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Project Sea Dragon
Core Breeding Centre and Broodstock Maturation Centre, Bynoe Harbour
Draft Environmental Impact Statement
PART B ‐ ENVIRONMENTAL ASSESSMENT 14‐264
14 SOCIO‐ECONOMICS
14.1 TERMS OF REFERENCE ADDRESSED IN THIS CHAPTER
This chapter describes the potential social and economic impacts of the Project relating to:
Community (including traffic use)
Economic benefits
Workforce
Matters raised during community consultation and
Cultural heritage.
Studies undertaken for the Project include an economic assessment (commercial in confidence: ACIL Allen
2016), workforce planning (commercial in confidence: IMS 2016) and Project Sea Dragon Dundee Consultation
Report (Creative Territory 2016). A copy of the consultation report is provided in Appendix 12.
Table 14‐1 summarises the requirements from the ToR for the Project of relevance to socio‐economics and
references where they have been addressed.
TABLE 14‐1 TERMS OF REFERENCE
Terms of Reference Sections
4.5 Socio‐economic
Environmental objective
To monitor and manage the intended and unintended social and economic
consequences, both positive and negative, of the Project.
Chapter 14
4.5.2 Assessment of risks
Assess the risks of the Project not realising its projected economic and social
benefits.
Chapter 6
Document the economic and social impacts (including to local tourism, recreation
and amenity values) of the Project, both positive and negative, on nearby
populations in the region and more broadly.
Section 14.4
Provide for appropriate contingencies during project feasibility and planning
stages to manage expectations of the community, local business owners and
residents who may be affected if the Project does not proceed.
Section 14.5
4.5.3 Mitigation and monitoring
Describe how the Proponent proposes to manage any identified and emergent
economic or social risks from and to the Project, or its associated workforce.
Section 14.5
Chapter 15
Describe how potential local and regional business and employment
opportunities related to the Project will be identified and managed
Project Sea Dragon
Core Breeding Centre and Broodstock Maturation Centre, Bynoe Harbour
Draft Environmental Impact Statement
PART B ‐ ENVIRONMENTAL ASSESSMENT 14‐265
Terms of Reference Sections
Include mechanisms for monitoring, mitigating, reporting and managing any
identified potential social or economic impacts
Provide a stakeholder communication plan that provides for updates and
opportunities for the community to raise any concerns during planning,
construction, operation and decommissioning phases
14.2 SOCIAL AND ECONOMIC OVERVIEW
14.2.1 Population and communities
14.2.1.1 Population
The estimated resident population of the Northern Territory, as at 30 June 2015, is around 245,000 people with
the majority of the population concentrated around the capital city of Darwin (see Table 14‐2), and the central
Australian town of Alice Springs. Population profiles show around 27 % of the individuals that live the Northern
Territory identify themselves as being of Aboriginal decent (ABS 2015).
The Dundee region is home to around 800 residents and a large number of weekenders. The population is
estimated to grow to around 1,200 each weekend. It is also a popular destination for tourists, with the
population swelling to more than 2,000 people on public holidays and long weekends.
TABLE 14‐2 POPULATION ESTIMATES
Location Population (2014) Population growth per year
Northern Territory 245,000 Average 1.6% up to 2015 then reducing to 0.4% from 2015
Darwin 142,258 Average 1.5% up to 2015 then reducing to 0.4% from 2015
Unincorporated Top End region
9,500 ‐
Dundee region 800 56.6% in total over the last six years
Source: (ABS, 2015 cited in Seafarms 2016b)
14.2.1.2 Community
The community in the Dundee region is characterised by:
Low cultural diversity, with low proportions of language other than English at home (7.9 %) or were
overseas born (14.4 %)
Low income levels ($604 median weekly household income) and high unemployment levels (25.5 %) and
Large retired community and an ageing population profile, with a median age of 48 years old.
The high environmental value of Bynoe Harbour and Dundee Beach area is the significant factor in the
attraction of residents to the region. The area has a low level of development with much of the area in a less
urbanised condition. ‘Life‐style’ sized blocks (i.e. 1 – 3 ha) that constitute Dundee Beach and the surrounds
enable people to enjoy semi‐rural or ‘natural’ values.
