Project Manager
Port of Brisbane Fisherman Islands Expansion
Projects and Infrastructure Division
Dept. of State Development

Thursday, 5 October 2000

Dear Sir or Madam

Please find attached our preliminary submission on the Draft Impact Assessment Study (IAS) for proposed Port of Brisbane extension.

Yours sincerely

signed 

Simon Baltais
Secretary

The IAS is an extensive document, requiring resources inaccessible to most individuals and community groups to address appropriately in the time permitted. A situation quite typical in Queensland and one which supports a process whereby inappropriate development can continue to flourish.

We believe a number of matters within the Terms of Reference have not been addressed adequately. The following matters include;

• Conformity of the Proposal with Ecologically Sustainable Development (ESD)
• Social Considerations
• Traffic and Transport
• Address the issue of light nuisance to residents and native fauna caused by the expansion of port facilities.
• Degree of detail.

Development that improves the total quality of life, both now and in the future, in a way that maintains the ecological processes on which life depends.

• to enhance individual and community well-being and welfare by following a path of economic development that safeguards the welfare of future generations
• to provide for equity within and between generations
• to protect biological diversity and maintain essential ecological processes and life-support systems

• decision making processes should effectively integrate both long and short-term economic, environmental, social and equity considerations.
• where there are threats of serious or irreversible environmental damage, lack of full scientific certainty should not be used as a reason for postponing measures to prevent environmental degradation.
• the global dimension of environmental impacts of actions and policies should be recognised and considered.
• the need to develop a strong, growing and diversified economy which can enhance the capacity for environmental protection should be recognised.
• the need to maintain and enhance international competitiveness in an environmentally sound manner should be recognised.
• cost effective and flexible policy instruments should be adopted, such as improved valuation, pricing and incentive mechanisms.
• decisions and actions should provide for broad community involvement on issues which affect them.

These guiding principles and core objectives need to be considered as a package. No objective or principle should predominate over the others. A balanced approach is required that takes into account all these objectives and principles to pursue the goal of ESD.

The IAS has failed to ensure individual and community well-being will be enhanced, and has failed to integrate short term and long term economic, environmental, social and equitable considerations appropriately as per ESD. We refer you to section 3.0, 4.0, 5.0, 6.0, 7.0, 8.0, 9.0, 10.0 and 11.0 of this report.

One major matter not addressed appropriately by the IAS is the transportation of rock material for the bund wall.

Residents located on minor transport corridors, impacted by the transportation of rock material for the bund wall, have not been consulted on the approaching disruption to their lifestyle. It is expected there will be at least 1 truck every 1.5 minutes for 1.5 - 2 years.  While this may represent a small increase in traffic on the major arterial roads, it represents a major increase when you consider the Local Council roads they will traverse to get from the Quarry to the major arterial roads.

There is a possibility that rock material for the bund wall will come from Quarries at Mt Cotton in the Redland Shire. However, a tendering process likely determines the final decision.

The IAS process appears to have failed to consult all residents along the various possible transport routes. Lifestyle and community amenity will be negatively impacted by an extra 1 truck every 1.5 minutes travelling along once significantly quieter roads.  Pedestrian traffic and local vehicle traffic will also be negatively impacted upon.  Quarry vehicles will pass routes frequented by students and residents, their safety and amenity issues on such routes have been ignored.

We believe Redland Shire Council has not been consulted on this issue, most inappropriate considering they will likely bare the cost of road upgrades and repairs, unless public monies from State revenue is utilised. 

It appears public money is supporting the Port of Brisbane Extension in an indirect manner and this will impact upon any Cost benefit analysis utilised in the IAS process, if not considered in such an analysis already.

Council ratepayers appear to bare the burden of road upgrades and repairs because of increased heavy vehicular traffic.  It is hardly conceivable that revenue gained from vehicle registration, from the quarry vehicles used in this operation, will cover the cost of such road works. These trucks are carrying 15 cubic metres of rock each.

If Mt Cotton is chosen these trucks will travel through Koala habitat zones, the Koalas are already suffering huge losses on Redland Shire roads, why add to this unsustainable impact. This issue hasn’t been considered or addressed as required by the State Planning Policy 1/97 and appears breaches of this policy are likely. It should be noted that the Environment and Planning Court recognises environmental values stated in planning documents and are obliged to protect them.

The offsite impacts from the Port Extension are many; the increased work at one quarry will likely mean the owners of the quarry will wish to utilise 3 recently purchased leases adjoining the quarry.  These are bushland blocks and within the Koala Coast region. It appears further Koala habitat/bushland losses will be incurred as a result of the Port Extension.

The treatment of fines found on the rock is an issue.  Silt plumes must be avoided. The treatment of fines at one Quarry represents a possible major risk to Tingalpa Creek. If treated at the Port it represents a major risk to the Marine Park, depending how and where the fines are treated.

The placement of bund material into the Bay will likely create silt plumes, and this matter hasn’t been addressed.

