Submission Against Proposed Traveston Crossing Dam.

Following release of the Travestion Crossing Dam EIS by the Queensland Government, I have made an assessement of the documents and have lodged my submission against the dam. A copy of my submission as forwarded to SEQ Infrastructure (Water) follows this introduction.

Submission in response to the proposed Traveston Crossing Dam EIS

Submitter; Jeff Lambert,

The Co-Ordinator General
Project manager,
SEQ Infrastructure (Water)
Traveston Crossing Dam
PO Box 15009
City East Qld 4002

Dear Sir,

Please find attached submission in response to the proposed Traveston Crossing Dam EIS. Would you kindly acknowledge receipt at your earliest convenience.

An alternate proposal (Lambert Plan) accompanies the submission. The alternate submission is presented under the relevance and provisions of Subdivision 3 — Purposes of EIS and EIS process, — Section 40(b) and (c) of the Environmental Protection Act 1994 as amended.

Although the Lambert plan thus submitted has a primary role of protection of the North Stradbroke Island aquifer and associated ecology, it is also presented as an ecologically sustainable, economical and climate independent alternative to the Traveston Dam proposal.

Yours sincerely

Jeff Lambert 22nd Nov.2007

Submission against the proposed Traveston Crossing Dam

Introduction

The most profound challenge facing mankind is climate change. Predictions by the world‘s best science as to its devastation to the planet‘s ecology, as we know it today, are becoming evident. World wide extremes are already causing highly unusual trails of destruction, injury and death, with the associated trauma and government action dilemma.

Many of the world scientists, correctly predicting these events, are now alarmed at the acceleration of their predictions in the rate of ice melt in both polar regions. Some scientists are now deliberating that we should be talking in metres, not centimetres, in estimating sea level rise due to global warming.

The most important concern arising from the above is, not whether climate change is real, but nature‘s time schedule in the eventuality of predicted events. This puts major developments in the forefront of climate change considerations, more particularly those that involve an environment that will be adversely affected by climate change.

The proposed Traveston Crossing Dam and the extraction of ground water from the North Stradbroke Island aquifer are two such concerns (proposed and actual) facing caring and concerned communities at this very moment. The objections to the Traveston dam EIS criteria and the proposed alternative attached, are aimed at recommended resolution to the two major concerns mentioned above, as well as further population expansion problems into the future.

It is submitted that climate change has already affected the two areas noted above and that the continuance and proposed expansion of the Stradbroke Island aquifer extraction and the damming of the Mary River, fraught with natural fluctuations (apart from the future affects of climate change) are too great a risk both to the ecology and the sustainability of guaranteed water supply. Just as the observations of ice melt have surprised even the best available science, who, in the argument for the dam construction or the Island extraction volumes is prepared to accept historical data to justify future rainfall and catchment recharge or for that matter, predict the future of same? Who is guaranteeing and accepting that responsibility?

Although it is the role of QWI to deliver information on the dam, its actions and promotion of same to the public appears more in keeping with a bias centred on the building of the dam as their prized objective. The Stradbroke Island extraction was justified by others originally under results from the John Laycock Report, however the investigations were carried out during relatively wet years, including the 1974 rain depressions.

Adoption of the desalination proposal would see the State Government qualify for the Rudd, National Water and Desalination Plan, offering a capped figure of $100 million per project.

A Case For Alternate Water Supply Other Than Climate Dependent Proposals.

The submission outlines five basic objections to the dam proposal as per the EIS.Objections1. The EIS fails to address, in any adequacy, the provisions of section 40 subsection (b) of the Environmental Protection Act 1994.

2. The EIS fails to address, in any adequacy, the provisions of section 40 subsection (c) of the Environmental Protection Act 1994.

3. The EIS fails, with the exception of a buffer volume allowance for droughts, to takeinto consideration or define climate change effects upon rainfall and flow capacities within the catchment zone into the future predicted life of the dam.

4. The EIS fails to appropriate costs to the Traveston Crossing Dam of substantial capital cost and continuing operating cost for the transfer of water from Lake MacDonald at Noosa to North Pine at Brisbane in comparisons between the proposed and alternate proposals.

5. The EIS statement relegates the safety factor of the dam construction to Extreme Hazard category. Failure would threaten lives and property lying below the dam more especially the City of Gympie.

