Lord Howe Island Critical Infrastructure Project

Lord Howe Island requires a new ship as our current "Island Trader" is nearing the end of her life.
Someone in their infinite wisdom put forward a grant application for a "RoRo" vessel. The island residents (the customers) were advised by community consultation that this was just in the infancy stages and that the type of vessel to be build was not set in stone. This was a relief. Turns out that information was incorrect and we're being told that a RoRo is what was applied for for the grant and therefore a RoRo is what we will received.

There are so many issues with the Lord Howe Island Critical Infrastructure Project and only 10,000 words to respond.
In section 2.6.3 Not Carrying Out The Development is basically emotionally blackmailing people to pass this through.

The environmental impacts of a RoRo and what will be required, extra ramps, anchorage ports in the Lagoon, heavier equipment that the roads and facilities on the island simply cannot handle will have the biggest negative environmental impact our island has ever seen. The idea of containerising everything adds extra weight to the ship, resulting in more draft required to enter the Lagoon and dock alongside the jetty (or somewhat near the jetty as it looks like, according to your plans, that the ship will not actually get alongside the jetty!!

I agree with the project in concept that we need a new vessel. However what we need is a replacement, similar with some tweaks, to the island trader which has been modified and customised to Lord Howe Island's needs. This works. This system is not broken. The only problem is the ship is aging. We need a replacement "Island Trader".

A consultation group was formed for this project. Their questions and concerns and advice and decades and lifetimes of knowledge and experience have not been heard. The box has been ticked to say "we consult with the community" but the reality is that you have not.

The persons who applied for this grant (assume Representatives of the Lord Howe Island Board), and those who are running it have no understanding and no concept of what is required for our unique island. From an environmental perspective, a practical workable vessel with correct unloading facilities perspective or from a safety perspective (as evident with the pedestrian areas and viewing areas). This is a work environment, not somewhere that pedestrians should be anywhere near!

The heavy equipment, larger trucks, heavy duty forklifts etc that are expected to operate this new vessel, ramp etc will be dangerous and destroy our roads.

There is nothing positive about forcing a RoRo upon this community.

Why are we reinventing the wheel and replacing it with a square.

As s a 6th generation Lord Howe Islander, whose family has been dedicated to protecting the Island environment since 1842, I am writing to voice my objection to the Environmental Impact Statement (EIS) for the proposed Critical Infrastructure Project on Lord Howe Island.
The EIS clearly fails to adequately address the ecological and heritage impacts of this development.

My submission focuses on two critical areas: Flora and Fauna impacts and the World Heritage obligations that are being overlooked.

Flora and Fauna Impacts
The EIS acknowledges that the project area contains an exceptionally high concentration of endemic, threatened, and migratory species—many found nowhere else on earth. These include the Lord Howe Woodhen, Golden Whistler (LHI subspecies), Silvereye (LHI subspecies), Pied Currawong (LHI subspecies), and vulnerable seabirds such as the Sooty Tern and Black-winged Petrel. Surveys recorded 32 species within the study area, 13 of which are listed as threatened under NSW or Commonwealth legislation.
Despite this, the EIS minimises the significance of habitat loss and disturbance.

Vegetation Clearing and Habitat Loss
The proposal involves removing approximately 360 tonnes of native vegetation and 380 tonnes of exotic vegetation, alongside extensive clearing for hardstand areas, marine access, and Waste Management Facility (WMF) expansion. This includes clearing for new access roads, laydown areas, ramp extensions, retaining walls, regrading, and additional sheds.
Residents face strict regulations for even minor works—removing a single native tree requires permits and ecological assessments. In stark contrast, this government project proposes wholesale clearing and soil disturbance, with impacts dismissed as “manageable.” This double standard demonstrates a disregard for ecological protections when government projects are involved.

