Lucky Bay iron ore export approval accepts uncalculated environmental impacts

The following is a Letter to the Editor, originally published in the Port Lincoln Times on December 5th, 2013. The letter was prompted by the announcement that iron ore exports from Lucky Bay had been approved by South Australia’s State Government. We maintain that there are inconsistencies between existing State and Federal approvals for this project, and that many of the environmental impacts we have identified and presented directly to the Development Assessment Commission are yet to be addressed by the responsible parties.



The State Government’s approval of the Lucky Bay Common User Export Facility has been claimed as a major milestone by IronClad Mining, eager to export iron ore from its future Wilcherry Hill mine. Regrettably, the environmental impacts of this proposal have been largely shielded from public consideration and debate.

IronClad now claims to have all approvals in place to commence mining and export, but this may not be so. The mine’s federal environmental approval was granted in 2011 to export from Port Adelaide via a rail from Whyalla. By this method, no impacts from new infrastructure were anticipated. Lucky Bay, however, located within the Franklin Harbour Marine Park and adjacent to the Franklin Harbour wetlands, is a different story.

The 2011 Lucky Bay iron ore export plan featured a negatively-pressurised floating harbour. Since then, capital costs have been slashed, with inevitable increases in environmental impact. Plans for a new ‘covered’ iron ore stockpile emerged, adjacent to the Franklin Harbour wetlands. The floating harbour was replaced by a floating platform. A transshipment area was relocated 5km closer inshore on the minister’s whim, within the Franklin Harbour Marine Park.

Will dredging be necessary?

What effects will spillage, sound and bottom-disturbance have on the marine environment?

How will weedy sea dragons and commercially fished species be impacted?

Ironclad Mining's proposed Lucky Bay iron ore export pathway, 2013

Ironclad Mining’s proposed Lucky Bay iron ore export pathway, 2013

The general public had three weeks to find, download, consider hundreds of pages of documentation and pass comment. The documentation was then withdrawn – a symptom specific to Crown sponsored developments under the state’s Development Act. Once approved, the public also has no right to appeal the minister’s decision.

Endangered White-bellied sea eagles nest in the Franklin Harbour wetland, and the species’ statewide population is an estimated 70 to 80 pairs.

White-bellied Sea Eagles are recorded adjacent to the proposed Lucky Bay iron ore export site

White-bellied Sea Eagles are recorded adjacent to the proposed Lucky Bay iron ore export site

Migratory waders feed and roost on the foreshore immediately south of the proposed expanded harbour, but no baseline data has been collected. Lucky Bay shackies are protected from sleep disturbance and dust by EPA regulations and an acoustic barrier wall, but threatened species receive no such protection. Despite presenting before the Development Assessment Commission and proponents, I still see no evidence that the issues I raised have been investigated or mitigated in any way. I yearn for a day when State Government and developers accept responsibility for environmental impacts. This approval will carry with it an uncalculated burden of environmental harm for which no one is likely to be held accountable.

Is this what is meant when we hear that South Australia is “open for business?”

Dan Monceaux
Director ‘Cuttlefish Country’


Dan Monceaux is a South Australian documentary filmmaker and the director of Cuttlefish Country.

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