launch accident involving petroleum industryinfrastructure to have environmental consequences in terms of oilspills; and,

Ø the potential for the curtailing of the range of beneficial uses of theenvironment (para 3.1.2 of the EPIP Act AdministrativeProcedures).

The EIS has given consideration to these issues and addressed the bulk ofthem, however there remains the potential for future conflict of use of someoffshore areas.

Recommendation 36: The Minister for Industry Science and Resources, inexercising portfolio responsibilities in relation to petroleum exploration andproduction and the regulation of space activities, should ensure that thepotential for conflict of resource use in offshore areas be taken into account.

6.4.7 Launch Impacts Upon Aircraft

As noted in the project proposal, aircraft exclusion zones will be establishedaround Christmas Island, along the flight corridor as far as the first drop zoneand then at the second and third drop zones. The March 2000 additionalinformation notes that final details for each launch would need to benegotiated with Airservices Australia and the Space Licensing Office. Therisk assessment aspects would be included in the calculations required for


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SLASO. Diversions around flight corridors and drop zones may requirediversions of up to 30 km and delay arrival by up to 2 minutes.

6.5 CREATION OF ORBITAL DEBRIS

The NASA Policy for Limiting Orbital Debris Generation describes orbital (orspace) debris as referring to human generated debris, specifically:

Ø Payloads that can no longer perform their mission;Ø Rocket bodies and other hardware (e.g., bolt fragments and covers) left in

orbit as a result of normal launch and operational activities;Ø Fragmentation of debris produced by failure or collision (gases and liquids

in free state are not considered orbital debris). (NASA 1997).

Radar and optical telescopes regularly track over 10,000 artificial objects inspace, amounting to an estimates 4,500 tonnes. Of this number, only fivepercent are functioning spacecraft (Johnson, N.L. 1998(b)). The number ofuntrackable objects ranging in size from 1 cm to 10 cm, is estimated atbetween 100,000 and 150,000 (ESA 1999). For the past two decades thetracked satellite population has grown at an average rate or roughly 175additional objects a year – more than one quarter of this has been due tosatellite break-ups.

Orbital debris can have the following impacts:

Ø Collisions with operational satellites and manned spacecraft.Collisions may disable satellites (and thus the services such astelecommunications or remote sensing they provide), create furtherspace debris in a cascade effect, and endanger human life incolliding with an operational spacecraft (the space shuttleoccasionally has to take evasive manoeuvres to dodge large piecesof debris, while the International Space Station will be equippedwith about 200 shields in order to defeat impacts of particles up toabout 1-2 cm in size).

Ø Reduce the amenity of near earth orbits for future missions thatmay be of benefit to humans and the environment;

Ø Contribute to the light pollution of space , adversely affectingground based astronomical observations (UNISPACE 3 1999);

Ø Larger objects may partly survive re-entry through the earth’satmosphere and pose a danger to humans or the environmenteither through direct impact, or in some cases fuel remaining on-board.

In the case of APSC launches, the third rocket stage, and, if used, a final kickstage will remain in orbit along with the satellite being launched. Johnson(1998(b)) notes that derelict rocket bodies have been known to detonate as a


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result of overpressurisation or ignition of residual propellant, with nearlyevery booster type vulnerable (we are unaware at to whether ARS-3K orAngara rockets are vulnerable). An upper stage of a Pegasus rocket broke upin 1996 creating more that 700 objects large enough to be tracked in orbitsfrom 250 to 2,500 km in altitude.

APSC has stated in the EIS that their rocket suppliers have informed themthat no operational material such as bolts or explosive stage separators are leftin space during launch campaigns. The Draft EIS also notes that it is possiblefor the third stage of a launch vehicle to be de-orbited , but it is not currentlycommon practice. APSC notes that “there are worldwide efforts within thespace industry generally to endeavour to incorporate facilities within therockets to enable the components which would generate space debris to eitherbe de-orbited or destroyed in ways that do not contribute to space debris.APSC will follow world trends in this area” (Draft EIS p8-11).

The second party with direct responsibility for this issue would be the ownerof the payload, the design of which will influence the production of spacedebris by the payload (instrument covers, paint chips) and the fate of thesatellite once it has reached the end of its operational lifespan. Operators candeliberately steer their spacecraft into the atmosphere, have them removed bythe space shuttle, move them to less crowded “graveyard orbits” or allowthem to spiral down in natural orbital decay (which will occur with those inlower orbits).

This is a recognised issue of concern – the Inter-Agency Space DebrisCoordination Committee met in October last year to consider these issues,which were also to be considered by the United Nations Committee on thePeaceful Uses of Outer Space.

Recommendation 37: Launch approval should include an assessment ofdebris generation potential and debris mitigation options based oninternational best practice, but at the least including the following:

The potential for orbital debris generation in both nominal operation andmalfunction conditions;The potential for orbital debris generation due to on-orbit impact withexisting space debris (natural or human generated) or other orbiting spacesystems;Post mission disposal; and,The potential for items to pose a safety or environmental threat upon re-entry.

Where the assessment finds that debris contributions or the risk to theenvironment or safety are not acceptable, additional design and mitigationmeasures must be implemented.


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6.6 IMPACTS ON CAVE SYSTEMS AND CLIFFS

As noted in the Natural Environment Chapter, Environment Australia is ofthe view that the proponent should be required to carry out furtherinvestigations into the presence of cave systems and subterranean faunaaround the South Point Facilities (see Recommendation 5).

Launch vibrations could result in aesthetic or structural damage to cavesystems, and to subterranean fauna habitat. One public submission(Yorkston, sub 23) notes that the last major construction on the island – theCasino – had to modify plans because of limited understanding of the poroussubstrate environment. The Arup Geotechnics report noted that if cavitieswere identified in areas proposed for construction of facilities, it would benecessary to assess the risk of sink holes forming either as a result of naturalfailure of the cave roof, or as a result of structural foundation loads. Thereport suggests three options to address this risk if the cavities are assessed asa risk to the structural integrity of buildings:

Ø Relocating the building;Ø Infilling the cavity; or,Ø Construction bored piles through the roof rock and sleeved through the

open cavern to found or the floor of the cavern.

The Geological survey report also noted the possible presence of sinkholesbased on analysis of aerial photographs, and the presence of a deep structuralirregularity at one of the boreholes. Due to access difficulties, boreholeinvestigation was not carried out over the old tailings ponds present on thesite (a product of phosphate processing on South Point), and noted that theoverall depth of tailings is unknown, as was whether the tailings hadsolidified at depth.

Environment Australia is of the view that it would be undesirable for theconstruction activities to cause degradation of the karst environments becauseof their intrinsic, aesthetic and habitat values as well as their record ofgeological processes. In addition, it would be important to demonstrate priorto construction that the proposed area was sufficiently stable to support theproposed structures and withstand launch and launch accident vibrations andshockwaves. The Draft EIS states that the anticipated repeat loading fromrocket launches may have the potential for long term settlement of theimmediate locations of the launch pads, but that the structural design of highperformance base structures and foundations would also minimise anypotential vibration effects. Instability might have repercussions for bothhuman safety and the environment.


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Recommendation 38: Approval for construction of the proposal should notoccur until it is demonstrated that the underlying geological structure issufficiently stable to support the proposed facilities and able to remain stableduring launch activities or accidents.

Recommendation 39: The report on the survey for possible cave systems andsubterranean fauna on South Point focusing on the proposed site of theTechnical and Launch Complexes should be used to develop measures toavoid, monitor or remediate impacts upon these environments. Thesemeasures must be included in the Environment Management Plan.

A launch or launch accident on or over South Point has the potential to resultin rockfalls from nearby cliffs. The Arup Geotechnics survey noted evidenceof recent rockfalls below the cliff adjacent to the NW border of the TechnicalComplex and recommended that construction be limited if possible to notcloser that 50 m from the cliff line. This is the area where APSC proposes tolocate storage facilities for the hazardous space fuels, causing concern thatthese storage facilities may be susceptible to rockfalls. In the March 2000additional information APSC provided an assessment of rockfalls on thesestores (p36-38) which concluded that the proposed store locations aresufficiently far from the cliff so as to not be in any danger. APSC estimatedthat the NTO store is 96 m from the cliff line.

Launch initiated rockfalls from the surrounding cliffs bordering the coastalterrace could impact upon cliff nesting seabirds, or damage coastal terracevegetation.

Recommendation 40: APSC should monitor and report on launch vibrationinitiated rockfalls as part of the Environment Management Plan.

Concern was expressed at public meetings of the possible impacts of launchvibration upon the high cliffs behind the Kampong area of the township. Thisarea has already been evaluated in relation to rockfall hazard resulting inbarricades being erected below the cliffs. APSC states in the March 2000additional information (p40) that it is not expected that vibration wouldinfluence the stability of the rocks at the Kampong area due to the distancesinvolved.

6.7 IMPACT OF SPILL AND WASTE WATER ON SOUTH POINT:

The South Point facilities would include storage for large quantities of dieselfuel and kerosene as well as quantities of UDMH and NTO. As noted in theproject proposal section, all above ground fuel storage areas would bebunded to appropriate standards. The exception to this would be the petrolstation where the Draft EIS states that petrol storage would be below ground.The Supplement (pII-41) states that the fuel supply at South Point will bediesel. In any case, given that all other fuel storage facilities are above


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ground, it would be desirable for the fuel storage at the “petrol” station to beabove ground and appropriately bunded as well, so as to further reduce thepossibility of fuel leaks entering the groundwater system.

ICF Consulting (February 2000) noted that while consideration was given toissues relating to the transport of hazardous substances and the fuelling ofvehicles, appropriate attention was not given to the emergency arrangementsin relation to spills during storage on site.

Recommendation 41: The Hazardous Materials Contingency Plan shouldinclude emergency response actions to be made to spills during storage aswell as transportation.

While the chances of a fuel leak entering the groundwater system from theSouth Point storage facilities would appear remote, the potential impactswould be similar to those described in S6.2.3.3.

The Arup Geotechnics report states that Christmas Island lies to the South ofone of the most seismically active areas in the world, known as the JavaTrench. Large earthquakes along this plate boundary have causeddestruction in both Java and Sumatra. The report advises that due to theproximity of this region, there is potential for an earthquake to affectChristmas Island and recommends that the seismic hazard associated withthese earthquakes must be determined using state-of-the-art seismic hazardassessment techniques. Buildings would then be able to be designed towithstand an earthquake of an expected magnitude over a set return period.The report notes that normal buildings are generally designed to experiencethe full Ultimate Limit State conditions during a 500 year return period, whilehazardous installations may be required to perform during higher intensityevents having a return period of up to 10,000 years.