Fauna Disturbance and Displacement
Threatened and endemic species rely on the very sites earmarked for development. For example:
• Wedge-tailed Shearwaters, which breed in the North Zone, are highly sensitive to noise, light, vibration, and ground disturbance.
• Ground-dwelling and burrowing birds, including the Woodhen, face acute risks from earthworks and heavy equipment.
• Marine species associated with lagoon reef ecosystems will be disturbed by reef trimming, piling, propeller wash, and increased vessel activity.
• Reptiles, migratory birds, and invertebrates—including several endemic species—will lose habitat or experience fragmentation.
Although the EIS claims no threatened flora species were recorded, it concedes that species such as Knicker Nut and Sand Spurge have a moderate likelihood of occurring in the project area. Dismissing their presence based on limited surveys ignores the well-known limitations of point-in-time ecological assessments.

Marine Impacts
The proposal includes reef removal or “trimming,” new pilings in sensitive areas, sediment disturbance, increased vessel frequency, and shading from new structures. These impacts are minimised in the EIS through vague language such as “unlikely to significantly impact,” without robust, species-specific assessment or exploration of less intrusive alternatives.

World Heritage Values Ignored
Lord Howe Island’s World Heritage status represents the highest level of environmental and cultural recognition. Every development decision must prioritise the preservation of the Outstanding Universal Value (OUV) that earned this listing. Yet the EIS treats World Heritage obligations as a procedural formality rather than a guiding principle.
The EIS asserts that the project will “not significantly impact World Heritage values” but provides:
• No independent heritage integrity assessment
• No comparative studies of landscape character impact
• No rigorous analysis of cumulative effects
• No modeling of long-term visual or ecological change
A project of this scale—marine ramps, expanded industrial zones, increased built footprint, major vegetation clearing—would trigger intense scrutiny in any other World Heritage site. Here, the assumption appears to be: If government wants to do it, then it must be acceptable.

The Double Standard
Residents are held to some of the strictest conservation standards in Australia. Cutting a single Norfolk Island pine, installing a water tank, or extending a deck requires ecological review and avoidance of threatened species habitat. Yet for this government project, involving thousands of tonnes of clearing, reef removal, seabed disturbance, and industrial-scale infrastructure, the EIS claims impacts are negligible.
This inconsistency erodes trust and undermines the principles that World Heritage status is meant to uphold. The protections that apply rigorously to residents appear flexible and negotiable when government interests are involved.

Conclusion
World Heritage status should constrain development, not serve as a justification for expansion. The EIS frames upgrades as essential for protecting World Heritage values through enhanced biosecurity, while the project itself directly damages those same values—removing vegetation, disrupting fauna habitat, altering landforms, and industrialising the visual setting of one of Australia’s most iconic protected places.
For over 40 years, World Heritage obligations have been enforced strictly for residents and small businesses. When a government megaproject is proposed, these protections suddenly become optional. This is inconsistent with UNESCO obligations and fundamentally unfair.
I urge decision-makers to reject the current proposal or require a complete reassessment that genuinely prioritises ecological integrity and World Heritage values.

The proposed size of this project is going to leave this small community with ongoing maintenance costs resulting in a much higher cost of living for us all.
As we value our island's natural beauty, a project of this size and impact visually, especially the Northern Zone , will ruin our World Heritage values and the island's natural beauty. The 'Unstuffing Shed' in the Northern Zone would be better if the roofline was in keeping with the other existing sheds already in place and ideally moved to be in line with the existing Marine and Cargo sheds. This would lesson the impact of buildings in the area.

Marine Vessel and Operations
Before the contract is awarded for construction of the vessel the following need to be considered:
Mainland port - has this been considered/decided upon. It would be a misuse of funds if a vessel were built before a suitable port had been sorted out.
The construction of the “ramp” to facilitate RoRo containerised freight is NOT the preferred option of the Community Consultation Group and the wider Island Community.
The construction of the ramp will impede the use of the south side of the wharf.


