Background Briefing on Northern Interconnector Pipeline Stage 1
1 Comment
Steve Burgess
MRCCC Waterwatch Officer
steve@mrccc.org.au
5482 4766
wurraglen@gmail.com
5484 3749
1/05/07
Time line
1. On 22/03/07 Stage 1 of the Northern Interconnector Pipeline (Landers Chute to Morayfield) was referred to the Federal DEW for a decision as to whether the project required EPBC assessment.
The Federal referral document and assessment decision can be downloaded here
2. On 14/04/07, the project was declared a significant project under the State Development and Public works Organization Act and an Initial Advice Statement and a draft Terms of Reference for an EIS under the State Development Act was released for public comment. Submissions close on 14/05/07.
General info from the CG department can be found here
The IAS can be downloaded here
The Terms of Reference for the EIS can be downloaded here
3. On 19/04/07, the Federal DEW decided that an assessment under the EPBC act would not be required. Apparently, no submissions requesting an assessment under the EPBC act were received.
Some important points from an initial scan of these documents.
The EIS and the federal referral only apply to Stage 1 of the project. (Landers Chute to Morayfield) Stage 2 (Connecting Lake McDonald) will be announced soon.
The proposal refers to the purpose of sending 65ML/day of ‘unallocated water’ down the pipeline from Maroochy and Caloundra Shires to Brisbane. (This is 23.74 GL/year).
The proposal states that much larger pipes (1290 mm diameter) are being used in some parts of the project to allow for another possible “future purpose” (this may be code for the transfer of Traveston Crossing water to Brisbane – pipes of this diameter would be appropriate for this purpose , but complete overkill for transferring 65ML/day).
Although the 23.74 GL/annum of water for this pipeline must come from sources within the Mary Basin Water Resource Plan area, I found no reference to the plan, or to the effects of this additional extraction on the watercourses of the Mary Basin. Particularly with respect to the referral to the Federal Government, it would be unlikely that anyone reading the documents would be aware that the project entails the removal of at least an additional 23.74 GL/annum of water from the Mary Basin, or be aware of the likely consequences of this extraction on Matters of National Environmental Significance under the EPBC act.
Most of the water being extracted will most likely come from currently unused Town Water allocations from Baroon Pocket Dam on Obi Obi Creek. (Total TWS allocations from Baroon Pocket are about 36GL/year, of which only about 18.5 are currently used by Caloundra and Maroochy Shires).
Extra information may be obtained from the proponent’s website www.srwpalliance.com.au
Some points from knowledge about the Mary Basin WRP, and studies done on the Mary Catchment.
IQQM modelling studies of the catchment conducted as part of the WRP show unequivocally that taking the full allocation out of Baroon Pocket Dam would have dire consequences for Obi Obi creek from the dam wall to the junction with the Mary. Long-term median flows would be reduced to less than half of the median flows in the current utilization scenario and there would be significant adverse impacts across all flow regimes. The APFD for the stream would be much greater than 2 along the entire length downstream of the dam.
There is no protection of environmental flows in Obi Obi Creek written into the WRP or into the iROL for the operation of Baroon Pocket dam.
Obi Obi creek is one of the most significant Mary River Cod habitats in the entire Mary system. Mary River Cod are a critically endangered EPBC species with a federally listed recovery plan under the act.
Obi Obi creek is also an important habitat for a number of federally listed EBPC species of stream frogs.
A number of State Government-funded Reports (Mary River Stream Processes Report, Mary Rehabilitation Plan, Obi Obi rehabilitation report, WRP hydrological modelling report) outline the severe consequences of taking the full allocation of water from Obi Obi creek.
It appears that the strategic reserve of 150GL/year referred to in the Mary Basin WRP is very vaguely defined and advice from NRW is that it can be taken from any part of the Mary Basin for any project identified as part of the SEQRWSS (eg. this pipeline). If stage 1 Traveston Crossing is only taking 70 to 80 GL/year, this leaves 70 to 80 that can be taken at whim from any watercourse in the plan area that SEQ can connect the pipe to (on top of existing allocations). This has worrying implications for the Maroochy , Mooloolah and Mary Rivers and especially Obi Obi and Six Mile Creeks – all of which can be accessed by this Northern Pipeline Interconnector in Stage 2.
There is very little effective protection of environmental flows in upstream reaches of these watercourses in the schedules in the WRP.
Confirmation that the ultimate intent of this pipe is to carry the Traveston Crossing water to Brisbane can be found in Caboolture Shire meeting minutes.
Suggested Course of Action
As many groups as possible with an interest in the Upper Mary, Obi, Maroochy and Mooloolah catchments familiarise themselves with the implications of this proposal, and co-operate in writing submissions on the TOR for the EIS. (DEADLINE is 14th MAY)
As many groups as possible formulate a case to present to the Federal DEW assessor (Alex Rankin) to reconsider her decision in light of the clear implications the project has for EPBC listed species (particularly the cod) on the grounds that the proponent did not provide any advice at all as to the likely implications of the project on stream flows and subsequent impacts on EPBC matters in the Mary. From the information submitted by the proponent it would have been impossible for the assessor to have any idea of the impact on these EPBC matters.
