Fraser Island Defenders Organisation

FIDO — The Watchdog of Fraser Island

c/- John Sinclair, 1/32 Weston Street, COORPAROO Q 4151

Phone : John Sinclair: (07) 3397 5889 or 0418 650 535

www.fido.org.au — Email: john@fido.org.au

Aim: To ensure the wisest us of the natural resources of Fraser Island







17th December, 2007





Project Manager

SEQ Infrastructure (Water) Traveston Crossing Dam

Department of Infrastructure and Planning

PO Box 15009

CITY EAST QLD 4002





Dear Project Manager,


FIDO’s Response to Traveston Crossing Dam Environmental Impact Statement.


The Fraser Island Defenders Organisation has as its primary concern the wisest use of the natural resources of Fraser Island and the Great Sandy Region. This Region as defined by the Fitzgerald Commission of Inquiry in 1991 to encompass the marine areas of Hervey Bay, Great Sandy Strait and Tin Can Bay as well as the terrestrial areas of Fraser Island and Cooloola and the Tin Can Bay Military area. While this organization believes that the Environmental Impact Statement has deficiencies in describing the full impacts in other districts, we will limit our submission to the Great Sandy Region as described above.


The Fraser Island Defenders Organisation was established in 1971 and has since had a creditable history in addressing all aspects of land-use which impact on the Great Sandy Region. As well as being vociferous advocates, we have been involved in intimately studying issues which could in any way affect the World Heritage values of the Great Sandy Region. A short History of FIDO is appended to this submission.


While FIDO’s specific responses are directed at the environmental impact on the Great Sandy Region, we believe that there are a number of aspects about the dam itself and the need for any water impoundment of this scale on the Mary River which are grounds for not building this dam. These include:

World Heritage Boundaries and Values:


It should be pointed out at the outset that the Environmental Impact Statement has only addressed the current World Heritage boundaries and values for the Fraser Island World Heritage area and seems to have avoided a full examination of the impact on Great Sandy Strait. In many respects the EIS has found it convenient to the case it wants to make to be anachronistic because older reports and data understate the values of this outstanding natural estuary. For example, the map (Figure 9.9) seem to have overlooked any reference to the Great Sandy Marine Park (Northern Section) which was proclaimed by the Queensland Government in 2006 and which reinforced the values of Great Sandy Strait.


As a result of a review of the outstanding universal values of both Fraser Island and Cooloola undertaken in 1999 by the Fraser Island World Heritage Area Scientific Advisory Committee and leading Queensland scientist,s there is scientific agreement that both Fraser Island and Cooloola are worthy of inclusion on the World Heritage List and for all four natural values. These two reports were accepted by the Fraser Island World Heritage Area Ministerial Council as the basis for the renomination of the whole area including Great Sandy Strait to have all of its identified World Heritage values recognized. These reports and the draft boundaries of the proposed new World Heritage area have been the subject of ongoing negotiations between the Queensland and Commonwealth Governments for several years.


In its report, “Fraser Island World Heritage Area — Review of Outstanding Universal Values”, the Fraser Island Scientific Advisory Committee devoted two pages (pp 60-61) to describing the values of the inter-tidal habitats. Although this study published by the Environmental Protection Agency in 2006 is available, it appears to have been ignored in addressing ?Matters of National Significance” in Chapter 9 of the EIS.


This same review also devoted pp 39 41 to the describing Fraser Island’s aesthetic values.


The proposed World Heritage renomination of Fraser Island plus a much larger area has been supported by a succession of Federal and Queensland Environment Ministers. It also proposes that the enlarged World Heritage site be recognized for meeting all four natural World Heritage criteria. The actual renomination has been delayed for procedural reasons.


FIDO submits that the Environmental Impact Statement is very deficient for failing to consider the additional values now proposed for the new World Heritage area which is much larger than just Fraser Island and 500 metres off-shore all the way around it.


As a result of revision of World Heritage criteria earlier in 2007 (and before the EIS was completed) Fraser Island is now listed as meeting three of the four natural criteria whereas it was previously inscribed as meeting only two.


The World Heritage Centre (WHC) has transferred all properties listed under the original 1992 Criteria, and the 2002 Criteria to the unified 2005 Criteria. Hence the WHC has agreed to transfer Fraser Island's original listing for Criterion (ii) geomorphological and biological values; and Criterion (iii) exceptional natural beauty to the following unified 2005 Criteria:

(vii) to contain superlative natural phenomena or areas of exceptional natural beauty and aesthetic importance;

(viii) to be outstanding examples representing major stages of earth's history, including the record of life, significant on-going geological processes in the development of landforms, or significant geomorphic or physiographic features;

(ix) to be outstanding examples representing significant on-going ecological and biological processes in the evolution and development of terrestrial, fresh water, coastal and marine ecosystems and communities of plants and animals.