The unloading area at the jetty needs to be reassessed to have minimal impact on the natural beauty of the area. The LEP restricts development on the island and with a cap on visitor numbers there is no need for over development in this area.
Vehicle storage when not used for unloading could be facilitated on the old nursery site well out of public view.
An area to facilitate mail storage/sorting is unnecessary in this precinct

I sincerely hope the views of the island community are taken into consideration when making decisions on this project

The consultation process is not adequate for this project and the reports in the EIS are lacking in input from the community, the tender process has not involved the Community Consultation Committee in a meaningful way. The community representative feedback has largely been ignored and there has been no representation of the Tender Review Committee. The risks associated with the D&C procurement process have not been explained to or understood by the LHI community . No representative of the visitor to the island cohort (the tourist) or the Government employees living on the island are included in the Community Representation Committee. The economic modelling and financial feasibility studies are weak and lack credibility without transparency as to assumptions and impact of freight costs with no sensitivity analysis or detailed Business Case

I do not support following aspects of the critical infrastructure project:-
* Roll on roll off loading ramp at jetty. This design is unfeasible for the proposed location.
* Unstuffing shed. This facility is solely designed for Bio Security needs around the use of containers. The facility is far too large and is unwarranted.
* Dog Kennel facility. This facility is far too large. Existing facilities at the Lord Howe Island Board should be upgraded at there current location.
* Placement of Dolphins to the West of the Jetty. This infrastructure is unwarranted and does not conform to the Island World Heritage values.

I am writing to formally object to the Lord Howe Island Critical Infrastructure Program (CIP) as outlined in the Environmental Impact Statement. While residents support genuine improvements to waste management, freight, and biosecurity, the current proposal is excessive, environmentally risky, and poorly aligned with the scale and character of our Island. It prioritises infrastructure expansion over environmental protection, community needs, and financial responsibility.
Unacceptable Impacts on Flora and Fauna
The EIS confirms that the proposed works occur in an area containing endemic and threatened species, including the Lord Howe Woodhen, Lord Howe Golden Whistler, Lord Howe Silvereye, and others . The development footprint also overlaps habitat for migratory and breeding bird species, including the Wedge-tailed Shearwater .
The proposal involves:
Significant vegetation clearance, including 360 tonnes of native vegetation during construction (North + South zones) .
Major disturbances to habitat through earthworks, drainage changes, increased noise, increased traffic, and heavy machinery.
Marine impacts associated with new piling, ramp construction, and vessel operations—activities that the EIS itself admits require removal or trimming of rock reef habitat .
These impacts are incompatible with the World Heritage protections of Lord Howe Island and with the stated purpose of safeguarding biodiversity. The EIS repeatedly attempts to downplay impacts as “low risk,” but this does not reflect the cumulative ecological strain of construction, marine disturbance, increased vessel reliance, and intensified waste operations.
Given the fragile nature of our ecosystems and the globally significant species we host, the proposed disturbance is unjustifiable.
The Marine Vessel and Ramp Proposal Is Impractical and Environmentally Harmful
The CIP depends on a new marine freight vessel and expanded marine infrastructure, but the design of the vessel is not part of this EIS and therefore cannot be assessed holistically. This is a fundamental failure of planning and transparency. This project is built on a " fairytale vessel" One that hasnt been built or we even know can be built.
The EIS acknowledges:
The new vessel requires a long, heavy-duty piled ramp and extensive hardstand areas, necessitating clearing of vegetation and altering natural landform .
Existing reef and marine habitat must be removed or trimmed to accommodate the extended ramp footprint.
Construction and operation will dramatically increase diesel use, with 1.59 million litres of diesel estimated to be burned during construction alone .
The reliance on a larger, more complex vessel is at odds with the island’s environmental principles. A freight system should become smaller, lighter, and lower impact—not larger, more intrusive, and more dependent on infrastructure that permanently alters the shoreline.
Residents have long argued that the issue is not the ramp or the jetty—it is the scale of the vessel being imposed on the community without alternatives seriously examined.
Community Consultation Has Been Insufficient and Surface-Level
While the EIS lists engagement activities, the quality and depth of consultation has been misrepresented. The population of Lord Howe Island is small, yet only 53 survey responses were received in Phase A and four submissions —numbers far too small to claim community endorsement of a project of this significance. With a population of over 400 it would be interesting to see if these 53 survey repsonses were from Residents ( as determined under the LHIReg/act)
Residents repeatedly raised concerns about:
Marina expansion
Ramp location, reef impacts, tidal conditions, and weather patterns
Visual bulk and operational risks
Waste facility overreach
Traffic and construction disturbance
Loss of character and sense of place
These concerns have not been meaningfully incorporated into the final design. Moreover, the EIS frames non-support as a “risk to be managed,” rather than a legitimate reason to reconsider the scale of the project.
This is not genuine consultation; it is procedural compliance.
Section 2.6.3 (“Not Carrying Out the Development”) Is Coercive and Inappropriate
The “do-nothing” scenario presented in Section 2.6.3 frames the alternative—not proceeding with the project—as unacceptable and harmful to the island’s future. This section is written in a way that is threatening in tone, implying that if residents oppose the CIP, the island will be left without essential services.
This framing violates the principles of neutral environmental assessment and undermines public trust. An EIS must transparently evaluate alternatives, not pressure residents into compliance.
- Waste Management Facility (WMF) Upgrades Are Excessive and Not Proportionate to Need
The WMF proposal represents a commercial-scale facility inappropriate for an island with:
Fewer than 400 residents
Strict tourist limits
A small number of commercial operators
The EIS proposes industrial-level processing including multiple new sheds, expanded operating hours, a large new Materials Recovery Facility, and new wastewater treatment systems . Yet the WMF currently processes very modest quantities of waste, with all non-compostables shipped off-island in existing systems.
A simpler, modest upgrade could meet EPA compliance without:
Large new structures
Increased emissions
Increased vehicle movements
Expanded staff needs
Significant financial burden
The CIP version of the WMF appears over-engineered, over-costed, and disconnected from the island’s actual waste volumes.
- Cost and Environmental Impact Far Outweigh Benefits
Across both the North and South zones, the CIP represents a huge financial outlay with enormous environmental footprint. Yet the incremental benefit to residents is minimal:
A larger, more intrusive freight vessel instead of a fit-for-purpose smaller one
A waste facility far exceeding community need
Landscape alterations, reef disturbance, and clearing for marginal operational improvements
Significant emissions from construction and operations
The CIP does not demonstrate clear value for money, nor does it align with the island’s sustainability goals, heritage protections, or community values.
Conclusion
I request that the Lord Howe Island Critical Infrastructure Program not proceed in its current form.
A more appropriate and sustainable approach would include:
A smaller, low-impact freight solution
Minimal, compliance-focused WMF upgrades rather than an industrial facility
Marine infrastructure designed to avoid reef removal and landform alteration
Genuine, detailed community co-design, not token consultation
An EIS that evaluates alternatives honestly and transparently
The current proposal does not protect Lord Howe Island—it risks fundamentally changing it.
Our community deserves infrastructure that respects our scale, our environment, and our way of life.

