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MY SUBMISSION TO TRAVESTON DAM EIS

10 January 2008  Project Manager
SEQ Infrastructure (Water) – Traveston Crossing Dam
Department of Infrastructure and Planning
PO Box 15009
City EastQLD 4002   

Dear Project Manager

 RE:    Response to Traveston Dam EIS   

 Wide Bay Burnett Conservation Council Inc has been the peak conservation body in the Mary Catchment since its inception in 1970, it is a not for profit community group. It has continuously provided conservation based knowledge to the Queensland government through various community consultation processes at the local , regional and state level .  Councils Water Policy Officer Mr Roger Currie was councils conservation delegate for the Mary Basin Water Resource Plan community stakeholder group and acted as technical advisor to the conservation sector representative Ms Jennifer Simpson on the Community Reference Panel (CRP) .  Mr Currie was also invited to the Federal Senate Inquiry in Canberra in June 2007 to present councils evidence concerning the Qld goverments inability to adequately protect MNES ( Matter of National Environmental Significance under the EPBC 1999)  and councils costs benefit analysis ( CBA) of the Traveston Dam project.

Councils submission is focused on the potential ecological , economical and social inadequacies  in  the EIS concerning , adherence to the TOR ( Terms of Reference), particularly for economical analysis and  regional planning policies relevant to the  adequate protection of MNES under s16 A& 16 B  (Ramsar Wetlands) , s 18A & 18B (listed threatened species and communities) , and s 20A & 20 B (migratory species)  , of the EPBC 1999. Councils submission also includes a discussion on the ‘suitability ‘of the proponent , ( s 137, (4))  based on an assessment of the proponents ( Burnett water/Sunwater) inability to meet its ‘variation to conditions of approval’ for adequate protection of Neoceratodus forsterii( Lungfish) in the Burnett River in respect of Ned Churchward Weir and Paradise Dam . Council also endorses the formal submissions of the Mary River Catchment Coordinating Association (MRCCA ) , the Save the Mary River Group ( STMRG) and the GMA ( Greater Mary Association)   

EXECUTIVE SUMMARY

  This submission is in response to the failings of the Traveston Dam EIS to adequately identify potential economic impacts to the Fraser Coast Regional economies, arising as a result of the implications of an interbasin transfer of a predicted (modeled) Historical No Failure Yield (HNFY) of 70,000 mega liters annually to the Moreton Basin , from the proposed Traveston Dam stage 1 .   The Terms Of Reference  ( TOR) expressly requested that a Costs Benefits Analysis ( CBA) be produced to identify the distribution of costs and benefits at the local ( Cooloola ) &  regional scale ( Fraser Coast )  and that this analysis include a calculation of the  lost  ( foregone ) opportunity costs of the use of the yield , for the regions future requirements .  

The consultancy firm engaged to prepare this CBA ( Marsden Jacobs )  has prepared a costs comparison analysis for a suite of supply options including desalination. This is clearly in breach of the TOR and a conclusion may be drawn that the Expression Of Interest ( EOI)   on behalf of the proponent , failed to indicate that a CBA was required. “we focus on identifying the least-cost supply option, The exclusion of a benefit stream in the analysis means that standard decision metrics employed in cost benefit analyses, such as return on investment and benefit:cost ratios, are not applicable.” (S1.2 Appendix F 11.2)   The TOR also required that ‘identified social & economic impacts be mitigated ‘, this submission will show that social & economic impacts  to the Fraser Coast Regional economy , arising from predictable impacts to the Great Sandy RAMSAR ( GSR) , have not been included , due to a flawed premise that  Mean Annual Flow ( MAF) into the GSR  will be maintained at 85%. Marsden Jacobshas acknowledged in its critique of the UTS  Alternative Supply Options Report  (Mary Mayors  2007) ,  that the Widebay ( Mary River ) regional communities are ‘vulnerable to water supply security’, and that the construction of Traveston Dam  offers improved supply security “.  

This submission will show that there are likely to be significant economic impacts to future regional growth based on 3 important errors within the EIS ; 

1.      The inability for the proponent (QWI/SUNWATER) to ensure that the legislated Environmental Flow Objectives( EFO) prescribed in the Mary Basin Water Resource Plan  2006  regulations will be met at the Mary River Barrage,  ensuring  the inability to maintain the  proponents claim of 85% Mean Annual Flow (MAF) at the Mary River mouth , and

 2.      The failure to recognize the ensuing downstream biological impacts to the receiving coastal environment ( Great Sandy RAMSAR Wetland) and the threat of economic impacts to the Fraser Coast Regional Tourism economy as a result and ,

3.      The failure of the proponent to calculate the lost opportunity costs to the Fraser Coast Regional economy from growth constraints created by a combination of  future unpredicted climate change  effects on the  natural flows within the Mary Basin catchment, and the annual extraction of 70,000mgl to the Moreton Basin.   

1.    Environmental Flow Objectives Mary River Barrage  

The current level of water extraction and infrastructure on the Mary has already had a negative impact on estuarine and marine ecology Freshwater flows from the Mary River to the Great Sandy Marine Park and to the Great Sandy Ramsar wetlands are regulated by the barrage on the Mary River and the barrage across Tinana Creek just above its confluence with the main trunk of the Mary.  These barrages are currently operated as water supply storages for the Lower Mary Irrigation scheme and also provide some town water supply for the city of Maryborough. These structures have already had major impacts on the flow regime at the river mouth, particularly the low-flow regime, with subsequent impacts on the marine and estuarine ecology of the area   It is reasonable to argue that the operation of the Mary River Barrage and the water supply schemes abstracting water from the barrage storage are the major determinants of outflows from the main trunk of the river during critical periods of low flow.  This is borne out by Estuarine and Marine Ecology report produced for the EIS

[1] There are various existing dams and barrages / weirs throughout the Mary catchment that currently impact upon downstream estuarine and marine environments. These include: Borumba Dam, which has downstream geomorphological and ecological impacts on the Mary River; the Mary Barrage, which limits the extent of tidal inundation further upstream; and the Tinana Barrage on Tinana Creek, a major tributary of the Mary River that enters the river at Maryborough. The barrages have impacted hydrology in the estuary, due to the truncation of tidal influence; fish passage (with the fitted fishways not always effective); and water quality in the estuary, as water quality in the upstream pondages deteriorates during long periods of low flow.The impacts of other major weirs in the Mary River on downstream flow regimes are largely limited to impacts on low flows and restriction of fish passage.   frc environmental (2007)  Traveston Crossing Dam EIS: Estuarine and Marine Ecology . 