The Draft EIS (p6-8) notes that Christmas Island is located on an activetectonic zone and that it is expected that seismic tremors do occur, but thatthere are no records of major seismic activity affecting the island. Theserecords only dated to 1960. Concerns were raised in a public submission, andat community meetings where some islanders noted tremors that had beenfelt on the island. More information was provided in the Supplement, notingthat minor tremors had been recorded, that a major concentration of activityin the Java Trench was to the North of the island, while a lesser concentrationhad been recorded in the immediate area surrounding the island. TheSupplement stated that “whilst there is little risk of major seismic activity onthe island the design and construction of the facility will be in compliancewith prevailing earthquake design codes”.

Recommendation 42: A Potential Seismic Hazard Assessment should becarried out and be taken into account in the design of foundations and


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building structures. All fuel storage facilities should be designed to thestandards required for hazardous installations.

The South Point facilities would include a sewage treatment plant that wouldtreat sewage to a tertiary level – removing suspended solids, micro-organismsand nutrients to an acceptable level approved by the WA Health Departmentfor reuse in irrigation systems. The resulting water would be irrigated on thefacility grounds, while solids would be dried in a manner similar to theexisting sewage plant on the island. The assessment report does not statehow these dried solids would then be disposed of (see waste managementsection in Social and Economic Impacts Chapter).


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7 POSSIBLE IMPACTS UPON THE SOCIAL ANDECONOMIC ENVIRONMENT AND IMPACTAVOIDANCE AND REMEDIATION

7.1 ACCESS TO SOUTH POINT AND CHINESE TEMPLE

As explained in the project description, APSC proposes that for a period of upto 24 hours before a launch, people would be excluded from a land and seaexclusion zone in a 2 km radius from the launch pad. Viewing areas outsidethis radius would be established in consultation with the Shire Council. Thisrestriction in access would occur up to twelve times a year. At all other timesAPSC activities on South Point would not restrict public access apart from thefenced security areas.

In reviewing the Draft EIS and Supplement, ICF Consulting noted that safetyspecialists who had reviewed the documents were unable to determine howthe exclusion zone had been set at 2 km for the 24 hours preceding launch.ICF recommended that if there was a technical reason why this distance wasselected, this information should be provided (ICF Feb 2000).

Recommendation 43: APSC should provide information on the criteria usedto set the 2 km exclusion zone around the launch site so that it may beconsidered in the space licence procedure.

While there may be some recreational use of the South Point area (fishing forexample), the primary impact of this restriction will be upon access to theSouth point Chinese Temple and the two shrines. As noted in theSupplement (p81) the main issue would be if a launch coincided with a majorreligious event in the Chinese calender. The location of the Temple andshrines is shown in Figure 13.

APSC states that while it believes that there can be a harmonious coexistencebetween the spaceport and its operations, and access to the temples, theremay be times when proposed launch exclusions would clash with religiousevents, despite the best intentions of both groups.

APSC met with available members of the Temple Committee, including thePresident and the Deputy President on 14 December, 1999, and reports thatagreement was reached, with APSC deferring from launching during two keyreligious celebrations: God’s Birthday and certain days in the Chinese NewYear period (1st and 15th days). The actual dates would be determined by thelunar calender.


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Provided ongoing consultation takes place as part of APSC’s communityconsultation plan, this agreement would appear to be a satisfactory resolutionto the key access problem.

Figure 13. Location of Chinese Temple and Shrines at South Point

from APSC Draft EIS

Recommendation 44: Launch activities should not result in closure of accessto the South Point Chinese Temple during religious celebrations associatedwith God’s Birthday and the 1st and 15th days of the Chinese New Year Period(as determined by the lunar calendar). Alterations to this restriction mayonly be made with the agreement of the South Point Chinese TempleCommittee.

A second issue is the proximity of the shrines in particular to the launch sitesas shown in the following table:

Launch Pad 1 Launch Pad 2Shrine 1 730 m 430 mShrine 2 1200 m 940 mSouth Point Temple 1400 m 1250 m

The first shrine therefore falls within the 500 m area that APSC expects wouldbe exposed to the fall of debris and potential shockwave damage to structuresin the case of an on-pad explosion. The other shrines fall into the area where,according to APSC’s calculations, there would be damage to only the flimsiestof structures. APSC states that the nearest shrine would possibly suffer somedamage, however, due to its small size and distance from the launch pad, any


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damage would be slight. The chances of an on-pad explosion are small butnot inconceivable (discussed further in Chapter 6).

ICF Consulting verified APSC’s calculation of shockwave intensity (ICF April2000), but noted that while the EIS discussed the impacts of an on-padexplosion, it did not consider in detail the impacts of the vibration associatedwith normal launch operations (ICF February 2000).

It is also of concern that in assessing the potential impacts, APSC did not giveany indication that it had considered the materials or structural integrity ofthe buildings. As with the proximity of the launch pads to natural habitat, theproposed launch pads would be located closer to the Shrines and the Templethan to the Technical Complex (1.4 km).

In the Supplement, APSC also states that they would be prepared to considerfunding the construction of a new shrine and temple in an alternativelocation, if this was deemed an appropriate alternative for whatever reason inthe future.

Recommendation 45: APSC, in consultation with the Temple Committee,must further analyse the potential for launches or on-pad explosions todamage the South Point Temple and Shrines. This information should beprovided to the Temple Committee so that they are in a position to evaluatethe potential impacts in considering the future of the South Point Temple andShrines.

Recommendation 46: APSC must investigate and report on alternativeconfigurations which would allow for a wider buffer zone between the launchpads and the South Point Temple and Shrines. The Temple Committee andthe Minister for Environment and Heritage should be allowed to comment onthe alternatives prior to the final siting decision being made.

7.2 ROLL-ON ROLL-OFF FACILITY

Submissions on the Draft EIS (including from residents living nearby and theChristmas Island Tourism Association), expressed a number of concernsregarding the proposed Roll-on Roll-of (Ro-Ro) facility. These included:

Ø The proximity of the facility to the Temple Court retail andresidential area. (Submission 3 was a letter of objection specificallydirected only at that aspect of the proposal and carried signaturesof 30 residents of the Temple Court area);

Ø Impacts upon parking and traffic flow along Gaze Road;Ø Noise impacts upon local residences and retailers;


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Ø The facility would be detrimental to the aesthetic appeal of theforeshore and the area in question is part of a proposed foreshorebeautification;

Ø Concern that use of the facility by members of the public wouldlead to boats, trailers etc in the area;

Ø Concern about the safety aspects of unloading and transportinghazardous substances in such close proximity to the residentialarea;

Ø The Ro-Ro might have an impact upon the view from the ChineseTemple at Temple Court;

Ø The proposal did not consider the “Gaze Road Townscape MasterPlan”;

Ø Alternative locations had not been discussed;Ø Concern that the ramp could allow storm waves to damage

buildings (as noted in the Draft EIS (p7-21) buildings along thisshoreline had previously suffered damage or destruction duringsevere storms).

In addition, the Australian Heritage Commission (AHC) noted that theproposed site was within the Settlement Service Precinct that is entered in theRegister of the National Estate. AHC requested that as the facility had thepotential to impact on national estate values, draft documentation (includingplans and design details) should be referred to the Commission in line withsection 30 of the Australian Heritage Commission Act 1975. The AHC noted thepossibility that the Ro-Ro facility has the potential to impact on the NationalEstate values as well as the urban design and amenity values of Gaze Road.

The Supplement provided a detailed response to some of these issues (P72-80& II-20), and provided information on changes to the proposed location (seeChapter 3).

APSC provided information on an assessment of wave conditions whichconcluded that in the case of maximum expected wave size, the wave run-upwould be approximately 35 metres up the road ramp, which would have atotal length of 115 metres. The final design analysis would need to be made atthe building approval stage.

The new location would not be in sight of the Temple at Temple Court, andAPSC states that the facility (presumably the ship docking area) would bealmost obscured from vision at the level of Gaze Road. The facility entry toGaze Road would of course be visible.

In relation to use of the facility by others, APSC’s position is that it wouldconsider public utilisation of the Ro-Ro only if the community and localgoverning authorities accepted such an arrangement. In terms of the Ro-Robecoming an alternative sea freight handling facility, APSC has stated that


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the facility would be for the use of APSC only, and is not viewed as being analternative sea freight handling facility in direct competition or in tandemwith the existing port (March 2000 additional information).

Increased traffic would occur along Gaze Road only when vessels areunloading, which is expected to be once a month (this may be more variableand frequent in the 18-20 month construction phase). APSC proposes toposition a traffic watchman at the intersection during those times. APSCexpects that about 41 heavy vehicle movements would be made fromSettlement to South Point per month when the facility is fully operational.The use of the Ro-Ro facility would focus around a number of days after thearrival of a ship at the facility.

The noise impacts would be similar to that experienced at the existing port.APSC states that with the exception of the large rocket component, there willbe no unusually large vehicles generating noise at the site and that a largeportion of the noise will be deflected by the edges of the cut formed by thegraded ramp. Predicted sound levels were not provided, nor wasinformation on the ambient noise levels in the area despite this beingrequested by the assessment guidelines (Guidelines S7.1.12).

The residential and retail nature of adjoining land uses demands morecareful consideration of the noise impacts of the Ro-Ro facility. Currentlythere are no applicable noise regulations.

Recommendation 47: If the Roll-on Roll-off facility is to be located asproposed in the supplement, restrictions on maximum noise levels to beproduced must be developed in consultation with the Western AustralianDepartment of Environmental Planning and the Shire of Christmas Island.The facility should only be used during normal business hours.

The supplement stated that further information would be provided in thefinal design on the following issues:

Ø Traffic management of the ingress and egress to the facility;Ø Amendments to road infrastructure in accordance with the

Department of Roads;Ø Parking requirements for the facility and general public;Ø Maximum retention of public amenity to the adjacent and

surrounding area;Ø Heritage and streetscape aspects of the facility;Ø All engineering issues including the realignment of existing

stormwater and sewer lines; and,Ø Landscaping and aesthetics management.


