Ocober 16th 2000
BREC Comments on the
POWERLINK E.I.A.R. GREENBANK TO MANSFIELD AND NERANG
The Brisbane Region Environment Council (BREC) rejects the current proposals from Powerlink on the basis that
The role of these easements in fragmenting major bushland areas is a major threat to regional and sub regional wildlife populations.
Major groups and the general public have been either not consultated or barely consulted with, by Powerlink
It alignment being coincident with major bushland areas and waterways corridors ensures that this proposal will work against biodiversity conservation principles. The waterways corridors contain at least one endangered regional ecosystems under the Qld Vegetation Management Act.
The alignment is coincident with areas identified as critical or broad nature conservation under the RFGM. It is also identified as either Regionally or Sub Regionally significant in the Draft SEQ Nature Conservation Strategy. Finally the areas are also identified as being part of the citywide greenspace system under the Brisbane City Plan.
The existing impacts of power easements are so severe in Belmont Hills, Kuraby, Karawatha and other places such as wildlife electrocutions, fire, weed invasions, erosion and vehicle access cost both the BCC and the wider community millions of dollars and thousands of hours of voluntary work in managing the impacts.
1. The EIS be redone taking into account new decentralised power generation systems and the necessity of redesigning the route of past and present transmission lines to:
2. Public Involvement processes need to be redesigned and redone in consultation with major stakeholders and Traditional Owners and Native Title Claimants.
3. The current proposal should be rejected and redesigned in the light of proper public consultations.
4. BREC endorses the submissions made by the B4C and endorses the points raised below by our Field Officer Dave Gasteen and by Ted Fensom President Southern Region Alliance
Yours for nature
Michael Petter Coordinator BREC
RESPONSE By Ted Fensom Southern Region Alliance
POWERLINK E.I.A.R. GREENBANK TO MANSFIELD AND NERANG
Powerlink have designed, among other things, to duplicate a powerline east of the existing 275 KVA power line from Illaweena Street Drewvale to Wecker Road Mansfield (referred to as Belmont) The proposed easement alignment severs and traverses a number of parks, remnant natural areas, other bushlands and waterway corridors within BCC. The proposal also further severs Brisbane City Councils major National Estate listed natural area known as Karawatha Forest. The State Lands at Kuraby are also involved. The largely unassessed Wally Tate Park is deleteriously affected. The proposed alignment is contained within existing vacant easements. Some substantial relocations and new easements are proposed in the upper Bulimba Creek area by Community Groups as alternatives.
The potential widening of this existing alignment by another 55 to 80 metres (pers comm Wayne Hickey Powerlink) and widened consolidation potentially facilitates the creation of a multimodal corridor for surface based and underground utilities and other infrastructure, from Drewvale to Belmont and beyond . This is contrary to the normative urban and regional planning processes in South East Queensland, Examining current air photo imagery, cityplan maps and Green Space Areas Map A in the Cityplan the strategic loss of further vegetated greenspace land in upper Bulimba Creek and environs is not acceptable. This predetermined outcome challenges the credibility and functionality of 3 levels of Planning Processes
A previous EIA or EIAs (may have been unavailable in 1985) was/were prepared for this project. The particular document for Bulimba Creek is not mentioned by name. It may be the undisclosed legal basis and framework for this EIAR.
AIMS OF EIA PROCESSES
The document should address scoping and Terms of Reference, should formally justify the need for the project and examine alternatives including route and modal alternatives, and address items of scale, spatial position and impacts.
Other items of adequate and effective consultation, changes, draft and final documents, and independent review are items generally neglected in Qld.
GENERAL PROCEDURAL ITEMS
The tick off by the Coordinator General or his replacement to avoid the need of a new T.O.R. and E.I.S. process, 15 years on, is not apparently documented.
The names of the reports recently undertaken by Powerlink in relation to need, for the 275KVA line were not named or otherwise referenced.