The Traveston Crossing Environmental Impact Statement has failed to recognize any of these factors. It listed in Table 9.9 Fraser Island World Heritage Values lists only two of the World Heritage values for which Fraser Island is now recorded and it has conveniently ignored the whole history of the extension of the World Heritage boundaries and the additional values which the Commonwealth and State were agreed upon.


The Environmental Impact Statement is thus seriously flawed in its failure to address adequately the impact of the Traveston Crossing Dam on the Fraser Island World Heritage area because it did not even seriously examine the World Heritage values which have now been recognized by the World Heritage Committee and by the World Heritage Ministerial Council.


Impacts on the World Heritage & Ramsar values of Great Sandy Strait:


The most critical aspect of the Traveston Crossing Dam in its impact on the World Heritage values of Fraser Island and the values of the Great Sandy Strait Ramsar site relate to:

  1. the extent to which the Mary River discharge into Great Sandy Strait is interrupted by the construction of the proposed dam;

  2. the amount of sediment and nutrient which will be denied to Great Sandy Strait as a result of the proposed dam; and

  3. where the discharge from the Mary River flows after leaving the Mary River Heads.


FIDO submits that the EIS fails to honestly address these three aspects that are so critical to the health and life of Great Sandy Strait and because it has either ignored or misrepresented the facts relating to these three questions, it has then failed to recognize the impact the dam will have indirectly on the productivity of Great Sandy Strait and the endangered species which use this very significant habitat.


Volumes of Mary River sediment discharged into Great Sandy Strait:


The productivity of the sea-grass meadows and mangrove forests of Great Sandy Strait Ramsar and World Heritage sites is vitally dependent on the quantity of nutrients and sediments flowing from the Mary River.


The EIS makes a categorical statement in 2.22.2 on the flow into the Great Sandy Strait:

“A decrease of 20% in the sediment exported from the Mary River as a result of the dam will have no impact on the natural sediment supply of Great Sandy Strait. The dam will trap some of this sediment but will have negligible difference at the river mouth as most of the sediment is sourced from downstream of the dam.”


FIDO disputes the calculation that there will be only a 20% reduction in sediment and that the Mary River catchment downstream of the Traveston Crossing Dam contributes as much sediment as is claimed. This is because although the bulk of the Mary River catchment is downstream of the Traveston Crossing Dam:

(a) the median rainfall of the lower Mary River catchment is much lower than the median rainfall above the Traveston Crossing Dam ,and

(b) due to its topography the run-off from those area outside the Traveston Crossing Dam catchment is not as great as in the areas above the Traveston Crossing Dam.

The assumption therefore that there will only be a 20% reduction in sediment and flow is nonsense and cannot go unchallenged.


The extent of the sediment carried down the Mary River to the western shores of Fraser Island was shown in 1987. At that time, during an inspection of North White Cliffs area (opposite to the mouth of the Mary River) the Fraser Island Defenders Organisation noted the western beach sand caked with a layer of silt about 5mm thick as a result of a Mary River flood immediately preceding our visit.


FIDO also finds a major deficiency in that this Environmental Impact Statement addresses only Stage 1 of the Traveston Crossing Dam. There is little doubt that this is fudging the issue of the full impact should Stage 2 of the proposal proceed as is foreshadowed.


The Discharge of the Mary River in Great Sandy Strait:


FIDO challenges the underlying assumption made in the Environmental Impact Statement that the main discharge from the Mary River is north into Hervey Bay. FIDO’s study of the situation over more than 35 years is that very little of the discharge from the Mary River ends up in Hervey Bay. FIDO’s observations are that most of the Mary River discharge flows south from Mary River Heads.


It is based on the observations on the flow of sediments from the Mary River. With only one significant exception in living memory there has been a lack of significant increase in turbidity in Hervey Bay north of Woody Island during or following Mary River floods. Even in the exceptions opinion is divided as to whether the turbidity in Hervey Bay which resulted in a significant loss of sea-grass and a subsequent dramatic decline in the dugong population was due to turbidity resulting from the Mary River or from the Burrum –Isis- Gregory Rivers discharge which coincided with the Mary River floods.


FIDO’s observations over 35 years also note that following floods in the Mary River there is a noticeable degree of turbidity stretching along Fraser Island’s east coast beaches and that and that some flood debri ends up being deposited along the ocean beach especially on the southern end of the island.