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Core Breeding Centre and Broodstock Maturation Centre, Bynoe Harbour
Draft Environmental Impact Statement
PART B ‐ ENVIRONMENTAL ASSESSMENT 14‐266
There are a number of community groups associated with the Dundee Beach region including:
Dundee Progress Association
Dundee Social and Recreation Club
Dundee Volunteer Bushfire Brigade and
Milne Volunteer Bushfire Brigade.
Another key stakeholder within the community is Amateur Fishermen’s Association of the Northern Territory
(AFANT).
Retail outlets in the area include a small store and fuel at The Lodge of Dundee and at the Sand Palms
Roadhouse. The majority of goods and services would likely be obtained from larger urban centres in the wider
area such as Darwin or Coolalinga.
14.2.2 Economics
Growth in Northern Territory Gross State Product (GSP) is variable due to the small size of the economy and
the comparatively large impact of major projects and global market conditions. Over the decade to 2014‐15,
the GSP of the Northern Territory grew by an average annual compound growth rate of 4.1% a year. In
comparison, the Gross Domestic Product of Australia grew by an average of 2.7 % a year over period 2005‐06
to 2014‐15. The value of the GSP of the Northern Territory is currently $23.1 billion (2014‐15). The Northern
Territory Government forecasts economic growth in the Territory as moderate from current levels of 4.5 % in
2014‐15, where it is forecast to remain for 2016‐17.
In terms of the value of industry contribution, the main industries in the Northern Territory are the
construction; government and community services; and mining industries. Together, these industries account
for about half of the Northern Territory’s total economic value. The largest employers are the community
services; construction; and retail and wholesale trade industries.
14.2.2.1 Commercial fishing and aquaculture
The commercial fishing industry in the Northern Territory includes the harvesting of wild catch fisheries,
aquaculture, and the processing of catch. The industry is largely made up of the capture of snapper,
barramundi and shark. The catch of crustaceans is dominated by prawns and mud crabs. The value of total
fisheries production in the Territory was estimated at $55 million in 2014‐15. The fishing industry is in decline
mainly as a result of falls in the production of aquaculture but also in the wild catch of fish and crustaceans.
In 2013‐14 the estimated value of the prawn catch by the Northern Prawn Fleet Commonwealth managed
Fishery increased by just under 4 % to $10.9 million. The value of production in 2015‐16 is estimated to
increase further to $11.4 million (DPI and Fisheries 2016). Output from the Northern Prawn Fleet for 2013‐14 is
estimated at 0.7 tonnes which is a 3% increase on the previous period (DPI and Fisheries 2014).
Commercial fishing within Bynoe Harbour includes mud crabs and is closed to commercial Barramundi fishing.
A pearl oyster licence exists within Bynoe Harbour with the oyster beds located to the north of the Project site.
14.2.2.2 Tourism
Tourism is an important component of the Northern Territory economy contributing 4.0 % of the GSP in
2013‐ 14. It is also one the largest employers in the Northern Territory providing around 8,000 jobs or 5.7 % of
employment (NT Treasury 2015). Much of this employment is in regional areas where there is limited economic
diversification and few opportunities.
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Core Breeding Centre and Broodstock Maturation Centre, Bynoe Harbour
Draft Environmental Impact Statement
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In 2014‐15 there were nearly 1.5 million visitors to the Northern Territory and total visitor expenditure was
nearly $1.5 billion. There was a very strong growth in the number of visitor nights in the Territory in 2014‐15 of
over 30% however long term projections of visitor growth are expected to remain at more conservative levels.
Over the five years to 2019‐20, the average number of visitor nights is expected to grow by around 4.3% a year.
This growth is in keeping with forecasts of most other jurisdictions in Australia and is consistent with the five‐
year Australian average annual growth rate of 4.4% a year (Tourism Research Australia 2015).
Fishing is the main activity that attracts to tourists and local residents to the area with land and sea‐based
fishing and crabbing activities available. At Dundee Beach, there is a boat ramp located near The Lodge of
Dundee and a large number of people fish from the beach, creeks and rivers from Patterson Point in the north
to the Finniss River mouth in the south. In the Bynoe Harbour area, access to fishing is via numerous boat
ramps and land‐based fishing areas on creeks, rivers and the beach (refer Figure 1‐2).
There are also a number of commercial fishing charters based in Dundee Beach and charter operators based in
Darwin that utilise the area.
