Jane MacDonald - Save Ralphs Bay

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The Panel assessment and findings on page 21 of the DIAR appear to restrict discussion to the topic of sediment plumes, without considering dissolved metals, which are especially concerning because of their likely high bioavailability for uptake, bioaccumulation and biomagnification up the food chain. These matters are perhaps more relevant to section 2.2.1. 3.3.2 Flushing, sedimentation and dredging (Section 2.1.9) I fully support the Panel’s conclusions that, “Sediment transport and, or, build‐up in the internal canals and the main navigation channel remains a concern which cannot be modelled with certainty. The implications of more frequent maintenance dredging remain in issue – particularly if this responsibility devolves to Clarence City Council (see section 2.10.1 of this draft Report).” And, “this aspect would require greater certainty – including resolution of the question as to who is to be responsible for maintenance dredging.” On page 43, it may be that Dr. Treloar noted that the CSIRO figures show net export of sediment “into” the River Derwent from Ralphs Bay (rather than “from the River Derwent from Ralphs bay”). 3.3.3 Pied Oystercatchers It is not clear why this appears in the “overwhelmingly outweighs” section and also the “other risks and uncertainties” list of the draft recommendations. I fully support the conclusion that threats to the Pied Oystercatcher are one of the factors which “overwhelmingly outweighs” any potential economic benefits of the proposal, and I consider that, in using the phrase, “an unacceptable result”, the Panel also gives this issue the higher priority level. 3.3.4 Spotted Handfish I support the Panel’s conclusions in respect of the Spotted Handfish. However, I would give this matter higher priority, given that the Spotted Handfish is already listed as Critically Endangered by the IUCN. Synergies between threats do not appear to have been considered, nor the risk of toxicity resulting from the remobilisation of heavy metals in dissolved form, nor the hydrological modelling of potential movement of dissolved metals out of Ralphs Bay and through nearby handfish colonies. On page 42 of Part B of the Save Ralphs Bay submission on the DIIS, we requested, “that the RPDC panel considers seeking a briefing from CSIRO scientists in the fields of hydrology and sediment transport regarding the possibility that pollutants disturbed by the proposed Jane MacDonald, submission on DIAR Page 12
“development” might travel to the Opossum Bay MPA or even right around the coast to Frederick Henry Bay, home to spotted handfish and red handfish colonies outside the Derwent estuary.” It does not appear that CSIRO hydrological modelling has been taken into consideration. Has there been an inadvertent omission of “issues raised in written representations” or “issues addressed at the hearings”, in this section of the DIAR, before the “Panel assessment and findings” on the Spotted Handfish on page 88? 4. Topics not mentioned in the draft recommendations 4.1 Sea level rise I was surprised that the Panel did not consider sea level rise to be an issue of significance in the case of a decision regarding the construction of a housing subdivision in the sea. It is my belief that frivolous construction projects in the marine environment cannot possibly be consistent with the application of the Precautionary Principal. Reliance on any particular engineering standard for sea level rise reminds me of King Canute’s (alleged) confidence in his ability to command the waves to stay back. I request that the Panel gives further consideration to the seriousness of the risk of much higher than anticipated sea level rises, coupled with increasingly severe weather impacts. I would like to draw the Panel’s attention to matters raised in a number of extracts from the ‘Climate Change Risks to Australia's Coasts’ report, released by the Australian Government Department of Climate Change on November 14. (Emphases added). KEY FINDINGS • Climate change risks in the coastal zone are large, increasing and in some areas will be felt in the near term. While these risks will unfold over time, there is a case to begin now with early national action to reduce current risks and avoid the building of new exposures. • Avoidance of future risk is the most cost‐effective adaptation response in most cases. Decisions on future development, particularly in areas highly exposed to the impacts of climate change, should not increase risk. • Natural ecosystems provide valuable ecosystem services and can buffer many of the risks associated with a changing climate in the coastal zone. Planning is needed to maximise system resilience, allow for ecosystem movement and make explicit decisions about tradeoffs. Jane MacDonald, submission on DIAR Page 13
Page 1 and 2: Jane MacDonald November 22 2009 Sub
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Page 15 and 16: Australia have been weather related
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Jane MacDonald - Save Ralphs Bay

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