The current draft master plan is deficient in a number of aspects and should be comprehensively rewritten before any further developments occur. The BACL is already moving on some elements of the master plans such as the industrial and commercial precincts before the process of the master plan has been concluded. This will clearly compromise the process and work against the public interests of the Brisbane community.

The BACL must address the impacts and consequences of water, soil and air pollution after its deposited on, or transits, its site.
Stormwater runoff has been inadequately addressed and we believe there will be major problems with contaminants entering State waters and lands. These contaminants may include sediments, litter, kerosene, oils and industrial runoff among other things. The master plan has not demonstrated how these contaminants are to treated up to lawful discharge quality. They have failed to research or present international best practice techniques in these areas.
What arrangements have been made with ASA to monitor and mitigate this pollution/contaminants which enter state lands and waters including ground water ?
The master plan glosses over potential acid sulfate problems on its site. Recent research has shown that traditional assumptions about dredged material and their acid buffering capacities are wrong. The airport site probably already has problems due to the filling on top of mangrove systems. Any filling on-site will also be subjected to subsidence problems due the nature of the soils.
The master plan provides minimal information on how they intend to assess, monitor and police pollution from the proposed industrial estate. The pollution control laws specified in the Airports Environmental regulation are deficient for minimising or preventing environmental harm. The detail provided in the environment strategy, the master plan is insufficient in the areas of training, compliance, inspectors, evidence, rights of entry, prosecutions, environmental protection orders and environmental management programs.
It is unfair and maybe unconstitutional to shield businesses from state laws, these activities are ancillary to the operation of air transport and should not have the shield of the crown.
Current practice and enforcement around the and in the Airport such as un-maintained jet fuel bunds and illegal dumping do not bode well for future environmental management under a weak regulatory regime.
The proportion of freight traffic carried in dedicated air freighters is of concern because of safety and noise. The overall risks of having mixed development within the airport is glossed over in the draft master plan. The air crash into an Amsterdam building and the recent air crash into an industrial estate in Chicago demonstrate the clear risk of such practices.
While having some legal immunity from the noise and pollution from aircraft the airport must still be responsible for its own pollution and pollution that traverses its land.
The draft master plan proposes that only a minute, and insufficient, area of mangroves , salt marshes and wetland be preserved. These ecosystems are threatened or endangered in our region. Other business enterprises are not allowed to destroy these valuable ecosystems with gay abandon and the airport likewise should be forced to comply with best practice.
The Draft master plan fails to asses secondary impacts of the increases of passenger and freight traffic. These impacts will be increased , roads, rail and other supporting infrastructure. Furthermore this infrastructure will generate contaminants and construction impacts of the local environment and affect human health.
The removal of substantial native vegetation buffer areas and transport interchange plans threaten the local community of Pinkenba and are opposed by us.
Finally we believe that this master plan should be rejected in it present form and the previously mentioned deficiencies should be corrected. The plan indicates a scale of development inappropriate for its location with unacceptable environmental impacts.

Yours sincerely


Michael Petter
Coordinator
The Web Incorporated's
Brisbane Region Environment Council
cc Federal Minister Transport