BRISBANE REGION ENVIRONMENT COUNCIL
16 December 1996
(Champions Way, Willowbank)
EIS received 18 November 1996
The QCC objects to the consent application on the grounds that the EIS has failed to provide adequate information to fulfil the TOR for its EIS. QCC believes the proponent should consider alternative sites nearby that could be rehabilitated and used for such a purpose. The removal of endangered ecosystems is not supported and the wastewater and stormwater management plans are insufficient.
The comments relating to the inadequacies in the EIS could extend beyond the reputed 2 kilometres of the vacuum-sucking waste treatment proposal. The whole report focuses on ways of allowing the development to proceed, and fails to recognise the ecological significance by failing to protect it.
In particular, there is very little ecological information which should have been included in a thorough Environmental Impact Statement, which was pre-empted by several media articles that favoured the new extension to existing raceway, prior to approval and without waiting for adverse findings.
In so doing, this EIS focuses on down playing the significance of this area and looks for arguments to support massive clearing "in support of a Consent Application to facilitate the development of a national standard Circuit Raceway".
This is in spite of acknowledgment that the site is ecologically significant with Ebenezer Creek tributary, 3 areas of old growth forest, and two Bioregional Endangered Ecosystems; which is the highest classification designated by Department of Environment:
1) Melaleuca tamarascina subspecies irbyana thicket
2) Forest Red Gum on alluvium
Most alarming are the suggested methods of recognising the importance of these endangered ecosystems in light of the proposed wholesale clearing for development; not to preserve them but to have Greening Australia on a `plant rescue' mission to remove understorey and fell trees for seed collection.
It should also be noted that there is enormous potential to retain these forest ecosystems and provide vegetation and wildlife linkages to the adjoining Water Reserve Champions Way, which contains two vulnerable species (Marsdenia coronata and Secamone elliptica).
The absence of detailed vegetation lists or reports from Ipswich City Council in the Appendix cannot confirm or deny the possible presence of these species on proposed development land, which would further justify retention or acquisition into the adjoining Water Reserve in the north; thereby achieving secure tenure of endangered ecosystems.
In fact the Department of Environment states that:
"site selection is the critical environmental issue for motor racing venues. Careful site selection can lead to substantially reduced environmental nuisance." Quite obviously, this report fails to reduce environmental nuisance by ardently supporting wholesale clearing for development of raceway.
This is in spite of the conclusion p 54 that "the regional significance of the existing Melaleuca irbyana, Forest Red Gum and wetland ecosystem cannot be disputed."
With such compelling evidence of the environmental significance of this area, it seems very strange that no alternative site was chosen which would save these ecosystems, and allow development without destroying significant flora and fauna habitats.
There are opposing statements such as recognising the ecological significance of the property and then supporting wholesale clearing and revegetation of any small areas left as a means of preserving endangered species. This technique does not consider the ecological importance of this area for preserving ecosystems or flora and fauna attributes.
It is also highly questionable whether the removal of all vegetation on the property will protect koalas or their habitat; especially in relation to the development which "will require that the majority of the site be cleared to enable appropriate earthworks to be carried out." p 56
Again, an inspection of the provided aerial photograph and proposed infrastructure for the development clearly shows a lack of understanding of flora and fauna habitat requirements that "clearing will be carried out in a manner which will allow fauna to move into undisturbed areas, with sufficient time to prevent loss of fauna currently inhabiting on the site... No `islands' of vegetation will be left overnight tempting animals to return...."
This is also in contravention of the wishes of Ebenezer Mines who have requested the maintenance of a koala corridor for linkage to their land in the north (Water Reserve) and west. In fact the site was considered by Ipswich City Council as a koala refuge and its inclusion into the existing Water Reserve would be highly desirable for continued survival of this species.
Aerial photographs of the proposed development highlight numerous sites with far less intrusion and ecological damage to the bio-regional endangered ecosystems acknowledged in the report.
The size and scope of this proposed development will place enormous pressure on existing water supplies with insufficient data produced on the possible sub-surface contaminants including mining operations, chemical residues from grazing/agriculture, The EIS acknowledges that the existing groundwater quality does not conform with standards and suggests from now on it will conduct regular testing. The statement that the problem could be fixed by more chlorination is also dangerous as there are clear signs worldwide that chlorination is failing to resolve bacterial problems. The deficiencies with the proposed waste treatment plant will only exacerbate this groundwater problem.
The EIS provides very little detail about how the wastes from vendors and canteens is to managed. The details provided in the appendices are incomplete and there is little information on solid waste volumes to be dealt with and how the biosolids are to be disposed of.
The proposed system is a 3000 l/day unit with a "shock load" holding tank of 30,000 l. With the EIS acknowledging that the peak visitor number could be around 18,000 this plant will almost certainly be inadequate. The EIS implies that each visitor will generate only 2 l of waste per visit, given that a flush toilet can hold from 8-16l per flush it seems improbable that a 30,000 l holding tank will be sufficient. We estimate each visitor could use around 40 l each for toilet and washing which yields the result that the system will need to cope with a "shock loading" of around 720 000 l.
The plants capacity of 3000l/day would mean that sewage would be pickled and difficult to treat if it was held for too long, it would take 10 days to clear the holding tank. Furthermore assuming that each person only uses 2 l each the BOD would be well above, 35 times, the rated BOD of the plant.
The report fails to detail what sort of microbe augmentation is to be used and fails to cite any examples of where this system has worked.. The assertion that this augmentation can deal with workshop waste is dangerous. Brisbane Water will not accept such wastes into its sewers because of the danger these wastes pose to the digestion process. we believe that if microbes could attack this waste the process would be too slow to cope.
The waste report says that the water discharge will be tested when necessary,. testing of water quality from STP is always necessary. A study conducted in 1996 by the NSW Health Dept showed that 86% of such systems had failed and were not operating to standard.
The final straw in this is that the treatment plant will then discharge this waste water to Stormwater drains.
Stormwater Quality and Hydrology
The stormwater plan fails to acknowledge the impacts of effluent discharges from the STP.
More information is needed on the type, efficiency and track record of the oil water separators used to treat the pit runoff water.
The hydrology report is mostly supposition and assumption and this is acknowledged by the consultants on page 11 of their report were they admit to having done no on site measurements at all. Figure 3-1 and the text in the document donít match with the description of the nodes used.
The hydrograph outputs were unreadable. The table 4-2 with predicted flow rates contained figures that stated that the flow rate from a 1 in 10 year flood was greater than a 1 in 100 flood a suggestion we find improbable.
The EIS fails to detail the design and construction of the proposed cross catchment links. The EIS also fails to provide clarity about the route of the proposed diversion channel, is it within the site or on adjacent mine land. If was it was put on rehabilitated land we would have concerns about the stability of the channel and its effect on the rehabilitation. The EIS fails to provide any results of soils structural tests or terrain analysis.
Air Quality For the EIS to state that a motorsport venue and its large volumes of associated spectator traffic will have not impact on air quality is ludicrous and unjustifiable.
Overall the EIS has failed to address its terms of reference and has not provided sufficient information. QCC believes the proponent should consider alternative sites nearby that could be rehabilitated and used for such a purpose. The removal of endangered ecosystems is not supported and the wastewater and stormwater management plans are insufficient.
Coordinator Brisbane Region Environment Council