Additional evidence that the Mary River discharge and sediments flows to the south is the tidal delta between Mary River Heads and Inskip Point. This is one of the outstanding features of Great Sandy Strait. This delta owes its existence to the tidal movement coming south down Hervey Bay driving the sediment load discharged from the Mary River south down Great Sandy Strait. When that tide meets the tide coming north up Great Sandy Strait from the Wide Bay Bar, the velocity slows or stops. This results in the precipitation of the suspended sediments. The tidal convergence occurs in the area between Boonlye Point and Stewart Island. This results in the most extensive accumulation of sediments on both sides of the Strait.


Therefore FIDO challenges the claim stated in the EIS (9/6.1.1). that:

sediments from the Mary River are supplied to the Great Sandy Strait and transported northwards by strong tidal currents and dominate the sediments between the mouth of the Mary River and Point Vernon, at Hervey Bay. Finer material is deposited in sheltered areas (e.g. Woody Island) while the rest bypasses Woody Island (generally to its west side);


There is no evidence for that assertion.

Deposition of Mary River Sediment in Great Sandy Strait


The EIS at 2.22.1 makes an incredibly false statement, namely,

“Sediment from the Mary River does not drive sediment processes on the west coast of Fraser Island. This is driven by marine processes. The relevance of fluvial transport from the Mary River is to Great Sandy Straits and not Fraser Island. The source of sediments for Fraser Island has been shown to come from fluvial, continental shelf and shoreline sediments whereas the sediment from the Mary River to the maintenance of the geomorphic form and process of Fraser Island as a whole is negligible.”


While this statement is true as far as sediment processes the eastern side of Fraser Island it ignores the fact that the Fraser Island World Heritage Area extends 500 metres offshore from the western side of Fraser Island and even 500 metres outside Dream and Stewart Islands which have been included in the World Heritage Area. This part of the World Heritage Area to the south of the river mouth is entirely dependent on fluvial sediment flow from the Mary River because Great Sandy Strait is the ancestral bed of the Mary River, which was turned into this course by the Woody Island syncline.


The late geomorphologist Cliff Thompson (pers comm) was able to point to evidence of where the ancestral river ran through what is now the Inskip Point peninsula. Even now the Woody Island syncline prevents any significant discharge of fluvial sediment from the Mary River into Hervey Bay. Thompson points out that Great Sandy Strait’s shallow depth of water is due to the accumulation of more than 100 metres of sediment derived from the Mary River. Thus any reduction in the fluvial flow of sediment from the Mary River is going to impact on the Fraser Island World Heritage Area.


The work of Associate Professor Ron Boyd of the University of Newcastle on the flow of sediments along Australia’s east coast, through underwater imagery revealed that a very significant chasm at the edge of the continental shelf (located north of Breaksea Spit) was the ancestral mouth of either the Burnett or Burrum Rivers. It therefore appears that what is now Woody Island has always been a watershed between the Mary and Burnett / Burrum catchments.


Therefore to assert as the Environmental Impact Statement has that the bulk of the Mary River discharge is to the north is clearly erroneous and demonstrates a serious flaw in this study.


The reduction of environmental flow, and particularly the periodic flooding in the Mary River as a result of the construction of the Traveston Crossing Dam will result in a significant loss of fluvial sediment. This reduction in the discharge from the Mary River will not only impact on the geomorphology of the Great Sandy Strait Ramsar site and the Fraser Island World Heritage Area, but it will also significantly affect the water quality of this very vital estuary as far as its nutrient, pH and salinity levels are concerned.


Having relied on a spurious assumption that the Fraser Island World Heritage Area was not reliant on the fluvial processes of the Mary River. the EIS appears to have ignored the impact of the reduction of environmental flow on these critical aspects in Great Sandy Strait.


Impacts on the Fraser Island World Heritage area:


Another nonsense of the Environmental Impact Statement is the claim that:

Discharges from the Mary River can only potentially influence the marine and estuarine habitats of Fraser Island. The freshwater and terrestrial habitats or significant faunal communities, which constitute the bulk of the listed World Heritage Values, could not be affected. Impacts upon the marine and estuarine habitats would only occur during flood flows and these will be largely unaffected by the proposed dam. Hydrological impacts are therefore assessed as zero.