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The AHC remained concerned that issues that may impact upon the nationalestate values of the area needed to be dealt with at the assessment stage. Inthe March 2000 additional information, APSC stated that the proposedlocation and design of the Ro-Ro facility would meet with the “generalthrust” of the Godden Mackay Logan Development Guidelines, and listed anumber of ways in which the facility would be designed to be consistent withthe heritage value of the Settlement Services Precinct (March 2000 additionalinformation p13-14).

After considering information provided in the supplement, the AHC remainsconcerned that the location of the Roll-on Roll-off facility, as proposed in thefinal EIS, has the potential to impact on the national estate values of the PoliceStation (Settlement Services) Precinct and will compromise the opportunity toregain the townscape and associated cultural values of the place in the future.While the AHC accepted that the proponent had attempted to minimise theadverse impact on the Precinct and agreed that the measures listed by theproponent would help to protect the heritage values of the place, the AHCdid not believe that it was sufficient for the proponent to only “meet thegeneral thrust” of the Godden Mackay Logan Development Guidelinesrecommendations. The AHC remains of the view that the proposal cannot beverified without detailed drawings that provide information such as wherethe ramp intersects Gaze Road and the parallel configuration of the ramp andparking on Gaze Road, as these may have the potential to impact upon thefuture planning of the area.

Recommendation 48: Further documentation on the proposed Roll-on Roll-offfacility including plans, elevations, sections, design details and a landscapeplan should be referred to the Australian Heritage Commission for commentin line with Section 30 of the Australian Heritage Commission Act (1975)prior to a final decision being made about construction of the facility.

The environment assessment process post the issuing of the supplement hasnot provided an opportunity for the local residents to respond to APSC’sproposal to shift the Ro-Ro facility further down Gaze Road. While this movemay alleviate some of the concerns of retailers and residents, given that thefacility is still nearby, it is unlikely that concerns will be fully satisfied.Environment Australia is of the view that based on available information, theproposed location of the Ro-Ro facility will have a major impact upon thecommunity and heritage values of the area and that options for an alternativemeans of bringing freight onto the island should be further investigated.However, given the detailed local planning nature of this particular issue, itwould be more appropriate for the decision making process to further involvethe local community and the Christmas Island Shire Council.

Recommendation 49: Further community consultation on the design andlocation of the Roll-on Roll-off facility should occur before final designs arecompleted. This process should be overseen by the Christmas Island Shire


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Council. Subject to comment from the Australian Heritage Commission onthe potential impact on the national estate values, the final decision on thecurrent proposal for the Roll-on Roll-off facility should rest with the ShireCouncil. If the current proposal is rejected, APSC must further examine andreport on other options for the delivery of freight to Christmas Island. Thisanalysis must be referred to Environment Australia for further considerationand possible recommendations prior to a final decision on siting being made.

7.3 IRVINE HILL RESIDENTIAL AND ADMINISTRATION COMPLEX

As noted in the description of the project, limited information has beenprovided on the proposed residential and administration complexes to besited at Irvine Hill. APSC states that the layout and planning of thesefacilities will involve close cooperation and liaison with the Shire Council, theWA Ministry for Planning and all other relevant statutory authorities.

The submission on the Draft EIS by officers of the WA Ministry for Planningnoted that the subdivision and development of any land at Irvine Hill wouldrequire comprehensive /structure planning and more detailed rezoning priorto its subdivision and development, including consideration of issues such asvegetation protection, servicing requirements, aircraft noise impacts as well asoff-site impacts associated with the nearby refuse disposal site. The Shire ofChristmas Island submission raised similar concerns while also questioningwhether it would be acceptable for the workforce to be located outside ofexisting residential areas.

The issue of segregation was also raised in some community meetings. Oneparticipant noted that existing Christmas Island residents had previously notbeen allowed to obtain land at Irvine Hill. While the plan to locateconstruction workers at South Point is probably logistically the best solution(and would alleviate concerns expressed by the Christmas Island TourismAssociation that pressure on accommodation during the construction periodmight limit accommodation available for tourism), there appear to be issuesboth from a planning sense and potentially from a social impact sense in theconstruction of the residential complex at Irvine Hill. The fact that theplanning framework for Christmas Island has yet to be finalised makes issuesmore difficult. The development of the residential complex would perhaps bemore acceptable if efforts were put into preventing the complex frombecoming isolated (both physically and socially) from the rest of the smallisland community.

APSC has already committed to making the active recreational facilities ofthe complex available to local residents for their use and enjoyment, and hasstated their interest in encouraging development of the surrounding area forresidential housing on a commercial basis (pending land availability,suitability and acceptance and approval by the relevant governing


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authorities) (March 2000 additional information p52). The Supplement (pII-25also notes that discussions with the Commonwealth regarding the planningand approval process suggest that a collaborative process of various statutorybodies, including the Shire, would be established as a formal instrument todeal with the complex demands of the exercise.

It would be in the interest of all concerned if the planning and thedevelopment of the residential and administrative complex was carried outthrough a transparent process, and one that did not occur outside of thenormal bounds of residential planning on Christmas Island – that is, it shouldoccur within the context of planning for the Irvine Hill area rather than as aspecial case.

The aircraft noise issue mentioned by the WA Ministry of Planning was alsoraised in a submission by the manager of Christmas Island Airport, whonoted that in evaluating Irvine hill as a future urban area, a study into theeffects of aircraft noise had been conducted which concluded that much of thearea was inappropriate for residential development due to much higher thanallowable aircraft noise based on the relevant Australian Standard. Inresponse, APSC stated in the Supplement that the noise contours of the IrvineHill area had been studied and the residential accommodation placed tominimise the incidence of aircraft noise generated at the runway, with thenoise contours being at acceptable levels except for single event noise levels(which would impact upon the entire existing settlement area). Given thepositioning of the complex within an overall planning complex andenvironmental complex has yet to be considered, the issue of noise would alsoneed to be considered when a final siting decision was made.

Recommendation 50: The planning and design of the proposed residential andadministration complex at Irvine Hill should be carried out within thecontext of the planning for the future of the Irvine Hill area in accordancewith the Shire of Christmas Island Town Planning Scheme and giveparticular consideration to the integration of the complex into the existingisland residential framework and siting to avoid aircraft noise impacts.

In relation to the design of the administration and residential complexbuildings, APSC states that design will be undertaken with due considerationand attention to the existing prevailing site conditions (terrain, landscaping,orientation, climate) and that the use of energy efficient systems such as solarheating and recyclable materials will also be considered where possible.Given that this would be a “greenfields” development, there should be littleto constrain adoption of these issues.

Recommendation 51: Design of the Residential and Administration Complexshould reflect the existing architectural styles on Christmas Island. APSCmust demonstrate that energy efficiency measures and use of renewable


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energy have been incorporated wherever possible into all buildings to beconstructed as part of the proposal (including those at South Point).


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7.4 WASTE GENERATION AND HAZARDOUS MATERIALS.

The level of information provided by APSC on waste management waslimited. APSC has stated that it will prepare and implement EnvironmentalManagement Plans for waste removal, disposal and recycling if and wherepossible, and will be discussing waste management with the Shire.

Launch facility staff and dependants will contribute to the production ofdomestic waste on the island, and shorten the life of landfill sites. Thepotential increase in cars on the island will also lead to an increased in theproblem of how to dispose of them. The statement in the Draft EIS that thiscontribution will be offset by the fact that the population of the island issubstantially lower than it has been in the past, is questionable given theestimates of a cumulative population increase to 3000 (including the proposaland the potential re-opening of resort casino) provided in the March 2000additional information. ASPC did not provide an estimate of the amount ofwastes the proposal would produce in categories such as domestic wastes andconstruction wastes.

APSC will require all suppliers and contractors to manage waste inaccordance with the plan. And that penalties for non-conformance will beimposed in the contract for all suppliers and contractors (Supplement pII-24).

APSC has also committed to implementing an eco-office policy.

Environmental managers and regulators dealing with launch preparation andassembly activities at the US Kennedy Space Centre and Cape Canaverallaunch facilities have likened the sites as having similar pollution and wasteissues to many other industrial sites (Busacca 1999 pers com, Garfein, 1999pers com). Industrial activities associated with such a site need to beexamined in their entirety rather than simply focusing upon the launchactivity. The evolutionary nature of the launch industry over the last fewdecades, combined with the pressure to ensure and improve safety standardshas meant that wasteful and polluting processes, materials and techniqueshave been adopted with little further consideration for assessing whetherthere might be better alternatives that meet the requirements of the launchindustry while also reducing environmental impacts. In recent years theFlorida Department of Environmental Protection has worked with NASA,airforce and commercial launch operators to assess processes to be used so asto find ways to reduce environmental impacts.

While the EIS has provided information on the hazardous materials to bebrought onto the island in bulk (space fuels, kerosene, diesel), ICF Consultingnoted that there had been no information provided on pollution preventionstrategies, nor information provided on hazardous material such as:


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Ø Hazardous material contained within the delivered components;Ø Hazardous materials used and wasted during testing, maintenance

and support of launch vehicles; and,Ø Materials and or waste used or emitted during the system operation

phase (ICF Consulting February 2000).

Careful consideration will need to be given to the storage, use and disposal(including transportation off the island) of hazardous and polluting materialssuch as oil, paints, grease and solvents. The Draft Hazardous MaterialsManagement Plan (Supplement Attachment IV) does provide some broadcommitments to some of these issues, but consideration has not been given tothe setting of strategic goals for reduction, elimination, or processmodification to reduce or eliminate the generation of waste. Christmas Islandis very removed from recycling centres – alternative strategies aimed atreducing the amount of wasteful material being brought onto the island needto be developed.

The APSC proposal involves the translocation of overseas technology, andprocesses that have not been developed within the context of the Australianregulatory environment. While it is understandable that there may beproprietary interests associated with launch facility, launch vehicle andpayload technology, sufficient information relating to the processes, materialsused, and waste produced must be made available to appropriate regulatorsso as to ensure that all efforts have been made to reduce or eliminate thegeneration of waste.

Recommendation 52: In developing plans for the management of waste andhazardous materials, APSC must identify processes, materials andtechniques to be used at the launch facility and work with regulators toensure all efforts have been made to reduce or eliminate the generation ofwaste. The waste management component of the Environmental ManagementPlan must be approved by the Shire of Christmas Island.

