Above Referral was listed on the EPBC site 10/7/14. It includes the proposed clearing of extremely significant vegetation of the entire southern development area in NSW (GCA site S/E) of 31.7ha, realignment of Coolangatta Creek (GCA now reference as airport drainage reserve) and earthworks. The Referral falsely states,“Coolangatta Creek commences at Betty Diamond Park” when the catchment of this Creek starts west of Tugun Heights (Tugun Bypass EIS Fig.8.5).
Realignment of Coolangatta Creek to GCA southern boundary is to the area severely impacted from oxidation of ASS resulting in extreme levels of acid/heavy metal contamination of groundwater (and at times surface water) from construction of the Tugun Bypass. Contrary to claims these conditions still exist (the genie is now out of the bottle).
There is of course no reference to this matter in the Referral which I believe was obligated to inform the department of the consequences of disturbing the hydrological regimes of these complex Cobaki ecosystems. The Referral simply states, “ASS investigations identified generally low actual ASS and potential ASS” and makes no acknowledgement that g/w flows and GCA’s drainage system in this area flow to the Cobaki Broadwater(CB), so will potentially substantially increase the severity of the ASS leachate entering this estuary – significant migratory wader habitat and a Class 1 Fishery.
Coolangatta Creek discharges from GCA to the lower reaches of this Creek with the outfall to Kirra Beach so potentially this will also be subject to ASS leachate contamination. Also with airport developments on both sides of the Tugun Bypass tunnel terminating hydrological regimes and exacerbating the oxidation of ASS will potentially result in increased impacts to the structural integrity of the concrete tunnel immersed in such acidic conditions.
Of interest is the covering letter advising the department of a recent Koala sighting at GCA. About 10yrs ago NSW NPWS found the remains of a Koala on the eastern side of CB.
Also, the GCA site is an integral part of the Murraba Landscape which is of extreme importance to the local Aboriginal community and this community have been thwarted at every step for proper consultation and management of their cultural heritage. (refer to pg.16/46 re indigenous stakeholder matters)
This Referral is most bizarre as at GCA CACG meetings since 12/13 we have only been advised of the pending ILS Major Development Plan (MDP) on the NSW Crown Reserve, there has been no mention of the above MDP!!!
It is justified that this proposed action is a Controlled Action under the EPBC Act and should require a full EIS.
Please fwd onto those who would wish to make comments on this matter.
Comment on the Referral as referenced above is open for 10 business days to;
epbc.referrals @environment.com.au; or
Referrals Gateway
Environment Assessment Branch
Department Environment
GPO Box 787
Canberra, ACT 2601
Many thanks.
Regards
Lindy
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Dear Sir/Madam,
COMMENT: EPBC REFERALL 2014/7266 – GOLD COAST AIRPORT PROJECT 2018
APPLICABLE LEGISLATION.
The above referral is most concerning and I query the legalities of Project 2018 under applicable Legislation governing development on airport sites.
The purpose of the ‘Airports Amendment Bill (12/10)’ was to amend the Airports Act with key changes including certain Airports (GCA included) establishing a ‘Community Aviation Consultative Group’ (CACG) to undertake regular and ongoing consultation including with state governments, local authorities and the community to improve information on the development of airports.
As a member of the GCA CACG we have only been advised of the pending Major Development Plan (MDP) for an Instrument Landing System (ILS) on NSW Crown Reserve 59260 for Public Recreation (attached) which will permanently destroy the migratory wader roost site (protected under Jamba/Camba Agreements) and significant area of salt marsh community. Hence the above referral is most bizarre!
Project 2018 comprises key elements including, “initial extension of the current terminal…” Extension of the current terminal is not included in the development plan (fig.7.2) in GCA’s current Master Plan 2011 (MP) which specifies the developments for the 5yr period of the MP, hence this element of Project 2018 and clearing of the entire 31.7 ha and earthworks for the total expansion into the ‘Southern Development Area’ (fig.1) is not consistent with the final MP.
The Airports Act: Part 5; Division 3 – Airport Master Plans (71) specifies matters that MUST be set out in each MP for an airport, i.e. “the airport-lessee company’s intentions for land use and related development of the airport site, where the uses and developments embrace airside, landside, surface access and land planning/zoning aspects.”
Division 4 – Major Development Plan (91), “a MDP is required for each major development at an airport which MUST be consistent with the final MP for the airport.”
REALIGNMENT OF COOLANGATTA CREEK
Pg.4, “The existing drainage reserve within the airport commences at Betty Diamond Park” is false/misleading. Historically and in all previous GCA documents until the 2011 MP this has been Coolangatta Creek with the catchment of this creek commencing west of Tugun Heights (Tugun Bypass EIS fig.8.5).