Tourism accommodation businesses local to the area include:
Sand Palms Roadhouse, Bynoe: Situated on the Fog Bay Road about 30 kilometres west of the Cox
Peninsula Road;
The Lodge of Dundee: Situated at Dundee Beach; and
Crab Claw Island Resort: Situated 10 kilometre to the north off Fog Bay Road (refer Figure 1‐2).
14.2.3 Employment and workforce
There is a large workforce in the Northern Territory of nearly 122,000 people of which around 6,000 are
currently seeking work. This equates to an unemployment rate in the Northern Territory of around 4.2 %
(2015) which is consistent with the five‐year Northern Territory average of 4.1 %.
The three main industries of employment in the Northern Territory are the public administration and safety
industry with 21 % of total employment, the health care and social assistance industry (10 %) and the
construction industry with 8.2 % of total employment.
The level of skills in the Northern Territory are high and reflective of a diverse and mature economy. Fifty‐seven
% of the Northern Territory working age population aged 15 and over hold a qualification.
The unemployment rate in the broader Finniss statistical area which includes the Project area is approximately
8% (ABS 2011) which is higher than the unemployment rate across the whole of the Northern Territory.
There are very limited opportunities for employment in the area with tourism generating the largest demand
for staff. Several residents are self‐employed and are able to work from home. The majority of employed
residents work closer to the Darwin region and return to Dundee Beach on the weekend.
14.2.4 Cultural heritage
14.2.4.1 Aboriginal heritage
An archaeological survey of the Project site was completed in late 2002 in association with the proposed
development of the Suntay’s land‐based aquaculture facility. All areas except for the access route, were
surveyed on foot, in transects that were at the most 150 metres apart. The access routes along Point Ceylon
were surveyed on foot and the track from Fog Bay Road to the base of Point Ceylon was surveyed by 75 %
pedestrian and 25 % vehicular transects. The majority of the area surveyed had been burnt in the dry season
Project Sea Dragon
Core Breeding Centre and Broodstock Maturation Centre, Bynoe Harbour
Draft Environmental Impact Statement
PART B ‐ ENVIRONMENTAL ASSESSMENT 14‐268
and new vegetation had started to appear. Ground visibility over these areas ranged from 70 ‐ 90 %. Small
patches on the end of Point Ceylon, mostly vine thickets, had not been burnt and visibility was lower at 30‐
40 %.
A shell scatter of approximately 40 Telescopium telescopium was located half way along a fifty metre chenier
ridge that runs south and parallel to the eastern side of Point Ceylon. The ridge is situated on the western side
of the mouth of mangrove lined tidal inlet and has been used as an access track for the launching of boats
through the mangroves into the inlet. The site is located approximately 100 metres south of the proposed
development. This area will not be affected by the development.
Further away from the Project site, a large artefact scatter and quarry site is located on the north of Indian
Island (Guse 1994). Stone artefacts were located for a kilometre along the top of a siltstone/conglomerate cliff.
Artefacts included flakes, cores retouched flakes, bifacial points, axe fragments and ochre. Also in the area
were shell scatters, consisting mainly of Nerita sp. The presence of a high percentage of bipolar cores in an area
close to a quartz quarry, suggested that there had been a long term occupation at the site.
An Aboriginal Areas Protection Authority (AAPA) Authority Certificate (C2016/059) has been issued for the
Project proposed works and uses specified on the certificate and within the subject land of NT Portion 3192. No
recorded or registered sacred sites (as defined under the Sacred Sites Act) are located within the Project site.
The closest registered site is approximately 2.5 kilometres to the north west of the Project site. No restricted
works areas are specified in conditions of C2016/059.
There are no current claims under the Native Title Act over the site (National Native Title Tribunal 2016). The
former DLPE advised that Native Title is considered to be extinguished over the area due to provisions relating
to exclusive rights to land within previous leases issued over the parcel (Seafarms 2016a).
The Larrakia people’s Kenbi Land Claim encompasses traditional lands on the northern side of Bynoe Harbour
and Indian Island (excluding the Project site).
14.2.4.2 Non‐Indigenous heritage
The main European activity, beside pastoral pursuits in the area was tin mining. High grade tin was found at
Bynoe Harbour in 1888. The Leviathan mine was located approximately 20 km south east of Indian Point and
other tin mines, such as Hang Gong, Lees and Bells Mona, and a gold mine, the Golden Boulder, were located
approximately 25 km east of Ceylon Point and commenced operation around the turn of the century (Seafarms
2016b).