This again ignores the boundaries of the Fraser Island World Heritage area which includes all of the wetlands on Boonlye Point and surrounding Dream and Stewart Islands. The particular wetlands are affected by the sediment and nutrient inputs of the Mary River. To a lesser extent so are the Wangoolba Creek wetlands and the wetlands between Bogimbah Creek and Moon Point. They rely on the every-day normal flows from the Mary River into Great Sandy Strait just as much as the periodic floods in the Mary River.


While it is true that the Traveston Crossing Dam won’t affect freshwater and terrestrial habitats of the World Heritage area, it does affect the World Heritage wetlands lining the eastern side of Great Sandy Strait. These represent about half of the mangrove wetlands of Great Sandy Strait which are nourished by the sediment and nutrient discharges from the Mary River.


Trying to define the Fraser Island World Heritage area as just being the terrestrial areas above the High Water Mark shows that either the Environmental Impact Statement is being patently dishonest or it has been very incompetently prepared.


Impact on Accepted World Heritage Values:


There is a contradiction between the penultimate conclusion of Chapter 9 and the World Heritage values Table 9.9

The Conclusion (Ref 9.8) reads:

The values of the Fraser Island World Heritage Area are not likely to be affected by the Project. All of the values cited in relation to Fraser Island are in areas remote from any possible impact from the Project as they are primarily on the island itself and even on its east coast, and the Project is 207.6 km from the west coast.

Yet in its quoting of the Fraser Island World Heritage values in Table 9.9 it reported amongst Fraser Island’s World Heritage values:

Fraser Island, the largest sand island in the world, has exceptional natural beauty and aesthetic importance and contains superlative natural phenomena including ….. sheltered mangrove areas in a spectacular mosaic landscape. (FIDO’s emphasis)

If the mangroves are part of the acknowledge aesthetic values and they may be impacted by the reduction in the volume of sediments and nutrients discharged by the Mary River as a result of the Traveston Crossing Dam then clearly there is an impact which this deficient EIS has failed to address.

Impact on Great Sandy Strait water quality:


This organization further challenges the assertion in the EIS that the Traveston Crossing Dam will have a positive effect on water quality down-steam due to reduced turbidity:

Changes to water quality downstream from the dam are expected to be generally positive, though with some risks associated with stratification and turnover events. No change is expected at the estuary so existing elevated nutrient concentrations will still occur. There may be improved conditions with respect to turbidity at times but these are very unlikely to be significant.


While this is an unsubstantiated assertion, it is in fact an unconscious admission that the upstream-catchment makes a much greater contribution to the flow of the Mary River than 20% of its sediment as asserted elsewhere.


The quality of water in Great Sandy Strait is dependent on the Mary River to maintain three most critical aspects for the health of the estuary:

  1. salinity

  2. nutrients and

  3. pH.


The EIS has failed to fully elaborate on this aspect \and what if anything can be done to ameliorate this increased salinity within the Great Sandy Strait estuary. There is no question that the Traveston Crossing Dam will reduce the flow of the Mary River into Great Sandy Strait and thus result in increased salinity. This will impact fish stocks as the young fish need reduced salinity to survive early life and grow, without the predators that are usually unable to survive in lower salinity water as well as juveniles. Reduced salinity will mean predators will travel further up the estuary to prey on juvenile fish while juvenile fish may not be able to retreat upstream to breed due to tidal barrages and agricultural and urban development. Fewer juveniles also means fewer fish breeding for the migratory birds in the Ramsar Site and the marine sections of the Fraser Island World Heritage Area.


On the issue of the flow of nutrients that are critical to the life and productivity of the Great Sandy Strait, the EIS has remained conspicuously mute and has failed to address this vital issue. The Mary River is clearly the main source of nutrients flowing into Great Sandy Strait. There are some contributions from creeks on Fraser Island such as Bogimbah, Wangoolba and Yankee Jack Creeks and on the mainland from Tuan, Poona and Kauri Creeks. These though drain areas of low nutrient and their relatively small flows do not match the Mary River as a source of nutrients for Great Sandy Strait.

The Great Sandy Strait Ramsar Site:


The Environmental Impact Statement correctly stated in 9.2.2, “The Great Sandy Strait is listed as a Wetland of International Importance under the Ramsar convention. It was added to the Ramsar convention for its importance to migratory shorebirds …” It was also listed because of its significance as a marine nursery for fish, a habitat for endangered dugong and turtles which are very dependent on the rich sea-grass beds of Great Sandy Strait. These sea grass beds and the mangroves of Great Sandy Strait are vitally dependent on the flow and flushing from the Mary River. With a very significant part of that flow stopped at the Traveston Crossing Dam even at Stage 1 the wetlands of Great Sandy Strait will be impoverished to a significant extent.


