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.
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;
3.0 Conformity of the proposal with ESD (TOR)
National Strategy for Ecologically Sustainable Development
The National Strategy for Ecologically Sustainable Development (NSESD) was endorsed by Heads of Government in 1992.
The Goal is:
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.
The Core Objectives are:
The Guiding Principles are:
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.
ENVIRONMENT PROTECTION AND BIODIVERSITY CONSERVATION ACT 1999 SECT. 3A. Principles of ecologically sustainable development.
The following principles are principles of ecologically sustainable development:
(a) decision-making processes should effectively integrate both long-term and short-term economic, environmental, social and equitable considerations;
(b) if 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;
(c) the principle of inter-generational equity—that the present generation should ensure that the health, diversity and productivity of the environment is maintained or enhanced for the benefit of future generations;
(d) the conservation of biological diversity and ecological integrity should be a fundamental consideration in decision-making;
(e) improved valuation, pricing and incentive mechanisms should be promoted.
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.
3.0 Social Considerations/ Traffic & Transport (TOR)
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.
As a result, the IAS has failed to address the Social considerations and Traffic and Transport matters, as per the Terms of Reference.
Source: IAS, Table 8.12.1 Estimation of Rock Volume Required Stage 1 of Bund Construction Volume in Cubic Metres.
Initial rock volume 1,000,000
Initial losses 450,000
In place recompaction 310,000
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).
Source: 126.96.36.199 Source of Quarry Rock
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.
Source: 188.8.131.52 Transport Routes To The Site For Quarry Rock And Bund Materials
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:
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.
4.0 Degree of Detail ( TOR )
The Terms of Reference state;
In preparing the IAS, it is the proponent’s responsibility to address the impacts of the proposal to the degree necessary to enable the stakeholders to be informed of all relevant impacts of the proposal. The level and nature of investigations should be relative to the likely extent and scale of impacts. It is suggested that the applicant/consultant contact the relevant referral agencies to clarify the nature and level of investigations.
The IAS has failed to provide sufficient information and detail, through lack of consultation and study, to address the impacts of transportation of bund wall material on community safety and amenity and upon environmental values, such as those enunciated under SPP 1/97.
The IAS has failed to provide sufficient information and detail, through lack of consultation and study, to address the impacts of future transportation, both rail and road, to and from the Port as a result of its expansion upon community amenity and environmental values.
The IAS has failed to provide sufficient information and detail, through lack of consultation and study, to address the changes in silt deposition in the North Wynnum area and Eastern side of Fisherman Islands.
5.0 Meaningful consultation (TOR)
With regard to bund wall material, there was a lack of meaningful consultation with residents likely to be impacted upon by increased vehicular traffic on proposed haulage routes in Local Shires.
With regard to increased vehicular and rail traffic to and from the Port of Brisbane on expected transport routes, due to its expansion, there was a lack of meaningful consultation with those along those routes likely to be impacted upon.
Source: 184.108.40.206.2 Dugong; Although Dugongs are uncommon in the western Bay area, the extensive seagrass beds associated with the intertidal and shallow subtidal areas east of the Fisherman Islands may provide suitable feeding habitat for dugong. Most seagrass beds in this area are dominated by the eelgrass Zostera capricorni, although large patches of the dugong’s preferred food seagrass Halophila spinosula (Lanyon and Morrice 1997) occur throughout the area (see Section 7.7.1).
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.
7.0 Use of dredge material for industry
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.
8.0 Lighting and Visual impacts
The IAS has failed to adequately address the issue of lighting.
Under section 220.127.116.11 International Conservation Agreements, ( IAS ), it’s stated RAMSAR is not enforceable or suggests any responsibilities. We believe this statement incorrect, and refer to the following High Court case;
High Court decision, Minister for Immigration - v - Teoh ( 1995 ) 128 ALR 353.
Mangroves and Silt
Local residents indicate there has been a gradual buildup of silt in the North Wynnum region since reclamation work commenced at the Port. This would appear consistent with expectations, given the clockwise movement of water in the Bay, depositing of silt would occur on the eastern side of Fisherman Island and Whyte Island, and any extension of the same would likely trap further silt, as this would act as a groyne. The sampling sites utilized by the POB in their 1992 and 1998 bed sediment studies appear not to have covered the North Wynnum area, and therefore provides no scientific data to either support or refute residents claims. With regard to the closest sampling sites to North Wynnum, sampling site 24 (1992-93 survey) and sampling site P, Q & R (1998 survey) are the closest, yet they are still a substantial distance from North Wynnum. It should be noted Seagrass is found in areas of low bed shear stress, generally less than 0.1 N/m² with some extending up to about 0.12 N/m². In the WBM 1998 report, "Review of Potential Impacts Associated with Super Bund Construction" it states, "… this study suggested an overall increase in broad-scale Seagrass extent…" ( WBM, pg. 35 ). The study area in question was located on the eastern side of Fisherman Island. If sediment material is available, siltation can be expected in areas with bed stress levels less than about 0.1 N/m². It can be reasonably assumed bed shear stress has decreased, supporting the claim sedimentation has likewise increased, and further, highlighting Hydrodynamic processes are possibly being impacted upon by the current Port Extensions.
The WBM 1998 report, "Review of Potential Impacts Associated with Super Bund Construction" it states, "Many mangrove areas along northern banks of the Boat Passage were eroding (Plate 1) whilst others had sand banks/ridges that appeared to have established recently within the stand. Such changes may adversely affect mangrove root systems and result in tree stress." As indicated in the IAS, Bait Wormers and others have reported increased sand accumulation and reduced silt in areas such as the Boat Passage. Fishers also reported decreased mullet catch and movement in the Boat Passage as per the Brisbane’s Port Environmental Study, 1991-92. These changes have said to have occurred within the 10 years since 1991-92, consistent with Port reclamation work at that time. The POB has failed to either confirm or refute this local knowledge. To suggest these changes are the sole result of increased South easterly winds would be irresponsible and are certainly not supported by sound scientific data.
We believe there is evidence to suggest the POB extensions have had, and are continuing to have, a negative impact upon a number of environmental values and likewise the same can be expected from further extensions.
We do not share the same optimism as the POB that the proposed Port of Brisbane extension will have minimal negative impacts upon the environment and the community. With impacts from past Port of Brisbane extensions still manifesting in many forms, the Precautionary Principle must prevail. Long term impacts must be understood and at present these are inadequately understood.
Further, the IAS has adopted an approach that appears to localize on some impacts thus avoiding disclosure of the real impacts upon the community and the environment. We refer particularly to the movement of bund wall material and interference to Hydrodynamic processes. We find this unacceptable and in breach of the Terms of Reference and ESD principles.
Our Group appreciates Simon Baltais's permission to display
Wildlife Preservation Society Queensland, Bayside Branch Inc submission on the
proposed expansion of Fisherman Island further into Moreton Bay.
This page is maintained by
The Rivermouth Action Group Inc
as a community service.