The alternatives of cogeneration, demand management and solar alternatives or other
Specific energy replacements sited within the down catchment/substation networks are not apparent in the report. Three other cogeneration plants in the Gateway Ports have not been mentioned as energy resource alternatives
The Need justification is mentioned in the Executive Summary, p.ix, Chpt. 2 Project Justification p10 and Appendix J MUNRUBEN AREA Technical Report item 4 "MUST HAVE" OUTCOMES FOR POWERLINK p.3 The crux appears to be a necessary loop circuit to the west, reserve capacity in case of other failure, and thirdly future demand.
It appears E.S.D. outcomes are not possible under this EIAR process as economic lowest cost alternatives(National Competition Policy). The Electricity Act and National Electricity Code (not in Appendices) do not have a balancing process against environmental impacts or social impacts, as seen in the Integrated Planning Act 1997.
Lack of suitable E.S.D outcomes or route relocation alternatives for RAGGAT & GAP
Organisations are evidence of this imbalance.
The population data appears outdated and limited in the Appendix J Community profile section and also at page 10. Further the data does not appear to be predicated against current BCC Cityplan population projections, the lower SEQRFGM2001 population projection updates, current low net migration figures for Sold or Port Industry energy demand reports, Government listed Industry Projects, and listed General Industry land availability. Consequently the calibration of a household and industrial energy needs equation is not evident. While the limited evidence provided may be factual, the methodology should be subject to scientific scrutiny. The statistical needs data has not been scoped against three levels of population projections. The tabular and graphical representations of derived future electricity demand needs have not been convincingly put and should be placed in a public reviewed Addendum volume.
The transmission line will cut and traverse several waterway corridors. BCC has had
only a Waterways Strategy, a waterways program, some Desired Environmental Outcomes and a code to protect most of Brisbanes waterways, as opposed to dedicated town planning policies, comprehensive floodlines and floodplain policies, endorsed Strategies, and comprehensive protection and enhancement codes and comprehensive DEOs across all areas(zones and tenures).
BCC is currently mapping Waterways as well as undertaking a belated Vegetation Mapping program to bring it in line with Sattler and Williams(1999)and the Vegetation Management Act 2000.
These maps should provide more appropriate regional ecosystem evaluation than the EIAR . Field Examination defines more sites with Endangered Regional Ecosystems.
The BCC Greenspace Strategy supposedly provides for the preservation and regeneration of riparian vegetation and a number of waterway corridor functions.
Under Appendix 2 of the CITYPLAN, Sites of Citywide Natural Significance, only the State land at Kuraby is listed. Karawatha is the only Natural Area in BCC to have a specific Environmental Management Plan as a Planning Scheme Policy. Karrawatha is now a frog site of National Significance (Dr Marc Hero Gold Coast Campus Griffith University)
In order to assess this infrastructure proposal, more thorough investigations of the requirements of new legislation such as the Vegetation Management Act 2000, the Water Act 2000(see translation of Quaid amendments protecting vegetation in the bed and banks), any Memoranda of Understanding and the recently "gazetted " BCC Cityplan are warranted.
EIAR fails to satisfactorily describe the functions of vegetation, fauna habitat, ecological processes on the new alignment and within its immediate environs.
The EIAR is deficient in many areas. The EIAR study of individual vegetation species, desktop fauna observations and ecological associations does not adequately describe : waterway corridors and land units generally, Endangered Regional Ecosystems (enacted 15.9.2000) ,wider fauna habitat distribution and functioning Ecological Processes in an up to date applied manner within Brisbane City in the E Sector Maps.
The EIAR clearly has not adequately described what the real impacts will be in terms of
CONSTRUCTION AND MAINTENANCE
The EIAR mitigation strategies are limited against principles of no net loss of vegetation or biomass, or severance of Koala habitat and other niche fauna habitat.
The EIAR has not discussed the proposal in terms of its potential for accumulative impact and offsite environmental impact upon BCCs vanishing Green Space System,
In this case applying to the narrow green avenue of Bulimba Creek.
The construction and maintenance impact may potentially be the visibly largest and longest impact. Soil transportation through accidents and erosion will enter the waterways and reach Brisbane River and Morton Bay.
Other construction impacts, which have not been adequately addressed, include:
The Environmental Protection Act is not apparent. The bunding of Tower sites, revegetation and rehabilitation of sites during and once construction has ceased has not been adequately addressed.