7.5 IMPACTS UPON INFRASTRUCTURE

The proposal will impose additional demands upon the island’sinfrastructure both in terms of project specific activities and the increase inpopulation on the island.

The March 2000 additional information (p7) identifies that the launch facilitywill result in a number of categories of additional people:

Ø Direct staff (employees of APSC or its contractors);Ø Dependents of direct staff; and,


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Ø Support industry personnel and their dependents (eg, peopleemployed in new business enterprises in areas that provideancillary services to APSC.

The number of employees on the island at any given time would fluctuateand would peak at the time of a launch. APSC estimates that once the stableoperating rate of 12 launches per year was attained, the above categorieswould contribute approximately 747 additional people to the islandpopulation. In addition, each launch would involve short term visitors suchas satellite launch clients and VIP guests (about 40 per launch) as well as sometourists.

This would increase the island’s population to about 2147 people, which doesnot exceed recent high levels associated with the operation of the resortcasino. However the current closed status of the resort casino is most likely atemporary situation. The Weekend Australian of 15 April reported that APSChad agreed to buy the Casino and hotel buildings (but not the licence). Whenresort casino employees, dependents and tourists (based on available numberof beds) are all taken into account, the estimated total population could rise toabout 3000 people – well above recent levels of population.

Such an increase has the potential to lead to added pressures on islandinfrastructure including power, sewage treatment, water supply, roads,hospital, educational and recreational facilities.

7.5.1 Power Supply & Sewage Treatment

APSC estimates that the existing power station should be able to provide forthe population increase expected from the proposal (estimate made at theDraft EIS stages did not cover the re-opening of the resort). As notedpreviously, the current sewage treatment plant is designed to cater for up to4000 people. The South Point facilities would include a sewage treatmentplant that would treat sewage to a tertiary level – removing suspended solids,micro-organisms and nutrients to an acceptable level approved by the WAHealth Department for reuse in irrigation systems. The resulting waterwould be irrigated on the facility grounds, while solids would be dried in amanner similar to the existing sewage plant on the island. The assessmentreport does not state how these dried solids would then be disposed of.

7.5.2 Road use

Road use will increase – both in terms of personal vehicle use, and heavyvehicles used associated with the proposal. This will potentially lead toincreased traffic, some congestion in relation to road closures for hazardousgoods transport, and the need for some alterations to intersections to cater for


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long loads. APSC committed to contribute to the maintenance and upkeep ofthe existing road system (draft EIS p8-3).

7.5.3 Water Supply

The water demand of the South point facilities is unlikely to impact upon theIsland’s town water supply. Much of the launch facility’s 40,000kl annualrequirement would be sourced from roof top water harvesting from thefacility buildings (20,000m2). APSC estimates this would produce between32,000kl and 38,000kl a year, to be stored in the 38,000kl on-site reservoir.The remainder of the required supply would be sourced from the Jedda Cavesource (the entire supply for the construction period would be sourced fromJedda Cave and stored in temporary lined areas on South Point).

The large storage area enables the facility to stockpile water, therefore notneeding to access draw on large quantities from Jedda Cave at any one time.With at least 32,000kl harvested from roofs, APSC estimates that themaximum daily draw rate would be 16m3/day. Existing demand on Jeddacave ranges from 778 m3/day to 1261 m3/day while flow rates rangefrom1123 m3/day to 12096 m3/day (average 5184 m3/day).

APSC also considered the impacts of other likely future population increases– resort casino, Irvine Hill development, and additional infill development(Supplement p38). The estimated total demand was a minimum of3,655 m3/day and maximum of 6,022 m3/day, while the flow-rates of existingsupplies is a minimum of 2,765 m3/day and maximum of 35,337 m3/day. Itwould appear that in the near future the cumulative impacts of thesedevelopments could lead to demand exceeding supply. APSC suggests threepossible approaches to resolving this issue:

Ø Initiate a water conservation strategy (1995 data indicated thatwater usage was four to five times higher than metropolitanAustralia);

Ø Initiate an improved maintenance program ensuring pipelines andequipment are routinely inspected, rectified or replaced; and,

Ø Initiate investigations o potential new water sources.

7.5.4 Education

An increase of more than 30 school students would require the establishmentof new classroom facilities. Increases in students could lead to changes in thestudent to teacher ratio and may require the employment of new teachingstaff. It is also possible that an increase might facilitate the extension of the


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current on-island schooling system to cover years 11 and 12. APSC notes thatit is difficult to estimate the level of impact as it will depend on the familystatus of the workers to be employed. APSC has committed to make efforts toforewarn the school of anticipated increases in student numbers at all stagesof the project.

7.5.5 Recreational Facilities

APSC would provide additional recreational facilities at the Irvine Hillcomplex and states that it will consider the location of some recreationalfacilities at the construction camp at South Point. The draft EIS states that thepresent recreational facilities are of a high standard and are not likely torequire upgrading as a result of the increase in population associated with theproposal.

Water based recreation on the island (swimming, fishing, diving, boating,snorkelling etc) focuses on Flying Fish Cove – which doubles as a commercialport. The increase in the number of recreational users of the cover –particularly temporary residents – may increase chances for conflict betweenthe two uses of the cove. APSC notes that the increase in population mayplace greater pressure on resources of the National Park. In particular thispressure might focus on visitor facilities. Some visitor facilities are also likelyto serve a secondary purpose as launch observation areas for the public.APSC states that it will “discuss the need to construct access areas in lesssensitive areas of the National Park to accommodate visitors with ParksAustralia North” (Draft EIS p9-21). It is also likely that liaison with APSC inrelation to the implementation of the Environmental Management Planduring both the construction and operational phases will place additionaldemands upon Parks Australia North staff on the island.

Recommendation 53: APSC’s contribution to the maintenance of visitorfacilities in Christmas Island National Park should be set out in theEnvironment Management Plan.

7.5.6 Hospital

The current hospital facilities are designed to provide for a residentialpopulation of up to 3000 people. This would suggest that while the facilitieswould be able to cater for the expected population increase associated withthe proposal, the cumulative increase discussed above could result in demandreaching design limits.

While it is unlikely that there will be any immediately severe impacts uponisland infrastructure, there would appear to be a number of areas where the


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cumulative impacts of predicted population increases in the next five yearscould lead to pressure upon infrastructure and resulting degradation of thequality of infrastructure standards on the island. It would be unreasonable toexpect existing residents to bear the burden of the pressures placed upon theisland by new commercial activities, and it could be expected that any suchimpact could serve to compound any community dissatisfaction with thelaunch facility.

While in some instances such as road maintenance APSC has madecommitments to contribute to costs, in other areas of infrastructure andcommunity development APSC has been non-committal in terms of making acontribution. APSC’s stated view is that it considers the significant amount ofcorporate tax that it will pay “ … would be an indirect contribution to theprovision of basic infrastructure and services on the island. Of course theextent to which this will occur is a matter for the CommonwealthGovernment” (Supplement pII-52). Concern was expressed by someattendees at community meetings as to whether this form of contribution tothe community would ever reach Christmas Island.

Recommendation 54: The Territories office should develop strategies tomonitor the cumulative impacts upon infrastructure and community servicesof the increase in population due to the launch facility project.

7.6 EMERGENCY PROCEDURES

Christmas Island has an Disaster Plan that deals with emergencymanagement arrangements and is organised by the Christmas Island CounterDisaster Committee. Some submissions and community meeting attendeesexpressed concern about how the voluntary fire service would cope with thenew scenarios. The draft Hazardous Material Contingency Plan includes theprovision of training on UDMH and NTO related emergencies to the police,fire brigade and hospital staff.

APSC has stated that if a medical emergency or in-flight emergency arises,then the required airport movements would be permitted immediately, withlaunches placed on hold or recycled until the emergency movements arecompleted (March 2000 additional information p18).

7.7 SOCIAL IMPACTS

The Draft EIS notes that the presence of launch facility staff would be likely toincrease the number of persons between the age of 25 and 40, and potentiallyreinforce the existing trend towards a larger percentage of males on theisland. The balance of the religious make-up of the island will be altered.


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Launch facility workers from off-island will be inexperienced in how theChristmas Island community functions. They may need time to becomefamiliar with the mix of ethnic groups, and to respect religious beliefs (forexample, the call to prayer from the Kampong Mosque. Russian techniciansmay have language difficulties.

Islanders will be faced with a large group of strangers. As discussed in theSocial and Economic Environment chapter, some islanders may harboursuspicions based on the partial failure of the resort casino operation tointegrate with the local community. Factors such as the temporary nature ofmany staff, a new ethnic group and language, and potentially isolatedaccommodation could all serve to cause problems if not dealt with.

Christmas Islanders are also likely to be concerned about the operation of thelaunch facility. Notes from community consultation meetings indicate a levelof concern and uncertainty about dangers of launches and space fuels. Someof these concerns have been fuelled by misinterpretation of information aboutother launch facilities elsewhere in the world, some of the concerns have beendeveloped in response to conflicting information provided in early attemptsby APSC at relating to the local community.

Given the existing diversity and strengths of the local community, therewould be every likelihood that the proposal would be able to operate onChristmas Island with minimal social impact if it implemented withsensitivity and a commitment to integrate with and involve the localcommunity as opposed to operating as a stand-alone project.

APSC states that in determining the most viable way to integrate the APSCworkforce into the island community, APSC was “cognoscente of the dangersof developing an insular enclave of citizens that were seen as remote andcontributing little to the Island’s economy and culture” (March 2000additional information p25). Yet APSC concluded that for reasons of bothpracticality (availability of land) and efficiency (economies of scale in serviceprovision), APSC decided on a centralised housing model for its workers.The approach allows APSC to provide the maximum standard and range offacilities for staff, thereby reducing the dependency on existing infrastructureand services. However in some areas such as medical and hospital services itwould be more feasible to utilise existing public sector infrastructure.

APSC argues that despite the centralised housing location, staff will movefreely within the Island community and will be encouraged to do so by APSC.Apart from that encouragement, and a commitment to making the activerecreational facilities of the complex available to local residents it is difficult toidentify how APSC proposes to take action to deal with this issue (seerecommendation 50).


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APSC has outlined a range of actions aimed at ensuring that the presentcultural norms and relaxed lifestyle of the Christmas Island community arenot compromised these are outlined in the following draft plans (Supplement,Attachment IV):

Ø Employee Cultural Education Plan;Ø Employee Environmental Education Plan;Ø Community Consultation Plan.

