To GBRMPA
via email
assessments@gbrmpa.gov.au
 
Re: PERMIT ASSESSMENT - G39785.1
 
I request  GBRMPA reconsider  their approval decision for PERMIT ASSESSMENT - G39785.1
Please see following statement of reasons.
​
1. Consultation inadequate and misleading; secrecy
There was no public consultation at all before the Application was lodged with the GBRMPA.
GBRMPA unquestionably  accepted the Queensland Government’s sham process as public consultation.  The Mission Beach Community Information Session 2016 was not public consultation – it was a presentation on behalf of the Queensland Government and the GBRMPA, and it was attended by invitation only; not open to the public.
The Project Reference Group members were selected by the State Government and were restricted to local Mission Beach residents. The meeting process was forced-choice questions leading to pre-determined outcomes. The local Environment representatives rejected both the process and the reports claimed to be the outcomes of the Reference Group meetings which were riddled with omissions, false statements and inaccuracies.
Neither the public  or  the  Project Reference Group  were informed that  an EPBC Act referral had been lodged by the Transport and Main Roads Department (DTMR), even from the Project Reference Group. As a consequence of the deliberately withheld information:
(1)    The Commonwealth Environment Department noted there WAS NOT ONE submission received.
(2)     The Federal Environment Minister was not made aware of the false claim by DTMR the Project was only slightly changed from the original project which the Commonwealth Environment Department had approved.     
 (4)    Because the public didn't know about the  referral, the deadline for comment and review passed and with it the opportunity for the development to be declared a 'Controlled Action' including a required Environmental Impact Study. (EIS)
 
2. No EIS.  Assessment through the  Public Information Package (PIP) inadequate.
It was entirely GBRMPA’s choice. Instead of a PIP, GBRMPA could have required an Environment Impact Statement (EIS) with scientifically valid and reliable surveys reviewed by experts in their fields; but they chose not to.
An EIS would have required sufficient studies to gain information to base a sound decision as to whether this large project could go ahead without causing immediate, direct, indirect, cumulative, combined and consequential impacts. Instead, the GBRMPA set the bar as low as it could – a Public Information Package (PIP) for which no detail is required.
The project described in the PIP (the only information supplied for the public to make comment on)  was the inaccurate account (outcomes)  of the Reference Group (RG) process. 

3. Inadequate surveys and no expert review   
No  detailed or accurate surveys were carried out for the Clump Point Proposal. A serious foundation flaw that affected everything else in the Assessment Process.
The GBRMPA relied on former surveys which were scientifically inadequate. They failed to identify fish and other creatures; total omitted some species; no study of dugong movements across seasons; nor of seagrass as an ephemeral and seasonal crop on which dugongs are entirely dependent.
By avoiding a proper and detailed assessment of the area the GBRMPA cannot possibly be properly informed of the impacts of the real losses the Project will cause.
Without this detailed knowledge the GBRMPA cannot properly make an assessment of cumulative, consequential and combined impacts.  
 
4. GBRMPA’s total misunderstanding of World Heritage Aesthetic Values
GBRMPA revealed its total incompetence to understand, let alone assess, aesthetic values and world heritage aesthetic values in particular. GBRMPA has no in-house expertise; to the extent it has no idea how much it doesn’t know.
The GBRMPA used concepts that describe scenic amenity, visual amenity and visitor amenity; which have nothing to do with the world heritage related aesthetic value (a natural value) that arise directly from the natural physical features and processes of the GBRWHA.
When a natural physical feature is altered (such as the unique rock structure of Clump Point), its natural aesthetic value too is altered. This impact cannot be disguised or prettied-up.  An earlier visual example is the replacement of one of the set of boulder headlands that used to form a matching and varying pattern along the Cleveland Bay face of Magnetic Island. The boulders of Bright Point have been replaced by a set of ugly apartment blocks; and an Alcatraz-like scaffolding ferry landing. The aesthetic value of that face of Magnetic Island has been lost forever.
This was the development example  the GBRMPA assessment  officer gave to the  attendees of the Information Session of how an artificial reef 'island' could be approved avoiding the requirement for the  Marine Park boundary to be realigned.  
This is where Clump Point is headed.
 
5. GBRMPA rhetoric “trust us”:  misinformation
The GBRWHA is at risk from being placed on the world heritage in danger list.
In frank denial of the facts,  GBRMPA claims "It (the GBR)  is one of the better known coral reef ecosystems in the world and remains one of the world's best managed natural wonders".
The poor state of the GBRWHA is exactly why it is at risk from being placed on the world heritage in danger list.
 
6. GBRMPA rhetoric “trust them”: DTMR claim the Application is whole of project   
The GBRMPA cites, without assessing it, a DTMR statement that the project will not be added to.
There is nothing in law or engineering to prevent this or another state government from making an application for further additions to the present Proposed Project.
The remarks in the PIP that the Queensland Government will not fund all of the project is an invitation to the interested developers who have been promoting this project for their own commercial interests. 
 