Summary (reference to discussions herein and to the attached report)

The EIS fails to define, non surface water alternatives and more particularly climate independent alternatives, in any realistic manner for comparison of true costs, ecological sustainability, cultural and social disturbance, good agricultural land diminution, acquisition and relocation costs, infrastructure costs, existing agricultural product losses to the local community and the State and emotional stress and social divide so evident and ongoing.

The attached ‘Lambert Plan’ is presented as an alternative to the Traveston Crossing Dam. The Plan exhibits other benefits, more importantly, the opportunity to eliminate extraction from the stressed North Stradbroke Island aquifer, apart from negating the building of the Traveston Crossing Dam, a project fraught with social, cultural, ecological and sustainability ramifications.

The quantities nominated in desalination, 250 ML/day are sufficient to replace the present and proposed extraction from Stradbroke Island as well as that of the Traveston Crossing Dam. With wind generation of the renewal power for the desalination and with both operations capable of incremental expansion, we would see the Stage1 and 2 of the Traveston Dam as well as the Stradbroke extraction covered by desalination increase to 300 ML/day (Melbourne target) and if increased to 500 ML/day, as proposed for the Sydney plant, the above as well as an extra 200 ML/day for future population usage.

The expected life of wind turbines is approximately 20 to 25 years. At the end of, or even prior to, that period other renewable techniques such as pumps powered by wave action, already under investigation, may be perfected. The opportunity for a research domain close to institutions and corporate interests is instrumental in facilitating such research and hopefully more efficient improvements to known methods and development of new technology. Such research is vital to the preservation of the planet as we know it. If we are to follow best scientific advice it is imperative to commence such research now.

Gradual implementation of the upgrading of the Sunshine Coast present water supplies, in prioritising selected alternatives under the ISF / Cardno report to cater progressively for increased population demands, together with desalination operations commenced so close to Brisbane, would see, not only the Traveston Crossing Dam being avoided, but also the northern connector pipeline postponed until population between Brisbane and the Coast so demands.

The objective of the Northern Pipeline inter-connector, according to the EIS, is that the pipeline is “being developed to support supply security in the northern regions of SEQ”. This statement is at odds with the true purpose of the Traveston Crossing Dam, — supply to augment the inadequate and failing Brisbane Valley dam supply to Brisbane industry and households. Lack of water supply in the traditional Brisbane supply resource would negate any argument that the pipeline is developed to supply the Sunshine Coast from Brisbane water supplies, making the statement above, at the very least, misleading.

The EIS fails to address the implications of climate change in any meaningful way in detailing what appropriate steps are taken and upon what data the predictions of future rainfall and flow capacities are based and the source of such data. Should the drier climate predicted, take the route of the ice melt and exceed expectations, then the predicted criteria supporting the justification of the dam may find its reliability and therefore its sustainability, supply and economic predictions in serious trouble, perhaps irreversibly so.

The very categorisation of the dam as Extreme Hazard potential, leaves populations working and living below the dam in constant concern, whether any catastrophic event occurs or not. In the event of a major failure of the dam, particularly if occurring during a flood event, would leave warning of the Gympie and surrounds population no time for adequate evacuation timing, especially if access is limited or negated in flood conditions.

It is submitted that green powered desalination should be the only reliable source of water planned for our predicted drier future. The Stradbroke Island aquifer is already under stress, from both the flora supporting water level reduction within the island high dune sand mass, and the probable advent of perimeter salt water outweighing and intruding, through reduced head pressure within the dunes, the freshwater envelope.

It is submitted that the proposal outlined herein and in the attached report will;

• eliminate threats to the Mary River and the North Stradbroke Island ecology and other associated problems.
• ensure guaranteed water supply to an adjacent, fast growing population whatever the events of climate change.
• promote Queensland as a committed player in the use and continued research into renewable energy.

With respect, it is further submitted that the EIS is contentious, both in selectivity of subject matter and subject format.

It is not the intention of the submitter to present argument herein relating to the ecological, social and cultural matters prompting objection via the EIS. The submitter is aware of, and in agreement in principle with, such response by others in more detailed submission.

Discussion

In relation to objections 1 and 2 above; the relevant sections and subs of section 40 are presented;

Environmental Protection Act 1994.

