Mary Basin WRP legislation released

[SteveB]

Just been informed that the Mary Basin Water Resource Plan is now legislation.

Here is the document. It is not up on the NRM Water Resource Plan website yet but it is up on the legislation site.

www.legislation.qld.gov.au/LEGISLTN/SLS/2006/06SL192.pdf

Had a quick look through at the environmental flow objectives and the news for downstream of the dam site seems to be essentially unchanged from the draft. ie. all the criticisms in the Save the Mary River Tech Note #2 still stand, the legislation does not protect the river from serious environmental flow impacts downstream of the proposed dam site.

However, it is encouraging to note that this legislation had some difficulty being approved by cabinet - perhaps an encouraging sign of division in the ministerial ranks.

I have not had time yet to carefully study the entire legislation and compare it with the draft that was available for public comment - perhaps others would like to check this out as well.

The next stage of the legislative process is the Resource Operations Plan, for which the public and scientific community will be well prepared. There will be no way that the government will be able to slip dodgy flow schedules through this next process now that the government's real intentions are known. The public should become deeply involved in "keeping the bastards honest" (to use a well known quote)in this next process.
_________________
"Bad luck ... you dickheads. Suffer in your jocks". (from: the Castle)

[Darren E]

Thanks for posting this steve.
80 pages of bureaucrat-speak. Fun fun fun.

[SteveB]

As I posted previously, the Mary Basin Water Resource Plan became legislation on Friday 28th July. You can compare the document that became law with the draft that was released for public comment on the NRM website - both copies are now there.

www.nrm.qld.gov.au/wrp/mary.html

Myslightly more detailed reading is that this legislation could be very bad news for the Mary downstream of the proposed dam site - worse than in the draft.

The monitoring sites downstream of the dam do not even have to comply with some of the the flow regimes outlined in the legislation - they only have to "minimise the extent to which flows are less than" the percentage flows outlined in the schedule. For example, the legislation states that river should be managed to "minimize the extent" to which predicted Mean Annual Flows at Fisherman's Pocket are less than 70% of pre-development flows.

An entire new section has been added to the legislation which allows the granting of interim resource operations licences to access the "Strategic Reserve" of 150000ML per year before the framework of a resource operations plan is established- simply on the approval of the executive. There is a public consultation process in the Resource Operations Plan framework - but there does not seem to be any public consultation required in the granting of an interim resource operations licence under this entirely new and previously unseen addition to the legislation. It seems on my reading that this would allow Queensland Water Infrastructure to licence a dam with no public input to its operations plan at all.

Downstream environmental flow schedules are worse than in the draft, particularly with respect to minor flushing flow events , for example the size of 1.5 year flushing flows at Fisherman's pocket can be reduced to 42% of pre- development flows under this legislation.
This is far more severe than the figures presented to the public in the draft.

If there are people of a legal or scientific bent who have the time to go through this document - could you please do so and post your findings here or contact me.

I thought I heard the Premier say that we lived in a democracy. What planet does he live on?
_________________
www.savethemaryriver.com - spread the word!
_________________
"Bad luck ... you dickheads. Suffer in your jocks". (from: the Castle)

[FOSS]

The efos for the plan for mean annual flow concerning medium and high flows at the Mary mouth , are now to "minimise the extent to which the MAF is less than 85%. If this is not an admission that the much claimed "85% MAF into the Great Sandy RAMSAR", will not be achieved in combination with a strategic reserve of 150,000 mgl , what is it?

[Darren E]

FOSS, not just an admission, it's an open door to the company operating the dam to do what they please. You can use the courts if necessary to enforce something like "MAF shall not be allowed to be less than 85%....".
But how can you enforce "minimise the extent to which the MAF is less than 85%.....".

[FOSS]

MEDIA RELEASE TUESDAY 1ST AUGUST 2006

ENSURING OR MINIMISING MEAN ANNUAL FLOW FOR THE MARY?

“The Water Resource (Mary Basin) plan 2005, has set environmental flow limits below those listed in the draft plan released for public comment in November last year”, said Roger Currie today , spokesperson for the Mary Basin Sustainable water resources consortium.

This is an admission by the Qld government that it can’t meet its claim of 85% of mean annual flow (MAF) for medium and high flow objectives at the river mouth and have a strategic reserve of 150,000 mgl. These are the essential triggering flows for fisheries production.

The Mary Basin Water Resource Plan minimum requirement of 70% of the pre-development flow at Fisherman’s Pocket 35km
downstream of the proposed dam wall) could be achieved by allowing the river downstream from the dam to run bone dry 94% of the time.


The draft plan stated that the MAF medium and high flow objectives for the Mary River mouth must be at least 85% , “but the Plan now states that these objectives are now to minimise the extent to which the flow is less than 85%”, and this indicates that the strategic reserve will reduce flow to less than 85%”, said roger.


FOR MORE INFORMATION CONTACT

ROGER CURRIE 41233361
SCOTT ALDERSON 54415747
HARRY JAMIESON 41292121

[tausyankee@optusnet.com.a]

Foss,

What effects would there be on the Great sandy ecology if Mary is allowed to run dry downstream from the dam 95% of the time, do you think?

