Comments on Draft Brisbane River and Moreton Bay Catchment Waterways Management Plan and Water Quality Strategy

Overall Comments

The definition of ecological health is by no means a done deal. The study and strategy don't address issues such as the robustness , resilience and resistance of the various ecosystems. It fails to address distribution pathways of carbon and other indicators of ecosystem structure. The scientific study has failed to make a model of the whole catchment and its land uses. The study was of course biased by its initial and abiding preoccupation with sewerage plants.

Rather than focussing on just wastewater a broad water quality strategy must deal with water every step of the way from its source to the ocean.

The complex problem of blue green algae in water storage's seems to have had no scrutiny from the study.

Other contaminants in the waterways have hardly been touched on by the scientific study. Trade Waste and human sewerage should be separated to allow for safer recycling.

Other treatment options such as composting toilets owned and maintained by the water authorities should be prioritised. Further cost effective treatment systems for rural residential areas, including upstream predigestion.

The problem of chlorine and antibiotic resistant bacteria is an urgent problem facing both water providers and waste water producers.

The off hand dismissal of sediment issues from other sources is disturbing, in that every catchment upper, middle and lower say they have problems with accelerated erosion.

The highest relative pollution loads are in low flow times, the study has failed to consider methods of increasing baseflow as well reducing pollutant inputs.

The strategy as outlined puts off the most fundamental task til the next century. That task is the restoration and rehabilitation of upper catchment, riparian, coastal and marine ecosystems.

Demand reduction , not just water efficiency, is another urgent priority in both rural and urban areas.

BREC believes that in addition to the upgrading of treatment facilities the state government should issue a Catchment Protection Bond . This bond would be used to pay for the management of key, riparian and water production, areas and rehabilitation works. This approach has recently been taken by the American state of New York as a cost saving measure to avoid even more costly treatment options

Moreton Region Consortium Draft

Independent objective research on ecosystem health criteria would be desirable. The Moreton Region Consortium proposes to only provide "politically acceptable" advice which precludes objective analysis. Science does not, as a rule produce "politically acceptable" results but the truth is often unpalatable. The scientists must then rely on advocacy and pressure groups to make the results acceptable through open and public debate and the mobilisation of political pressure.

Science Program

The current scientific study of the MBBWWS as been characterised by a lack of breadth. Water quality objectives are all well and good but the rivers and stream are a product of their catchments. This means we need criteria of catchment quality as well as water quality measures.

Parameters such us :

• soil water content not to fall below 30% of maximum,

• groundwater production and consumption the ratio of consumption to production not to exceed 70% with a desirable level to 50% ,

• percentage of very upper catchment(>5th order steams?) under natural land use with a minimum of 70%,

• percentage of whole catchment under natural land use Min 30% ,

• percentage of riparian corridors under natural land use Min 30%

• percentage of major floodplains under urban land use Max 10%,

• establish parameters for environmental flows of nutrients and materials distributed by waterways, and

• the value of ecological services provided by catchments, waterways and bays not to decline by 5% in any year,

are just some examples for possible criteria.

Detailed Comments

Draft Water Quality Strategy

2.1 Not just Moreton bay the whole catchment

2.2. commentary on vision ...says nothing about how

2.3 outcomes last dot point community understanding and ownership of problem what % of particulate fallout from aircraft do we own each and am I breaching the Ramsar convention by BACL upgrading airport ?

3.1 comparison would not be so favourable if we consider the time frames involved ie 1000 yrs to current state in Europe vs 150 years here to reduce pristine to moderately good.

p12 The main aim of the strategy is to bring about changes to how we utilise the ecosystem and adopt management practices in a co-ordinated and integrated manner to achieve this

3.2 where do pathogens come in

p17 seagrass loss and chain trawling needs looking at especially with a view to re establishment.

