SCEC’s EPBC referral submission
05 May 2015
Title of Referral: Department of Transport and Main Roads/Transport – land/Glenview/QLD/Bruce Highway upgrade Caloundra to Sunshine Motorway Project no: 280/10A/1
SUBMISSION by the Sunshine Coast Environment Council
The Sunshine Coast Environment Council (SCEC) is the peak regional environmental advocacy group on the Sunshine Coast, Queensland. Established in 1980, it currently represents 50 community groups working on conservation and sustainability with a combined membership of over 15,000 individuals.
EXECUTIVE SUMMARY
We submit that the proposed action would have unacceptable impacts on Matters on National Environmental Significance and should therefore not proceed in its current forum. At the very least, it should be deemed a CONTROLLED action. However, a higher level of assessment would be appropriate in our view. The Mooloolah Logging Area (locally known as the Steve Irwin Way Forest) within Beerwah State Forest lies partly within the project footprint and therefore subjected to direct impacts. Associated indirect impacts would affect a much larger area of the forest. Despite historical native logging activity, this critical portion of state forest was earmarked to transition into National Park tenure under the South-East Queensland Regional Forestry Agreement (SEQRFA) due to its high conservation values. This robustly negotiated agreement was arbitrarily and contentiously withdrawn by the former Queensland LNP government in late 2013. The transition process of state forest to protected estate is being revisited since the change of government following the Queensland State election on 31st January 2015.
The significant conservation values which elevated this area for transition remain intact and warrant appropriate and in-perpetuity protection. This project would fragment an integral part of a ‘bioregional corridor’ from the coastal lowlands to the hinterland vital for wildlife movement and the viability of species. We submit that the suggested mitigation measures by the Department of Transport and Main Roads (TMR) in no way provide the necessary protections or justification for impacts on MNES and should not proceed There are also unacceptable intrusions into the Palmview Conservation Park – a core connecting conservation reserve in the locality
FLAWS IN ENVIRONMENTAL ASSESSMENTS AND SURVEY METHODOLOGIES
Existing concerns relating to continued and inherent flaws in the environmental assessments relating to this project have been reinforced in the referral documentation.
FLORA
No reference to Lowland subtropical rainforest (LSR) occurring in Beerwah state forest in referral. It is discussed briefly in GHD flora assessment and dismissed. They appear to have relied solely on Qld government Regional Ecosystem mapping to determine where EEC occurs. This mapping is at a minimum scale of 1:50,000 and is based on 1:250,000 geology mapping. By definition the EEC can be a small as 0.1 ha. The minimum polygon size for RE mapping is generally 5ha. Small areas of lowland subtropical rainforest occur in the Beerwah state forest at the western end of the proposed realignment, south of the Steve Irwin Way. On page 31 of the GHD Flora & Fauna report (Attachment B of referral documents) they refer to ‘Closed rainforest gully along a small creekline (associated with ‘of concern’ remnant vegetation)’ in Beerwah state forest. This assessment is in direct conflict with their assessment that LSR doesn’t occur within Beerwah state forest.
Assessment states that Acacia attenuata population is not significant. This species is an obligate seeder. While the current population within the Beerwah State Forest may be small this is simply an indication of the time interval since the last fire. The soil seed bank of the population will still be present on site and after the next fire event the population will be replenished. This can often result in hundreds of individuals regenerating in an area where they have been absent for some time. The fact that this has not been discussed in the report means that the conservation significance of this record is significantly understated. Eucalyptus conglomerata (Swamp Stringybark) is one of Australia’s most endangered eucalypts[1]. Any remaining population is ‘significant’. This species occurs in Palmview conservation park (herbarium specimens). The western edge of this reserve will be impacted by the project. Suitable habitat for this species also occurs within Beerwah state forest. Please also refer to attached supporting document ‘Review of Bruce Highway Upgrade Planning Caloundra Road to Sunshine Motorway Project No: 280/10A/1 by Ann Moran (Bachelor of Science)’
FAUNA
Other than amphibian surveys the field survey effort for fauna does not appear to be quantified in terms of hours/days anywhere in referral or the review of environmental factors, GHD flora/fauna report. There is no mention in the referral of the potential for Long-nosed potoroo occurring within the project area. This species is known historically from Beerwah state forest to the south of the project area. It appears that no targeted searches occurred for this elusive species despite the presence of suitable habitat. Indeed the use of motion sensor camera traps has not been included in the methodology for fauna searches. The absence of this and other technologies such as song meters and trapping in general will have significantly reduced the number of species recorded with in the project area. Again, this results in the ecological values found within the project area being grossly understated. The methodology utilised for field based surveys are considered inadequate to gain a sufficient understanding of the ecological values that will be impacted by the proposed road upgrade.
