Threatened and Endangered Species
Southern Launch's major development proposal has been flagged by the Federal Environmental Minister, Sussan Ley, as a controlled action under the EPBC Act - Environment Protection and Biodiversity Conservation Act. This controlled action has highlighted 48 threatened species within 10km of the proposal - of these, 10 were deemed to be particularly at risk (The Western Whipbird, Southern Emu Wren, Australian Sea Lion, Australian Fairy Tern, Eastern Hooded Plover, Leather-back Turtle, Loggerhead Turtle, Southern Right Whale, Blue Whale, White Shark).
Birdlife and Impact of Noise
Whalers Way is home to over 28 bird species; with 6 threatened bird species identified on field studies and a further 10 threatened species known to occur in Whalers Way (page 50, EIS). Birds are at extreme risk of behaviour change and nest/habitat abandonment during breeding seasons, which occur for 4-6 months of the year. Whalers Way needs to remain under the Heritage Act to protect the home of these endangered species. A rocket launch facility will have detrimental effects on these populations.
Birds suffer permanent hearing loss at 140dBA and temporary hearing loss and behavioural change at 93dBA. Southern Launch state in Appendix O of their EIS that the rockets will cause a sound, lasting 1-2minutes, ranging from 135dBA at the launch site and 95dBA at the northern tip of Liguanea Island (a marine sanctuary home to the endangered Australian sea lion and many other animals including bird species). Contradicting, in appendix R, they state that “noise modelling is likely to range from 140 dB for the largest rockets (100 tonne), to 120dB for smaller rockets (50 tonne) (page 3, Appendix R, EIS). “Studies of terrestrial mammals have shown that noise levels of 120 dBA can damage mammals’ ears, and levels at 95 dBA can cause temporary loss of hearing acuity (Wyle, 2003)” (page 78, appendix P, EIS). They have confirmed “there may be temporary hearing loss or behavioural impacts on birds using sections of the mainland coastline near the launch sites.” (page 41, appendix S, EIS). This will extend over 8km from the launch site as “the maximum instantaneous sound pressure level (airborne) would be 90–95 dBA at the northern end of Liguanea Island. “This is close to the threshold at which temporary hearing loss may occur for birds” on the island – let alone the birds on the mainland. (page 6, appendix S, EIS). Therefore, the potential to cause permanent hearing loss, as well as temporary hearing loss, in endangered birds in this area is significant.
Additionally, their mitigation measures include a “scare gun” (120 dB) that will be fired from dawn til launch times to "remove sensitive fauna from the immediate noise zone (page 5, Appendix R, EIS). So even their mitigation measure will cause temporary hearing loss to birds. This activity, let alone the activity of general construction and every day movements, in this sensitive area will cause change in behaviour. This will ultimately result in the abandonment of the area and eventual demise of the bird populations, some of which are endangered.
The Southern Emu Wren
The Southern Emu Wren is classified as ENDANGERED under the NPW Act and this specific sub-species on the Eyre Peninsula is on the brink of extinction. Southern Launch have provided a map showing where the known Southern Emu-Wren hotspots are, superimposed over their facility. It is obvious that both launch sites, especially Launch Site A, will either directly displace their habitat as well as pose a significant threat to normal behaviour. Habitat loss is their number one killer. Considering the sound of a launch will reach 135dBA at the launch site, and that temporary hearing loss occurs at 95dBA, with permanent hearing loss occurring at 140dBA, launches this close to all of these hotspots will be devastating to the populations here, not only for the Southern Emu-Wren, but also to all of the other bird species. Furthermore, the noise from generators running regularly will also disrupt normal behaviour. To do this to an already endangered species will be devastating and will likely result in the subspecies extinction. If this occurs, then this will be a massive failure on the South Australian Government to protect the native fauna.
Photo credit: Dion Thompson
Launch Pad Image: Figure 6, Appendix P, EIS
The Western Whipbird
The Western Whipbird is another endangered bird that inhabits Whalers Way. It is a weak flier and is a species that requires its habitat to be protected. There are three clusters of these birds on the Eyre Peninsula, one being at D’Anville Bay in Whalers Way. We have no knowledge of the effect of noise and human activity on Whipbird populations and must endeavour to protect their habitat from destruction and noise pollution.