The Integrated Quantity Quality model (IQQM) modeling comparisons of flows downstream of the Mary River Barrage contained in the EIS evaluate two different ways of operating the barrages.

With respect to impacts on marine and estuarine environmental values in the Great Sandy Marine Park and the Great Sandy Strait Ramsar wetlands, the purpose of the EIS is to investigate the additional impact that constructing and operating the proposed Traveston Crossing Dam on the main trunk of the river is likely to have.  The IQQM modelling scenarios presented in the EIS are totally inappropriate for this purpose, because the ‘with dam’ and ‘without dam’ scenarios use vastly different assumptions about the operation of the barrage and the water extraction patterns from the barrage. So rather than evaluating the impacts of the dam proposal on the estuary, instead they mainly evaluate two different methods of operating the Mary River barrage.   This can be illustrated by an analysis of the simulated daily flow data presented in the EIS in report 17 of the supporting technical documents, prepared by Sunwater.  By plotting modeled daily flows presented in this document for Home Park (just upstream of the barrage storage) against outflows at the barrage we can see the effect that the operation of the barrage and associated water extraction has on the low-flow regime of the river ( GRAPHS 1&2) 

 It is clear from this analysis that vastly different methods of operating the barrage and barrage storage are used in the scenarios supposedly representing the impacts of ‘with’ and ‘without’ the proposed Traveston Crossing Dam. Across the same range of daily inflows, the ‘with dam’ scenario shows a consistent operation of the barrage fishway (the horizontal line at 21 ML/day), and a very different extraction pattern from the barrage (shown by the number of points above the diagonal line on the graph – where outflows from the Barrage exceed inflows from Home Park). This contrasts with the ‘without dam’ scenario that shows no fishway operation and much reduced outflows at times of low flow (very few points above the diagonal  line).


REFER TO GRAPH 1

[1]FRC 2007, APPENDIX F.6.

Thus, any comparison in the EIS of modeled low flow data downstream of the Mary River Barrage, (eg at the river mouth) between the ‘with dam’ and the ‘without dam’ scenarios is comparing different methods of operation of the barrage, rather than the impact of the proposed dam upstream.   Interestingly, the EIS demonstrates how the existing significant environmental impacts of the barrage on the estuary may have been greatly mitigated by Sunwater, simply by running the barrage storage and the associated water supply schemes in the manner proposed in the ‘with dam’ scenario presented in this EIS. (which, according to Sunwater, still complies with the water supply security objectives written into the Mary Basin Water Resource Plan). 

Impacts on flow regime from the Mary River into the barrage storage

The most downstream location on the river for which the proponent presents data from which valid comparisons can be made (between the impact of the proposed dam and the impacts of the current level of infrastructure development) is at Home Park, which is one of the environmental flow nodes in the Mary Basin Water Resource Plan. Table 6.73 of the EIS shows that with the current infrastructure and system of water allocation in the river, flows in July, August and September do not fall within the guidelines outlined in the current Mary Basin water resource plan legislation.  Further, when the impact of the first stage of Traveston Crossing Dam is added, the seasonal flow patterns are pushed further outside the flow guidelines in the WRP.    

The wording of the legislation with respect to these particular guidelines is that any new operations in the river MUST MINIMIZE THE EXTENT TO WHICH flows fall outside the stated guidelines.  Schedule 6 of the WRP is very clear in this respect.  There is no “Should comply” specification at all in the legislation, and as such, the interpretation in Table 6.73 of EIS is completely misleading. It is very difficult to see how a proposal which clearly demonstrates that it will push flows further outside of compliance with the legislated guidelines than they currently are is minimizing the level of non-compliance.  Non-compliance with the guidelines in the WRP is evidence of an existing unsustainable level of extraction, hence of an over-allocated system (as legally defined under the National Water Initiative).  The Mary Basin Water Resource Plan is a regulatory instrument of the NWI – part of Queensland’s bi-lateral agreement.  Pushing a system from an over-allocated state to a more over-allocated state is directly in conflict with the one of  the principal objectives of the NWI. 

Another way of investigating this impact is to look at the impact on mean flows in comparison to the reference or natural state of the river.  The flow data presented in the EIS is shown in GRAPH  2compared against the commonly used flow benchmarks of 85% of natural flow, and 2/3 ( 75% MAF)  of natural – both referred to in the EIS.   Although it is not an environmental flow node in the WRP, flows past the barrage to the estuary are a better indicator of flows to the estuary than flows at Home Park, because they take into account the impact of the Lower Mary Irrigation Scheme and the general operation of the barrage.  It is valid to compare the Traveston Crossing Dam scenario in the EIS document to the natural flow regime in the document.  Understanding the way the barrage was modelled in that scenario represents a far better way of operating the barrage with respect to environmental flows than what currently occurs.

It is very clear that the state of flows into the estuary, even with ‘good’ operation of the barrage would be significantly altered from the natural state. The data presented in the EIS predicts that mean flows in September, over the entire climatic simulation period of 1890 to 2000 would be halved. It is important to note that none of the flow modelling presented in the EIS takes any account of existing climate change trends or future climate predictions on streamflow.  It specifically assumes that the pattern of streamflows over the period from 1890 to 2007 will be indicative of patterns into the life of the dam project.  This is also in contravention of the National Action Plans for Climate Change and Agriculture, and Climate Change and Biodiversity, and is in contravention with the Queensland Climate Change Action Plan which implements the National Agreements. 

CLIMATE CHANGE MODELLING

Recent modeling of streamflow reduction due to climate change in WA [1]has shown that a projected decrease of 10% annual rainfall results in a 30% reduction in yields for storages. This would equate to a similar reduction on MAF to the Great Sandy RAMSAR.  