The IAS makes no mention of ensuring social and environmental impacts are factored into the Tendering process, with regard to acquisition of quarry material.  This Tendering process should be publicly scrutinized.

Transport issues were raised by WPSQ Bayside Branch as a major issue in the early stages of the consultation process, they appeared not been addressed adequately. Consequently, the IAS has shown little respect for residents likely to be impacted by increase heavy vehicle usage.

Initial rock volume 1,000,000

Initial losses 450,000

Settlement 100,000

In place recompaction 310,000

    Total 1,860,000

In estimating daily and hourly truck volumes required to supply this volume of rock over a two year construction period, assumptions were made in relation to critical parameters as follows: Average truck volume - 15 m 3

Haul period - 50 weeks/year

Haul days/week - 6

Haulage hours/day – 10

On the basis of the above listed assumptions, 207 truck visits/day (i.e. 414 vehicle trip ends) would be required for rock haulage over the first two year period. Over a ten hour day, there would be an average of 21 loaded trucks entering the Port each hour (i.e 42 trips/hour).

Rock material to be used in bund construction is expected to be drawn from one or more of the existing licensed quarries in southern Redlands Shire, Beenleigh, the Coomera area and/or at Petrie.

Other quarries may also be considered on the basis of material suitability and cost. The precise location of the source of quarry rock is not essential information from a traffic engineering viewpoint since all quarries are able to operate to the extent of their licensed capacity. The suitability of the road network to service the quarry operations will have been considered as part of the license process. Consequently, the route between any quarries used and the main arterial road network including the Gateway Motorway would be capable of serving the generated truck volume up to the full extraction rate permitted under the particular quarry license. Fresh development applications and accompanying environmental impact statements would be necessary if extraction rates needed to service the proposed port requirements would lead to the licensed capacity being exceeded.

Given that consideration has previously been given to the suitability of the route from the quarries to the arterial road network, the travel route subject to this investigation may be restricted to:

• Gateway Motorway;
• Lytton Road;
• Pritchard Street (linking Lytton Road to Port Drive); and
• Port Drive.

Pritchard Street and Port Drive are routes through industrial areas (although residential parts of Wynnum North overlook Pritchard Street). The Gateway Motorway and Lytton Road travel through a mixture of industrial and residential areas.

We don’t support this statement. WPSQ Bayside Branch has since March 1998 coordinated the Moreton Bay Community Dugong Watch program. Results from this program have provided enough incidental sightings to suggest the Western side of Moreton Bay is important to the Moreton Bay Dugong Population.

After the recent Lyngbya bloom on the Eastern side of the Bay, Southern Bay Island residents reported Dugong numbers increased to levels not seen for over 11 years. An assumption drawn from these sightings is the Lyngbya had forced Dugongs away from normal feeding grounds and that other less frequented sea grass beds had become important to their survival.

Further, there has been little scientific study to conclusively prove Dugongs are uncommon users of the sea grass beds on the Western side of the Bay. The aerial surveys conducted to determine Dugong numbers are unsuitable for the turbid western waters of Moreton Bay.

We have incidental sightings of 200 – 250 in the vicinity of Aquatic Paradise, Birkdale located on the Western side of Moreton Bay. While such numbers are uncommon, sightings of smaller groups, of 1 – 6, have been seen from Thornlands to Wynnum to St Helena and are not unusual. Dugong sightings around the Southern Bay Islands are likewise.

Important Dugong food, such as Halophila spinosula and Halophila ovalis are found in the Study area, every action possible should be taken to protect or enhance such sea grass beds.

Alternative uses for dredge material needs to be established. With a limited life span for dumping of dredged material onto Port land, other industrial uses for this material must be found. Dumping of material into the Bay or on terrestrial land is inappropriate and inconsistent with ESD principles.

The IAS has failed to adequately address the issue of lighting.

• It hasn’t established the impacts of lighting on avifauna, particularly migratory species.
• The solution to lighting such as, vegetation screens at key locations, shows a lack of concern for community visual amenity. It would appear the Port expects the community to implement vegetation buffers to resolve light impacts caused by the Port. It’s the POB responsibility to resolve light impacts, not the communities. Costs associated with these buffers are a Port concern, not the communities. Vegetation buffers should only be considered if they enhance community amenity. Suitable lighting technology and techniques are required to implemented by the POB.
• There has been inadequate consultation with those directly impacted by such lighting and thus no information to suggest if the community is prepared to accept vegetation buffers as a solution or where such buffers can be created.
• Such vegetation buffers must be consistent with the Brisbane City Council Bayside Regional Parkland planning process.
• There has been no assessment as to the impact of lighting on tourism on the Bay, particularly Eco-tourism. WPSQ Bayside Branch, as operators in the eco-tourism industry on Moreton Bay, believe the extension of the Port and it’s lighting, will reduce the Eco-tourist values of Moreton Bay. It is likely lost eco-tourist values have not been factored into the cost benefit analysis for this proposal. The light minimisation measures appear insufficient and poorly conceived.