[FOSS]

a reduction in nutrients and sediment which would impact seagrass communities , dugongs , fish habitas , fish creches, possibly crustacea spawning rythms, massive explosion in mangrove fecundity due to hypersaline effects (less fresh) , potential reduction in wader bird food resources, potential collapse of mullet, flathead, barramindi , banana prawn stocks, and other estuary dependent species. ALLspecies , habitats and marine ecotones are linked , right up to the whales, what effects occur along the chain must be investigated , not blindly ignored and all of the economic sectors which rely on this linkage must start whinging very , very loud to the people of brisy.

[tausyankee@optusnet.com.a]

[FOSS]

The Mary is hyrologically linked to the RAMSAR, the federal minister cant ignore it and he promotes himself as an international whale hugger doesnt he?

[tausyankee@optusnet.com.a]

Any disregard of the Lungfish et al. will show the Minister's whale antics for what they are - populist clap trap.

[Darren E]

The WRP identifies 3 "nodes" on the Mary River downstream of the dam wall, where certain flow objectives are identified. As previously noted, some of these flow objectives have "no teeth" because the legislation uses weasel words such as "minimise the extent to which ...".

There are some other troubling aspects related to the monitoring nodes which I believe are worthy of comment.

The nodes are:

• Node 1: River Mouth, approx 205km downstream of dam wall
  
• Node 2: Home Park, approx 114km downstream of dam wall
  
• Node 3: Fisherman's Pocket, approx 34km downstream of dam wall
  

In the legislation, one of the key "Medium to High" flow objectives (see pages 61-63) is the mean annual flow, expressed as a percentage of the mean annual flow for the pre-development flow pattern, or %MAF. In the Save The Mary River Technical Note Series (1) it is demonstrated that %MAF is a poor statistic for describing river flow behaviour. Nonetheless, it is probably the simplest to understand, and also the most often quoted by the Premier and other politicians.

The %MAF flow objectives in the legislation are:

• Node 1: must be at least 85%
  
• Node 2: minimise extent to which it is less than 79%
  
• Node 3: minimise extent to which it is less than 70%
  

My concerns are:

1. Why is there no monitoring node at the dam wall? Historical data at the Dagun Pocket monitoring station (approx 1km from wall) is publicly available dating back to 1957, and I understand the DNRM has 110 years of historical data. The flow models used in the WRP must certainly model the flow at this point, or it would be impossible to model downstream flows.
   The flow disruption on the Mary River immediately downstream of the dam wall, before the inflows from other creeks, must certainly be greater than at the three nodes specified in the WRP. Could this be why there is no monitoring node at the wall location?
   
   
2. By correlating the publicly available historical flow data from Dagun Pocket, Fisherman's Pocket and Home Park, it is possible to back-calculate the likely %MAF at Dagun Pocket based on corresponding figures from the other nodes.
   79% at Node 2 (Home Park) corresponds to around 51% at Dagun Pocket.
   70% at Node 3 (Fisherman's Pocket) corresponds to around 59% at Dagun Pocket.
   
   
3. Node 1, at the River Mouth, is not actually a real monitoring station. It is a "virtual node". There is no actual historical measured data at this point. This is a very serious concern, especially given that it is the only node in the legislation that doesn't have weasel words in the %MAF flow objective. I make a living from modelling flow rates in industrial process plants, and I can assert that any flow model is only as good as the data against which it is calibrated. We call this principle "garbage in, garbage out".
   At the other nodes, the flow models are not only calibrated against up to 110 years of measured data, but it will also be possible to continually benchmark the modelled flows against real measurements. Not so for Node 1 at the River Mouth. The WRP legislation does not include a single word as to how the flow at Node 1 will be modelled, calibrated or monitored.
   

[Rev Watt]

So Darren the legislation requires the dam continues to allow 85% flow (well not too much under, too often anyway) at the river mouth. That is 85% of - well nobody knows - because there are no previous measurements there.
OK and is this nobody nodes what place being measured at high tide?, low tide? neap tide? spring tide? outgoing or incoming?

_________________
Everyone who drinks this water will be thirsty again, but whoever drinks the water I give him will never thirst. John 4:13f

[Darren E]

You got it, Rev Watt.
Achieving the Premier's oft-quoted 85% modelled flow at the river mouth will be very simple indeed - just adjust the data-free bodgy model until it gives 85.1% as the answer.

Hey, the same idea could be used to ensure no damage is done to the Great Sandy ecosystem. Just model a whole lot of happy, carefree fish, whales etc. much like that popular aquarium computer screen-saver.

[Rev Watt]

Oh I see just like the happy lungfish using the ladder at Paradise Dam.
The ones that have avoided the seabirds feasting on the fishfood basket that goes by up and over the wall.
_________________
Everyone who drinks this water will be thirsty again, but whoever drinks the water I give him will never thirst. John 4:13f