REFER TO GRAPH 3


[1] Modelling of streamflow reduction due to climate changein Western Australia – A case study1Bari, M.A., 1Berti, M.L., 2Charles, S.P., 1Hauck. E.J. and 1M. Pearcey1 Department of Environment, PO Box 6740, Hay Street East, East Perth, W.A. 6892, Australia,E-Mail: mohammed.bari@environment.wa.gov.au2 CSIRO Land and Water, Private Bag Number 5, Wembley, W.A. 6913, Australia  
GRAPH 3 illustrates the behaviour of the climate adjusted ( modeled) stream flow at the project gauging station, each mm decrease in rainfall correlates with a 1.567GL decrease in annual stream flow. 
RESPONSE
It can be clearly seen from the above information that the proponents claim of maintaining MAF of 85%  at the Mary River mouth cannot be substantiated and seasonal flows into the upper Mary estuary feeding the Great Sandy RAMSAR, will be significantly altered from the natural state . The graphical illustrations above clearly shows that MAF at both the Home Park flow node and the barrage will fall to 50%, for the stage 1 proposal (pink line)    
 A 10% reduction in annual rainfall would see MAF at the Mary barrage reduced well below the 50% indicated in the above graphs. The above information also substantiates that climate change modeling has not occurred despite the proponent claiming a rationale for the project of , “ the need to ensure that Brisbane has adequate supply by 2026 in case , “the worst-case reality of climate  change eventuates, and in case of increased climatic variability, such as another significant drought.” (Executive Summary S 1.1 Project Rationale) ,
this is further substantiated by the media release from the Minister for Infrastructure and Planning dated 6 Jan 2008 , outlining a contingency plan to produce 100 MGL of daily demand from mobile desalination plants  in Brisbane to ,ensure water security even if the worst drought on record worsens,” “In its analysis of extended worst case inflow scenarios, the Queensland Water Commission estimates our dam storage levels could drop to seven percent by 2010 based on 2006/07 inflows,” 
RESPONSE
The geographical position of the large Brisbane supply dams of Wivenhoe and Somerset  across the range from the Mary River , ensures that the Mary River will also be subjected to these potential “ worst case inflow scenarios “ ,  appendix 1 shows the geographical relationship between the Mary River Headwaters and the Stanley River headwaters , the line A-B shows that  the  headwaters of both  streams and hence catchments,  are a mere 13 km apart . ( refer appendix 1)    
RECOMMENDATION 
The serious nature of the uncertainty concerning adequate environmental flows to the receiving waters of the Great Sandy RAMSAR , and the absence of cumulative impact modeling for climate change , must invoke the application of the Precautionary Principle. Therefore the project should not be given approval under the EPBC 1999 S 16 A& 16 B  (RAMSAR WETLANDS ) , due to its inability to guarantee a ‘non significant impact’ to one or more values of the Great Sandy RAMSAR . 
2. DOWNSTREAM RAMSAR IMPACTS 
No acceptable scientific research has been completed under the EIS on surface and groundwater base flows, required to demonstrate protection of state significance wetlands in the Great Sandy RAMSAR. The EIS does not adequately address identified potential fisheries productivity impacts,  as the Mary Basin Water Resource Plan (MBWRP)  flow schedules design process,  did  not include contemporary research on fisheries and estuarine freshwater flow productivity requirements.   
LEGISLATIVE INCONSISTENCY 
The Mary Basin Water Resource Plan ( MBWRP)  does not acknowledge the need for the Great Sandy RAMSAR (receiving waters) to be considered, this is in conflict with global contemporary protected area management best practice for RAMSAR sites,   and is in direct contrast with the Moreton ( Brisbane) WRP. Both catchment basins support a RAMSAR wetland . 
This is substantiated by the following comparison of legislative requirements between the MBWRP and the Moreton (Brisbane) WRP; 

Moreton WRP  S 26 Moreton WRP (1)  , In dealing with unallocated water from the strategic reserve , the chief executive must consider , Mary WRP S 26 Mary  WRP (1)  , In dealing with unallocated water from the strategic reserve , the chief executive must consider ,
(c)  the impact the proposed taking of or interfering with thewater may have on the following—(i) water quality;(ii) brackish water habitats in estuarine reaches;(iii) inundation of habitats;(iv) the movement of fish and other aquatic species;(v) the natural movement and delivery of sediment,and the delivery of fresh water, natural nutrients ororganic matter, to Moreton Bay or PumicestoneChannel;          (vi) recreation and aesthetic values;(vii) cultural values, including, for example, cultural values of the traditional owners of the area; and  (c)  the impact the proposed taking of or interfering with thewater may have on the following—(i) water quality;(ii) inundation of habitats(iii) the movement of fish and other aquatic species(iv) the natural movement of sediments (v) recreational and aesthetic values(vi) ) cultural values, including, for example, cultural values of the traditional owners of the area; and  

 RESPONSE 

It can be seen from this comparison that the Queensland government has in fact acknowledged that the Moreton RAMSAR may be impacted from proposed infrastructure development within the basin, however the wording of “the natural movement and delivery of sediment, and the delivery of freshwater, natural nutrients or organic matter, to Hervey Bay or Great Sandy Strait”, has not been included in the Mary WRP.   The State Coastal management Plan 2002, the SEQ Coastal Management Plan 2007,   the Draft Widebay Coastal Management Plan 2007 and the Wide Bay Burnett Regional Growth Plan 2007,   all acknowledge that “adequate  freshwater inflows are important to the physical and ecological processes of the coast, and that extraction from coastal waterways can modify the size and frequency of flows, with adverse impacts on coastal resources”.  

This is an acknowledgement on the part of the QLD government , of the intent of the Precautionary Principle being applied to a virtually identical closed ( off shore sand island barrier) estuarine ecosystem  ( Moreton RAMSAR) , and it must be applied to the Mary Basin Water Resource Plan , because the receiving waters estuarine and marine  systems are geographically, geologically  & biologically  the same.                              

FAILURE TO ADDRESS RAMSAR VALUES ADEQUATELY 

The EIS fails to adequately address the wetlands policy intent of the Widebay Burnett Regional Growth Plan 2006, Draft Widebay Coastal Management Plan 2007 and the State Coastal Management Plan 2002,  Widebay Burnett Regional Plan 2006 The EIS does not adequately address and is in conflict with the policies of the Widebay Burnett Regional Plan 2006: POLICY 1.4 Water Supply , Policy Principle 1.4.1 , Management of regional water resources will balance economic and social outcomes within the ecological capacity of catchment ecosystems, and be cognisant of the implications of seasonal climate variability and long term climate change”.  Policy Action; “development of risk management strategies addressing security of both rural and urban water supplies;”  

RESPONSE 

The EIS indicates that a Costs Benefits Analysis ( CBA)  to determine the local and regional distribution of impacts has not been completed ,  this does not allow for balance of economic and social outcomes to occur. A flawed modeling assumption of 85% MAF to the  RAMSAR which does not include a climate change assessment  , does not assess the potential for exceeding the ecological capacity of the ecosystem. The absence of climate change modeling to determine risk and supply security is in direct conflict with the policy action stated.    

POLICY 2 .2 BIODIVERSITY,

 Policy Principle , 2.2.1 

“The extent, function and condition of wetlands is maintained andimproved, enhancing their capacity to sustain habitat for dependantflora and fauna species and hydrological processes”.  