7.7.1 Employee Education

APSC proposes the development of cultural training workshops aimed at:

Informing employees of the cultural history of the island;Informing employees of appropriate customs to adopt when in the Kampongand other culturally sensitive areas;Training employees in conflict resolution techniques.

In addition, APSC would maintain a register of complaints received regardingthe conduct of their staff within the wider community, and would develop aset of guidelines setting out what is considered acceptable practice foremployees whilst on the island. Employees in breach of the guidelines wouldbe disciplined.

Recommendation 55: The Employee Cultural Education Plan and culturaltraining workshops should be developed in consultation with communityorganisation representative of the major cultural groups present onChristmas Island. APSC should also consider the possibility of employingmembers of the local community to conduct all or part of the culturaltraining workshops.

7.7.2 Community Consultation

The community consultation plan focuses on ensuring information regardingAPSC activities would reach the community – via notices in three languages,public meetings, information seminars etc. APSC would employ aCommunity Liaison Officer representing each ethnic sector of the community.“The primary role of this officer will be to act as a spokesperson for the sectorof the community he/she represents and will act as an interpreter which willmaintain effective community consultation” March 2000 additionalinformation p51).

APSC proposes to liaise with the community via regular meetings heldbetween members of APSC and representatives of the community. Thesewould be structured as a presentation by APSC followed by questions andanswers. Other means of liasing with the community would include:


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Ø Information available at the APSC Office;Ø Information packages provided to schools and other public

facilities;Ø A quarterly newsletter published in “The Islander” (local

newsletter);Ø A telephone number and email address made available for

inquiries.

The draft consultation plan appears to focus on the dissemination ofinformation, which while essential is only half of the task required.Performance indicators in the draft plan mostly refer to ensuring copies ofnotices and correspondences are kept and reviewed. More emphasis needs tobe given to openly being prepared to receive feedback from the community,and acting on this feedback in a positive and transparent manner whereverpossible. Auditing procedures need to include assessments of how APSC hasresponded to the needs of the local community.

While the employment of community liaison officer could be seen as avaluable recognition of APSC’s regard for the community and recognition oftheir potential contribution, some effort would need to go into ensuring thatthe liaison officers are not perceived as by-passing the communityorganisations formed by the community itself. Recognition of localcommunity organisations should also extend beyond ethnic groups toencompass other active groupings in the community with common needs andgoals such as business groups (Chamber of Commerce and TourismAssociation), and the Christmas Island Women’s Association.

Recommendation 56: The Community Consultation Plan must be extended toencompass mechanisms for receiving and acting on feedback from the localcommunity and auditing this process. The final Community ConsultationPlan must be developed in consultation with a wide range of localcommunity groups and should be endorsed by the Shire of Christmas Islandand Christmas Island Administration.


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8 ENVIRONMENTAL MANAGEMENT

8.1 ENVIRONMENT MANAGEMENT PLANS

The EIS presents a two stage environmental management system. Impactmatrices examine the potential for adverse and beneficial impact associatedwith the project; identify the implications and magnitude of these impacts;outline APSC’s commitment to mitigating any adverse impacts; and, assignthe commitments to an Environmental Management Plan. The final versionof the Impact Matrices can be found appended to the March 2000 additionalinformation. The Draft EIS described the second stage - EnvironmentalManagement Plans (EMPs) as formalising APSC’s commitments to mitigatingadverse environmental impacts associated with the construction andoperation of the proposed satellite launch facility. A second version of theEMPs was attached to the Supplement. The Supplement noted that thecurrent EMPs were a framework for future EMPs as part of the FacilitiesEnvironmental Management System to be developed after the EIS.

The impact matrices were found in some places to too readily dismiss thepossibility of negative impacts, and in some cases base this dismissal oninsufficient information. In other instances the conclusions or commitmentsconflicted with those made in the text of the EIS. Examples have been notedwhere relevant in the discussion of impacts in this report. The draft EMPSwere also found to be unsatisfactory in terms of some performance indicatorsand adaptive management responses.

As noted in this report, further data collection will be required on some issuesprior to the finalisation of the EMP. Environment Australia is of the view thatthe Environmental Management Plan for the proposal should be completed inconsultation with Environment Australia and other agencies responsible forrelevant regulation (via WA legislation). Many of the recommendations inthis report relate to issues that would need to be resolved in the EMP.

In addition to commitments in relation to specific activities and potentialimpacts, APSC makes a number of more general commitments relating to theenvironmental management of the project. These include:

Ø Close cooperation with Parks Australia North to ensure consistency withthe land management strategies Parks Australia North already has inplace;

Ø Establishment of an Environmental Management Division within APSC tocover all environmental aspects of the construction and operation of theSpace Centre.


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Ø Development and implementation of an Employee EnvironmentalEducation Plan;

Ø The establishment of the “Christmas Island Environmental Foundation”,which, in recognition of the interconnected nature of the ecological regimeon the island, would contribute to the management of the natural heritageon Christmas Island. APSC would contribute $1.0 million over ten yearsto the Foundation, and use the initial contribution to leverage funds, realand in kind, from other companies and government agencies. A smallboard of directors would manage the foundation with representativesfrom APSC, major financial contributors and Parks Australia North.

In relation to the last point, it should be noted that due to past and ongoingimpacts, the management of Christmas Island’s natural environment is a highcost exercise. For example, the cost of rehabilitation of previously minedareas is approximately $100,000 per hectare. The potential threat of theYellow Crazy Ant may require further resources in the near future.

The Space Activities Act 1998 requires that before a space licence is granted, therelevant Minister (intended to be the Minister for Industry, Science andResources) must be satisfied that all necessary environmental approvalsunder Australian law have been obtained, and that an adequateenvironmental plan has been made, for the construction and operation of thelaunch facility. Regulations to the Space Activities Act 1998 are still beingdeveloped.

The second key approval for the project would be the transfer of land toAPSC (via lease or freehold) by the Minister for Regional Development,Territories and Local Government. The Supplement states that APSC expectsthat the company would initially be granted a 99 year lease over the site, withthis lease converting to freehold possession once construction has finishedand the space centre is ready for operations (pII-3).

Further approvals will be required under the Space Activities Act 1998 for eachlaunch or series of launches. APSC has expressed the view that the currentEIS is intended to encompass all possibilities, so that no furtherenvironmental issues are raised at that stage (March 2000 additionalinformation p31). Given that ongoing operations and implementation of theEMP may result in restrictions on launch timing, it is not possible for allissues (for example, restrictions on launch scheduling in relation to birdnesting seasons) to be considered in this assessment.

It is considered that it would be appropriate for the Minister for Environmentand Heritage to approve the Environment Management Plan prior to theproposal proceeding.


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Recommendation 57: The final Environmental Management Plan for theproposed Christmas Island Satellite Launch Facility and associatedinfrastructure must be developed in consultation with Environment Australiaand agencies responsible for other relevant environmental regulation. TheMinister for Environment and Heritage must approve the EnvironmentalManagement Plan prior to the commencement of the construction of theproject.

Recommendation 58: The granting of a Space Licence for the ChristmasIsland Launch Facility must be conditional on APSC complying with therecommendations of the Minister for Environment and Heritage, and inparticular compliance with the Environmental Management Plan approvedby the Minister for Environment and Heritage. Granting of launch permitsfor the facility must also be conditional upon ongoing compliance with theEnvironmental Management Plan.

Recommendation 59: The granting of land to Asia Pacific Space Centre PtyLtd as either leasehold or freehold for the construction and operation of theChristmas Island Launch Facility must be conditional on APSC complyingwith the recommendations of the Minister for Environment and Heritage, andin particular compliance with the Environmental Management Planapproved by the Minister for Environment and Heritage.

8.2 REHABILITATION

A noted in Chapter 6, the EIS commits APSC to rehabilitation of areas as soonas possible after construction activity has ceased in a given area.

The Supplement (pII-3) provides some information on the end of life plan forthe project. APSC’s expectation is that based on financial viability andforeseeable market demand, the lifespan of the project would be 15-20 yearsbut that should the market provide an ongoing demand, the facility mightoperate beyond this. The EIS provides two alternative scenarios for theconclusion of the project:

“Upon the expiration of a viable operation, the Facility and its buildings maybe converted into an appropriate future development such as a researchcentre, museum and/or tourist/recreational facility. Alternatively, should itprove that the buildings are of no functional or productive use, the proponentwill dismantle and remove the structures and sensitively rehabilitate the sitein accordance with the prevailing statutory requirements and land useapprovals. A detailed Decommissioning Plan will be prepared by APSC PtyLtd within 5 years.”


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The South Point areas are currently held under mining leases by ChristmasIsland Phosphates. The leases require that the company must revegetate allmining leases before handing them back to the Commonwealth. Given that APSCwill be receiving this land, therefore preventing this condition from beingcomplied with, it would be appropriate for APSC to be required to undertakethe rehabilitation at the end of the life of the launch facility.

Recommendation 60: South Point Facilities should be decommissioned andremoved from the site and preferably the island at the end of the life of theproject. The South Point facility areas should be rehabilitated to a conditionconsistent with the surrounding natural environment.

Recommendation 61: The Decommissioning Plan should be prepared inconsultation with Environment Australia.

While the form of title that APSC will hold on the land for the South Pointfacilities has yet to be decided by the Minister for Regional Development,Territories and Local Government, it is intended that a bank guarantee will berequired during the construction of the facilities. This would be intended tocover the cost of restoration of the sites to original condition if the project failspartway through construction.

The Space Activities Act 1998 requires that the holder of a launch permit mustsatisfy insurance requirements by insuring both the permit holder and theCommonwealth for an amount not less than the maximum probable loss thatmay be incurred in respect of damage to third parties caused by the launch orreturn, as determined using the method set out the regulations.

APSC have committed to the rehabilitation of all areas affected by a launchanomaly with native floral species as soon as practical following devastationof an area by fire (Natural Impact Matrix p19). In the case of environmentaldamage to rainforest areas, rehabilitation may take decades before the arearesembles its original condition and possibly becomes suitable habitat forwildlife such as tree-top nesting seabirds. Given this, it would be appropriatein such cases for the proponent to be required to undertake additional,compensatory efforts to improve habitat on the island. This may involverehabilitation of other sites, or stress mitigation in terms of reducing otherthreats to fauna and flora (eg, feral animals). This option is suggested byAPSC (Supplement p28-30), although no commitment is given. APSC notesthat before such a program was initiated, there needs to be confirmation thatthe activity (eg, removal of feral cats) would be beneficial. The control of theYellow Crazy Ant would be one possible avenue that the proponent couldcontribute to.