Realignment of Coolangatta Creek to GCA’s southern boundary is to the area severely impacted from oxidation of ASS resulting in extreme levels of acid/heavy metal contamination of groundwater (g/w) and die-back from construction of the Tugun Bypass. i.e. PH reduced to 1.4, Iron levels reached 1740mg/L, Aluminium 381mg/L. Contrary to claims the site has stabilised associated ASS conditions still exist confirmed by lab data and extensive photo evidence including huge loads of iron oxide scum (the genie is now out of the bottle).
There is no reference to this matter in the referral and the consequences of disturbing the hydrological regimes of these sensitive and complex Cobaki ecosystems in the southern boundary area which include layers of coffee rock, organic matter and perched water tables. The referral simply states ASS investigations identified“generally low and potential acidity.” (pg.38)
The realignment of the creek will have significant and permanent impacts to hydrological regimes including significant adverse impacts on the NSW Crown Reserve immediately adjacent and the Cobaki Broadwater (CB). G/W flows in this area are to the south and west and GCA’s drainage systems in the southern boundary area flow into the CB, so will potentially substantially increase the severity of ASS leachate entering the estuary – significant migratory wader habitat and Class 1 Fishery. Further exacerbating the oxidation of ASS in this area will also potentially result in increased impacts to the structural integrity of the concrete tunnel immersed in such increased acidic conditions. The discharge from GCA to the lower reaches of Coolangatta Creek with the outfall to Kirra beach will be potentially subjected to ASS leachate contamination and increased pollutants of stormwater runoff and quantity of runoff.
Alteration of g/w hydrological regime in the Cobaki ecosystems has caused subsidence and as a coastal lowland processes will be altered. Project 2018 substantially increases impervious surface and diversion of surface water which will substantially permanently terminate g/w recharge and surface water regimes to the extremely sensitive and significant ecosystems of the Crown Reserve and CB downstream of the GCA site impacting on EPBC listed species/habitat.
MATTERS OF NATIONAL ENVIRONMENTAL SIGNIFICANCE
The S/W area of GCA, the NSW Crown Reserve immediately adjacent and CB are of very high environmental significance, i.e. threatened species and EEC’s (including EPBC listed species), habitat, corridors and also significant Indigenous heritage values.
Wallum Sedgefrog: Project 2018 will permanently destroy known locations and habitat of this species. It must be noted there are further known locations of this species and habitat that will also be destroyed with further developments on the west of the GCA site. To add to this the ‘Tugun Bypass Frog MP-5yr Review’ confirms the 4 compensatory ponds for this species on GCA was a total failure (pg.38/9). Hence it must be considered there will be a real risk of local extinction of this species and due to its specific habitat requirements warrants identification as an ‘important population’ for its survival/recovery.
Grey-headed Flying Fox: The project will result in the removal of substantial foraging habitat for this species with the potential cumulative impacts to further significant foraging habitat downstream from altered hydrological regimes and oxidation of ASS. This species is under duress from impacts to foraging habitat and research has indicated that the species is secreting the deadly Hendra virus when stressed. It must be noted there are horse establishments in close proximity to the south, west and north. Climate change and increased intensity of weather events needs to be considered for this species.
Listed migratory species: The Cobaki ecosystems is recognised as significant habitat for bird species including Listed migratory species/threatened species with records of more than 200 species of which more than 20 are Listed migratory species. The significant state protected wetlands and CB downstream of project 2018 which provide important habitat for Listed migratory species will potentially be significantly impacted from altered hydrological regimes and exacerbation of ASS leachate discharging into vital habitat.
Phaius australis: A colony of this species is on the NSW Crown Reserve in very close proximity to GCA southern boundary (the area of Coolangatta Creek alignment). This colony has been documented as, “probably the largest remaining colony of this endangered orchid left in the wild.” Such substantial termination of g/w and surface water hydrological regimes and further exacerbating oxidation of ASS just upstream of this colony will significantly impact on this important population potentially causing its local extinction.
Conclusion: The Cobaki ecosystems are part of a priority area of high conservation which is the ‘only area of the Southern Coastal Lowlands Interim Biogeographic Regionalisation for Australia subregion included in NSW.’ (NSW Far North Coast Regional Conservation Plan; fig.1,pg.6/59)
Realignment of Coolangatta Creek poses enormous risk to these ecosystems that are vital for the survival of many matters of national environmental significance downstream of Project 2018, along with potential increased impacts to major infrastructure immersed in groundwater. Potentially the degree of harm will be permanent/irreversible – tipping these important ecosystems over the edge.
Regards
Lindy Smith