RESPONSE 

The EIS indicates that there is potential for change to the ‘extent, function, condition, hydrological process and habitat sustainability for the Great Sandy RAMSAR.   

Policy Principle 2.2.3 ,

 Aquatic ecosystems, their constituent species and related processesare maintained and improved”.   

RESPONSE

The EIS indicates that maintenance and or improvements’ to the RAMSAR may not occur, due to uncertainty for  EFO’s to be met.

 POLICY  2.3 Coastal Environments, 

Policy Principle 2.3.2 

“High value natural assets of the coast are protected from incompatible uses and managed for community benefit.”  

RESPONSE

The potential for the MAF to be reduced to ca 50% is a non protective and incompatible use of the RAMSAR and the transfer of 70,000mgl will benefit the greater Brisbane community, not the Mary catchment communities  , this use is in direct conflict with the regional policy intention.  

POLICY 7.2 

Regional Water Supply Water supply is expected to be a major limiting factor for growth in many of the region’s communities. This is likely to be exacerbated by projected population growth in coastal areas, coupled with predicted climate change impacts of increased temperatures and rainfall uncertainty. Potential disruption to industrial, agricultural and urban growth through drought and water shortages could adversely affect prosperity and quality of life aspirations for the region’s inhabitants. Objective: To provide sufficient water and related infrastructure to service theneeds of the community and economic activities in the region whilstmaintaining healthy ecosystems. 

Policy Principle: 7.2.1 

Regional and sub regional collaboration, planning and coordination ofthe Wide Bay Burnett water resources to ensure the efficient, costeffective and sustainable management of the region’s watercatchments, impoundments and distributions systems.   

RESPONSE

The EIS has failed  to acknowledge  the policy intention of the  regional water supply strategy  ,there has been no regional collaboration , planning & coordination in respect of the distribution of the projected yield from this project.     The project site is within Cooloola LGA , the potential project impacts on flows are  within the jurisdictional boundary of the regional plan and as such, the EIS has failed to adhere to the TOR specifically at section 1.7: 

1.7 PROJECT APPROVALS 

1.7.1 Relevant Legislation and Policy Requirements The EIS should identify all relevant legislation, policies and strategies, as well as assess their specific implications and requirements for the Project and impact assessment.  The proponent will need to identify and address other strategies, subordinate legislation and related management or planning processes that may be relevant to the assessment of the Project. 

RESPONSE

The EIS has failed the TOR requirement to consider the Widebay Regional Plan , Draft Widebay Coastal Plan , and State Coastal Management Plan which are all State Planning Policies  relevant to the project .  

STATE COASTAL MANAGEMENT PLAN 2002 

 There is inadequate linkage to The State Coastal Management Plan 2002 ( SCMP)  and Draft Widebay Coastal Management Plan 2007( DWBCMP) policies for ‘Areas of Natural Significance” (Natural Resources) . The EIS has not shown how the project will notimpact highly protected areas (Marine parks) and existing values within the RAMSAR; o                                         

   The EIS fails to identify and list the use values (both economic and non economic) of these areas which may be effected by the project, as required by the RAMSAR Convention BMP. o                                          

  The EIS fails to identify ecological processes within highly protected areas which maybe freshwater flow dependent.  o                                           

The EIS fails to indicate how proposed EFOS will adequately mitigate for these ecological processes.  o                                           

The EIS fails to adequately identify the environmental, social and cultural relationships linking the RAMSAR values and how the WRP EFOS recognize these relationships as defined by the RAMSAR Convention BMP. o                                          

  The EIS raises the issue of water quality and the requirements of migratory Cetaceans (Humpback whales) but assumes that EFOS will adequately mitigate this, despite no current understanding of the levels of freshwater flows required for maintaining suitable WQ, for interim residences of the species.                                                                                    o                                       

     The EIS fails to demonstrate how  the project is consistent with  the purposes and objects of the Marine Parks Act 2004 , Marine Parks Regulation 2006  and , the Marine Parks ( Great Sandy) Zoning Plan 2006. Ø                  No adequate discussion of flow modification impacts on JAMBA CAMBA related avian species has been included.               

  The EIS fails to adequately address State Coastal Management Plan (SCMP) policy 2.8.3 ; b (iii) “retaining the current extent and quality of migratory and resident shorebird roosting and feeding habitat. (iv) maintaining the values and integrity of fish habitats and fish migratory pathways through suitable management measures including buffers for those habitats;  (v) protecting the values and integrity of soft bottom (benthic) communities; “  

Ø                  The EIS fails to adequately address Draft Widebay Coastal Management Plan (DWBCMP) policy 2.8.3 Coastal Biodiversity ;  Marine and Estuarine Biodiversity (including intertidal habitats) ·                     “protection of intertidal communities, including significant mangrove and shorebird habitats such as salt flats”  o                               

 The EIS fails to adequately deal with the legislated requirement of the Water Act 2000 for ecological and environmental values of the RAMSAR to be maintained under the Environmental Protection Policy ( water) (EPP 1999 ) for scheduled waters of the Great Sandy Region .  o                               

 EIS has paucity of information sufficient to determine if there will be impacts to macrobenthic communities and reductions in productivity for shorebird feeding areas within both the RAMSAR and Maroom Fish Habitat area A. o                               

 FRC paper (Appendix 6)  fails to recognize that suitable EFOS for macrobenthic and resulting trophic layering within the RAMSAR , are currently unknown    This requires scientific research ( not snapshot analysis)  to determine these requirements before project commencement (application of precautionary principle) . Insufficient information is available to demonstrate that this is the case.  The EIS needs to address SCMP  & DWBCMP policies 2.8.1, 2.8.2, 2.8.3, 

There is a need to demonstrate EFOs, trophic modelling and species life cycle conceptual models within the Mary estuary/ Northern Great Sandy Strait and Hervey Bay for:

Ø      Seagrass and subsequent trophic layers eg dugong and green turtles

Ø      Macrobenthos and subsequent trophic layers eg whiting, shorebirds in the Ramsar area, hawksbill and loggerhead turtles, dolphins including Indo-Pacific humpback dolphins

Ø      Detritus and subsequent trophic layers eg prawns, bass, barramundi, threadfin salmon, catfish, dolphins including Info-Pacific humpback dolphin Wetlands and wetland- dependent species such as water mouse.