Little attention has been given to working in sensitive environments such as Karawatha, Kuraby not only related to on-site impacts (eg significant plant removal), but also off-site impacts in terms of impacts to waterways alongside the easement.
Consultation with key conservation groups is not well documented. B4C BREC, QCC & WPSQ
Bulimba Creek Catchment Coordinating Committee (B4C) is an umbrella organisation,
servicing a dozen other groups whom in partnership with other stakeholders and parties (eg. Land owners, BCC, Conservation, Bushcare groups) works to manage and improve the health of the Bulimba Creek catchment landscape and waterways.
The EIAR clearly needs to describe what the likely impacts in these areas will be (eg. Permanent vegetation removal, permanent severance, gross and net loss of vegetation and biomes) or what mitigation strategies are proposed (eg. Planned regeneration of dwarf species compatible with local habitat needs and location within power easement).
THE BULIMBA CREEK CATCHMENT
B4C would like to express their dismay at the process of the Powerlink EIAR undertaken by PPK.
The lack of independent mediation and lack of equity is demonstrated by the process of route selection, without appropriate full and appropriate consultation process, as evidenced in the report.
The Process still places the easements either perilously close to Bulimba Creek ,or in the Creek and in several remnant natural areas and in multipurpose parklands.
Comments by Powerlink representatives suggest that route easements have been planned for 10-15 years. However this information has not been necessarily available on published maps for either public or community conservation groups until the "public consultation process", and report release.
Various groups could not obtain reasonable cadastral maps for the Route location from Powerlink and were told to get a Street Directory. Parts of the creek contain ambulatory boundaries and have been altered by construction and will have to be resurveyed. This lack of maps made it extremely difficult for field assessment in BCC, and a waste of resources elsewhere in Logan City and Beaudesert Shire
The many linear "park" corridors are now targeted for the construction of new towers and proposed lines through remnant forests and wetlands, which form viable nodes of
Many of these bushland remnants and substantial regrowth areas occur along creek margins and wetland areas that have been difficult to retain because of Powerlinks apparent design preference for creek margins and wetlands. The proposed Easements directly threaten and will destroy dominant and subdominant Regionally Endangered Ecosystems, containing broad communities of blue gum, ironbark and paperbark. These ecosystems are prevalent on and adjoining drainage lines of Bulimba Creek, its tributaries and its floodplain.
We recommend that there is an immediate halt to these plans for parallel easement construction in Bulimba Creek , in favour of route selection in disturbed areas, such as the Gateway Arterial and other road alignments ,quarried areas, and industrial land
This is line with" BCCs High Level strategic aim to restore riparian vegetation and protect waterway functions"
Frequently when options are suggested to Powerlink representatives, they relate engineering problems that will not allow movement of the route, despite existing precedent sharp bends constructed nearby and elsewhere.
The sitting of Towers on dubious soils in the floodplain is treated with great incredulity by Conservation groups.
Private property renegotiations over degraded lands and Motorways were thrown up as an impenetrable barriers to route relocation at the expense of destruction of Old Growth Value Forest and retention of Endangered Regional Ecosystems.
Local Authority viewpoints if obtainable do not adequately reflect wider public interests.
SPECIFIC SITE ANALYSIS
This is most notable north of Holmead Road and the mobile village, where the transmission lines suddenly and deliberately target the Bulimba Creek remnants linked to Boyanda Street wetlands, Boorabin Picnic Grounds and Broadwater Picnic Ground.
The route selected will but significantly contribute to the loss of ecological values, and processes including loss of breeding sites and habitats, fragmented edge effects of tracks, weeds, fires, but also has no regard for the welfare or sustainability of wildlife, ecological processes and broader conservation issues
Some of the specific major impacts associated with the construction and placement of transmission towers and lines through remnant forests and bushland includes
A Composite of Vegetation Maps of sections of the proposed route ,clearly indicate that several threatened ecosystems will be cleared and become highly disturbed, with dire long-term ecological consequences. This is another example of the failure of the legislative and administrative process to push ahead with the project, despite warnings and protestations from disaffected sections of public.
