W
ARNING No 3
MORE BROKEN MITIGATION PROMISES
A CASE STUDY
October 2007
The Coffs Harbour – Clarence Valley Regional Water Supply Project provides ideal
material to illustrate the way in which consent conditions are flouted, manipulated or
ignored. One such mitigation promise related to the potential introduction of weed
species into high conservation value habitat, and the Chambigne Nature Reserves.
This potential problem was identified by the then National Parks and Wildlife
Service, and was addressed at some length in the various documents presented to the
public for comment, including the 1999 Environmental Impact Statement (EIS).
Page 10.48 (EIS, Vol. 1) lists:
“Mitigation measures that would be implemented to
minimise the impacts of weed infestation."
One being the simple procedure of:
“Washing down machinery
coming on site
during the construction component."
Having never seen any of the thousands of vehicles, machines or otherwise, being
washed on entry to the property, or anywhere else, a letter was written to Clarence
Valley Council requesting an explanation. The response came from North Coast
Water (NCW) stating:
“Weed brushdown procedures are implemented based on
the location of works, weed species, season, and the activities being undertaken."
Basically, this is another way of saying – “there will be no wash-down of machines
entering the site". Changing a consent condition is as easy as that.
Following the discovery of
Phytophthora cinnamomi
on the NCW property in late
2004, a Plan of Management (PoM) was presented in May 2005 as part of a
comprehensive Species Impact Statement (SIS). Recommendations of that PoM are
referenced extensively throughout the SIS as a mitigation strategy to protect all
threatened species, stating:
The suite of soil hygiene measures to be implemented
according to the Phytophthora cinnamomi Management Plan are likely to greatly
lessen the chances of spread of the pathogen by the project."
Department of Environment and Conservation (DEC) incorporated that major
mitigation commitment, as well as the hundreds of other commitments, into its
concurrence when stating:
“The activity must be undertaken in accordance with
the ameliorative measures documented in the EIS, SIS A SIS C,
Management
Plans
listed in Section 2 of this report and
Final Assessment Reports
part B & C
."
The PoM identified areas of high conservation value habitat that were not
contaminated and should be protected. Specifically these occurred along sandstone
ridges surrounding Shannon Creek, containing an endangered ecological community.