The fact that only 40 species of birds were recorded during the environmental investigations is alarming. The project area lies within a region of significant bird diversity (349 species recorded in the Sunshine coast region). The project area also contains a variety of habitats including wetlands, rainforest, wet and dry sclerophyll forests and highly modified areas. The low number of birds recorded is a reflection on this lack of survey effort, and as stated in the flora & fauna report survey timing in unfavourable hot conditions. The statement that the endangered Coxen’s fig parrot has not been recorded within 2km of the project is site is false. This species has been recorded (4 individuals on 9/04/2002) within the project area by renowned birder, author and long serving Queensland museum staff member Greg Czechura. This is one of the few reliable records for this extremely rare species and one of the few locations that is known habitat. Australian Painted Snipe is dismissed as not being present in the local area despite recent records from Ewen Maddock dam only 3 km west of the project site. Koala: The project as currently designed will clear approx. 36,668 non-juvenile koala habitat trees equating to 24ha in the project extent. This is unacceptable. TMR’s argument that is only a ‘small portion of mapped habitat’ in no way makes it so given the exponential loss of core/high-value koala habitat in South-East Queensland and the accelerating decline of this species
12. While population density may be low due to compounding pressures in the locality, there is evidence of koalas being present. With improved survey effort (which is poor generally for koalas) and given the suitability of the habitat in the project area and surrounds the likelihood of koala presence and movement is high. The lack of appropriate fauna treatments to facilitate wildlife movement is also of concern and below standard in terms of measures to reduce impact on wildlife. The imperative to install wildlife bridges and crossings, not just koala fencing, given the fragmentation of vegetated/high value habitat areas resulting from the road infrastructure has been consistently raised with the TMR project team. Commitment to commensurate and appropriate fauna sensitive treatments is still absent from their material and project.
ACID FROGS
Litoria olongburensis (Wallum sedge frog) is known to occur in Beerwah state forest, there is no reference to these records in the referral. It is also concerning that Crinia tinnula (Wallum froglet) was not recorded during the surveys. This species has been heard on numerous occasions by qualified persons in the Beerwah state forest in the project area. Its presence is verified by previous fauna surveys (Conservation significance of Mooloolah logging area, 2012 and Beerwah State forest, Mooloolah Logging Area – Fauna survey 25th-28th October 2010 QPWS). Interestingly neither of these surveys recorded Crinia signifera which was recorded by the consultants undertaking this investigation. This raises concerns as to whether they may have misidentified the call? This raises important questions regarding the reliability of the survey in terms of locating target species such as Litoria olongburensis (Wallum sedge frog) and Mixophyes iteratus (Giant barred frog). The amphibian survey effort for the entire Caloundra road interchange area was a mere 4 people for 3 hours on one night. The proposed clearing footprint within just the Beerwah state forest section is 24 hectares. This equates to each person needing to survey 20,000 square metres per hour. This is not considered to be a sufficiently thorough survey effort to substantiate the assumptions regarding presence or absence of what are often cryptic species such as Litoria olongburensis. Mixophyes iteratus (Giant barred frog): the referral statement makes a number of assumptions regarding the impact of the proposal on this species. Namely, that the existing Bruce highway (where it crosses the Mooloolah river) acts a dispersal barrier for this species between the known significant population and the project area to be impacted. ‘Tall grassy weeds’ indicate are an ephemeral component of this habitat, present after long periods of low energy flows. During significant rain events in the wet season such grasses are either washed down stream completely or flattened by flood waters and would no longer pose any barrier to dispersal. The presence of these grasses also suggests that the timing of the surveys was not optimal. There is underlying presumption in the referral statements that there is no Mixophyes iteratus downstream of the project area. Further, the referral statement relating to the nature and likely extent of impact makes no reference to the short and long term impacts of the proposed road construction and drainage works immediately upstream of the Mixophyes iteratus population in the Mooloolah River National Park.