Subdivision 3 —- Purposes of EIS and EIS Process

40 Purposes
The purposes of an EIS and the EIS process are as follows—
(a) to assess -
(i) the potential adverse and beneficial environmental, economic and social impacts of the project; and
(ii) management, monitoring, planning and other measures proposed to minimise any adverse environmental impacts on the project

(b) to consider feasible alternative ways to carry out the project

(c) to give enough information about the matters mentioned in paragraphs (a) and (b) to the proponent, Commonwealth and State authorities and the public

This submission supports argument against the dam, in favour of climate independent alternative. The EIS mentions one such alternative, desalination, however the negative feasibility factors applied to this alternative under the EIS, relating to suitable siting close to seawater availability and because of land value constraints do not, in any way, constitute a realistic appraisal of this alternative.

There are other alternatives than those mentioned in the EIS (namely Bribie Island and the Sunshine Coast) where suitable sea water sites are available for desalination operations. In relation to land value constraints land has been selected and acquired at Tugun in probably more restricted land availability than most areas and no doubt if the matter was fully investigated land could be acquired at the Sunshine Coast and/or Bribie Island.

In the EIS cost comparisons, the operating costs of energy usage for desalination are described as high and of course this is so if reliant upon grid power. However there has been no attempt to marry the energy requirements of desalination to renewable energy.

In spite of the precedence of a desalination plant in Perth with intake and discharge into Cockburn Sound (a fraction the size and volume of Moreton Bay), now in operation and offsetting its power usage to wind generation near Cervantes 200 kilometres north of Perth; or of Perth planning a second desalination plant using alternate power that will take their desalination production to 250 million litres per day; or of Sydney planning a 500 million litres per day operation at Kurnell under wind powered energy; or of Melbourne planning a 300 million litres per day plant possibly utilising Port Phillip or Western Port Bay and powered by renewable energy, no mention of such scope and opportunities is forthcoming in the EIS very limited discussions concerning alternatives.

The accompanying report promotes the establishment of a plant at North Stradbroke Island within Crown lands using possible wind and/or solar power. The positioning of either the desalination plant or the renewable energy package does not necessarily have to be at North Stradbroke Island and through renewable energy input to grid connection, anywhere in the State provided it is economically viable, the operations may be divorced.

The prospect however, of adequate wind velocities, the surround of sea water, the existence of crown land, the opportunity for research of alternate energy projects so close to institutions, the proximity to a growing population area, the significant scope for Island employment, together with elimination of groundwater extraction from the Island on ecological grounds, makes Stradbroke Island an attractive proposition.

The EIS refers to water extracted from the Stradbroke aquifer. It also refers (briefly) to the possibility of water resources within the National Park declared sand masses of Cooloola and Fraser Island. The EIS goes on to state that in relation to possible extraction from the Cooloola and Fraser Island sand masses (which bear similar transgressive dunal build up to Stradbroke Island)

“The environmental impacts are currently acknowledged as potentially significant and there is a great deal of uncertainty in the potential yield of these aquifers, given the current extended period of drought”.

The question, undoubtedly on the lips of Stradbroke residents, is why this philosophy does not extend to Stradbroke Island???

Any proposal and allied justification of future water supply using alternate energy must, in the circumstances of the challenge of Global warming, be deemed not only valid, but highly desirable, under this or any other project assessed. The EIS lacks any such vision on this matter and appears more intent in discarding the alternatives in favour of the chosen project.

In relation to Objection 3 above.

Droughts are a concern and always have been, regardless of the added threats posed by climate change. The buffer of 50,000 ML provided for drought conditions will last less than one year (approximately 7 months) at the proposed extraction rate of 70,000 ML/a. However that buffer is included in the total capacity of 153 000 ML. which is two years supply at the extraction rate, less the volume promised for river sustainability. The ―an nnual flow rate cited in the EIS is 606,000 ML (we can only assume that this is a reference to Max annual flow) with the median annual flow cited as 341,000 ML.

Approximate cross sectional and flow rate measurements conducted last year at Traveston Crossing, delivered in the order of 30 ML per day or 11,000 ML per annum. This was during a dry period that lasted for several months. Comparison of this with the median flow of 341,000 ML (30 times more) highlights the flow variations and the fact that averages cannot be supported in dam fill estimates throughout the year. Except for unusual events, most of the flow capacity occurs during the months of December through to March and where the storage capacity is limited to the dam holding capacity at that particular time. The EIS cites the dam storage as being at full supply level for 23% of the year, no doubt coinciding with the months mentioned above. It is submitted that the reliance on the use of averages is misleading in the capacity estimates of median flow rate influencing dam fill levels throughout the year.