The proposal blocks public and pedestrian access to the jetty during ship operations, which is unacceptable - a safe access walkway and waiting area is essential!

Excluding the boat ramp in this immediate project works is a major safety oversight and must it be included! The funds from the previously proposed office developments should be redirected to fix this urgent need.

Commercial vessel operations require proper planning and inclusion, with relocation to the north side for wash-down access at allow equitable access at all times and not to be excluded during ship operations

The added deck to the jetty shed could be misused by the “radio shack” and must meet BCA and community noise standards - better consultation with immediate community leases is required

The height of the new shed and design are excessive and should be revised to meet the design size and heights of similar buildings in the area

Bunding is required on the new ramp to the jetty to avoid a spill - EPA

Marine Parks vessels should be removed from permanent vessel parking in the area! This is not required and places further pressure on the area. They should meet same requirements as all other operators.

Zone 1 is not a safe and practical area to store vessels and trailers and better design or zones 2 and 3 is required to include the zone one overflow into this area

*Without the boat ramp completion in this immediate scope and funding - the project fails community requirements.

As a long-term resident of Lord Howe Island, raising my young family here, I’m deeply grateful for the Government’s continued commitment to preserving and supporting our unique community through initiatives such as the Critical Infrastructure Project. I also acknowledge the ongoing investment in safeguarding the island’s environment through bush regeneration, the rodent eradication program, and biosecurity efforts.