4.1 Environmental values for freshwater streams will be dealt with in Stage 3 This does not seem an integrated approach.

4.2 Australian water quality Guidelines for fresh and ,marine waters are guidelines only. There are no Australian standards for these criteria and all jurisdictions should adopt national standards as a matter of extreme urgency.

Waterways Management Plan

Page 22 Water Quality and Ecological Health

Water Quality Actions. The reliance on the RFGM to address sustainable land use and water quality issues is misguided and doomed. The RFGM is about growth promotion not sustainable development and its regional outline plan can only deliver environmental degradation and further loss of biodiversity. We need better legislation and some understanding of the regions ecology before the RFGM could even begin to address the problems, assuming it wanted to.

The outcomes fail to mention catchment health or the protection of ecological processes and as such the stated outcomes cannot achieve the goal.

Page 24 Key Future Strategies

A major strategy of ICM has been completely missed it is doubtful whether most of the researchers and many of the participants have any knowledge of ICM.

Page 25 fails to mention other important contaminant such as pesticides, metals(such as Iron) and pathogens. In our view the pathogen releases in the wastewater pose a grave threat to humans and the ecology.

Page 26 This page neglects the impacts of intensive livestock activities and BREC believes that the wastewater from these activities should not be released to Qld waters or sewers.

3.2.4. Key Future Actions The faecal coliform standard should be a B or A priority because of the proven incidence and dangers of pathogens. The role of wastewater treatment plants in "breeding" antibiotic and chlorine resistant bacteria should be urgently investigated.

The section of industrial discharges fails to acknowledge that this move to best practice is legislated and enforceable this should be an A. Waste tracking and the introduction of a waste EPP is an urgent priority and should have an A priority. The waste tracking should be funded by a industry levy and overseen by an independent panel.

Strategy 2

This strategy fails to mention the introduction in Jan 99 of ERA 38-39 dealing with Land development and construction. The licences for these era's should include conditions to control the release of sediments and other contaminants as well as issues of stormwater management and riparian protection. With this introduction due in less than six months one would hope the governments would've allocated budgetary resources to achieve this implementation, unless of course it would interrupt their campaign donations(sic).

The fact there is no time frame to achieve specific stormwater loads is telling and implies that this will never happen.

Strategy 3

The relegation of this item to C priority is not acceptable. The recent death of invertebrates and other organisms from pesticide residues is extremely worrying. This should be an A the problem has been well known since the early 60's. The government should prioritise waste tracking, collection points and some form of refundable deposit on old containers.

Strategy 4 (sigh)

The fact the first item ICM is ranked as a B is mysterious. the NHT this year alone has put over $1 000 000 into ICM groups and the program has been running for at least ten years. This should be an A by definition.

Sediment control should at least be a B priority. the production, and regular reporting, of hazard assessments and risk mapping would be beneficial.

The fact is that the code of practice for agriculture is already been gazetted so therefore the adoption of it should be an A priority or why was it gazetted, publicity ?, a cheap legal defence against implementing the EP act or just for the hell of it ?

We presume that the next state of the waterways report will be in 1999 ?

Strategy 5

The actions dealing with the restoration of marine plants shouldn't be left til the year 2000.

Strategy 6

This strategy fails to address the total impacts of transport systems including road runoff and wash from boats, the construction impacts of roads, bridge and boat facilities. the strategy should also do a cots benefit analysis of the different modes of transport around the Port. BREC believes that the use of cross river barges should be looked at as an alternative to future and current road transport.

Strategy 7

environmental allocations and payment for water productions should be implemented as a matter of extreme urgency. Environmental allocation should approximate baseflow conditions between 15 and 30%.

3.2.5 Key Performance measures

The last item "reduced impacts caused by use of the waterways for economic and recreational purposes should span all of the measures. In that economic uses include use of the rivers as discharge points , extraction of water and housing development.