The Environmental Impact Statement Chapter 9 concludes:

Listed migratory species have been found in the area of the dam and also in the Great Sandy Strait Ramsar wetland. The habitat that these species use in the Mary catchment and the Great Sandy Strait are not directly impacted (FIDO’s emphasis) by the Project and the migratory species will continue to occupy and visit these areas once the dam is completed.


While this statement is probably true it should be noted that while not directly being impacted, the reality is that the indirect impacts of reducing the flow of sediment and nutrient and the changes to pH and salinity as a result of reduced water flow will mean that although migratory species will continue to occupy and visit these areas their populations will decline over time. The critical question which the Environmental Impact Statement has failed to address is to what extent these populations may decline and what could be done to ameliorate the situation.


Impact on Endangered Species


Of the Endangered marine creatures cited in Chapter 9, dugongs and turtles are known to be dependent on sea-grass. Although sea-grass itself is not endangered by the construction of the Traveston Crossing Dam, with respect to dugong the EIS noted: “Poor water quality can directly impact on dugong health.“ The inference of section 9.5.6.3 Dugong (Dugong dugong) is that by reducing the flow of sediment that the Traveston Crossing Dam might result in healthier sea-grass beds on which the dugong feed.

Halophila, a preferred food item, appears to be particularly sensitive to the duration and frequency of light-deprivation events such as the high-sediment loads of floodwater. This is particularly true for environments subject to temporarily variable light conditions (Longstaff et al., 1999), such as the Mary River estuary and Great Sandy Strait.

This is true and there has been a mass exodus of dugong from the Great Sandy Region due to too much sediment resulting in a vast sea-grass dieback in the 1990s. However the essential fact remains that the habitat of the Great Sandy Strait sea-grass is very heavily reliant the sediment deposited by the Mary River and that the on-going productivity of the seagrass meadows is dependent on the nutrients mainly supplied with the environmental flows from the Mary River.


Impact on Shorebirds:


Of the many serious omissions and dismissals of the downstream impacts on the Great Sandy Strait estuary is the impact on shorebirds.


The report stated that “a number of migratory shorebirds … estuarine species and forage, roost and breed on sand, mud flats and mangrove wetlands. As a result they do not occur within the Project footprint and are not directly impacted by the Project.” This an outrageous dismissal of the impact that the Traveston Crossing Dam will have on the sand, mud flats and mangrove wetlands of Great Sandy Strait that are acknowledged as the habitat of these species. The above statement is as bad statement to the effect, “Because we may put poison in the water we are not responsible if any shorebirds die once it leaves the river”. There can be no absolution of responsibility for the impact on shorebirds or marine life as a result of the construction of the Traveston Crossing Dam.


In “9.5.6.8 Migratory Shorebirds,” the EIS notes

Wetlands along the Great Sandy Strait approximately AMTD 143 km downstream of Traveston Crossing Dam is known to support a number of migratory shorebirds. These species are estuarine species and forage, roost and breed on sand, mud flats and mangrove wetlands. As a result they do not occur within the Project footprint and are not directly impacted by the Project. These species are discussed collectively in Section 9.6.5.

However Section 9.6.5 (Impacts on Listed Migratory Species within the Study Area) fails to even mention the word ”shorebirds” presumably because these are outside the study area even though they will be impacted by any changes to the rich habitat in Great Sandy Strait they currently utilize. Elsewhere we have shown that shorebirds will be adversely impacted by the changes in salinity, nutrients and pH that will impact on their food supply and that these factors are critically affected by the reduction in the environmental flow from the Mary River.




With respect to the whole issue of Fraser Island and Great Sandy Strait and their importance to the national interest the EIS has been exceedingly sloppy, negligent, or contemptuous of the process it is supposed to serve. The proponent’s view seems to be that the Traveston Crossing Dam has to go ahead irrespective of any valid environmental arguments to the contrary. It appears that the proponent is relying on political pressure to force the EPBC Act to be ignored just to satisfy South East Queensland’s misplaced political priorities. The EIS has failed to address satisfactorily alternative form of meeting the water needs such as desalination or consideration of water harvesting or even the alternative of attempting to slow the migration to South East Queensland because its water resources are overstretched.


It is FIDO’s view that the Environmental Impact Statement for the Traveston Crossing Dam has not satisfactorily dealt with the environmental issues of national significance and that the Commonwealth Government should determine that it does not meet the requirements of the EPBC Act.

Yours sincerely




John Sinclair,

Honorary Project Officer.


Attachment: Short History of FIDO