Ø      EFOs need to be developed to determine migration cues in estuarine waters of the Mary River and great Sandy Strait

Ø      EFOs determining habitat connectivity (Robins et al) need to be developed

Ø      Trophic modelling between various benthic habitats and higher trophic layers needs to be taken into account when devising EFOs Robins et al 2007[1] recommend that ”Conceptual models of each species of interest should be used to determining at which stages of a species life-cycle freshwater flows were most likely to influence. This may be achieved using quantitative data for the biology of a species or hydrological data”. 

RESPONSE  

EIS needs to follow Robins et al’s 2007 (p182) recommended procedures for assessing the changes in Queensland’s estuarine fisheries production within the Mary River Basin and Great Sandy RAMSAR Wetland that result from water abstraction and regulation.  

ENVIRONMENTAL PROTECTION POLICY (WATER) SCHEDULE 1MARY BASIN/GREAT SANDY REGION  

The EIS fails to address High Ecological Value waterways scheduled under the EPP (water). Information supplied relating to water quality objectives is not consistent with EPA ambient water quality data and inaccurately represents water quality of the lower Mary River and Great Sandy Strait. There is a legislative requirement under the Water Act 2000 (QLD) ,  that ecological values and WQ  of HEVwaters scheduled under EPP(water)  are maintained.   Insufficient information is provided to identify impacts on High Ecological Value (HEV) waterways scheduled under EPP(water). Management intent for HEV waterways is to maintain their values and their existing water quality. If post reference condition sediment and nutrient levels are likely to be impacted, these values may be altered. 

Fluvial geomorphology assessment in EIS predicts that :the dam will reduce the amount of fine, Sediment reaching the Mary River mouth by 13-20% and the amount of coarse Sediment reaching the mouth by 3-6%” However, “these estimates do not account for changes to bank erosion rates associated with a changed hydrological regime post dam construction. There is a legislative requirement under the Water Act 2000 (QLD) ,  that ecological values and WQ  of HEVwaters scheduled under EPP(water) be  maintained.   Quantities of both fine and coarse sediment and hydraulic processes for their movement within the lower Mary estuary and Great Sandy Strait need to be maintained to ensure current sandbank, seagrass and macrobenthos distribution is maintained within the intertidal meadows.

RESPONSE 

The EIS needs to respond to the inability to maintain current sediment and nutrient levels as outlined in Appendix  F.6 (FRC) .   It is highly likely that the prioritization of water distribution will be towards human use , should current seasonal trends( low decadal inflows)  continue , this is reinforced by the current situation with Paradise Dam, where no significant environmental flows have been released, post construction and operation. 

CUMULATIVE IMPACTS  EXOTIC WATER PLANT THREAT 

Given the lessening frequency of medium-sized flows due to Traveston Dam, flow events are likely to be accompanied by substantial water hyacinth and salvinia outflows of a presently unknown mass. The impacts of decaying water hyacinth on water quality of the Ramsar area are not known. The recent unseasonal flush resulting from intense rainfall in the head waters of Six mile and Tinana creeks ( Aug 2007) , resulted in approximately 12,000 tonnes[2]  being deposited within the RAMSAR. This was a direct result of low decadal in- flows , leading to elevated growth , in stream blockages and WQ impacts. The construction of the Dam is likely to exacerbate this issue, based on the 50% MAF predictions for the upper estuary.    

The EIS has failed to identify potential cumulative impacts to the RAMSAR,The TOR expressly required that , “These impacts should be considered over time or in combination with other impacts because of the scale, intensity, duration or frequency of the impacts. In particular, the requirements of any relevant State Planning Policies, EPPs, National Environmental Protection Measures, the Mary Basin WRP and any relevant Integrated Catchment Management Plans should be addressed.” ( TOR 3.13) T

The EIS does not contain a CIA with an obvious analytical basis, the comparative ratings given , lack substantial credibility due to simplistic risk analysis. The EIS has failed the TOR requirement to consider the Widebay Regional Plan , Draft Widebay Coastal Plan , and State Coastal Management Plan which are all State Planning Policies . The absence of assessment of potential cumulative impacts ( adequate risk assessment) to the Great Sandy RAMSAR has been omitted based on an assumption that MAF will not be reduced below 85% , this submission has indicated that the assumption is flawed . It will be essential for a cumulative impacts analysis to include the effect of a reduction in MAF to 50% at the Mary Barrage.  

The cumulative impacts do not account for The Reef Plan (The Reef Water Quality Protection Plan).  Conclusions in the Executive Summary conflict with Appendix F-6 ( FRC)  and the scientific literature, Impacts on benthic macroinvertebrate communities are unable to be substantiated by current knowledge.(SCMP & DWBCMP Policy 2.8.1, 2.8.3) Studied are required on benthic macro invertebrates before statements about the acceptable levels of impact can be made. 2.22.2.3 , Benthic Macro-invertebrate Communities “Any changes to the magnitude of freshwater flows to the estuary are unlikely to affect in-benthic  invertebrates as the larger flows will change relative to natural conditions to a very minor degree.”  To date there has been no scientific assessment of fisheries productivity responses to the current flow regimes within the Mary catchment, and RAMSAR/Hervey Bay estuarine and Marine systems,   therefore this statement is unable to be substantiated.  

RESPONSE

“Wetlands: water, life, and culture”
8th Meeting of the Conference of the Contracting Parties
to the Convention on Wetlands (Ramsar, Iran, 1971)
Valencia, Spain, 18-26 November 2002
RAMSAR

Resolution VIII.9

‘Guidelines for incorporating biodiversity-related issues into environmental impact assessment legislation and/or processes and in strategic environmental assessment’ adopted by the Convention on Biological Diversity (CBD), and their relevance to the Ramsar Convention.  

1. Purpose and approach.

The environmental impact assessment process, in order to be effective, should be fully incorporated into existing legal planning processes and not be seen as an “add-on” process.

2. As a prerequisite, the definition of the term “environment” in national legislation and procedures should fully incorporate the concept of biological diversity as defined by the Convention on Biological Diversity, such that plants, animals and micro-organisms are considered at the genetic, species/community and ecosystem/habitat levels, and also in terms of ecosystem structure and function. 4. With regard to biodiversity considerations, the ecosystem approach, as described in decision V/6 of the Conference of the Parties and taking into account any further elaboration of the concept within the framework of the Convention, is an appropriate framework for the assessment of planned action and policies. In accordance with the approach, the proper temporal and spatial scales of the problems should be determined as well as the functions of biodiversity and their tangible and intangible values for humans that could be affected by the proposed project or policy, the type of adaptive mitigation measures and the need for the participation of stakeholders in decision-making.

