W
ARNING No 2
BROKEN MITIGATION PROMISES
A CASE STUDY
April 2007
Members of an unsuspecting public need to be aware that mitigation promises made
in a development application (DA), or an Environmental Impact Statement, will not
necessarily be kept, even when those promised measures are incorporated into
official conditions of consent.
Again we use the Coffs Harbour – Clarence Valley Regional Water Supply Project to
illustrate what can, and frequently does, occur when work finally begins, and the
impact assessments and management plans are hidden away and forgotten.
Once work commenced on the final construction program, specifically the access
road to the Shannon Creek dam site, it was clear that numerous promised mitigation
measures were not being implemented. One major element of the work which did not
match that described in the DA was the clearing width of the road easement, and the
DA's Statement of Environmental Effects (SEE), and the Ecological Impact
Assessment (Vols A and B) are analysed below for this case study.
The SEE
(page 72) states:
“Clearing for the preferred alignment will result in the
removal of approximately 11 hectares of bushland, most of which has been
disturbed to varying degrees
(previously logged)
but still retains some areas of
relatively high habitat value. This clearing will generally be carried out along a 15
metre strip, which represents a reduction in clearing width by 10 metres from the
previous DA route. The clearing width requirement will be greater however, where
cuts and batters are required, and will range from 25 to 30 metres generally."
That promise of a general 15m clearing width was repeated six times in the
referenced documents, and was made in the face of strong opposition from
environmental groups, especially the Friends of Shannon Creek Action Group, who
were concerned over the plan to clear two corridors rather than combine all
infrastructure, pipelines, power, and roads, to a single easement.
Subsequently, the proponent made much of the predicted 11ha loss, claiming that the
clearing that actually occurred (from 20 metres minimum to 40 metres at several
locations) had not exceeded 11ha. However, from the outset
it was explained
(SEE,
page 6) that,
“...the proposal would require the removal of approximately 11ha of
native vegetation. This estimate is considered to be a conservative estimate and the
clearing levels are likely to be less."
Reinforcing the notion that the road easement clearing would not exceed 15 metres
for much of the route, we were also told:
(page 46)
The road would have a total
formation of 7m. The full width of the final carriageway with table drains will be
approximately 11m, where there are no batters required.