3.3 Livelihood and resources

3.3.1 outcomes

Outcome 5 can only be supported if these resources also have component reserved for both nature and intergenerational equity. Just as nature needs an allocation of water to survive it also needs aquifers, sand masses and other materials. Offshore ecosystems rely on a replenishment of sands and gravels to replace that loss by longshore drift. Sand masses beside streams are vital in maintaining river baseflow in dry times. In-stream sand masses provide important habitat for fish and important benthic fauna. These sand masses also serve as an in-stream filtration structure which helps maintain water quality.

3.3.2 Key actions

"Water allocation, policy and regulation actions" this section fails to mention any regulations or regulatory frameworks. An essential part of regulation of water use that of paying for water production hasn't been addressed. We believe that land managers should be paid or credited water use for managing their properties to enhance the production of water, in particular baseflow.

Managing Flood Risks This section could also address the regulation and enforcement of developments in flood plains. It could also address the need and desirability of flooding being allowed to happen and planning for this by restricting inappropriate development.

Dredging and Extractive industry actions

This section fails to address the urgent need for demand management and alternatives to these resources. It also fails to acknowledge the need to allocate some of these resources for the future(50-100yrs) and to maintain the ecological processes upon which life depends.

Port and River Mouth operations actions

This section fails to address the fundamental deficiencies in the environmental impacts assessment of this ill conceived plan. The filling, with who knows what, of thousands of hectares to a depth of 2.5m on a river delta can only worsen flooding upstream. The runoff and other pollution impacts, of this much general and noxious industry, on the river and bay have not been assessed.

3.3.4 Key future Actions

Strategy 1 The fact that restoration of the catchment has the lowest priority indicates yet again that the study doesn't understand basic hydrology and is not prepared to do much beyond tinkering with sewage plants. This item number 4 should be at least a B and the government should considering raising a catchment infrastructure bond to pay land managers for the rehab and management of water production areas. This will be cheaper than building, operationing and replacing evermore expensive water treatment systems.

Strategy 2 The DNR theoretically has been doing this for at least 10 years and the SPP on agricultural land is at least 6 years old, why is this still only a B priority?

Strategy 3 needs a further objective that of "maximising environmental flows"

Strategy 4 This should have and action dealing with paying for water production.

Strategy 5 This should contain an action to do a WAMP for the whole Brisbane R catchment.

Strategy 6 The push for just water use efficiency is not enough. Western Mining Corporation in its first annual environment report boast about its increased efficiency per tonne while the truth is that they actual are using much more water than before. Demand reduction strategies must be implemented if use is to be sustainable.

Strategy 7 Fails to specify any action of how "appropriate" location might be identified. The current plans and policies include plans to mine just about every river, Bribie Is, Stradbroke Is and to keep grabbing more and more from the bay with the Western Banks currently threatened. Just because a resource has been identified it doesn't mean that it should be automatically allocated. We should be identifying and setting half life and third life limits on extractive and mineral resources. Even with the steady downward trends in commodity prices over time, those producers with lower extraction costs will still have an advantage.

Strategy 8 Until industry can prove its ability to do best practice in design, construction and operations of industry adjacent to a marine park the Gateways project shouldn't proceed. The gateway ports plan, in its current form, can only diminish the environmental values of the airshed, river and bay.

The river delta is an important organ in maintaining the health of the bay and must be allow to serve those function without be comprised by inappropriate development.

Key Performance Measures should be revised to reflect some of the concerns raised above.

3.6 Coordinated Waterways management. we have a lot of the necessary measures in place such as the Water EPP, waterways plans under the EPP, and environmental outcomes, policies and regulation in planning schemes.

We need a strengthening of the time frames in the EPP. We need for land development and construction to be proclaimed environmentally relevant activities and appropriate licence conditions applied. We need for extractive industries to be better regulated under the EP act and for the DNR/DEH to draft natural resource allocation regulations and amendments.

The floating of a catchment infrastructure bond and paying for water production can provide financial incentives. Furthermore if the infrastructure bond focuses on paying land managers it will provide a useful stream of farm income.


Michael Petter Co-ordinator

Brisbane Region Environment Council