Response to Supplementary EIS Chapters 18-20

[Glenda Pickersgill]

Overall rationale relating to Matters of National Environmental Significance (MNES):
Australia has ratified UN Convention on Biological Diversity (CBD) which includes a commitment to promote the recovery of threatened species.

The Mary River has numerous threatened species on national and international registers (IUCN Red List) including local and regional endemics

A large dam in the middle of this critical habitat area WILL NOT contribute to the recovery of these species, irrespective of the ‘spin’ created by the proponents of the dam and their largely untried mitigation measures.

The supplementary EIS reconfirms the great importance of the area for threatened species of plants and animals, including remarkable endemic species that occur no where else on earth.

It adds several more threatened species to the list for the area.

It acknowledges the appalling lack of data: “We do not have basic population and life history information for most species, and this is certainly the case for the suite of threatened species recorded from the study area” (Ch. 18, p 18-20)

Yet there are very few additional field studies since the original EIS, other than a few ‘site visits’ and additional literature searches.

The supplementary EIS acknowledges the project will cause loss of habitat for threatened and migratory species. It acknowledges the dam will fragment populations of threatened species Eg. for the Southern Barred Frog: “Therefore, the distribution of this species in the Mary River catchment is not expected to retract, although the loss of habitat may lead to a decline in species abundance and fragmentation of populations within lowland areas.”

It takes a very restricted approach to the likely area and scale of impact of the dam during both construction and operation on threatened species

There is considerable ‘cherry-picking’ of information to make the best possible case for the dam to proceed and to avoid doing the necessary field and analytical studies .

No Population Viability Analyses (PVA) or Population and Habitat Viability Assessments (PHVA) for endemic and/or threatened species or habitats– the excuse given is the lack of data and problems with reliability of some PVAs, but these are not valid excuses providing sufficient time and effort are made to adequately assess risks to threatened species. Such time and effort are actually required in the ToR.

The extent of baseline and predictive studies should be commensurate to risks which must include risks of extinction to threatened endemic species.

The EIS is clearly incomplete without such analyses. This is a major flaw which is not remedied by the claim that: “Qualitative forms of assessment (such as expert assessment) are reasonable alternatives.”
‘
Smart State’? Not evident in this EIS which has avoided World’s Best Practice methods (eg. PVA), made excuses about ‘lack of data’ and provided a range of largely untried, unproven or unsuccessful proposals re ‘mitigation’

There are acknowledgments that: “Without mitigation the dam wall and inundation area will prevent any natural upstream movement of fauna. Limited successful downstream movement would occur during overtopping as this is a time of likely physical damage to individuals.”

There are proposals of various mitigation strategies and ‘environmental offsets’ to fix any and all environmental impacts. But many of the proposed mitigation strategies are untried, unproven or have failed elsewhere (eg. artificial breeding – husbandry, turtle ramp, fish ladders for lung-fish, etc. etc.)

To establish and maintain the proposed mitigation strategies would require a veritable army of people, solely focused on mitigation, monitoring and research – yet no estimates of manpower and cost are produced but to do what is proposed would tally in the millions of dollars per year
And given the poor performance of some other such mitigation projects elsewhere, this is highly unlikely to occur, despite the best intentions and wishful thinking of those preparing the EIS

QWI and the EIS team have taken it on themselves to act as the decision-makers in terms of assessing levels of risk in the absence of any EIS studies whatsoever (eg. “In the case of estuarine environments or the Great Sandy Strait for example, the risk posed by hydrological, water quality or sediment change was deemed to be very low, so no field studies were deemed necessary.”

Who / what experience in all this does QWI really have?
The EIS is similarly full of assurances in respect of the ability of the dam to meet supply demand and maintain environmental flows, whilst admitting that climate is changing fast.

Similarly there are numerous assertions as to the ability to maintain good water quality and control weeds, the latter recommending ‘prevention’, a highly uncertain long-term outcome given the prevalence of weeds in many other QLD water storages.

Remarkably, QWI claim that the construction of a research centre will offer certainty of the survival of the threatened species in the wild. This claim cannot be justified.

In all of the above, the optimistic conclusions of the EIS appear based on an ‘ideal world’ where water levels and quality will remain within manageable levels, invasive aquatic weeds will be prevented or successfully ‘controlled’, ‘good’ macrophytes will flourish, lungfish will happily breed and make good use of the ladder to visit their relatives.
Turtles will happily negotiate their purpose-built ramp and breed in the new nesting banks so thoughtfully provided, full-time dedicated researchers will develop more eco-friendly approaches to dam function etc. etc.

All this can lull the casual reader into a ‘false sense of security’. Clearly the dam proponents subscribe to the ‘My dam is half-full’ group of optimists, whereas a critical review by a realist can equally conclude that ‘Your dam is actually half empty’ or worse (like other water storages in SE QLD).

In reality, little if any of this rosy future for threatened species may actually eventuate, and the best indication of the reality is to examine the situation at Paradise Dam, the previous major dam constructed by the QLD Govt. and involving some of the same team as involved in the present proposal.

Is QWI capable and competent to actually do what they claim?
Paradise Dam is reported to have major ongoing unforseen problems re water management, provision of environmental flows and management of species.

The upstream fishlift has only worked a few times and reports on its efficiency have not been made public. Although a lift may operate, there has to be suitable conditions for species to live and breed above and below the dam wall. Similarly the downstream fishlock has still to be operated and monitored because of insufficient water in the dam and the salvinia that covers the entrance.

The above concerns all point to a major problem with the entire EIS process in respect of the need for clear independence and objectivity between those conducting and preparing the EIS, the proponents of the project and the assessors.

To date all aspects have fallen within the control of the QLD Govt. who are clearly determined that the dam will proceed, come what may.
The EIS was prepared by consultants in the direct employ of the proponents of the project (QWI on behalf of QLD Govt.) and has been assessed by another branch of the QLD Govt. (Coordinator-General)

It is crucial that the Federal Govt. are not fooled by the spin and actually provide a thorough independent and realistic assessment in respect of the EPBC Act and MNES, in light of this flawed approach and in respect of Australia’s national and international obligations under the UN Convention on Biological Diversity, specifically to promote the recovery of threatened species.

By definition, these species are already under severe population depletion / extinction pressure and Australia has committed through ratifying the CBD to promoting their recovery.

The EIS does not provide confidence that this can be achieved. To the contrary, the deliberate destruction of critical habitat and major modifications to flow regime, among numerous other impacts, will, on the balance of evidence, result in major (unquantified, no PVA) declines of the threatened species, directly contrary to Australia’s national and international obligations.

Be interested in hearing what others have found in this section.