Category Archives: Biodiversity

Impact of selective logging on native fauna in southern Queensland

Aila Keto & Keith Scott

There is a number of studies showing the impacts of selective logging on arboreal marsupials in southern Queensland. This paper presents a review of those studies. The purpose of the paper is principally to address the issue of 40 cm diameter limit harvesting (40 cm+) and its expected impacts on fauna. Hence, there is a focus on logging intensity. Overall, the paper focuses on impacts of logging on the Greater Glider (Petauroides volans) which in 2022 was declared endangered in Queensland and nationally. However, the Greater Glider has been identified as an indicator species of forest disturbance (Kavanagh and Stanton 2005) and if it is being impacted by 40 cm+ logging it is likely that other species are also impacted. A recent global assessment by a large number of herpetologists, including nine Australians, found logging to be high among the main threats to forest-dwelling reptiles (Cox et al. 2022).

Some history

In the final stages of negotiations that led to the 1999 South East Queensland Forest Agreement (SEQFA), Australian Rainforest Conservation Society (ARCS) put forward a proposal to phase out native forest harvesting in the area and transition to hardwood plantations over a 20-year period. The timber industry indicated a preparedness to accept the proposal but on the condition that the phase out occur over 25 years. It had been established that there was sufficient timber outside the proposed immediate additions to the protected area estate to supply the industry for 20 years under the standard harvesting regime current at the time. 

       In order to extend supply for a further five years, forestry officers proposed that 40 cm+ harvesting be applied to certain areas. Conservation representatives accepted the proposal on the grounds that the more intense logging would be over a limited area and the areas would never be logged again. A clause in the SEQFA defines Part A areas, high conservation value forests, where the standard logging regime would be applied.[1]

       It would appear that the SEQFA was effectively abandoned by the Liberal National Party (LNP) government which was elected in 2012. We understand that shortly after taking office, the LNP government applied 40 cm+ logging across the region as standard practice, including in the Part A areas which were excluded from 40 cm+ logging in the SEQFA.

       When Labor returned to office in 2012, it did not reverse the LNP decision but continued to apply the more intensive 40 cm+ harvesting regime across the south-east Queensland supply zone including the Part A areas. Further, an even more intensive 30 cm diameter limit harvesting regime has apparently been used in some areas. ARCS has submitted a Right to Information request to try to establish when and why this regime was introduced and where it has been applied.

The Code of practice

Native forest logging in Queensland is subject to the Code of practice for native forest timber production on Queensland’s State forest estate 2020 (the Code). The Code requires retention of six live habitat trees and two recruitment habitat trees within the range of the Greater Glider and four live habitat trees and one recruitment habitat tree per hectare in hardwood forests outside the Greater Glider range.

       The Code refers to Species Management Profiles (SMP) as being designed to meet statutory requirements. The SMP for the Greater Glider does not provide any management provisions beyond those within the Code itself and notes that the Code “requires an increased retention and protection of large hollow-bearing trees as habitat and selective harvesting regime that retains structure and species mix of forest”. Whereas the Objective of the Code is to “ensure the forest can, in time, recover its pre-harvesting species composition, structure and function”, there is no specific provision to retain forest structure and species mix.

       We note that the SMP for the Greater Glider was prepared by the Department of Agriculture and Fisheries, presumably by Forest Products unit.

Statutory obligations

The Nature Conservation (Animals) Regulation 2020 (the Regulation) defines the management intent for endangered wildlife which includes (Schedule 1, section 26(i)) “to protect the critical habitat, or the areas of major interest, for the animal”. 

       The term ‘critical habitat’ is defined in the Nature Conservation Act 1992 as “habitat that is essential for the conservation of a viable population of protected wildlife” which can include areas where the wildlife is not currently present. An ‘area of major interest’ is defined as “an area that contains natural resources of significant nature conservation value”.

       The Queensland Herbarium has mapped modelled Greater Glider habitat in Queensland (Eyre et al. 2022). The map in Appendix 1 was prepared by ARCS from data provided by Queensland Herbarium and shows a significant area of habitat occurs within State Forests in southern Queensland.

       The Regulation (section 26(j)) also proposes the following requirement:

  • to monitor and review environmental impact procedures to ensure they —
    • accurately assess the extent of the impact, on the animal, of the activities to which the procedures relate; and
    • provide for effective measures to mitigate any adverse impact of the activities on the animal; and
    • o if there is an adverse impact of the activities on an area in which the animal normally lives, provide for the enhancement of other areas where the animal normally lives.

It is not clear that 40 cm+ harvesting meets the statutory obligations. This is discussed later in this paper.

Impacts of logging on Greater Glider habitat in southern Queensland

A range of studies has shown Greater Glider occupancy to be influenced by logging disturbance, particularly because of a reduction in hollow-bearing trees and the loss of old-growth forest e.g., Lunney et al. (1987) and Lindenmayer et al. (1990). Incoll et al. (2001) showed the abundance of greater gliders in the montane forests of the Victorian Central Highlands was significantly related to the overstorey basal area, a parameter that, in turn, relates to the intensity of logging.