Around the 1990’s, an experimental Barramundi farm was established at Point Ceylon. Farm infrastructure
including concrete foundations, earth wall ponds and a dump site remain. This remaining infrastructure is of
relatively contemporary activities and, therefore, does not hold any historical significance.
Project Sea Dragon
Core Breeding Centre and Broodstock Maturation Centre, Bynoe Harbour
Draft Environmental Impact Statement
PART B ‐ ENVIRONMENTAL ASSESSMENT 14‐269
14.3 METHODOLOGY
14.3.1 Economic assessment
The baseline economic environment for the study area has been identified utilising publically available
quantitative economic data (e.g. 2011 Census data). The areas assessed included both spatially and
economically important areas such as the Dundee region and the Northern Territory.
This baseline data was used to complete economic modelling or Computable General Equilibrium modelling.
For this analysis, ACIL Allen’s Computable General Equilibrium model, Tasman Global, was used to estimate the
impacts of the construction and operation activities associated with the whole of Project Sea Dragon. Three
regions were modelled:
The Kununurra region (as defined by the Australian Bureau of Statistics SA2 area)
The Northern Territory
Western Australia.
The model analyses scenarios built on a dynamic set of variables, with the approach illustrated in Figure 14‐1.
The economic analysis which informs this impact assessment thus considers, based on informed modelling, the
change expected to occur should the Project meet its economic potential – that is, the difference between the
reference case (i.e. no Project), and the situation should the Project proceed as planned.
FIGURE 14‐1 TASMAN GLOBAL SCENARIO ANALYSIS
Project Sea Dragon
Core Breeding Centre and Broodstock Maturation Centre, Bynoe Harbour
Draft Environmental Impact Statement
PART B ‐ ENVIRONMENTAL ASSESSMENT 14‐270
14.3.2 Workforce planning
A workforce planning and development analysis has been undertaken for the Project (IMS 2016), which informs
the local workforce analysis. This is complemented by the Project’s economic impact assessment. Both
documents consider the availability of employment resources and provide guidance to Project Sea Dragon in its
workforce planning. It should be noted that the workforce planning report is confidential; however, relevant
findings and recommendations are cited herein.
14.3.3 Community consultation
14.3.3.1 Consultation activities
Formal consultation with the local community was initiated in early 2016. Consultation was undertaken by
Creative Territory on behalf of Seafarms. Consultation focused on residents and landowners in the Dundee
area, encompassing Dundee Beach, Dundee Forest, Dundee Downs and Bynoe Haven. The consultation process
identified a number of key stakeholders including residents and landowners, local clubs and associations, local
retail businesses and community groups.
A total of 67 individuals were reached 55 were permanent residents, 11 were weekenders and one was a
visitor (Member for Daly, Gary Higgins). Consultation activities included:
Distribution of a Project flyer outlining the proposal and inviting local residents to the Australian Day Fun
Day
Australia Day Fun Day function – Saturday 23 January 2016 at the Dundee Social and Recreation Club (42)
Australia Day Fun Day function – Tuesday 26 January 2016 at The Lodge of Dundee (4)
An impromptu visit Friday 29 January 2016 at The Lodge of Dundee (9)
Personal contact with individuals (7) and
Contact via email or Facebook (5).
The intention of this consultation was to inform the local Dundee area of the potential BMC and CBC Project
and seek their views related to the Project.
In addition, as part of the environmental impact assessment process:
The referral of the Project under the EPBC Act was available to the public for comment on the Department
of the Environment and Energy website and
The draft ToR and NOI for the Project were available to the public for comment on the NT EPA website.
Matters raised by the community are incorporated into the ToR by the NT EPA where appropriate.
14.3.3.2 Matters raised during consultation
Key matters raised during consultation are categorised in Figure 14‐2. Overwhelmingly, people want
reassurance that fishing will not be negatively impacted by any development at the site. Refer to Appendix 12
for further information on the consultation undertaken to date.