After more than a decade living here, I’ve seen firsthand the challenges our remoteness presents — particularly rising freight costs and supply disruptions that impact every household and business. Strengthening critical infrastructure offers an opportunity to improve reliability, reduce freight costs, and create employment opportunities both locally and on the mainland.

Most importantly, I hope this project continues to involve local voices so it feels genuinely community-led — aligning progress with the island’s values of preservation, sustainability, and shared responsibility for future generations

The infrastructure is not suitable.
The shipping area will not suit the island conditions

This project does not appear to affect NSW Crown Land

I support all aspects of this project.

I am completely in objection to the proposed Lord Howe Island Critical Infrastructure Plan and believe that it goes against the best interests of the community. It would seem that the whole premises of the Plan revolves around promoting biosecurity and the design has been done in a way that prioritises this above all else and fails to take into consideration, let alone achieve, the main objective, which is to provide the community with a long-term, sustainable shipping service. The proposed container shipping design is utterly inappropriate and would inadequately cope with handling the sea conditions on the Island, making unloading extremely difficult, if not impossible at times. The notion of installing dolphin pilings would unquestionably destroy the visual aesthetics of the whole lagoon and goes against our World Heritage values. They would also create a major water traffic hazard and compromise the lagoon floor’s sensitive ecosystem. Furthermore, the proposed biosecurity dog kennel premises is of a completely preposterous size and occupies valuable land space that could be used for far more valuable purposes such as agriculture. Positioning the main fuel depot at the Southern end of the Island is also totally ridiculous! This would create and unseemly amount of road traffic across the length of the Island due to the main settlement zone being at the far Northern end of the Island. The South end has always been quieter and less populated and trafficked, which I believe is how it should remain. Positioning the fuel depot a long distance from the main settlement area is completely absurd as it would result in residents having to travel further and burn more fuel, which is exactly what should be avoided. The whole plan has been devised in a manner that fails to take into consideration the opinions and desires of the community. It is negligent towards the communities needs and is completely flawed. Everything in this plan needs to be reconsidered with community consultation and input.

I object to the type of ship and the new ramp proposal. Comments from the Local consultation committee have not been listened to.

I object to the project for the following reasons:

VESSEL -
1. a RoRo freight delivery service is unsuitable for Lord Howe Island as the majority of the freight now delivered is not suitable to be containerised.

2. A containerised system will result in unusable valuable space within the containers, reducing freight volume.

3. The additional weight of the containers will impact on the draft of the vessel. This in turn will have an impact on the vessels entry into the Lagoon on marginal tides.

4. The exposed storage of freight in an open vessel during heavy sea conditions will result in unnecessary damage to cargo.

WHARF/RAMP

1. The proposed ramp system is unproven, especially in open water conditions such as Lord Howe Island during high tide, wind and heavy sea conditions.

2. Consideration for the ramp should be discarded and the wharf upgrade for lift on lift off cargo should be pursued

UNLOADING AREA

I acknowledge the current area is unsafe and is in need of a major upgrade.
The upgrade should be in keeping with the Island’s World Heritage values and designed accordingly.

The opinions and suggestions of Generational Islanders and long
term residents need to be taken into consideration before any decision is made on this project.

As a member of the CIP, and a Director of Lord Howe Island Sea Freight (which were the cargo operators for over 25 years), I am concerned our experience, opinions and suggestions have not been adequately listened to.

In summary - I am concerned that the proposed vessel and infrastructure for the North Precinct Project will result in prohibitive freight costs for the island and is unsuitable for future needs of residents and businesses operators.

1. Introduction and Context (Project Need – Clause 7(1)(f))

I operated the Island Trader for over fifty years, providing Lord Howe Island’s freight lifeline.
The vessel, its handling methods and on-shore operations have been progressively refined to match the Island’s tidal windows, lagoon depth, weather exposure, and small workforce.
The current system is proven, safe, and specifically adapted to local constraints. I acknowledge that replacement of the ageing vessel is essential to maintain reliability and compliance.
However, the proposed ramp-based, containerised Ro-Ro model represents a wholesale change to a system that already functions effectively, and may introduce greater environmental and operational risks than it resolves.