Ramsar: In a Ramsar context, the appropriate spatial scale may sometimes be wider than the ecosystem. In particular, the river basin (water catchment) is an important spatial scale at which to address aspects of wetland-related impacts. Also, where impacts on particularly important species values, such as migratory fish or birds, are at stake, assessment at the scale of the migratory range (flyway) of the relevant populations will be very relevant. This may involve a chain of ecosystems (perhaps disjunct ones), and therefore may need to take a broader perspective than would normally be the case under the ecosystem approach.

  Given the depth of the critique above  and the lack of recognition of current RAMSAR planning requirements ( 2,3,4 ) within the EIS, in respect of the absence of adequate information and investigation of potential flow related impacts , the FRC  report  (  APP F.6) appears to be  a time constrained ‘snap shot’  , not a definitive scientific assessment .   The EIS does not attempt to scope the ‘proper spatial & temporal scale of the issue as well as the functions of biodiversity and the tangible (economic) and non tangible ( ecosystem services)  values for human  use,  that could be affected by the proposed project, the type of adaptive mitigation measures and the need for participation of stakeholders in decision making”, as required under RAMSAR conventions .    

The EIS relies on the proponents claim ( unsubstantiated)  of 85% MAF and results in a failure to meet the RAMSAR requirements for EIS, therefore the EIS gives   no definitive guarantee that impacts to the GSR will not occur.  The single recommendation of a scoping study of the potential fisheries productivity impacts in the GSR, is a recognition that a mid order trophic level (fish) may be impacted, which translates to a recognition that lower and higher order trophic layers will also be impacted,  while ignoring that all of the ecological values which underpin the regional economy may be threatened, but the projects time constraints do not allow for an independent EIS for the RAMSAR to be carried out . 

RECOMMENDATION

The serious nature of the uncertainty concerning adequate environmental flows to the receiving waters of the Great Sandy RAMSAR , the inability of the EIS to meet specific TOR issues for the RAMSAR , the neglect of Regional & State Statutory Planning Policy requirements for the protection of the RAMSAR values, and the admission that estuarine productivity may be impacted ,     must invoke the application of the Precautionary Principle.  Therefore the project should not be given approval under the EPBC 1999 S 16 A& 16 B  (RAMSAR WETLANDS ) , S 18A & 18B (listed threatened species and communities) , S 20A & 20 B (migratory species)  , due to its inability to guarantee a ‘non significant impact’ to one or more values of the Great Sandy RAMSAR .   

3.

REGIONAL ECONOMIC COSTS  

BREACH OF THE TERMS OF REFERENCE (TOR)  BY THE PROPONENT 

Page 72 of the EIS TOR expressly required that a Cost Benefit Analysis (CBA) be carried out to determine, “the significance of this Project on the local and regional economic context”,  this has clearly not occurred . The proponent has engaged the firm of Marsden Jacobs to produce a ‘least costs options analysis’ and this firm has admitted this in section 1.2 appendix F 11.2, “we focus on identifying the least-cost supply option, The exclusion of a benefit stream in the analysis means that standard decision metrics employed in cost benefit analyses, such as return on investment and benefit:cost ratios, are not applicable.”  THIS IS IN BREACH OF THE TOR  .

The report has been prepared under, “the scope of services described in the contract agreement between Marsden Jacob Associates Pty Ltd ACN 072 233 204 (MJA) and the Client. It is assumed then that the client ( QWIPL) has expressly drafted the contract to require the consultant to notperform a CBA. If so, then the proponent needs to publicly release the contract, for public transparency and determination. This process has not allowed the distribution of the costs and benefits of the project to be identified at the Widebay  (Fraser Coast) regional level , therefore the proponent is in direct breach of the TOR.   

The Marden Jacobs Report  is merely a least costs comparison. This is in fact not a cost-benefit study but a “least cost” identification procedure. The benefit side is relatively undeveloped, and deliberately so.  The consultancy firm engaged to prepare this CBA ( Marsden Jacobs )  has prepared a ‘least costs comparison analysis’ for a suite of supply options including desalination. This is clearly in breach of the TOR and a conclusion may be drawn that the Expression Of Interest ( EOI)   on behalf of the proponent , failed to indicate that a CBA identifying the stream of costs and benefits was required .

  LOST OPPORTUNITY COSTS TO THE FRASER COAST REGION 

Stage 1 of the project is to extract 70,000 mgl per annum for interbasin transfer to the Moreton catchment . This resource is to be used for urban and or industrial application , previous  economic analysis for the Paradise Dam EIS indicates that a gross marginal return of >$2000 /mgl [3]would be  expected to be produced from this application. The EIS indicates that a gross marginal return of $3485[4] is to be generated for application of this resource to the Brisbane (SEQ) region. This creates an annual benefit to that region of  $243,950,000 ,at the same time this application also creates an annual opportunity loss to the Widebay regional economy of the same order ,  ca  $244M . 

This use of this resource for the Widebay Burnett  region would also see the $244M of benefit injected into the regional economy.  The region is currently preparing a water supply strategy to meet expected growth demand, the predicted yield of 70,000mgl/yr from the project would consolidate the Fraser Coast Region’s projected annual  requirement’ s until >2050. The proponent sent an employee ( Mr Scott Smith ) to address the Regional Planning Advisory Committee ( RPAC) of regional Mayors meeting at the Kondari Resort ( Hervey Bay )  in June 2006 , to inform the Mayors of the need to produce a regional water supply strategy, after his employers had  just announced the decision to extract 70,000 mgl from the Mary River , with no prior consultation.    

The calculated annual costs for the project are incorrect; the inclusion of this opportunity loss elevates the annual costs to $328M[5] whilst creating an annual benefit of $244M.The bulk of these costs will be distributed to the WideBay region  , transversely the bulk of the benefits will be distributed to the SEQ region .

To address the issues of equitable distribution of costs and benefits from the investment of public monies , Pareto Welfare economic theory[6]suggests that those who benefit the most from use of a public good , such as water , must compensate those who carry the burden of costs . This would require a Widebay Regional compensation package to the equal value of the total annual benefit of $244M , thus the annual cost of the project to ensure that public use equity is maintained , would be $328M.   However the total annual return ( benefit) on the investment would still be $240M.

   This reveals that the project is not economically sustainable due to costs outweighing benefits at the regional scale and should be considered a very poor investment of public funds.The current scenario of extraction of the 70,000 mgl to Brisbane,   dictates that the regional economy will have restricted growth based on current requirements and the potential for reduced yields to current storages from climate change projections.  