Comments for B4C, BREC and Ted Fensom on Powerlink & the Environmental Impact Assessment Review & Mgt Plans (PPK)
Written by David Gasteen September/October 2000
These comments are based upon field surveys of sections of the proposed route for B4C in the Bulimba Creek easements, including Rosicrucian land (off Wembly Road) with Powerlink representatives, and consultants from PPK. This includes both a review of report and the revealing series of maps in Appendix E - Land Use Zonings.
Powerlink propose to duplicate the existing 275 kV power line from Drewvale to Mansfield, which will place the easement perilously close to Bulimba Creek and several remnant natural areas in BCC parks and jurisdiction. These include BCC National Estate area of Karawatha Forest, adjoining Kuraby forest, and wetlands in Wally Tate Park.
Case for Objection
The report does not adequately address the consequences of construction upon the different varieties of ecosystems, from sandstone ridgelines in the upper Bulimba Creek catchment, including Karawatha and Kuraby.
By recommending these routes that will cause further forest fragmentation, this company clearly has no responsibility for the consequences of their actions by not fencing and securing these areas; and exposing them to fire threats and other degrading factors.
B4C would like to express their anger and frustration at the Powerlink EIAR by PPK, and also the arrogance demonstrated by the process of route selection, without a full and appropriate consultation process, as reflected by the feedback and comments expressed in the report.
The EIAR also fails to adequately address the likely impact of vegetation removal on habitats or any planned regeneration or rehabilitation strategies, and does not acknowledge BCC aims to restore and enhance riparian ecosystems.
Comments by Powerlink representatives suggest that route easements have been planned for 10-15 years, but not available for either public or community conservation groups until the "public consultation process", and report release.
In a cynical exercise, many linear "park" corridors are now targeted for the construction of new towers and lines through remnant forests and wetlands.
Despite the vast array of BCC parks and bushland remnants that are going to be severely impacted upon by Powerlink, it appears that BCC waterways may raise concerns, but one wonders if this is the consensus of planning and development, or the hierarchy who make the ultimate decisions.
Because of Powerlinks preference for creek margins and wetlands, they directly threaten Regionally Endangered Ecosystems, dominated by blue gum, ironbark and paperbark. These ecosystems are dominant adjoining drainage lines, such as Bulimba Creek, its floodplain and in the broader catchment.
The question remains why Powerlink have a set and inflexible policy that is not in accord with environmental best practice, and deliberately targeted for these massive towers, despite more preferable, alternative route options.
We recommend that there is an immediate halt to these plans for parallel easement construction, in favour of already disturbed areas, such as road alignments and fence lines.
The Brisbane City Officials have made some very pertinent points regarding the EIAR, including acknowledgement of Bulimba Creek Catchment Coordinating Committee (B4C) and other stakeholders, and their efforts to save and protect urban bushland adjoining creeks and wetlands.
They also noted the lack of adequate consultation process by many of these groups, probably the result of having more of "them" than "us", with the express outcome of validating their infrastructure planning construction through forests.
When alternative options have been suggested to Powerlink representatives, they frequently defer to engineering problems which prevent movement of the route, including tight corners, unusual bends, private property issues and local councils. However, an examination of the proposed route clearly indicates that the planners do not consider these as constraints.
This is most notable north of Holmead Road, where the transmission line and easement suddenly and deliberately target the Bulimba Creek remnants linked to Boyanda Street wetlands, Boorabin Picnic Grounds and Broadwater Picnic Ground.
The route selected will significantly contribute to the loss of ecological values, and processes including loss of breeding sites and habitats, fragmented edge effects of tracks, weeds, fires, but also has no regard for the welfare or sustainability of wildlife, ecological processes and broader conservation issues
Vegetation Map of sections of proposed route that were provided, clearly indicate that several threatened ecosystems will be cleared and become highly disturbed, with dire long-term ecological consequences. This is another example of the display of arrogance to push ahead with their project, despite warnings and protestations from disaffected sections of public.
Lack of responsibility for their "asset", including failure to protect access to either tower, transmission lines or other infrastructure, by restrictive fencing.
BREC Field Officer Report -Summary
Some of the major impacts associated with the construction and placement of transmission towers and lines through remnant forests and bushland includes