Recommendation 62: APSC must give a legally binding commitment(enforceable by the Commonwealth) that it will, at the request of the


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Commonwealth, rehabilitate any aspect of the environment that issignificantly damaged as a result of the construction or operation of theproposed launch facility and associated infrastructure

Recommendation 63: In the event of a launch accident over the island whichdestroys significant habitat, APSC must provide additional compensationmeasures to improve habitat on the island.

Recommendation 64: APSC should be required to lodge a security so as toreduce the risk to the Commonwealth that may be incurred by failure of theproponent to meet environmental management responsibilities.


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9 CONCLUSION

This assessment report has provided an examination of the environmentalimpact statement prepared by ERA. In other chapters of this report,recommendations have been made regarding either actions that should betaken prior to any Commonwealth approval for this proposal, or conditionsthat should be placed on approvals given by the Commonwealth for thisproposal. There are two key Commonwealth approvals required beforeconstruction of the proposal may proceed:

Ø Approval for the transfer of land to APSC (via lease or freehold) bythe Minister for Regional Development, Territories and LocalGovernment;

Ø Granting of a Space Licence by the Minister for Industry, Scienceand Resources as required by the Space Activities Act 1998.

Approval of Launch Permits will also be required under the Space ActivitiesAct 1998 for each launch or series of launches. This provides the opportunityfor the Departments of Regional Development, Territories and LocalGovernment, and Industry Science and Resources to determine inconsultation with Environment Australia the most appropriate means ofimplementing the recommendations in this report.

In addition to the recommendations, APSC has outlined numerouscommitments regarding the design, management and operation of theproposal that are aimed at avoiding or minimising environmental impacts.

Recommendation 65: APSC must ensure that the proposal is implemented inaccordance with the commitments and safeguards identified in the ChristmasIsland Satellite Launch Facility Draft Environmental Impacts Study August1999, or as modified or added to in the Christmas Island Satellite LaunchFacility Final Environmental Impact Statement January 2000, and theadditional information provided by APSC on 24 March 2000 unless thesecommitments and safeguards are superseded by recommendations made bythe Minister for the Environment in relation to this proposal.

Final planning and design of the project and the environmental managementplans has yet to be completed. This environmental assessment report hasbeen prepared in that context. The recommendations identify where APSCwill need to involve Environment Australia, the Territories Office (andthrough the Office, relevant Western Australian Government Departmentsacting as service providers), the Shire Council of Christmas Island andrelevant community groups in implementing recommendations as theplanning for the project proceeds.


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In conclusion however, Environment Australia is of the view that theproposed establishment of a launch facility on Christmas Island may not bean activity that will be compatible with the natural environment of ChristmasIsland and in particular the environment of South Point. As discussed inChapter 4 of this report, the environment of Christmas island has manyfeatures that are unique – including a number of endemic species, some ofwhich are endangered, and unique habitats and ecological interrelationships.These unique aspects are confined to the 135 square kilometres of ChristmasIsland, and many of them to specific habitats distributed across only part ofthe island. In addition, Christmas Island also harbours species that are underthreat elsewhere in their ranges, and also possesses important geologicalfeatures.

As set out in Chapter 6, the proposal, if undertaken, would present thisimportant natural environment with a range of potential impacts whichcannot be completely ruled out through mitigation measures. Some, such asthe possibility of a fuel spill that harms the natural environment have only avery small chance of occurring. Others, such as the explosion of a launchvehicle over the island have a greater but still small chance of occurringduring the life of the project. Such an accident would probably cause damageto valuable habitat for important seabird colonies on South Point. Eachlaunch will expose those same South Point colonies to the impact of launchnoise. This noise will have some impact upon the seabird colonies, but itcannot be known whether the impact will be significant until after a series oflaunches are monitored and the data compared to baseline data. The launchactivity could also cause the loss of one or more territories of the endangeredChristmas Island Goshawk.

As noted in Recommendation 27, Environment Australia is of the view that iflaunch activities are found to cause a significant negative impact upon theSouth Point seabird colonies, this must result in a suspension of the launchregime while the possible causes are investigated by a panel of avian expertsappointed by the Minister for Environment and Heritage. In order to preventfurther impacts to the colonies launches would need to be delayed until sucha time that it has been determined whether further launches are possiblewithout bringing about further decline or preventing recovery of numbers.While adaptive management of the launch facility may offer solutions in somecases, APSC has not been able to demonstrate to our satisfaction that it wouldin all cases be able to modify launch activities so that they might continuewithout causing further significant negative impacts upon the seabird colony.Therefore, the only course that could be taken to protect the colonies wouldbe to discontinue rocket launches from the facility.


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10 REFERENCES

Much of the information in the assessment report is derived from the informationprovided by APSC in the Draft EIS, Supplement and additional information. Pagenumbers for specific points made by APSC are referenced in the text. Additionalinformation on the natural environment of Christmas Island is sourced from the 1999National Park Draft Plan of Management, and input from Parks Australia staff.Other sources are referenced in the text where referred to.

Adams, J., Neale, M. 1993 “Christmas Island, The Early Years”, SouthwoodPress, Marrickville NSW.

ARUP Geotechnics, May 1999 “APSC Christmas Island Project – Report onGeotechnical Investigations”, ARUP Geotechnics Brisbane, QLD.

Asia Pacific Space Centre Pty Ltd, 1999 “APSC Christmas Island SatelliteLaunch Facility- Draft Environmental Impact Statement”, Sinclair, Knight,Merz August 1999.

Asia Pacific Space Centre Pty Ltd, 2000 “APSC Christmas Island SatelliteLaunch Facility- Final Environmental Impact Statement”, Sinclair, Knight,Merz January 2000.

Asia Pacific Space Centre Pty Ltd, 2000 “Proposed Satellite Launch Facilityon Christmas Island – Assessment of Final Environmental Impact Statement –Responses From Asia Pacific Space Centre Pty. Ltd. On further InformationRequired Under Para 9.2 of the Administrative Procedures of theEnvironment Protection (Impact of Proposals) Act 1974”. AdditionalInformation received by Environment Australia 24 March 2000.

Busacca, M., 1999, Pers Com, Kennedy Space Centre Environmental ProgramOffice.

Breininger, D. R, et al March 1994, “Endangered and Potential EndangeredWildlife on John F. Kennedy Space Centre and Faunal Integrity as a Gaol forMaintaining Biological Diversity”, NASA Technical Memorandum 109204.

Briggs, J.D., and Leigh, J.H (1995). “Rare or threatened Australian plants”.CSIRO Publishing. Collingwood, Victoria

Brown, I. K., 1998 “New Millenium NASA – International Space Station and21st Century Space Exploration”, Pioneer Publications, California.

Curl, D., 1997 “The Changing Fortunes of Christmas Island”, AustralianGeographic, January-March 1997.


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De Korte, J. “Status and Conservation of Indonesia’s Seabird Colonies” ICBPTechnical Publication No 11, 1991.

ESA (European Space Agency) 1999 “World experts on space debris meet inEurope on 11-13 October” ESA Press Release No 41-99 Paris, 4 October 1999.

Garfein, V. 1999, Pers Com, Florida Department of Environment Protection.

Great Barrier Reef Marine Park Authority (1997) “Guidelines for Managingvisitation to Seabird Breeding Islands”, Great Barrier Reef Marine ParkAuthority, Townsville, Queensland.

Green, P.T., O'Dowd, D.J., and Lake, P.S (1997) “Control of seedlingrecruitment by land crabs on a remote oceanic island”. Ecology 78:2474--2486

Green, P.T., O'Dowd, D.J., and Lake, P.S (1998) “Long term control of seedlingrecruitment and litter dynamics by red land crabs in rainforest on ChristmasIsland Indian Ocean”. Unpublished report to Environment Australia, ParksAustralia North. 41pp

Green, P.T., Lake, P.S., and O'Dowd, D.J (1999) “Monopolization of litterprocessing by a dominant land crab on a tropical oceanic island”. Oecologia119:435-444

Humphreys, W.F. , in press. Chapter 0. Background and glossary. Pp 1-14.In: H. Wilkens, D.C. Culver and W.F. Humphreys (eds). Ecosystems of theWorld, vol. 30. Subterranean Exosystems Elsevier, Amsterdam.

ICF Consulting, December 1999 “Review of an Environmental ImpactStatement for the Construction and Operation of a Satellite Launch Facility onChristmas Island”, ICF Consulting Pty Ltd, North Fitzroy, Victoria.

ICF Consulting, February 2000 “Review of an Final Environmental ImpactStatement for the Construction and Operation of a Satellite Launch Facility onChristmas Island”, ICF Consulting Pty Ltd, North Fitzroy, Victoria

ICF Consulting, April 2000, “Verification of Selected Environmental ImpactStatement Analyses for the Christmas Island Satellite Launch Facility”, ICFConsulting Pty Ltd, North Fitzroy, Victoria.

Johnson, L. August 1998(a) “Submission on the Social Impact of the ProposedSatellite Launch Project, Christmas Island”, Christmas Island.

Johnson, N. L., August 1998(b) “Monitoring and Controlling Debris in Space”,Scientific American,.


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Lynch, K. (Christmas Island Phosphates Environmental Coordinator) PersCom, 18 November 1999

Lumsden, L. (Arthur Rylah Institute, Victorian Dept of Natural Resources andEnvironment), Pers Com, 30 March 1999

Lumsden, L; Silins, J; Schulz, M; 1999; “Population Dynamics and Ecology ofthe Christmas Island Pipistrelle, Pipistrellus murrayi, on Christmas Island –Consultancy for Parks Australia North – Christmas Island”; Arthur RylahInstitute for Environmental Research, Department of Natural Resources andEnvironment, Victoria.

Mazurski, E., Project Officer Hazardous Substances Unit, NationalOccupational Health and Safety Commission, Pers Com, 3 February 2000.

