WWF-Australia Level 1, 17 Burnett Lane Brisbane QLD 4000 Postal: same as above Tel: +61 7 3003 1480 Fax: +61 7 3229 4431 [email protected] @ WWF_Australia wwf.org.au ABN 57 001 594 074 Mr Dale Bell Senior Planning Officer Department of Natural Resources and Mines South Region Centenary Square Building 52-64 Currie Street, PO Box 573 NAMBOUR QLD 4560 Email: [email protected] Cc: James Purtill Director-General Department of Natural Resources and Mines Email: [email protected] Date: 11th December 2015 Re: MSF application to lease Unallocated State Land (USL) at Churchill and Granville in the Wide Bay Burnett region Dear Sir, WWF-Australia welcomes this opportunity to provide the following comments regarding the assessment of the Most Appropriate Use (MAU) that DNRM is conducting under section of the Lands Act 1994 for parcels of Unallocated State Land (USL) at Churchill and Granville in the Wide Bay Burnett region, which MSF’s is seeking to lease to grow sugarcane for ethanol production. Summary of key issues: Key issues associated with the proposed use of the USL at Churchill and Granville include: • Significantly increasing sediment, nitrogen and pesticide loads, which will cause further degradation of marine water quality thereby breaching Governments commitments to reduce water quality impacts under Reef Plan and the Reef 2050 Long Term Sustainability Plan. • Causing significant impacts to threatened species through the removal of essential habitat. • Altering catchment hydrology, which will cause significant adverse impacts to groundwater dependent ecosystems, wetlands and the Great Sandy Straits Marine Park. • Disrupting ecological connectivity, which will impede the migration of terrestrial species. • Causing significant greenhouse emissions as a result of vegetation clearing. WWF Australia is confident that an objective evaluation of the most appropriate use would find that use to be nature conservation. 1 1. Physical values of the land The Fraser Coast region is recognised nationally and internationally for its unique environmental values, which provide a wide range of socioeconomic benefits that underpin the regions tourism industry and liveability. As they are in relatively pristine ecological condition, the parcels of USL at Churchill and Granville have been classified as having high ecological significance under the Wide Bay Burnett Regional Plan (Queensland Government 2011). Due to their intact ecological values, the parcels of USL at Churchill and Granville provide an array of essential ecosystem services and functions such as maintaining water quality in waterways and the Great Sandy Straits Marine Park (also a RAMSAR listed wetland), providing habitat that supports a variety of species, storing carbon, protecting important fish habitat areas, groundwater dependent ecosystems and providing connectivity to enable species to migrate between protected areas (map showing state wildlife corridors and ecological connectivity shown is Appendix 1.) Species likely to been found on the USL at Churchill and Granville are shown in Appendix 9 relative to nearby protected areas (Atlas of Living Australia 2015). 2. Constraints affecting potential use of the land Key constraints affecting the proposed use of the USL at Churchill and Granville to grow sugarcane to produce ethanol includes: • Biodiversity loss: The clearing of remnant vegetation that will occur as a result of the proposed use of the USL will cause significant adverse impacts to endemic flora and fauna species – many of which are protected under the Nature Conservation Act as well as the Commonwealth Environment Protection and Biodiversity Conservation Act. • Alteration of catchment hydrology: Changes that occur to surface water flows and groundwater recharge as a result of the proposed use of the USL will significant alter the hydrology of the Susan River catchment, which will cause adverse impacts to the wetlands, groundwater dependent ecosystems and marine receiving waters, the Great Sandy Ramsar site in particular. • Loss of ecosystem services and functions: Due to the resulting vegetation clearing and significant alteration of catchment hydrology, the proposed use of the USL will result in a significant loss of the ecosystem services and functions that are currently provided by the parcels of land at Churchill and Granville, which will cause significant adverse impacts to waterways, wetlands, groundwater dependent ecosystems and marine receiving waters • Increased agricultural pollution: The cause of poor marine water quality leading to the increased regularity and severity of Crown of Thorns Starfish has been attributed to the increased levels of sediment, nitrogen and pesticides entering the GBR lagoon in runoff from sugarcane