Alliance to Save Hinchinbrook Inc. (ASH) PO Box 2457, Townsville Q 4810 Mobile 0427 724 052 [email protected] ATT: Garry Sharman Minister for Climate Change and Sustainability The Hon Kate Jones MP PO Box 15155 City East QLD 4002 27 July 2010 by email cc John Lane c/- DERM CPU Dear Minister re retaining existing standards of ecological protection in the draft Queensland Coastal Plan. We thank the Acting Minister The Hon. Anastacia Palaszczuk and her staff for the detailed and informative letters of 17 June 2010 and 12 July 2010. Our members will be relieved to know that some important improvements will be possible in the draft Queensland Coastal Plan. In this letter we address only the following statement in the letter of 17 June 2010: The Minister is keen for John Lane and Louise Smyth of the Department of Environment and Resource Management (DERM) to continue to work through options with you and other conservation groups to ensure the implementation of the proposed Queensland Coastal plan does not result in a lowering of standards for biodiversity conservation. To this end we have collated some of the Desired Coastal Outcomes (DCOs), from the Cardwell- Hinchinbrook Regional Coastal Plan (CHRCMP) Chapter 3, assembled below in tabular form, for the purpose of ensuring that measure which achieve these outcomes are incorporated into the draft QCP.. Through these DCOs, the CHRCMP expresses prohibition and other strongly protective measures; as directed in 2.9.1 regional policy for implementing State Coastal Plan policy: Decisions and activities regarding planning, development and management within key coastal sites (map 9) and coastal localities (maps 10, 11 and 12) in the Cardwell- Hinchinbrook region are to be compatible with the desired coastal outcomes identified in Chapter 3. In general, the specificity, intent and prohibitive or restrictive power of the measures presented below are generally lacking in the draft Queensland Coastal Plan (QCP), and must be included to ensure the implementation of the proposed Queensland Coastal plan does not result in a lowering of standards for biodiversity conservation. Yours sincerely Margaret Moorhouse ASH 1 Selected CHRCMP DCOs expressing prohibition Terms denoting the topic are in bold type; some are colour coded. Tables 1(a), 1(b), 2 and 3, not discussed here, will be the subject of a further submission . 4(a) No new canals, marinas or maritime infrastructure/dredging Because the draft Queensland Coastal Plan (QCP) does not limit future maritime development (within the life of the draft plan) to the proposed Maritime Development Areas (MDA), the present highly specific prohibitions and restrictions on maritime development and dredging (presented below) would be entirely lost if not written into the draft plan. Coastal waters retain a relatively pristine and Coastal locality 1.3: Hull River wetlands (map 10) undeveloped character free of new maritime Coastal locality 4.4: Hinchinbrook Channel (map 11) infrastructure, other than essential navigation aids ... Coastal locality 5.1: Gentle Annie wetlands (map 12) Canals or dry land marinas are not developed. Coastal locality 7.4: Forrest Beach to Crystal Creek wetlands (map 12) Canals or dry land marinas are not developed . Coastal locality 3.1: Tully – Murray wetlands and dunes (map 10) Coastal locality 5.4: Taylors Beach wetlands and dunes (map 12) Coastal locality 7.1: Forrest Beach wetlands and dunes (map 12) Key coastal site 2: Family Islands (maps 9 and 10) Canals or dry land marinas are not developed in this Key coastal site 3: Kennedy (maps 9 and 10) coastal locality between the Tully River and Cardwell, including the coastal waters of the Tully River, Murray River, Dallachy Creek, Wreck Creek and Meunga Creek ... Coastal waters in the Murray River to Meunga Creek wetlands and dunes (coastal locality 3.6) retain a relatively pristine and undeveloped character free of new maritime infrastructure, other than essential navigation aids. New private maritime infrastructure or intensive uses Coastal locality 2.3: Richards (Bedarra) Island (map 10) are confined to the existing intensive use areas. No new capital dredging occurs. Coastal locality 4.4: Hinchinbrook Channel (map 11) Future maritime infrastructure at Dungeness is small Coastal locality 5.2: Dungeness (map 12) scale ... 