2. Project Justification and Alternatives (Clauses 7(1)(f) & (g))

The EIS should demonstrate that the selected design provides measurable improvement over a like-for-like replacement.
At present, the proposal appears to be driven by global shipping trends rather than island-specific need.
A direct comparison of the existing Lo-Lo model and the proposed Ro-Ro/containerised model—covering cost, environmental footprint, tidal efficiency, risk, and workforce capacity—has not been publicly presented.
Without that comparison, the justification for major infrastructure such as dolphins, a ramp, and expanded hardstand remains incomplete.

3. Marine and Visual Environment (Clauses 7(1)(a)–(d))
Dolphins and Ramp

The proposed dolphins will permanently alter lagoon character and restrict access for other wharf users, including rescue and research vessels.

Construction and operation would increase marine disturbance, scour, and visual bulk within a World Heritage area.

The ramp converts a flexible, low-impact jetty into a single-purpose mechanised structure that, if damaged, removes all unloading capability.
The EIS should quantify these impacts, model sediment movement and view-lines, and demonstrate that less-impacting alternatives were considered.

Thrusters

Continuous thruster use will disturb the benthic environment by resuspending fine sediments and affecting lagoon ecology.

Failure of a thruster during manoeuvre increases the risk of grounding, creating a higher environmental hazard than the current manual mooring system.
The EIS should assess sediment plume extent, turbidity, and emergency-response implications.

4. Biosecurity within Environmental Balance (Clauses 7(1)(a) & (j))

I strongly support maintaining high biosecurity standards. However, biosecurity should not be the sole or dominant driver of vessel and infrastructure design.
Environmental performance must consider the full range of impacts—visual, ecological, operational, and social.
Around the world, effective biosecurity is retrofitted to existing systems. There is no reason Lord Howe cannot achieve a high-grade, compliant standard without major structural change.
The EIS should show how biosecurity objectives can be integrated into a proportionate, low-impact design rather than dictating the entire form of the vessel and wharf.

5. Containerisation and Operational Feasibility (Clauses 7(1)(f), (h) & (i))

Containerisation introduces the need for heavier equipment and greater lay-down area than currently exists.
The proposed unstuffing shed and external storage hardstand may not physically fit within the constrained precinct and could affect visual amenity and access.
The push to enclose more of the vessel to keep non-containerised cargo under cover effectively replicates what the existing mixed-freight model already provides.
Containerisation may therefore duplicate, rather than enhance, existing functionality.
The EIS should demonstrate that the spatial, traffic, and aesthetic impacts of container handling have been accurately assessed and that operational efficiency gains are real, not assumed.

6. Workforce, Skills and Socio-Economic Impacts (Clause 7(1)(h))

Lord Howe’s workforce is limited, ageing, and already stretched across essential services.
Accommodation shortages prevent additional personnel from relocating to operate complex new machinery.
The EIS should assess the social and economic feasibility of the proposed system by evaluating:

Training requirements and costs;

Maintenance dependency on mainland contractors;

The effect on local employment continuity; and

The resilience of freight operations if key personnel are unavailable.
Infrastructure that cannot be operated or repaired locally is not sustainable in this context.

7. Efficiency and Return on Effort (Clauses 7(1)(f) & (i))

In my professional opinion, the potential efficiency gain from a shallower-draft vessel is minor—perhaps a few extra hours per tidal window—and remains unproven.
The EIS should present tide-corrected data comparing turnaround time, fuel use, emissions, maintenance, and weather downtime between models.
Without verified metrics, “efficiency” cannot be accepted as justification for major environmental change.

8. Risk, Resilience and Contingency (Clauses 7(1)(i) & (j))

Risk management must include operational resilience, not just design safety factors.
The current method allows multiple fallback options; the proposed model introduces single points of failure in the ramp and thruster systems.
A resilience analysis should identify how freight delivery will continue under:

Ramp damage or closure;

Thruster or power failure;

Extreme weather; and

Temporary loss of specialist staff or parts.
The EIS should confirm that contingency plans maintain essential supply without relying solely on external support.