Start negotiations/lobbying as appropriate to have appropriate environmental flows provisions written into the operating rules for Baroon Pocket Dam, Lake McDonald and Borumba Dam. (in order of priority)
Monitor federal EPBC website for signs of Stage 2 referral and start preparing case for the protection of Six Mile Creek
stevem
Time running out for water pipeline plan comment
Thursday, 3 May 2007.
Residents of the Sunshine and Cooloola coasts have less than two weeks left to comment on a proposed water pipeline that will take water from the region to Brisbane.
The northern pipeline interconnector involves the construction of two new pipelines near Baroon Pocket Dam and Lake MacDonald.
Steve Burgess from the Save the Mary River Coordinating Group says the group is concerned the pipeline will impact on species of national significance like the Mary River cod.
“It’s already been referred to the Federal Government and the Federal Government has already passed a decision that it will not need to assess it under the federal EPBC [Environment Protection and Biodiversity Conservation] Act,” Mr Burgess said.
“We will be approaching the federal Department of Environment and Water to actually reconsider that decision because we don’t think they were given the full amount of information on what the impacts would be on federal issues.”
Submissions close on Monday, May 14.
stevem
Reconsideration by the Minister for Environment and Water Resources Regarding the EPBC Status of the NPI Project
Here is a summary of advice received by the STMR from the Commonwealth Department of Environment and Water:
Quote:
On 21 March 2007, a referral was received by the Department of Environment and Water Resources to construct the Northern Pipeline Interconnector from the Landers Shute Water Treatment Plant to the Morayfield Reservoir.
On 19 April 2007, the proposed action was determined to be not a controlled action under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act). This decision determined that the project does not require assessment and approval by the Minister for the Environment and Water Resources before it can proceed.
This Department has since received two submissions, including yours, requesting the Minister for Environment and Water Resources to reconsider his decision under Section 78 (1) of the EPBC Act.
Your request is currently being considered and, in line with the requirements of the EPBC Act a response to your request is being sought from the proponent for the proposed action and the relevant State Ministers. In addition, under the EPBC Act the Department is required to publish your request for reconsideration on the Department’s website for public comment for a period of ten business days. Both submissions may be viewed at www.environment.gov.au/epbc/. The period for public comment closes on 4 June 2007.
After the closing date, the Minister will make a decision on whether to confirm the original decision that the proposed action is not a controlled action, or to revoke the original decision and substitute a new decision for it. The Minister’s power to vary a decision is is set out in Section 78 of the EPBC Act.
(Comments by Darren Edward) So basically there is a 10 day period, closing 4th June 2007, for public comment on the proposed Northern Pipeline Interconnector, which initially will be taking water from the Mary system via the Obi Obi creek, but which is being designed with sufficent capacity to also take the water from Traveston Crossing Dam.
The Qld government snuck their original proposal past the Federal department by failing to mention that the proposed pipeline would be taking water from the Mary catchment, or any of the matters of environmental significance (such as the Mary River cod habitats) which would be affected.
Based on new information the federal department has decided to re-assess their position. Please tell them what you think.
Background info and links on the project were previously posted on the forum at:
The direct link to the Federal DEW website, which includes copies of the submissions requesting reconsideration.
Some groups and individuals also made submissions to the Qld Coordinator General’s office regarding the draft Terms of Reference for the EIS. These have not yet been published on the CG website, but keep your eyes on:
stevem
Here is a link to the Southern Regional Water Pipeline Alliance website, where you can download the IAS, and also a copy of the completed EIS for stage 1.
Here is the direct link to the IAS.
The project has been referred to the federal department of the environment, to assess whether it will require approval under the EPBC act. Remember, they decided stage 1 did not require federal approval.
The referral is currently open for public comment. However, there are only 5 days left (invitation for public comment ends on the 19th September 2007)
Here is a link to the DEH website where you can download the referral document.
Here is a direct link to the referral.
stevem
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Reader Comments (1)
"an impact which is important, notable, or of consequence, having regard to its context or intensity ( bleeding the Great Sandy Ramsar of its natural flow regimes ) . Whether or not an action is likely to have a significant impact depends ,upon the sensitivity, value, and quality of the environment which is impacted, and upon the intensity, duration, magnitude and geographic extent of the impacts. You ( Dr Mark Breitfuss & Mr Peter Macnanoman) should consider all of these factors when determining whether an action is likely to have a significant impact on matters of national environmental significance" .
Yes they did consider this , but came to the same conclusion for both stages , that in their opinion , the RAMSAR is unlikley to be significantley impacted, why is this so? because they argue that " the alliance is not responsible for the 'action' of and 'operation of', the pipeline , which is sucking water from the Mary river which is hydrologically and hydraulically linked to the RAMSAR
>> When is a significant impact likely?
“To be ‘likely’, it is not necessary for a significant impact to have a greater than 50% chance of happening; it is sufficient if a significant impact on the environment is a real or not remote chance or possibility.
If there is scientific uncertainty about the impacts of your action and potential impacts are serious or irreversible, the precautionary principle is applicable. Accordingly, a lack of scientific certainty about the potential impacts of an action will not itself justify a decision that the action is not likely to have a significant impact on the environment.”
They have given no scientific certainty or justification that a 'significant impact' is unlikley to occur , so they have ignored the precautionary principle. But it could be argued they have applied the Bligh goverments precautionary principle which is , " if you think there is a way to squirm out of applying the precautionary priniciple , just ignore the obvious and squirm.