7 Limited Seasonal use -  seven wet and windy months
GBRMPA hasn't considered the highly limited seasonal use of the proposed facility as a boat landing/loading facility.  
GBRMPA has not considered the only year-round use possible – as a boat storage facility; otherwise known as a marina; or the consequential future demands for higher, longer and wider rock structure to better protect moored/berthed vessels during bad weather.
GBRMPA has not assessed the risk of vessels being cast ashore in strong winds; nor of the project becoming a large-ferry servicing new private development on Dunk Island; nor the risk of insurance requirements that the enclosure and pens be reinforced to current standards. 

8. Displacement of existing tourism operators and local recreational users. 
The existing local tourism operators were given no opportunity to provide input to the advice documents that determined the Development Plan. They were not invited to attend the Information Session or  take part in the Reference Group meetings. Their needs have not been considered during the 9 - 12 month expected construction period.  Neither has access for the  recreational users.  As a result, the economic cost to the local community has been estimated to be as high as the claimed (unsubstantiated) economic benefits.  
 
9 Djiru wishes misrepresented
GBRMPA appear to have taken Djiru response that they did not wish to meet with the Queensland Government for another meeting "because they had nothing more to say", as acceptance of the project. The Djiru people have consistently said they would not  give consent for this proposed development.
 
10 Conflicting Uses
The Clump Point headland is a strong part of the Mission Beach Community identity.  As a unique  metamorphic landform it is  appreciated and enjoyed by  locals and visitors who  understand  or who wish to learn of its social, cultural and heritage significance. The public's quiet enjoyment of the high natural and cultural values of Clump Point is often inhibited by  existing  recreational  boating activities.  The proposed development will considerably hardening  natural areas of the headland. Increased commercial and industrial activities will dominate and intrude on the tranquillity of  Clump Point and bay environs and deny access for appreciation of  a significant part of the Marine Park.    
 
11 Feasible alternatives and options to prevent harm  
Throughout the process, numerous requests by  Reference Group members  to include the  Perry Harvey Jetty in  the project were denied.  By including the jetty, the scale of the boat ramp upgrade would have significantly reduced the footprint and impacts at the Clump Point  headland.  By GBRMPA's assessment officer's own definition the boat ramp original upgrade proposal was  "..small works not a large work like this one". 
By including the jetty, larger commercial vessels would be separated from smaller vessels reducing conflict between the two. Feasible  alternatives  and options were aggressively discounted by the members of the Reference Group  who supported a marina. These were not recorded in the outcome reports.
​
Signed

The project began as a Queensland “major project of state significance” but was re-invented as “code-assessable” for automated intra-departmental tick-and-flick approval so that no public consultation was “required”.  ​

​Similarly, the Queensland government failed to notify the public, including the local Project Reference Group, when referring the development proposal to the Commonwealth Government (a requirement of the EPBC Act). The Commonwealth noted “no submissions” and happily approved it; perhaps unaware the public had not been notified, or that the contents of the Application were misleading – an obvious reason for keeping the Referral from the knowledgeable Reference Group community members. ​

​Somehow the project also avoided the Commonwealth Environment Protection (Sea Dumping) Act.

**SERIOUS SERIOUS CONCERNS**

**AND A LOT OF QUESTIONS**
At any time only 100 people could be mustered for public meetings called by Bob Katter through MBCA in favour of this development. The 90% of MBCA members who supposedly support the development was taken from a survey that only attracted a small number of people. The MBCA executive would be able to give us those figures. Perhaps around 10?
Of the supposed 600+ MBCA members, an organisation that claims to be the 'one voice' for Mission Beach, there are never more than around 40 people (Maximum) who attend meetings. They seldom take a vote on important issues. THEY HAVE NEVER INVITED A BALANCED VIEW for the marine infrastructure upgrade to be presented.
MBCA may well have over 600 people on their email database but they CANNOT CLAIM THE MAJORITY of that number agree with the Clump Point development.

Now the MBCA 'membership' is subjected to FURTHER BULLYING from its executive to AIR DIVISIVE PERSONAL OPINION using what should be an unbiased information sharing forum.

Why was Bob Katter and vested interests allowed to dominate the numbers (STACK THE MEETING) of 'community' members invited to attend the Information Session in May 2016?

Why were LOCAL MARINE TOURISM OPERATORS EXCLUDED FROM THE MEETING which, in the Qld Government words, "took some time to determine who could attend"?

Why, after Novemebr 2015, did the Queensland Government REFUSE TO COMMUNICATE with the broader community and those who had been 'stakeholders' in all discussions concerning proposed marine infrastructure development between 2011 and the end of 2015?

Why did the Qld Government (Mr Lynham) only have discussions (BEHIND CLOSED DOORS) with Bob Katter and select members of the community who claim to represent the majority of the community?

Why did the present council, immediately on gaining office, change CCRC position and exclude the the jetty from marine infrastructure upgrades? Were they part of the secret meetings with the Minister?

