Preliminary BREC Comments - Western Catchment group - draft plan June 2004
Total clearing of Woody Vegetation 1991-2001 in the WCG area would be in the order of >16,000 ha or around 2.5% of the 1991 Vegetation based on the BREC - LGA Clearing Report 1991-2001.
The plan should address the causes of the problems as well as the symptoms
Overall the suggested targets in most areas are inadequate. The lack of scientific information should not be used to avoid precautionary actions.
The focus on biodiversity rather than the broader concept of nature conservation is a limitation of the draft. It fails to allude to the relationships between ecosystems and species or the ecological process those ecosystems and species depend on. The value of water to plants and animals is barely addressed.
We support the Draft NRM plans comments that the EPA Biodiversity Planning Assessments have ignored waterways. The Common Nature Conservation Classification System on which the EPAs BPA is largely based did address waterways values. The CNCCS has been endorsed by SEQROC and along with the criteria listed in SEQ Nature Conservation Strategy (pages 32-35) should form the basis of assessments of Nature Conservation assets. There is also a set of HCV criteria developed by the Ministerial Advisory Committee on Vegetation Management.
The use of the draft SEQ RVMP is not widely supported by conservation groups and suggestions for "acceptable" solutions need to take into account the proposed amendments to the Vegetation Management Act. Protection of Aboriginal cultural heritage resources should take into account the Cultural Heritage Act. We do support the use of the SEQROC endorsed CNCCS and SEQ-RCC endorsed SEQNCS criteria.
The failure to suggest any water quantity targets is very disappointing. The Qld Water Act clearly provides for environmental allocations. It is known that in some parts of the WCG area extraction is close to or has gone past recharge rates. Base-flows of some creeks have been severely reduced.
Suggested Water Quantity targets 1) That streams with reductions in stream base-flow due to human activities have some more base-flow restored, as an interim environmental allocation, through water savings. 2) That the floodplain ecological services are maintained eg floodplain capacity and sediment settling capacity
Suggested additional Nature Conservation targets - That the identified nature conservation values(CNCCS & SEQNCS criteria) have not declined. 2) That fragmented patches of Endangered & Of Concern communities have connection plans developed and implementation is commenced by 2006
Suggested additional Aquatic Ecosystem Targets 1) Identify and eliminate sources of heavy metals upstream of Wivenhoe dam. 2) That wetlands be protected and restored where necessary as being essential for both aquatic ecosystems and other animal species.
Suggested Atmosphere Targets 1) That the air pollutant corridors identified by the regional windfield study have preliminary environmental and human health assessments finished by 2005. 2) The NO_x and SO_x emissions from Swanbank and Tarong be reduced. 3) That emissions of greenhouse gases be reduced by at least 30%.
Suggest additional Salinity targets 1)That a rapid survey of salinity signs in WCG using bio-indicators be completed by 2005. 2)That actual salinity areas of identified in CMPs be targeted for urgent remediation planning 2004 with implementation commencing in 2005.
This is not the full extent of our concerns and a more detailed submission will be submitted in the near future.