McGovern, N. (Christmas Island Harbourmaster) Pers Com 24 September1999

NASA 1997 “NASA Policy Directive. Office of Safety and Mission Assurance.NASA Policy for Limiting Orbital Debris Generation” NPD 8710.3, NASA

Nettleship, D. N., Burger, J., Gochfeld, M. “Seabirds on Islands: Threats, CaseStudies and Action Plans”, Birdlife International 1994.

Parks Australia, Environment Australia (Oct 1999) “Christmas IslandNational Park – Draft Plan of Management”, Commonwealth of Australia1999.

Schultz, S. J., “Californian Least Tern Monitoring Report for the July 9, 1997SLC-2 Delta Space Vehicle Launch, Vandenberg Air Force Base” Bioresources,18 August 1997.

Spence, P. (Australian Federal Police, Christmas Island) pers com24 September 1999

Thorson, P., Francine, J., Eidson, D., (1998) “Acoustic Measurement of theTitan IV A-18 Launch and Quantitative Analysis of Harbor Seal (Phoca vitulinarichardsi) Behavioural and Auditory Responses”, SRS Technologies, California

UNISPACE 3 “Draft Report of the Third United Nations Conference on theExploration and Peaceful Uses of Outer Space”, 16 April 1999

United States Environment Protection Agency, US Department ofTransportation, Office of Commercial Space Transportation, August 1990,Safety Evaluation of Astrotech Payload Processing Facility Titusville Florida.


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United States Fish and Wildlife Service “Merrit Island Wildlife Refuge”(information brochure) US Government Printing Office.

United States Fish and Wildlife Service “Biological Conference Opinion forthe Delta II Launch Program at Space Launch Complex 2, and Taurus LaunchProgram at 576-E, Vandenberg Air Force Base 1-8-98-F-25R” Dec 4 1998,provided by Lee An Naue, US Fish and Wildlife Service.

Wade, M., 2000 “Encyclopedia Astronautica”,http://www.friends-partners.org/~mwade/lvs/angara.htm


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11 GLOSSARY

Anchialine anchialine (or anchihaline) * Anchialine habitats consist ofbodies of haline waters, usually with a restricted exposure toopen air, always with more or less extensive subterraneanconnections to the sea, and showing noticeable marine as well asterrestrial influences. They typically occur in volcanic orlimestone bedrock.

APPEA Australian Petroleum Production and Exploration AssociationAPSC : Asia Pacific Space Centre Pty LtdBH Bore holeCAMBA China and Australia Migratory Birds AgreementCI Christmas IslandCIP Christmas Island PhosphatesDB DecibeldBA Decibel A weighted sound levelDEIS Draft Environmental Impact StatementDISR Department of Industry Science and ResourcesEIS Environmental Impact StatementEP Act Environmental Protection Act (WA) 1986EPIP Environment Protection (Impact of Proposals) Act 1974ESA European Space AgencyGBMRPA Great Barrier Reef Marine Park AuthorityHa HectareISO International Standards OrganisationJAMBA Japanese and Australia Migratory Birds AgreementKBOM Design Bureau of General Machine BuildingKBTM Design Bureau of Transport MachineryLV Launch Vehicle Assemblym MetreML Mining leaseMOU Memorandum of UnderstandingMW MegawattNAERG North American Emergency Response GroupNASA National Aeronautics and Space AdministrationNTO Nitrogen tetroxideRO-RO Roll-on Roll-off (Port facility)SLASO Space Licence and Safety OrganisationUDMH Unsymmetric di-methyl hydrazineUSA United States Of America


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Proposal To Establish A Satellite Launch Facilityand Associated Infrastructure on Christmas Island.

Recommendations Contained in theEnvironment Assessment Report

Prepared by Environment Australia, May 2000.

Recommendation 1: APSC, in consultation with the Christmas IslandConservator, should establish a comprehensive baseline by identifying areasof vegetation on the proposed Launch and Technical Complex that are ofimportant habitat value.

Recommendation 2: APSC, in consultation with the Christmas IslandConservator, should establish a comprehensive baseline by conducting floraand fauna surveys of the Administration and Residential Complex, and anyareas to be disturbed during construction of additional airport facilities.

Recommendation 3: APSC should establish a comprehensive baseline for theChristmas Island Pipistrelle Bat by conducting surveys of its distributionusing ultrasonic detectors, and where appropriate, radio tracking, in order toestablish the distribution and abundance of the bat on South Point. Thesurvey should be completed prior to the commencement of any constructionactivity on South Point by APSC and the survey design should be approvedby the Environment Australia.

Recommendation 4: APSC should establish a comprehensive baseline, byundertaking a survey of the occurrence of endemic reptile species should becarried out in the areas that would be disturbed during the construction andoperation of the Technical and Launch Complexes on South Point. Thesurvey should be completed prior to the commencement of any constructionactivity on South Point by APSC and the survey design should be approvedby Environment Australia.

Recommendation 5: APSC must develop a proposal to conduct a survey forpossible cave systems and subterranean fauna on South Point focusing on theproposed site of the Technical and Launch Complexes and using nondamaging techniques such as ground probing radar. This plan is to beapproved by Environment Australia prior to the survey taking place. Areport on the survey results must be provided to Environment Australia andshould be taken into account in the development of the EnvironmentalManagement Plan for the project.


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Recommendation 6: The layout of buildings and infrastructure in all areas ofthe proposal must be designed as far as possible (without compromisingsafety requirements) to avoid necessitating the clearance of importantregrowth habitat during construction. Project layout and construction mustnot involve the clearance or damage of primary rainforest. Buffer zones atleast 20m in width, consisting of regrowth vegetation or rehabilitated areasmust be left between primary rainforest and project areas. Clearedvegetation must not be burnt and should be mulched where possible. APSCmust obtain the approval from Environment Australia for vegetationclearance prior to construction commencing.

Recommendation 7: Rehabilitation and landscaping plans must be developedas part of the Environment Management Plans to be approved byEnvironment Australia.

Recommendation 8: The water pipeline from Jedda Cave to South Pointmust be placed underground. Placement of the pipeline through a section ofnational park will require separate consideration under the National Parksand Wildlife Conservation Act 1975 or Environment Protection andBiodiversity Conservation Act 1999.

Recommendation 9: The cost for control of feral animals on project sites andferal animals dispersed to adjacent areas as a result of construction activitymust be met by APSC. Control techniques must be approved by ParksAustralia.

Recommendation 10: A strategy for the prevention of transportation of theYellow Crazy Ant and soil micro-organisms through the movement ofearthmoving and construction vehicles must be developed and implementedas part of the Environment Management Plan.

Recommendation 11: APSC must include awareness of quarantine proceduresand requirements in introductory training for all employees and contractors.

Recommendation 12: APSC, in consultation with the Australian Quarantineand Inspection Service, must construct appropriate quarantine facilities atall new points of entry to Christmas Island that are established as part of theproposal.

Recommendation 13: Territories Office must ensure that adequate levels ofsuitably trained inspection staff are available to undertake quarantineinspections and treatments of the expected increased levels of cargo andcontainers arriving on the island as a result of the proposal.

Recommendation 14: In addition to APSC’s commitments in the EIS, APSCshould record instances of significant avifauna road mortality, both on theSouth Point project area and during cross-island transportation and report


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instances to the Conservator (monthly). Modification of transport activitymay have to be made if Environment Australia determines that levels of roadmortality may endanger or further endanger native species. APSC shouldinstall crab tunnels under new and existing roads at points to be determinedby the Conservator, and should contribute to the maintenance of existing crabtunnels.

Recommendation 15: APSC must present the results of a routing analysis(including the landing of materials onto the island) describing and evaluatingall options for the transportation of Kerosene, Diesel fuel, Unsymmetric di-methyl hydrazine and Nitrogen Tetroxide, so that the Minister for theEnvironment and Heritage can provide additional advice on the preferredroute in relation to his responsibilities under the Environment Protection(Impact of Proposals) Act 1974.

Recommendation 16: APSC must produce a report modelling the impacts ofworst case releases of Unsymmetric di-methyl hydrazine and NitrogenTetroxide in inhabited and ecologically sensitive areas of the island andprovide it to the Minister for Environment and Heritage no later than theprovision of the routing analysis.

Recommendation 17: APSC should not use helicopters as a means oftransporting construction material to South Point. If APSC believes that ithas no alternative to the use of helicopters, then a trial should be carefullydesigned and approved by Environment Australia (and other relevantauthorities). After approval, the trial should be carried out with appropriatemonitoring to determine the reaction of seabird colonies to helicopterdisturbance. After considering the outcomes of the trial, the Minister for theEnvironment may provide further recommendations.

Recommendation 18: Lighting facilities must be designed in such a mannerthat light from the South Point facilities must not be visible in the sky overGreta or Dolly Beaches.

Recommendation 19: Strategies for lighting design and the minimisation oflighting and tall structure impacts and for the monitoring of impacts andsubsequent management responses must be approved by EnvironmentAustralia as part of the Environmental Management Plan.

Recommendation 20: The management of liquid oxygen must be addressed inthe Hazardous Material Contingency Plan.

Recommendation 21: All UDMH and NTO storage and transport containers(including payload fuel tanks) must be approved as safe for use under therelevant Western Australian legislation. The payload processing facility, itssafety features and certification of fuel handling teams must also beapproved under relevant Western Australian legislation. Where such


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regulation does not currently exist, it must be developed to match or exceedworld’s best practice prior to any operation involving these fuels proceeding.

Recommendation 22: APSC must monitor the impact of the ground cloud inthe first five launches. Monitoring reports must include measurements on thecloud composition, temperature, dispersal and area of harmful impact.Surveys for impacts on fauna and flora must be conducted at a number ofsites spaced downwind of the launch pad concerned (100m, 300m, 600m, 1km,2km). Reporting arrangements and possible management responses will bespecified in the Environmental Management Plan.

Recommendation 23: APSC must investigate and report on alternativeconfigurations which would allow for a wider buffer zone between the launchpads and areas of natural habitat. Comment should be sought from theMinister for Environment and Heritage on the alternatives prior to the finalsiting decision being made.

Recommendation 24: APSC must carry out and report on measurements oflaunch noise for the first launch of each model of rocket so that the predictednoise levels may be verified. Distances at which noise levels are measuredshould be determined in consultation with Environment Australia andappropriate noise regulation authorities under applicable Western Australianlaw.

Recommendation 25: APSC must develop weighted sound filters for a rangeof target species to be agreed with Environment Australia.