GBRMPA base some of their statement of reasons for their approval decision on a letter received by CCED (Cassowary Coast Economic Development) claiming the development will give a much needed boost to the Mission Beach Economy when there are NO STUDIES TO SUPPORT THIS CLAIM. The group also claims to be the peak regional Economic Development representative but no longer meet as they could not establish a purpose to continue.
Why did TMR provide false information in their referral to the Federal Government?

Why was the Reference Group not informed when TMR lodged their referral for the development proposal to have opportunity for public comment?

Why did TMR refuse to have any further communication with *SOME* members of the Reference Group following the Governing from the Regions meeting in Cairns when the Hon Mark Bailey's attention was brought to;
**SERIOUS CONCERNS AT THE HIGHLY FLAWED** Reference Group process and **FALSE CLAIMS** made by his department in their development referral to the Federal Government?
​
WE DEMAND AN INDEPENDENT EXPERT REVIEW OF THE ENTIRE PROCESS.

The GBRMPA approval came as no surprise. From the outset at the Information Session they were advising those who attended  how to circumnavigate  legislation.  How to avoid a realignment of the  Marine Park boundary by separating the rock wall from the land.  The precedent had already been set. "An example" said Kirstin Dobbs, Acting General Manager Reef Protection, who was the principle assessment officer for the project "is Nellie Bay"

It has only just now become apparent to the current marine tourism businesses who operate from Clump Point boat ramp that they will have nowhere to  transfer passengers from or to for at least 9 months during construction.

For those who are interested all the approval documents (below) can be found on the GBRMPA website here

The proposal for the  Clump Point Port/marina is based on a 'WISH LIST' produced by SOME of the members of the Reference Group.  Here's what it says in the  Public Information Package (PIP)

"The Reference Group (RG) members also provided information about a number of issues including the likely size of vessels that should be considered (see Table) and the desirable facilities to be included in any design". 

Some of  the reference group members and local marine tourism operators (who attended meetings as  'expert advisers') wanted the existing jetty to be included in the overall considerations.  Any discussion about the jetty was denied. 

The facilitator even went as far as to say "the minister would get angry if the jetty was mentioned and that he didn't like the references already being recorded in the minutes"  

The State government refused to consider input from the RG other than the range of  proposals they specifically limited to Clump Point. 

The list (above) includes two large 150 passenger cats and another 70 passenger vessel. These three vessels alone comprise 370 passengers without counting the other charter vessels on the list,  one of which is a tourist sailing boat that left the area solely because of weather conditions. (Not enough sunny days) 

When the Clump Point (now called the Perry Harvey) jetty supported a thriving tourism industry in the 80's, Dunk Island resort was operating at capacity and the Cairns reef tourism industry was limited to Green Island.   Passengers were bussed from Cairns.  Mission Beach tourism businesses experienced pressure to operate even when weather conditions were unfavourable.  Locals working on the large fast boats often described their day  by  how many paper bags were used by the passengers. 

The larger boats became non-viable when Cairns developed as an international World Heritage Reef and Rainforest  destination. 

Existing tourism businesses don't operate reef tours in weather that would cause discomfort to passengers.

International studies have shown that tourists now prefer a more personal, cultural  and natural experience that relates to a local community.    

Mission Beach has got it all and is developing a strong identity and character as a low key village atmosphere supporting boutique businesses.

The Queensland Government is leading the proposal for Clump Point. There has been:

• NO  studies to show supposed NEEDS
• NO market research to support visitor demand 
• NO statistics showing how many days a year tourist  boats can expect to operate from Mission Beach.
• NO  consideration for existing BOUTIQUE OWNER OPERATOR  MARINE TOURISM  OPERATORS
• NO  consideration for sustainable nature based tourism
• NO consideration for the dire condition of the The Great Barrier Reef Marine Park or the Great Barrier Reef World Heritage Area.
• NO consideration for long term ECONOMIC STABILITY

There are much better solutions for an upgrade of marine facilities that would give far more long term surety for businesses  and be more appropriate for a place that is positioned at the meeting of two World Heritage Areas.​

Given the large number of claims in the Public Information Package (PIP) that can be shown to be untrue - 
​WE DEMAND AN INDEPENDENT EXPERT REVIEW OF THE ENTIRE PROCESS.


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Your comments must be referenced as G39785.1. 
to assessments@gbrmpa.gov.au before 17 February 2018.
Public Information Package here​

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We obtained a letter through FOI written from the GBRMPA officer to the Federal Government (below) which claimed there has already been “extensive public consultation”. 
​                                          What was so secret that a paragraph needed to be  redacted? 
We received the following from  the Federal  Environment department in regard to the redaction. 
"Document 12 contains material that would reveal the gist of legal advice provided to the Great Barrier Reef Marine Park Authority by their legal advisors".  "I am also satisfied that release the advice would result in 'real harm' to the Department".