Photo credit: Dion Thompson
Eastern Osprey
Of notable importance, are the two Eastern Osprey nests located in Whalers Way. The Eastern Osprey is listed as endangered under the South Australian National Parks and Wildlife Act 1972 (p.6, Appendix R). Recent surveys undertaken in South Australia have revealed a decline in population for the Osprey, including in western South Australia (p.6, Appendix R). This population is considered "unstable" (p.6, Appendix R). Whalers Way has known Osprey territories that were still occupied during the most recent surveys (p.7, Appendix R). The Osprey is known to form long-term pair bonds and use the same nesting locations over long time periods (p.7, Appendix R).
Known threats to the Osprey include (p.7 and 16, Appendix R):
Human Disturbance
Habitat Degradation
Vegetation clearance
Fire
Development
Southern Launch acknowledge that Osprey have "historically" been present in the immediate region (p.8, Appendix R). "Bird enthusiast Mike Damp claims the nests have not been active for about 5 years" (p.9, Appendix R) – please note that Mike Damp is the Southern Launch CEO’s father. Southern Launch proposed sites range from 2 to 4 kilometres from the known nest sites at Whalers Way (p.9, Appendix R). The AECOM preliminary significant impact assessment considered that no significant residual impact to the Eastern Osprey was anticipated "based on anecdotal evidence that the nest was considered inactive" (p.15, Appendix R). However, one individual Osprey was recorded flying over the project site during vegetation assessment. Based on this, it was considered at least one pair with an established territory may be impacted by the project (p.15, Appendix R). Southern Launch believe by reducing human access to Whalers Way that it will encourage the Osprey to return. It is highly unlikely that having a rocket launch facility, at full functioning capacity, launching 36-42 times a year, would encourage the Osprey to return. The noise from the launches will reach Osprey nest site 1 at 98dB and nest site 2 at 105 dB, enough to cause temporary hearing loss and habitat disruption (page 17, Appendix R, EIS). This is all detailed in their Raptor report, which is prefaced with Southern Launch having been advised to obtain an assessment by a suitably qualified coastal raptor expert. In reply, they engaged Dr Zeta Bull, who confesses she is "not a qualified coastal raptor expert" (page 1, Appendix R, EIS). The fact that Southern Launch did not hire a qualified Raptor expert and used anecdotal evidence from the CEO’s father in regards to the assessment of impact on an endangered species is laughable and unacceptable. It highlights their incompetence and disrespect for the native environment that clearly needs protecting from this company.
There have been numerous sightings of the Eastern Osprey in the abandoned nests at Whalers Way over January 2022, showing the promise and potential for re-establishment of these nests. A rocket launch facility will, without doubt, prevent the recovery and rehabilitation of these birds in this area.
The White-bellied Sea Eagle
The White-bellied Sea Eagle is listed as Endangered under the SA National Parks and Wildlife Act 1972 (p.17, Appendix R). Population of the White-bellied Sea Eagle is in decline in South Australia (p.18, Appendix R). Disturbance during critical phases of breeding are known to result in nest failures and displacement to sub-optimal habitats (p.18, Appendix R). Any disturbance during their nesting period, particularly overhead, may cause the Eagles to abandon their nest (p.19, Appendix R). The White-bellied Sea Eagles have regularly been reported in the Whalers Way region, and flying overhead, including a known nest site around 5 kilometres to the east of the launch sites (p.19, Appendix R). On Kangaroo Island, it was recommended to avoid construction activities between May and December for 1 kilometre inland from a known WBSE nest, and develop an exclusion zone at other times with local wildlife specialists (p.21, Appendix R). To minimise impacts on nests and territories, construction should only occur from mid-January to May, outside of critical breeding times of mid-May to mid-September (p.21, Appendix R). However, Southern Launch have already commenced construction of a test pad during the month of September, significantly threatening this vulnerable species. Yet, despite all of this, along with the noise pollution of construction and launching, they have considered it "highly unlikely" that launch activities would cause disturbance to WBSE nests (p.21, Appendix R). How can that conclusion be made from the data presented?
