National Office of the Australian Marine Conservation Society (AMCS)

6 October 2000

Project Manager
Port of Brisbane Fisherman Islands Expansion
Projects and Infrastructure Division
Department of State Development
PO Box 168
BRISBANE ALBERT STREET, QLD 4002

Dear Sir

Submission on Draft Impact Assessment Study (IAS) - Fisherman Islands Proposed Port Expansion

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.

2) Justification

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.

3) Methods

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:

• Calibration and Validation of the model.
• The suitability of a two dimensional model to accurately quantify the changes occurring or likely to occur in relatively shallow river and estuarine areas and
• The interpretation and quantification of results in relation to interconnected processes and the associated natural ecosystems.

4) Process

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 responsibilities.

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 Study.

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.

Yours faithfully

signed

Kate Davey
National Co-ordinator

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