The 2011 surveys were undertaken on nights in sub-optimal conditions given that there was no rainfall. They were also undertaken at the end of the dry season, with only two days of precipitation in the month of November. The 2013 ‘survey’ consisted of just one night. Pink underwing moth – statement that the host vine for this species (Carronia multisepalea) does not occur within 2kms of the project area is false. It occurs on Mooloolah River immediately upstream of the project site. Beerwah state forest is a key feeding site for the Grey-headed flying fox. It is one of the few remaining large tracts (>500ha) of lowland forest remaining in South-east Queensland. It has a high diversity of food trees both in terms of blossom and fruiting trees. The impacts on Regional Ecosystems (RE’s) identified as being impacted represent an unacceptable loss to locally significant RE’s some of which are at or beyond regional/local thresholds. According to local biodiversity assessments (as identified in the Sunshine Coast Council ‘Sunshine Coast Biodiversity Background Report 2013’ which supports the Sunshine Coast Biodiversity Strategy 2010-2020’) these RE’s have been assessed as follows;
12.3.2: (which is likely to incorporate or be 12.3.1): there has been a 65% loss in this RE from pre-clearing extent
12.3.5: this is a target RE for local conservation efforts with 68% loss based on pre-clearing extent
12.3.11: has experienced significant impact with 95% lost based on pre-clearing extent
12.9-10.14: locally down 57% based on pre-clearing extent
12.9-10.1: 75% lost
Based on the locally relevant status, RE’s are considered as being ‘vulnerable’ if the loss is greater than 70% of pre-clearing extent and critically endangered if the loss is greater than 90%. Clearly, from the above status and what is proposed by this project, the Sunshine Coast cannot afford to lose any more these important RE’s which are critical for the region’s biodiversity.
Specific comments relating to (2) Detailed description of proposed action:
2.2 While road safety improvements are acknowledged, the scale of the project demonstrates an overreliance on the need for the extent of this road infrastructure out to 2041. We submit that necessary safety aspects in the medium term could be delivered through an alternative design that does not wreak the impact of the design currently proposed.
Environmental management concerns
There is no confidence that the necessary environmental management will be exercised in this area of high conservation value. The actions inherent to this proposal will exert significant impact from commencement, increase during construction/operation and destroy MNES. The indirect impacts will also be of a magnitude that will permanently impede the viability of the MNES associated with this forest. We submit there are gross deficiencies inherent in TMR’s referral reports eg the Review of Environmental Factors (REF). The paucity of detail does not acknowledge, let alone address, the values in this forest. In our view and with the knowledge of what has been omitted from the referral documents, the Impact Significance Criteria applied in the various table summaries grossly underestimate the values, impacts and risks. Furthermore, the approach taken by TMR to use a Double Early Contractor Involvement creates an uncertainty and lack of confidence around the capacity of contractors to meet the necessary standards relating to the range and intensity of issues associated with this project. Unfortunately the track record for these types of infrastructure projects is, in the main, not positive. There is a considerable amount of work still required to be undertaken to even begin to demonstrate how the risks to MNES would be mitigated/managed. For example, there is a concerning underestimation of the risks described in the Review of Environmental Factors (Attachment E) in section 5, Table 22
CONCLUSION
– This project as referred represents unacceptable impacts on MNES.
– There are significant flaws in the environmental assessments and survey methodologies
– There is a lack of detail about potential and actual impacts with a reliance on design changes arising from the tender process
– There are insufficient mitigation measures proposed for MNES
– This is a contentious project with significant community opposition to the unacceptable impact on the forest (concerns relating to removal of access to established businesses is also a major issue)
Please refer to attachments:
– Conservation Significance of the Mooloolah Logging Area-Queensland Parks and Wildlife Service
– ‘Review of Bruce Highway Upgrade Planning Caloundra Road to Sunshine Motorway Project No: 280/10A/1 by Ann Moran (Bachelor of Science)’
– MNES-Threatened species (Fauna) Likelihood of Occurrence-independent ecologist report to SCEC
– Fauna Survey 25th-28th October 2010 – Beerwah State Forest/Mooloolah Logging Area, Queensland Parks and Wildlife Service
– Map: Remnant Vegetation with manual refinement of known RE extent
– Rapid Land use assessment – Mooloolah Logging Area
– Image-Mooloolah Logging Area (behind Mooloolah Cemetery – in project footprint)
– List of SCEC Member Groups
Yours sincerely
Narelle McCarthy
Liaison and Advocacy
Sunshine Coast Environment Council
[email protected]
[1] The Swamp Stringybark is confined to southern coastal Queensland, between Kin Kin and Beerwah (Drake 1995) http://www.environment.gov.au/cgi-bin/sprat/public/publicspecies.pl?taxon_id=3160 – accessed 04May 2015
[2] Email: Dr Ian Gynther Senior Conservation Officer, Conservation Services, Queensland Parks and Wildlife Service, Southern Region – accessed 04 May 2015