production areas. Based on current estimates of pollutant loads from the Burnett-Mary region, converting 4000 ha of USL that is in relatively pristine condition to sugarcane production will release an additional 856 tonnes of sediment, 16.7 tonnes of DIN (totally bioavailable nitrogen) and 70 kg of PSII herbicides per year to the regions waterways. This has the potential to cause significant adverse impacts the quality of marine receiving waters and degrade sea-grass areas • Soil suitability: The Land Suitability for Irrigated Sugar Cane Report produced by DNRM shows the USL at Churchill and Granville predominantly contain Class 4 and 5 soils, 2 which are unsuitable for sugarcane and most crop production. • Climate Change: As rainfall across the region has fallen below long-term averages over recent years on a consistent basis due to climate change, this indicates that non- irrigated sugarcane production in the Wide Bay Burnett region is not viable. • Environmental offsets: As the USL in question contains matters of state and national environmental significance (MSES, MNES), the proponent of the proposed use of the USL will be required to offset any residual adverse impacts that occur to protected species and ecological communities. Under the Environmental Offsets Act 2014, the proponent can either provide a land based offset or a financial settlement. For example, offsetting just 1000ha of Regional Ecosystem 12.3.11 the predominant RE on the Churchill that will be significantly impacted by the proposed use of the USL would amount to approximately $61 m • RAMSAR listed wetlands: Water quality degradation caused by increased sediment, nitrogen and pesticide loads as a result of the proposed use of the USL is likely to cause adverse impacts to the values of the RAMSAR listed Great Sandy Straits Marine Park, which will affect dugongs, turtles and other marine species. 3. Consideration of any interests in the land When assessing the Most Appropriate Use (MAU) for the Unallocated State Land (USL) at Churchill and Granville, full consideration must be given to: • The socioeconomic benefits that are delivered by the ecosystem services and functions provided by the ecological values of the USL, for example: maintaining water quality, reducing flood velocity, protecting fish habitat areas, reducing GHG emissions and others; • Whether the proposed use of the USL will degrade environmental values that underpin the regions tourism industry; • Whether the proposed use of the USL aligns with the Queensland and Australian Governments commitments to UNESCO contained in the Reef 2050 Long Term Sustainability Plan; • Nearby areas that are suitable for sugarcane production where land clearing has already occurred. A list of lot numbers of already cleared suitable land is also contained in the Wide Bay Burnett Environment Councils submission to this assessment (Map showing areas suitable for sugarcane production shown in Appendix 4.) 4. State, regional, local and other strategies and policies State, regional, local and other strategies and policies that must be taken into consideration when assessing the Most Appropriate Use of the USL at Churchill and Granville includes: 4.1 Vegetation Management Act 1999 (VMA) As the proposed use of the parcels of USL in question will involve significant clearing of regualted vegetation, it is essential the MAU assessment must take into account the purpose of the VMA, particularly whether the proposed use of the USL will: • Conserve endangered regional ecosystems, of concern regional ecosystems and of least concern regional ecosystem under s3 (1) (a) • Not cause land degradation under s3 (1) (c) • Not cause biodiversity loss under s3 (1) (d) 3 • Ensure ecological processes are maintained under s3 (1) (e) • Reduce greenhouse gas emissions under s3 (1) (g) https://www.legislation.qld.gov.au/legisltn/current/v/vegetmana99.pdf (Map showing extent of regulated vegetation shown in Appendix 2.) 4.2 Water Resource (Mary Basin) Plan 2006 As the proposed use of the USL has the potential to cause significant impacts to water resources, it is essential that the objectives and strategies contained in the Water Resource (Mary Basin) Plan 2006 are taken into account when undertaking the MAU. In particular, the MAU assessment must consider whether the proposed use will: • Have a detrimental affect on achieving the ecological objectives of the Water Resource (Mary Basin) Plan 2006, and • Cause adverse impacts to the Environmental Flow Objectives (EFOs) and Water Allocation Security Objectives (WASOs) contained in the Water Resource (Mary Basin) Plan 2006 http://www.legislation.qld.gov.au/LEGISLTN/CURRENT/W/WaterReMaryP06.pdf 4.3 Environmental Protection (Water) Policy 2009 As the proposed use of