Although some estimated provisions are made for droughts, there is no provision made for the climate change (dryer climate) predictions made for the east coast. The predictions also exacerbate the problems of acceptance of historical data use in the flow and rainfall data in dam fill capacity modelling, in that extremes are likely to be more severe and of longer duration. World‘s best science got it right in predicting the climate change associated with global warming, however their predictions of ice melt, although correct in substance, have been alarmingly exceeded in the time factor originally estimated. An indication the climate change is moving faster than their most pessimistic predictions.

The above scenario draws considerable concern to the reliance on historical data when we are not sure what the next ten or twenty years will eventuate in terms of lesser rainfall, extended droughts and higher temperatures affecting evaporation etc. Applying todays and yesterdays figures to future performance criteria of the dam, in the face of unknown future climate constraints, is a gamble. A $1.6 billion + gamble.

In relation to Objection 4 above

A pipeline connection from the Mary River to Lake MacDonald is already in place. The proposed pipeline from Lake MacDonald to North Pine which is proposed to be staged has not entered into the Traveston Crossing Dam costing. It is costed independently and yet why is the pipeline proposed? With all the EIS discussion on the inadequacies of the Brisbane valley dams to support Brisbane water requirements alone, surely no one is suggesting that the pipeline is proposed to supply water to the North Coast from Brisbane? It has long been the argument by North Coast Shires that the reverse is the case in that the North Coast supply dams, intended for use as staging dams under the northern connector pipeline, may suffer additional extraction along the way in further support of Brisbane usage. Whether that be the case or not, in realistic terms, the pipeline is a one way ticket, with its major use in transporting Traveston Crossing Dam water to Brisbane.

Under the above circumstances the costing for same should be allied to the Traveston Crossing dam costs. Without it the Traveston waters would not reach their intended destination and further it is inconceivable that the northern inter connector pipeline reaching as far north as Noosa, would have eventuated were it not so required. Operating costs are attributable, apart from the capital costs and it is submitted that these costs will add substantially to the stated dam costs. The justification for the dam cannot be upheld without the cost of the conduit for the intended use by the major beneficiaries.

In relation to Objection 5 above

Paragraph 2.10.1 of the EIS assumes that the project (the dam) will be assessed as an Extreme Hazard categoryin accordance with QDSM Guidelines and the definitions given by ANCOLD. The EIS goes on to say that it is expected to fall within category 2 in terms of Failure Impact as defined under the Queensland Water Act (2000). This latter category has nothing to do with the dam construction reliability but sets population density of those at risk. Category 2 failure impact rating –more than 100 persons.

It is submitted that thousands, not hundreds, would be at risk should there be any major dam failure. The impact would be devastating. More so, in the situation where the dam is at full capacity and the river in full flood at the time, introducing a higher probability of dam failure than otherwise.

Apart from the safety concerns of the wall itself, those who have witnessed the Mary River in raging flood, could not help but express doubt as to the ability of the proposed gate controls to cope with such a comparable volume for release to spillway discharge. Logs and other debris would add to such concern.

The EIS goes on to state that whilst remote monitoring of the dam and its instrumentation may be possible, the dam safety program will require, among other surveillance activities, daily visual inspection. This is not very reassuring for the populace and their property and livestock below the dam, if you take the scenario above, of a full dam and the river in full flood and inspections expected to be carried out under possibly severe weather conditions and back swell flooding of the river below the dam, more particularly in the hours of darkness. If it should happen, who goes to trial? Who takes responsibility? Such a catastrophe would promote dominance over even the most stringently worded disclaimers.

Attached report “The Lambert Plan” submitted for alternative solution to the Traveston Crossing Dam as well as a solution to the extraction of water from the North Stradbroke Island aquifer.

Jeff Lambert
22nd November 2007

I have also prepared an Addendum to the above submission - The Addendum can ve viewed here.

My alternative proposal entitled “The Lambert Plan” can be viewed here.  This is PDF document about 1.9MB in size.  If you have the free Adobe Reader software on your PC, the document will open in a new window in your browser but may take up to a minute on broadband.  If you are on a dial up Internet connection, it is suggested that you download the document to your PC.  To download the document, right click on the link and select “Save Target As” and save the document to your PC.