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Core Breeding Centre and Broodstock Maturation Centre, Bynoe Harbour
Draft Environmental Impact Statement
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FIGURE 14‐2 ISSUES RAISED BY NUMBER OF PEOPLE
0 5 10 15 20 25 30 35 40 45 50
Access to site
Fire management
Road placement
Boat water access
Water discharge quality
Work opportunities
Fishing
Issues Raised
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Core Breeding Centre and Broodstock Maturation Centre, Bynoe Harbour
Draft Environmental Impact Statement
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The key matters raised and Seafarms’ response is summarised in Table 14‐3.
TABLE 14‐3 COMMUNITY CONSULTATION
Issue Number of people that raised the issue
Response
Fishing
Concern was raised about the potential for the project to have a negative impact on fishing and crabbing activities in the area.
50 The proposal will not impact upon fishing and crabbing access at all. Only the land area itself will have limits on access.
The daily water release rate at full scale will be 11,000 m³/day. This is equivalent to approximately 0.1% of the tidal volume flushed through Wheatley Creek during a spring tide and around 0.55% of the volume during a neap tide. In other words, at most, the additional water volume being released into Wheatley Creek will be around half of one percent of the volume that currently passes through the creek.
There will be no release of any elements that do not occur naturally in the local environment.
Levels of total nitrogen and total phosphorous will not exceed the Water Quality Guidelines in the receiving environment.
No anti‐biotic, anti‐parasitic or anti‐fouling agents will be released into the environment.
All cleaning products used in the tanks (i.e. chlorines) are biodegradable and all water will be held in the settlement ponds until the products have fully broken down.
An assessment of water quality impacts is included in Chapter 11.
Both the BMC and CBC facilities will be fully biosecure and will be managed in accordance with the Project Sea Dragon Biosecurity Manual. The biosecurity strategy for Project Sea Dragon is premised upon developing a domesticated and selectively bred population of animals that has been screened for a suite of known pathogens, satisfying the ‘Specific Pathogen Free’ condition. Unscreened animals will not be used within the production system.
In the event of a disease outbreak within the production system, any diseased prawns identified will be euthanised and disposed of either through incineration or licenced landfill offsite.
To prevent the accidental escape of prawns from the CBC and BMC into the surrounding environment, filters will be placed over all outlets to the settlement ponds prior to release. The channels/pipelines which lead to the release point also present a harsh environment in which any escaped prawns are unlikely to survive.
Work opportunities
Strong interest in future work opportunities, particularly from the ‘weekenders’ who live in Darwin during the week and see the
18 To support the development of the Stage 1 Legune Grow‐out Facility a workforce of 27 will be required to be employed at the CBC and BMC, including managers, a geneticist, various technicians, administrators and aquaculture workers.
At full scale production there is estimated to be a workforce of 40 at the CBC and BMC.
Project Sea Dragon
Core Breeding Centre and Broodstock Maturation Centre, Bynoe Harbour
Draft Environmental Impact Statement
PART B ‐ ENVIRONMENTAL ASSESSMENT 14‐273
Issue Number of people that raised the issue
Response
opportunity to move permanently to the region as well as young local residents who have limited opportunity for local work at present.
Seafarms would welcome applications from appropriately qualified local workers.
The workforce is expected to come from a mixture of sources, including:
directly employed staff, self‐accommodated in the Dundee Downs areas and/or accommodated nearby; and drive‐in/drive‐out from Darwin environs
local contractors, self‐accommodated in the Dundee Downs areas and/or accommodated nearby; and drive‐in/drive‐out from Darwin environs
local indigenous people
fly‐in/fly out (this option is likely to be the exception but for specialist expertise)
temporary work skilled visa (sub‐class 457) program for selected specialist expertise.
Refer to Section 14.4.2 for further information.
Discharge water quality
13 of the residents enquired
about the quality of discharge water
11 No significant impact on discharge water quality – see response to “fishing” above and results presented in Chapter 11 for details.
Road placement
The siting of the access road is of interest to residents in the immediate facility
10 The access road is located within an existing road reserve that was incorporated into the subdivision. Section 2.5.5 provides further information on the location and design of the road.
Fire management
Fire management was
canvassed by residents involved
with the Dundee Volunteer Bushfire Brigade.
5 Fire risk will be managed in accordance with the Bushfire Act 2009. Management will include vegetation clearing to maintain firebreaks around shared boundaries, internal fence lines and other facility assets. Bushfire risk will also be mitigated through construction of onsite fire‐suppression infrastructure, as well as consultation and ongoing liaising with the nearby Dundee Volunteer Bushfire Brigade.