Endangered and Threatened Marine Life
Liguanea Island is 5-8kms south of the launch facility. Liguanea Island falls within the Habitat Protection Zone under the Marine Parks Act 2007 and is home to…
A breeding colony of endangered Australian sea lions (the 5th largest breeding colony in the Spencer Gulf)
Estimated pup counts were 30 in 19901, 43 in 2004, 25 in 2015 and 27 in 2019 (p. 15, appendix S, Southern Launch EIS)
A breeding colony of long-nosed fur seals
A breeding colony of Short-tailed Shearwater (Mutton Bird)
A breeding colony of Crested Tern (bird)
(p. 5, Appendix S, EIS)
Orbital rockets, after releasing the satellites, will fall back to earth at approx. 500km from the launch site. Suborbital rockets will fall back to earth within 3-8km from the launch site. Southern Launch has stated that “debris from failed launches with Polar and Sun-synchronous trajectories has the potential to impact Liguanea Island.” (p. 5, Appendix S, EIS).
“Within the Southern Ocean, including the waters of the Thorny Passage Marine Park surrounding Liguanea Island, there may be occasional debris strike impacts on individual animals on the sea surface but no impact at population level.” (p. 6, appendix S, Southern Launch EIS).
Southern Launch have identified that an “air burst, which results in the launch vehicle breaking up into a number of pieces and landing over a large area, would have an average frequency of Long-Nosed Fur Seals and Australian Sea Lion casualties of one every 3,375 and 194,470 launches, respectively, for small rockets” (p.5, appendix S, Southern Launch EIS). Although they state “an air burst over Liguanea Island would be a very rare event that could result in mortalities but there would be negligible impact at subpopulation level” this area is protected and these species are listed as endangered so there should be no risk posed to these populations at all (p.6, Appendix S, EIS).
More importantly, the impact of noise will likely cause more detrimental effect on these endangered and protected species. “The maximum instantaneous sound pressure level during a launch would be 125 dBA4 at the closest shoreline to either launch site, less than 95 and 100 dBA at Cape Wiles for launches from Site A and Site B, respectively, and about 95 dBA at the northern end of Liguanea Island (slightly higher for Site A launches)” (p. 41, Appendix S, EIS). “Noise from launches would temporarily alter the quiet setting of the natural environment for one to two minutes during launches. The maximum instantaneous sound pressure level (airborne) would be 90–95 dBA at the northern end of Liguanea Island. This is close to the threshold at which temporary hearing loss may occur for birds” on the island. (p.6, Appendix S, EIS). “Impacts on pinniped behaviour are the primary concern with regard to rocket launches. Marine mammal reactions to rocket launches are highly variable and may be attributable to the species, age, time of year, air temperature and potential habituation to noise. Seals may flush into the water when frightened, with pups being trampled or separated from their mothers in the process.” (p.6, Appendix S, EIS). Overtime, regular launches may change mating behaviours and could possibly result in habitat abandonment; it is impossible to know for certain. That risk should not be taken in an area such as this.
Southern Right Whales also frequent the area and are known to stay in Sleaford Bay and Fishery Bay, and regularly within 1-3km of the launch site. Southern right whales are currently listed as an endangered and migratory species under the Commonwealth Environment Protection and Biodiversity Conservation (EPBC) Act 1999. Southern Launch have stated “Southern Right Whales very close to shore during the launch may be exposed to sound levels approaching the threshold for temporary hearing loss, but could avoid the noise by submerging for less than two minutes.” (p.6, Appendix S, EIS). Frequent launches will undoubtedly alter whale migration pathways, especially as the majority of these whales are calving mothers. This would also impact local tourism in the area, as whale watching is a known attraction.
Rocket debris will also impact the marine environment. “The breakup of rocket debris during re-entry or on impact with the sea surface would create particles small enough to be ingested by most biota, but will likely sink fast enough to avoid air-breathing fauna.” (p. 41, Appendix S, EIS). We already have an issue with micro-plastics in fish from a similar cause.
In failed launches, rocket fuel that is not burnt up, will spill into the ocean, which accounts for 90% of the rocket weight – i.e. 42 000 kg of fuel for a 58 tonne rocket (p.7, Appendix V, EIS).
“Sessile organisms may be impacted by larger items of debris or accumulations of fragments settling on the seafloor, but the descent of such debris is expected to be slow enough for mobile fauna to avoid (NIWA 2017).
Fragile biota may be damaged or destroyed, and feeding or respiration may be inhibited.” (p.41, Appendix S, EIS).
“All component materials are inert and harmless to the marine environment except lithium (within batteries) and copper (within electrical wiring)” (p.40, Appendix S, EIS).
“Copper fragments would sink to the seafloor where their slow dissolution may have long-term local effects on sediment infauna” (p. 40, Appendix S, EIS).