The proponents rationale for the project is to , ensure that Brisbane has adequate supply by 2026 in case , “the worst-case reality of climate  change eventuates, and in case of increased climatic variability, such as another significant drought.”[7] 

The distribution of benefits among different sections of society and among different regions and, in particular,   the local distribution of benefits must be revealed and clarified prior to project approval.  All these issues of distribution, equity and access must be explicitly treated in public presentations.  Equity Impact Assessments (EqIAs) are imperative.

       REGIONAL ECONOMIC VALUES DERIVED FROM THE GREAT SANDY RAMSAR WETLAND 

Current economic statistics for Great Sandy RAMSAR regional economy (economic use values) . Socio-Economic Analysis

 An economic analysis, including a cost-benefit analysis to demonstrate the regional impact has not presently been made, despite being required under the EPBC Act 1999 and being included within the EIS Terms of Reference. Table 1– Estimate of value of the Great Sandy Strait RAMSAR site to the regional economy of the Fraser Coast.

Code Attribute Source of Information Economic Value(A$ per annum)
a Coral Reefs [8]Blackwell (Coastal CRC) 305 M
b Mangroves Blackwell (Coastal CRC) 93 M
c Seagrass & Algal Beds Blackwell (Coastal CRC) 418 M
d Estuaries Blackwell (Coastal CRC) 2870 M
e Saltmarsh & Saltpans Blackwell (Coastal CRC) 24 M
1 Total Ecosystem Services   3710 M
2 Tourism (Accommodation) [9]OESR 2007 30 M
3 Recreational Fishing   8 M
4 Commercial Fishing CHRISWEB 2007 (DPI&F) 58 M
  Total Regional Value    AUS $ 3.8 B

 An estimate of the value of the Great Sandy Strait RAMSAR site to the regional economy of the Fraser Coast, has been extrapolated from data within the scientific literature (with ecosystem service based on m2 area) and is presented in Table 1.

A full assessment of the impact on these economics is required in the EIS.  

RESPONSE 

The EIS fails to recognize the economic productive capability of the RAMSAR values and the regional economic dependence on them; it also fails to acknowledge the ability for the project to impact these values. The demonstrated reduction in MAF of up to 50% at the barrage does not calculate the potential for climate change impacts (reduced seasonal flows) at the regional or catchments scale , which recent research[10] has shown to be significant .  The EIS fails to identify the stream of costs and benefits and their distribution at the regional scale, to assist Local Government to determine the potential for economic growth restrictions to the region. 

RECOMMENDATION 

The proponents failure to adequately meet the TOR for economic analysis is a serious breach of best management practice for EIS at the Global scale , the distribution of wealth generated from the use of a public good ( water resource ) must be arrived at by a transparent and open process. The ‘least cost option ‘analysis produced for the proponent does not meet the requirements of the TOR . It is therefore recommended that the project is not given approval until a COST BENEFIT ANALYSIS  ( CBA)  which identifies the distribution of costs and benefits at the local and regional scale is completed as the TOR required. 

SUITABILITY OF THE PROPONENT

The EIS states “The company has employed a senior and middle management team with a wealth of experience in delivering large infrastructure projects, supported by an extensive range of specialised consultants with a wealth of experience in delivering sound environmental and technical advice for water infrastructure projects”.  WBBCC questions some of the “sound environmental and technical advice”  for the following reasons:

  • An examination of the environmental, economic and social impacts of recent water infrastructure projects managed by the directors, senior staff and major contractors of the corporation is relevant to this section of the EIS.
  • A suitable case study would be a thorough appraisal of the performance of Paradise Dam. Have the mitigation strategies in the EIS for that project been successfully implemented? Have the economic benefits outlined in the EIS been realized? Has the project complied with the environmental flow outcomes and water security provisions of the Burnett Water Resource Plan? Have the measures outlined in the Environmental Management Plans for the project been properly implemented? Are the stakeholders identified in that project happy with the outcomes? Has there been successful mitigation of adverse impacts on EPBC listed species in the Burnett catchment?  Did the economic outcomes meet predictions for the dam?

 ·         This comparison is directly relevant to the proponent of this project – the two projects share the same CEO, the same consulting firm conducting the EIS, the same corporation doing the hydrological planning and operating the storage as is contracted to do the hydrological planning for the current project. 

·         There are a number of examples from Paradise Dam where mitigation strategies used in that project have not been effectively carried out. These include: 

 ·         Water manager Sunwater has conceded that the fishway mechanism at Paradise Dam to help fish navigate the dam wall has never worked in both directions. Acting chief executive Peter Boettcher says fish are able to travel up stream but not down stream. “It”s designed to operate at between 57 per cent and 100 per cent capacity and the current level of the dam is at 15 per cent,” he said.   The height of this wall is 25.6m compared to the proposed Traveston Crossing wall height of 45m. There is a high risk that the same problem of insufficient water in the dam will apply to the Traveston Crossing Dam.  This combined with loss of prime breeding habitat for the lungfish has put this species under considerable survival risk.The EPBC Variation of Approval ( EPBC 2001/422) required Burnett Water Pty Ltd  to , “adhere to the environmental flow requirements specified in the Water Resource Plan * Burnett Basin ) 2000 and the Resource Operation Plan ( Burnett Basin) 2003 and the Burnett River Dam Flow Strategy for Lungfish dated 22 May 2003.The Burnett River Dam Flow Strategy for Lungfish has a specific ecological outcome which is recognized under the WRP , which is  , “ Water is to be managed and allocated

 –a) To maintain pool habitats , native plants and animals associated with habitats , in watercourses: and

b) to maintain long term water quality suitable for riverine and estuarine ecosystems; and

c) to provide flow regimes that favour native plants and animals associated with watercourses and riparian zones and

d) To provide wet season flow to benefit native plants and animals , including for example fish and prawns in estuaries : and

e) To improve stream flow conditions to assist the movement of fish along watercourses.

In particular  for the Burnett River Basin and Burnett River the WRP states:1)                                                     

“Water in the Burnett River is to be managed and allocated to provide for lungfish habitat in the river particularly habitat downstream of Gayndah at AMTD 200KM“Operational water release from the dam must occur In a manner that enables the Environmental Flow Objectives and Indicators specified in the WRP to be achieved. As a result , the operation of the dam will promote the proposed ecological outcomes targeted by the WRP , including for lungfish habitat”[11] 

The Queensland Environmental Protection Agency has noted in its“Final Report: Operation of the Ned Churchward Weir between 1998-2005, that  , “ the report has been prepared in response to a request from Sunwater ( the operator who subsumed Burnett Water Pty Ltd) , for confirmation that they have fulfilled the monitoring requirements as part of the agreement between the commonwealth and State governments.