Access to site
Three residents identified themselves as currently accessing the site on a regular
basis. One resident has a fisherman’s shack located at Point Ceylon and two others also said they used this shack
3 For the security of infrastructure assets on site, and for biosecurity purposes, access to the land area will be restricted to personnel working on site and will not be open to the public.
A biosecurity fence will be erected at the entrance to the site.
Project Sea Dragon
Core Breeding Centre and Broodstock Maturation Centre, Bynoe Harbour
Draft Environmental Impact Statement
PART B ‐ ENVIRONMENTAL ASSESSMENT 14‐274
Issue Number of people that raised the issue
Response
and the surrounding land on a regular basis. A number of other residents said they fished and hunted from the land area.
The social impact assessment has drawn upon and incorporates the findings of the economic impact
assessment undertaken for Project Sea Dragon (as detailed in Section 14.3.1) and the workforce development
assessment prepared by Integrated Management Services Pty Ltd (IMS 2016).
14.3.4 Stakeholder consultation
Seafarms has also undertaken consultation with other stakeholders within the community regarding the whole
Project Sea Dragon and, as part of that, aspects of the CBC and BMC Project. The stakeholders engaged to date
are detailed in Table 14‐4.
TABLE 14‐4: STAKEHOLDER CONSULTATION
Organisation Date
Environmental Defenders Office 02 February 2016
Northern Territory Cattlemen’s association 22 April 2016
Larrakia Development Corporation 22 April 2016
AFANT, including the Board 19 April 2016
Northern Land Council Ongoing
14.3.5 Paspaley consultation
The intake pipe alignment has been designed to avoid the adjacent Paspaley oyster leases in Bynoe Harbour.
Seafarms have discussed the implications of such proximity with Paspaley. Paspaley have been encouraging of
the proposed development and see potential for future shared use of infrastructure. Paspaley have also shared
local water quality data with Seafarms and allowed Seafarms to anchor water quality loggers to their
infrastructure. Seafarms will continue to liaise with Paspaley as the project progresses.
14.4 ASSESSMENT OF POTENTIAL IMPACTS
The risk assessment examined the potential impacts, both positive and negative that the project will have on
key social and economic features of the region. The level of risk posed to socio‐economic values by each source
of impact was assessed using standard qualitative risk assessment procedures, which have been described in
Chapter 6 (Risk assessment).
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Core Breeding Centre and Broodstock Maturation Centre, Bynoe Harbour
Draft Environmental Impact Statement
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14.4.1 Construction
14.4.1.1 Population and communities
Accommodation for construction personnel will be sought in the Dundee Beach area, which is a 30‐minute
drive from the Project site. This will provide economic benefits to the local guest house or property rental
businesses which are important for employment in the local area.
Construction activities will occur during the dry season which is considered to be the peak period for tourism.
The demand for accommodation from both the construction work force and tourists will put short‐term
pressure on current supply.
Tourist levels fluctuate considerably with the weekend being the busiest period. The construction workforce,
however, will be accommodated in the area during the week and will likely return to Darwin during their
rostered days off. There will be some overlap where both the tourist and workforce are utilising Dundee Beach.
Land based access to Point Ceylon will be closed to public access from the commencement of construction.
Those utilising the area for recreational activities such as camping, hunting and land‐based fishing will not be
permitted beyond the site office. It is assumed that restricting access will only affect small numbers of
individuals. There will be no impediments to boat based fishing.
A Northern Territory Government road count station located on Fog Bay Road, approximately two kilometres
west from Cox Peninsular Road, details the current road usage from 2006 to 2015 and is shown in Table 14‐5
(DoT 2015). The average annual daily traffic (AADT) for 2015 for Fog Bay Road is 373. It is anticipated that a
total of 630 truck movements will be required for the construction phase with truck access peaking at 150 truck
movements a week or 25 truck movements a day. Another 264 vehicle movements will be required for the
movement of personnel during the eight month construction phase with buses driving in and out from the
Dundee region and managers/supervisors driving in and out from both Dundee and Darwin (Table 14‐6). The
volumes of traffic estimated over the eight‐month construction period are unlikely to impact on the
communities use of the road due to the current low utilisation and additional capacity available (DoT 2015).
TABLE 14‐5 CURRENT ROAD USAGE OF FOG BAY ROAD (AADT)