Recommendation 26: A full seabird monitoring program be developed andtested as part of the Environment Management Plan to be approved by theMinister for Environment and Heritage. The seabird monitoring programmust include the collection of baseline data for at least three years prior tothe first launch. The monitoring program must be developed in consultationwith Environment Australia and scientists recognised as having expertise inrelation to both the seabirds concerned and expertise in the development ofmonitoring techniques.

Recommendation 27: The adaptive response management regime must berevised as part of the Environment Management Plan to be approved by theMinister for Environment and Heritage. The revised regime must bedeveloped in consultation with Environment Australia and scientistsrecognised as having expertise in relation to the seabirds concerned andexpertise in monitoring techniques. A significant impact upon the seabirdcolony such as a decline in reproductive output of seabirds at 15-30% or moreof sites monitored on South Point (without a corresponding decline at controlsites) must result in a suspension of the launch regime while the possiblecauses are investigated by a panel of avian experts appointed by the Ministerfor Environment and Heritage, until such a time that the panel has


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determined whether further launches are possible without bringing aboutfurther decline or preventing recovery of numbers.

Recommendation 28: For any night launches conducted, APSC must carryout the monitoring program to ensure effective monitoring of short termimpacts.

Recommendation 29: Monitoring proposed in the EIS for land fauna must besignificantly revised in consultation with Environment Australia in thepreparation of the Environment Management Plan.

Recommendation 30: An adaptive management regime must be developed forall endangered and vulnerable species present on South Point, as well as forspecies for which significant populations have been found in the vicinity ofthe launch area. The management regime must take into account recoveryplans prepared for endangered and vulnerable species. The managementregime must be included in the Environment Management Plan to beapproved by the Minister for Environment and Heritage.

Recommendation 31: The Environment Management Plan must include aplan for how APSC will respond to the environmental impacts of a launchaccident over the island. The plan must include a survey of impacts uponflora and fauna, and immediate, short term and longer term responses tominimising and remediating impacts.

Recommendation 33: APSC’s spill response plan must include effectivemechanisms that prevent the contamination of Christmas Island beachesfrom fuel spills.

Recommendation 34: APSC should investigate means of ensuring thatfairings sink soon after impact.

Recommendation 35: APSC should develop and implement recoveryprocedures for rocket stages as this becomes international practice for othercommercial launch operations.

Recommendation 36: The Minister for Industry Science and Resources, inexercising portfolio responsibilities in relation to petroleum exploration andproduction and the regulation of space activities, should ensure that thepotential for conflict of resource use in offshore areas be taken into account.

Recommendation 37: Launch approval should include an assessment ofdebris generation potential and debris mitigation options based oninternational best practice, but at the least including the following:

Ø The potential for orbital debris generation in both nominaloperation and malfunction conditions;


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Ø The potential for orbital debris generation due to on-orbit impactwith existing space debris (natural or human generated) or otherorbiting space systems;

Ø Post mission disposal; and,Ø The potential for items to pose a safety or environmental threat

upon re-entry.

Where the assessment finds that debris contributions or the risk to theenvironment or safety are not acceptable, additional design and mitigationmeasures must be implemented.

Recommendation 38: Approval for construction of the proposal should notoccur until it is demonstrated that the underlying geological structure issufficiently stable to support the proposed facilities and able to remain stableduring launch activities or accidents.

Recommendation 39: The report on the survey for possible cave systems andsubterranean fauna on South Point focusing on the proposed site of theTechnical and Launch Complexes should be used to develop measures toavoid, monitor or remediate impacts upon these environments. Thesemeasures must be included in the Environment Management Plan.

Recommendation 40: APSC should monitor and report on launch vibrationinitiated rockfalls as part of the Environment Management Plan.

Recommendation 41: The Hazardous Materials Contingency Plan shouldinclude emergency response actions to be made to spills during storage aswell as transportation.

Recommendation 42: A Potential Seismic Hazard Assessment should becarried out and be taken into account in the design of foundations andbuilding structures. All fuel storage facilities should be designed to thestandards required for hazardous installations.

Recommendation 43: APSC should provide information on the criteria usedto set the 2 km exclusion zone around the launch site so that it may beconsidered in the space licence procedure.

Recommendation 44: Launch activities should not result in closure of accessto the South Point Chinese Temple during religious celebrations associatedwith God’s Birthday and the 1st and 15th days of the Chinese New Year Period(as determined by the lunar calendar). Alterations to this restriction mayonly be made with the agreement of the South Point Chinese TempleCommittee.

Recommendation 45: APSC, in consultation with the Temple Committee,must further analyse the potential for launches or on-pad explosions to


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damage the South Point Temple and Shrines. This information should beprovided to the Temple Committee so that they are in a position to evaluatethe potential impacts in considering the future of the South Point Temple andShrines.

Recommendation 46: APSC must investigate and report on alternativeconfigurations which would allow for a wider buffer zone between the launchpads and the South Point Temple and Shrines. The Temple Committee andthe Minister for Environment and Heritage should be allowed to comment onthe alternatives prior to the final siting decision being made.

Recommendation 47: If the Roll-on Roll-off facility is to be located asproposed in the supplement, restrictions on maximum noise levels to beproduced must be developed in consultation with the Western AustralianDepartment of Environmental Planning and the Shire of Christmas Island.The facility should only be used during normal business hours.

Recommendation 48: Further documentation on the proposed Roll-on Roll-offfacility including plans, elevations, sections, design details and a landscapeplan should be referred to the Australian Heritage Commission for commentin line with Section 30 of the Australian Heritage Commission Act (1975)prior to a final decision being made about construction of the facility.

Recommendation 49: Further community consultation on the design andlocation of the Roll-on Roll-off facility should occur before final designs arecompleted. This process should be overseen by the Christmas Island ShireCouncil. Subject to comment from the Australian Heritage Commission onthe potential impact on the national estate values, the final decision on thecurrent proposal for the Roll-on Roll-off facility should rest with the ShireCouncil. If the current proposal is rejected, APSC must further examine andreport on other options for the delivery of freight to Christmas Island. Thisanalysis must be referred to Environment Australia for further considerationand possible recommendations prior to a final decision on siting being made.

Recommendation 50: The planning and design of the proposed residential andadministration complex at Irvine Hill should be carried out within thecontext of the planning for the future of the Irvine Hill area in accordancewith the Shire of Christmas Island Town Planning Scheme and giveparticular consideration to the integration of the complex into the existingisland residential framework and siting to avoid aircraft noise impacts.

Recommendation 51: Design of the Residential and Administration Complexshould reflect the existing architectural styles on Christmas Island. APSCmust demonstrate that energy efficiency measures and use of renewableenergy have been incorporated wherever possible into all buildings to beconstructed as part of the proposal (including those at South Point).


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Recommendation 52: In developing plans for the management of waste andhazardous materials, APSC must identify processes, materials andtechniques to be used at the launch facility and work with regulators toensure all efforts have been made to reduce or eliminate the generation ofwaste. The waste management component of the Environmental ManagementPlan must be approved by the Shire of Christmas Island.

Recommendation 53: APSC’s contribution to the maintenance of visitorfacilities in Christmas Island National Park should be set out in theEnvironment Management Plan.

Recommendation 54: The Territories office should develop strategies tomonitor the cumulative impacts upon infrastructure and community servicesof the increase in population due to the launch facility project.

Recommendation 55: The Employee Cultural Education Plan and culturaltraining workshops should be developed in consultation with communityorganisation representative of the major cultural groups present onChristmas Island. APSC should also consider the possibility of employingmembers of the local community to conduct all or part of the culturaltraining workshops.

Recommendation 56: The Community Consultation Plan must be extended toencompass mechanisms for receiving and acting on feedback from the localcommunity and auditing this process. The final Community ConsultationPlan must be developed in consultation with a wide range of localcommunity groups and should be endorsed by the Shire of Christmas Islandand Christmas Island Administration.

Recommendation 57: The final Environmental Management Plan for theproposed Christmas Island Satellite Launch Facility and associatedinfrastructure must be developed in consultation with Environment Australiaand agencies responsible for other relevant environmental regulation. TheMinister for Environment and Heritage must approve the EnvironmentalManagement Plan prior to the commencement of the construction of theproject.

Recommendation 58: The granting of a Space Licence for the ChristmasIsland Launch Facility must be conditional on APSC complying with therecommendations of the Minister for Environment and Heritage, and inparticular compliance with the Environmental Management Plan approvedby the Minister for Environment and Heritage. Granting of launch permitsfor the facility must also be conditional upon ongoing compliance with theEnvironmental Management Plan.

Recommendation 59: The granting of land to Asia Pacific Space Centre PtyLtd as either leasehold or freehold for the construction and operation of theChristmas Island Launch Facility must be conditional on APSC complying


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with the recommendations of the Minister for Environment and Heritage, andin particular compliance with the Environmental Management Planapproved by the Minister for Environment and Heritage.

Recommendation 60: South Point Facilities should be decommissioned andremoved from the site and preferably the island at the end of the life of theproject. The South Point facility areas should be rehabilitated to a conditionconsistent with the surrounding natural environment.

Recommendation 61: The Decommissioning Plan should be prepared inconsultation with Environment Australia.

Recommendation 62: APSC must give a legally binding commitment(enforceable by the Commonwealth) that it will, at the request of theCommonwealth, rehabilitate any aspect of the environment that issignificantly damaged as a result of the construction or operation of theproposed launch facility and associated infrastructure

Recommendation 63: In the event of a launch accident over the island whichdestroys significant habitat, APSC must provide additional compensationmeasures to improve habitat on the island.

Recommendation 64: APSC should be required to lodge a security so as toreduce the risk to the Commonwealth that may be incurred by failure of theproponent to meet environmental management responsibilities.

Recommendation 65: APSC must ensure that the proposal is implemented inaccordance with the commitments and safeguards identified in the ChristmasIsland Satellite Launch Facility Draft Environmental Impacts Study August1999, or as modified or added to in the Christmas Island Satellite LaunchFacility Final Environmental Impact Statement January 2000, and theadditional information provided by APSC on 24 March 2000 unless thesecommitments and safeguards are superseded by recommendations made bythe Minister for the Environment in relation to this proposal.

Documents

PROPOSAL TO CONSTRUCT AND OPERATE A ...Christmas Island Satellite Launch Facility Proposal Environment Assessment Report - Environment Assessment Branch – May 2000 8 Guidelines were