National Office of the Australian Marine Conservation Society (AMCS)
6 October 2000
Port of Brisbane Fisherman Islands Expansion
Projects and Infrastructure Division
Department of State Development
PO Box 168
BRISBANE ALBERT STREET, QLD 4002
Submission on Draft Impact Assessment Study (IAS) - Fisherman Islands Proposed Port
The National Office of the Australian Marine Conservation Society (AMCS) is pleased to make
this submission on the above draft IAS. The Society has been fighting for marine and coastal
conservation for over 30 years and is concerned by any development proposal that is likely to
effect our precious marine and coastal habitat.
The AMCS has been involved in the Consultation process and has made comment on the
proposed development. Many of our concerns relate to issues, such as transport infrastructure,
which, it was determined, were not to be included in the final Terms of Reference for the Study.
Therefore, the following comments relate only to those issues listed in the Summary of
Stakeholders Interviews and the adequacy of responses to them in the draft Study document.
1) "Ethics" of the Proposed Reclamation
The AMCS accepts the need for the judicial use of coastal land for ship loading and unloading
facilities. However it is against the destruction of important marine habitat for activities which
are often only loosely related to actual port operations and could be adequately accommodated
in areas allocated elsewhere for the purpose. We see, for example, a great deal of available land
in close proximity to the port which would be better used for this purpose.
In the draft Study it states that there will be no further expansion of the
port area after the 25 years it will take to complete this proposed extension.
It is suggested that we will have to find different ways to accommodate further
expansion of port operations and deal with the issue of placing dredged material.
Why are we waiting 25 years for the next generation of Queenslanders? The AMCS
would like to believe that we have the ability now to identify better ways to
produce options that recognise genuine ecological sustainability. We note that
the Study has made no effort to value the many facets of the marine environment
as it has port operations.
The AMCS does not believe that the draft IAS has responded to identifying the need for the
creation of additional port land to accommodate port growth. There are figures showing some
planned efficiency improvements, however no mention is made of improvements to the present
actual use of facilities or statistics that compare the utilisation of land in ports of a size to which
the port of Brisbane aspires, with future planned operations.
The AMCS is pleased to see the considerable effort that has been put into identifying the
changes to currents, sedimentation and wind patterns in western Moreton Bay due to the present
port development and the planned extension. The hydrodynamic changes are important if we are
to effect the recovery of areas in Moreton Bay identified as being in poor health by the SE
Queensland Regional Water Quality Study Group.
However, while we are shown that changes have and will continue to occur we consider that the Study has not attempted to quantify these changes that are effecting coastal processes. The AMCS would like this section relating to Hydrodynamic Processes and modelling peer reviewed especially in the areas of:
The concern of the AMCS for the time frame of the IAS remains. Perhaps if more time had been
allowed for the study we would have been able to know the type and source of the material for
the peripheral bund wall. (Which was a requirement of the Terms of Reference) We also believe
that details of the design and methods for construction of the bund wall and quay line revetment,
including the other options for construction should have been more adequately addressed. This
is especially important when we consider the issues involved in delivering bund wall material
by road before the dedicated port road construction is completed.
We are being asked in many sections of the report to rely on the ISO 14001
Environmental Management System to give the community assurance of environmental
protection . While this system may be well respected, without seeing the results
from its implementation it is hard for groups like the AMCS to be confident
that the Port of Brisbane Corporation will adequatly manage its environmental
An attempt have been made throughout the draft IAS document to emphasis the transparency
of the process through public consultation, newsletters and workshops and promises of increased
community public access to the Port. However, to not be allowed access to the documents such
as the Strategic Development Plan 2000-2005, the Dredging and Dredged Material Placment
Management Plan and Stormwater Management Plan from which so much statistical and factual
information has been quoted makes it difficult to accept a lot of the information presented in the
The Australian Marine Conservation Society hopes that the above information will be useful
and will contribute to a more balanced view of the likely environmental effects of this proposal.
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