9. Community and Long-Term Lifestyle Effects (Clause 7(1)(h))

Lord Howe residents will live with the outcomes of this project indefinitely.
The proposed infrastructure will change the working character of the wharf, the appearance of the lagoon, and the rhythm of community life.
If the system proves incompatible, those impacts will be permanent.
The EIS should therefore assess community character, landscape values, and cumulative lifestyle implications alongside technical impacts, ensuring that the project enhances—not erodes—the Island’s heritage and way of life.

10. Balanced Recommendation

Require the EIS to present a like-for-like replacement option that upgrades safety, emissions and biosecurity while retaining the proven Lo-Lo method.

Evaluate all alternatives on measurable, island-specific criteria rather than global shipping assumptions.

Ensure the risk assessment covers operational resilience, workforce feasibility, and environmental sustainability.

Treat biosecurity as a component of environmental protection, not its entirety.

Confirm that the final design can be operated, maintained, and repaired by existing island resources.

11. Conclusion (Clause 7(1)(j))

For half a century I have seen what works in Lord Howe waters. Every refinement came from careful observation and respect for this environment.
The lagoon, the tides, and the people define the system—not external trends.
The proposed containerised, ramp-based model increases environmental footprint and operational fragility while offering no proven improvement in reliability.
Lord Howe deserves a vessel and infrastructure that are fit for its place: resilient, maintainable, low-impact, and reflective of the community it serves.
Replacing the ship is necessary; replacing a proven methodology with an untested one is not.
The EIS should focus on evidence-based improvement, not reinvention, ensuring that future generations inherit a system that works as well as the one that has sustained us for the last fifty years.

We are residents of Lord Howe Island impacted by the Critical Infrastructure Project. Our comments are contained in the attachments.

Submission regarding the Critical Infra Structure Development Application
I am writing to convey my dismay at the deficiencies of the consultation process regarding the current DA for the Critical Infrastructure Program.
Firstly, the DA involves more than 27 separate detailed reports (over 4000 pages I've been told) about (a) a new waste management facility (b) a new port facility for Lord Howe Island. No-where, however, (at least in the documents we've seen) is there any information about the proposed cargo vessel to transport supplies from the mainland to LHI, which is a critical part of the success of these infrastructure upgrades. Three weeks is an absurdly short time to allow Island residents to read the contents of these reports and comment upon them.
What is lacking in an "Executive Summary" of manageable proportions that would enable Island residents to gain an overview of the Critical Infrastructure Program.
The infrastructure DA has highly significant deficiencies. A process of consultation and input from local community has not been adequately undertaken. As a minimum, the CCG should be:
1) Entitled to see tender documents for the nominated project.
2) Entitled to see the shortlist of tender respondents for the project.
3) Entitled to know what criteria will be used to assess the tenders.
Due to the complexity of the reports and the Infrastructure Program the CCG should also be entitled to have an independent external consultant advise them. The consultant could assist the community members of the CCG to fully understand and comment on the technical aspects of the Consultant's reports.
The Board website has regular updates to the community without any input from the community through the CCG. The CCG's comments should be made available to members of the public via the LHI Board website.
The Financial and Economic reports are vague and lack detail about assumptions on which they are based. Freight costs are a critical issue for all Islanders and a lack of confidence in the financial projections need to be addressed.

Kind regards,
Karen Taaffe. 6/11/2025
Neds Beach Rd, Lord Howe Island, NSW 2898

Ive attached a drawing from the proposed plan highlighting an area I believe should be opened up as part of the driveway into the unloading area. Otherwise it will be a bottleneck for trucks and forklifts entering and exiting. It will also create a blind spot for traffic heading south along the Lagoon Road.

I support the project. While there are definitely environmental impacts of implementing the project, I think that overall the long-term environmental benefits (particularly in biosecurity improvements) will outweigh the short-term impacts of the project's construction.