The report focuses on the review of the Storage Operations Management Plan ( SOMP.)”The report indicates that , “ a major ( not minor) omission in the SOMP process has been the failure to update the SOMP in light of new scientific data , particularly in relation to lungfish and macrophyte management. This has meant that while Sunwater may have complied with the SOMP monitoring requirements, compliance itself was not achieving the biological goals for some of the SOMP elements , namely , to date there has been no successful spawning of lungfish with the Ned Churchward Weir.[12]

“The importance of providing suitable habitat for lungfish spawning and recruitment was recognized right at the inception of the Weir project, with the Administrative Arrangements requiring that investigations were to be undertaken to establish requirements for the maintenance of lungfish breeding habitat and juvenile recruitment so that these could be incorporated into the operational rules for the weir ( specifically to stabilize  water levels), there was an understanding then that operation of the Weir would be based on the results of studies subsequent to the construction of the weir and that rules would be changed to accommodate those results.While the spawning habitat requirements of lungfish have been established through subsequent studies( Brooks and Kind  2002) , the reason behind complete failure of macrophytes to establish and provide habitat  within the weir have not been addressed .As a priority the operating requirements to establish macrophytes beds need to be agreed by Sunwater with Macrophyte experts. Until appropriate spawning habitat  can be established in the Weir  and suitable stable water levels are maintained  during spawning , incubation and hatching, lungfish populations in the weir  will either fail to reproduce  or will need to travel to suitable spawning habitat in unimpounded waters.

The ability for Lungfish to successfully travel upstream to unimpounded waters is compounded by the operators admission that the Burnett Dam  Fishway can only operate during times of high flow and greater than 57% storage. The Burnett River Dam has only ever achieved 31 % [13]capacity since commencement of operation.2.1.2 OUTSTANDING ISSUESThe following issues have not been resolved over the life of the SOMP nor will they be resolved under current arrangements within the ROP

(a)                                                   No lungfish spawning or recruitment within the Ned Churchward Weir to date due to; (b)                                                   Insufficient establishment of suitable macrophyte beds for lungfish spawning and recruitment(c)                                                   lack of suitable substrate : and (d) Egg mortality if spawning did occur[14]

This   report gives a reasonable insight into the inability of the resource operator ( Sunwater) to implement the Burnett River Dam Flow Strategy for Lungfish May 2003with particular reference to special ecological outcomes of the WRP (a) –(e) and (1)  

The  failure on behalf of the operator ( Sunwater) to implement agreed water level stability management is , a demonstration of  non compliance with the policy intent of the Lungfish Flow Strategy  and  it can successfully  be argued as a non compliance of the EPBC Variation of Approval ( EPBC 2001/422) to , “adhere to the environmental flow requirements specified in the Water Resource Plan * Burnett Basin ) 2000 and the Resource Operation Plan ( Burnett Basin) 2003 and the Burnett River Dam Flow Strategy for Lungfish dated 22 May 2003.[15] 

It is therefore requested that the Federal Minister for the Environment take this in to account under S 137 of the EPBC 1999, Person’s environmental history(4)

In deciding whether or not to approve the taking of an action by a person,( proponent)  and what conditions to attach to an approval, the Minister may consider whether the person ( proponent) is a suitable person to be granted an approval, having regard to the person’s (proponents) history in relation to environmental matters”, in respect of any decisions regarding approval for Traveston Dam.

A formal request was made in June 2007 to the Federal Minister for the Environment by WBBCC, STMRG and MRCCA for a DEH audit to be carried out on aspects of mitigation and the proponent’s performance in implementing the conditions of approval for Lungfish protection in the Burnett River.

To date, there has been no public release of the findings of this audit despite the proponents having possession of the document for the past 3 months.The findings of this report would assist in clarifying the performance of the proponents.  

Ø      We therefore recommend that the Federal Minister for the Environment consider this documented neglect of the proponent for adequate mitigation of MNES, as a   failing to meet its approval of conditions under the variation.

Ø      That the Minister not give approval for the Traveston Dam Project until such time as the proponent has demonstrated successful mitigation and implementation of the conditions of approval for the variation. 

Ø      The findings of the recent federal audit of Paradise Dam be used as evidence that the Proponent needs more environmental or technical advice to assess all the environmental impacts or provide evidence of efficient mitigation strategies.

  

Roger M Currie Bc Sc UQ Protected Area Management

Water Policy Officer

For and on behalf of WideBay Burnett Conservation Council Inc

11 Jan 2008


[1] Environmental flows for sub-tropical estuaries: understanding the freshwater needs of estuaries for sustainablefi sheries production and assessing the impacts of water regulation Compiled by Ian Halliday and Julie RobinsFinal Report FRDC Project No. 2001/022 Coastal Zone Project FH3/AF QDPIF 2007. 

[2]MRCCC Teddington Weir Aquatic Weed Management Strategy 2007.

[3]Qld Govt NECG 2000 report for Paradise Dam CBA .

[4] Executive summary table 1 ( $244M / 70,000MGL )

[5] Includes direct agricultural , commercial /recreational fisheries, tourism losses , urban use opportunity cost , treatment & pumping to Brisbane, mitigation and operational costs .

[6] Paretian Welfare Theory: Some Neglected Aspects
Vincent J. Tarascio The Journal of Political Economy, Vol. 77, No. 1 (Jan. – Feb., 1969), pp. 1-20

[7] Executive summary 1.1. rationale.

[8] Blackwell, B. (2007) A preliminary estimate of the eco-services of some of Australia’s natural coastal assets. Coastal Cooperative Research Centre (CRC).
 

[9]Office of Statistical Research QLD 2007.

[10] Modelling of streamflow reduction due to climate changein Western Australia – A case study1Bari, M.A., 1Berti, M.L., 2Charles, S.P., 1Hauck. E.J. and 1M. Pearcey1 Department of Environment, PO Box 6740, Hay Street East, East Perth, W.A. 6892, Australia,E-Mail: mohammed.bari@environment.wa.gov.au2 CSIRO Land and Water, Private Bag Number 5, Wembley, W.A. 6913, Australia  

[11]Burnet River Dam Flow Strategy for Lungfish

Burnett Water Pty Ltd May 2003 , Introduction , pp 1

[12]QEPA 2007 Final Report: Operation of the Ned Churchward Weir between 1998-2005, Executive Summary , pp2 .

[14] Final Report: Operation of the Ned Churchward Weir between 1998-2005, PP 32.

[15]EPBC 1999 Variation of approval for Burnett River Dam ( EPBC 2001/422)

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