2 4(b) aquaculture and agriculture Because the draft QCP does not adequately address aquaculture and mariculture, the present specific prohibitions and restrictions on aquaculture and agricultural drainage (presented below) would be lost if not written into the draft plan. Water quality standards generally are not adequate for high ecological value coastal wetlands. Discharge licences are licences to pollute; this is unacceptable along this coast. The benthic communities of the Great Barrier Reef World Heritage Area - particularly seagrasses - require protection from ALL human-induced additions of nutrients, chemicals and sediments (specially colloids), which encourage inappropriate growth of algae and weed, reduce light penetration, and foul marine plants. Dilution is not the solution to pollution. New land-based aquaculture does not adversely affect Coastal locality 7.4: Forrest Beach to Crystal Creek the values of this site’s coastal resources, particularly the wetlands (map 12) coastal wetlands. Key coastal site 4: Hinchinbrook (maps 9 and 11) Existing and new land-based aquaculture does not adversely affect the coastal resource values, particularly of the Hinchinbrook Channel and adjoining estuarine communities. Drainage schemes and agricultural development Coastal locality 7.3: Allingham/Mungalla wetlands (map within and adjacent to this coastal locality do not interfere 12) with the natural hydrological functioning of the wetlands. No new aquaculture development occurs. Key coastal site 2: Family Islands (maps 9 and 10) 5(a) Landscape/Scenic; WH aesthetic values/integrity The draft QCP deals poorly with world heritage aesthetic and wilderness values. The directions below, which now guide assessment managers including local councils, are generally stronger than the measures proposed in the draft QCP; representing a reduction in protection levels when compared with the CHRCMP. Natural scenic landscape values which are part of the Key coastal site 1: Hull (maps 9 and 10) area’s World Heritage values are maintained , particularly in and adjoining areas with high or very high scenic coastal landscape values (e.g. the coastline from Wongaling Beach to Tully River and the Walter Hill Range), through ensuring minimal visual impact from commercial and residential development. The scenic coastal landscape values of the prominent Coastal locality 1.2: Tam O’Shanter Point (map 10) coastal headland at Tam O’Shanter Point are protected from incompatible development and activities. The very high natural scenic landscape values are Key coastal site 2: Family Islands (maps 9 and 10) maintained and coastal development has minimal impact on coastal resources and coastal processes. The very high scenic coastal landscape values of the Coastal locality 3.1: Tully – Murray wetlands and dunes open coast at the mouths of the Tully and Murray rivers (map 10) are maintained . The site’s overall high natural integrity and outstanding Key coastal site 4: Hinchinbrook (maps 9 and 11) biodiversity, which are part of the area’s World Heritage 3 values, are maintained , including: ... The very high natural scenic landscape values of the passage landscape comprising the Cardwell Range escarpment, Hinchinbrook Island and Hinchinbrook Channel, a re maintained with minimal visual impact from commercial and residential development. The very high scenic coastal landscape values of Coastal locality 4.1: Garden (Tindappah) Island (map 11) Garden (Tindappah) Island are protected from Coastal locality 4.4: Hinchinbrook Channel (map 11) incompatible development and activities. Any future development of Port Hinchinbrook is low- Coastal locality 4.2: Port Hinchinbrook (map 11) key and can demonstrate that coastal resources and their values are not adversely affected ... Any future development of Port Hinchinbrook should also demonstrate minimal adverse impacts on the scenic values of the Hinchinbrook Channel. The very high scenic coastal landscape values are Coastal locality 4.3: Hinchinbrook Channel scenic rim maintained. (map 11) Coastal locality 4.5: Hinchinbrook Island (map 11) Natural scenic landscape values which are part of the Key coastal site 5: Herbert (maps 9 and 12) area’s World Heritage values are maintained , particularly in and adjoining areas with high or very high scenic coastal landscape values (e.g. the open coastline from Taylors Beach to Lucinda), by ensuring minimal coastal visual impact from commercial and residential land use . 5(b) Building height and screening The directions below now direct assessment managers, including local councils, when assessing development. If these specific measures are not represented in the draft QCP the result would be a reduction in protection level when compared with the CHRCMP. The reference to the Deed of Agreement for "Port Hinchinbrook" gives teeth to an otherwise toothless (ex- legislative) agreement. The draft QCP entirely lacks this protective measure. Buildings are screened with native vegetation to Coastal locality 2.1: Dunk (Coonanglebah) Island Spit complement the landscape character and do not exceed and associated freehold land (map 10) two storeys. Coastal locality 4.5: Hinchinbrook Island