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.