       Eyre (2006) studied habitat selection of the Greater Glider in southern Queensland, specifically the South East Queensland and Brigalow Belt Bioregions. Eyre modelled Greater Glider habitat based on glider numbers and habitat attributes recorded at 428 sites across the study area. The most significant feature in habitat selection by greater gliders was found to be the number of live hollow-bearing trees. The model predicted that three hollow-bearing trees per hectare were required to maintain one glider per 3 hectares. However, the study found the mean number of live hollow-bearing trees in glider habitat types in southern Queensland was 2.2 ± 0.1. Eyre noted the difficulty in locating the number of hollow-bearing trees required by the Code to be retained during harvesting.

       The model predicted a negative response of greater gliders to more intensive logging. It also predicted that Corymbia citriodora (Spotted Gum) and Eucalyptus tereticornis (Queensland Blue Gum) were important in glider habitat selection. Both are favoured timber species.

       This study also concluded that at least 85% of the original basal area needs to be retained to maintain at least one glider per 3 hectares. We are not aware of the basal area retention limit currently applied under 40 cm+ harvesting but the Code envisages removal of greater than 50% of basal area.

       As a summary statement, Eyre concluded “The introduction of a new, more intensive harvesting regime in areas of greater glider habitat in south-east Queensland will therefore have a significant impact on glider populations, unless current habitat tree prescriptions are adjusted to specify the retention of large C. citriodora and E. tereticornis trees, and species that rapidly form hollows.”

Impacts of logging on Greater Glider habitat in the Western Hardwoods area

Eyre et al. (2010) studied the impacts of forest management on forest structure in the Brigalow Belt South Bioregion. This region includes the major part of the Western Hardwoods Area (Western Hardwoods Supply Zone). The study aimed to determine the response of a range of habitat features to variation in disturbance history and intensity at the stand scale. Timber harvesting was one disturbance considered. A total of 120 sites was studied.

       The mean number of live trees with hollows across the study area was 4.0 ± 0.4 per hectare. For harvesting in this area, the Code requires retention of six live habitat trees and two recruitment habitat trees per hectare.

       The study found that live trees of the five most common species were more likely to have hollows if the diameter at breast height (DBH) was greater than 60 cm.

       Disturbance variables selected for the study included time since logging and logging intensity. The latter was determined as the ratio of basal area removed (stumps) to total basal area (live trees plus stumps). Data from the sampled sites were used to model the response of habitat features to the disturbance variables. With respect to impacts of timber harvesting, logging intensity was the most important variable affecting the abundance of hollow bearing trees and large living trees. Time since logging was a very poor predictor of the abundance of the relevant habitat features. This can be explained by the extremely slow recovery of habitat features as a result of the slow growth rates in the region because of the low rainfall compared to coastal areas.

       The results of this study raise serious concerns about the impacts of 40 cm+ logging, and especially 30 cm+ logging, on habitat quality for the Greater Glider in the Western Hardwoods Area in particular but also in South East Queensland where 40 cm+ logging is being practised.

       It is noted that the Federal Government’s recently released 2022–2032 Threatened Species Action Plan Towards zero extinctions includes Brigalow country, Queensland as a Priority Place.

Queensland Herbarium recommendations regarding habitat for the Greater Glider

In 2022 Queensland Herbarium published a report Guide to greater glider habitat in Queensland (Eyre et al. 2022)(the Guide) which was prepared for the federal Department of Agriculture, Water and the Environment.

       Six tree species were identified as dominant or co-dominant in habitat of the Greater Glider — Corymbia citriodora(Spotted Gum), Eucalyptus moluccana (Gum-topped Box), E. tereticornis (Queensland Blue Gum or Forest Red Gum). E. crebra (Narrow-leaved Ironbark), C. intermedia (Pink Bloodwood) and E. portuensis (White Mahogany). All of these species are used for timber with Spotted Gum representing around 70% of hardwood log timber produced from State-owned forests (State of Queensland 2016).

       The Guide notes that trees preferentially selected by greater gliders for foraging are generally greater than 30 cm DBH and greater than 50 cm DBH for denning.

       Whereas hollow-bearing trees are an essential habitat feature for greater gliders, a review of the literature (Eyre et al. 2022) found there is high variability and low reliability in ground-based detection of tree hollows. In studies carried out in European forests, Cosyns et al. (2020) illustrated bias among observers. The researchers compared habitat tree selection by a group of foresters with that by a group of conservationists. Foresters typically chose smaller trees with low commercial value while conservationists chose large trees with high commercial value.

       It is now generally considered that tree size is a better indicator of habitat and the authors conclude that retention of an adequate resource of appropriately large sized trees is critical for maintaining populations of the Greater Glider. The authors note that the number of hollow-bearing trees is no longer accepted as an attribute in condition assessments in Queensland. This is also the case in New South Wales where the attribute ‘number of trees with hollows’ has been replaced by the attribute ‘number of large trees’ in determining native vegetation integrity benchmarks (Office of Environment and Heritage 2017).

       The Guide determined thresholds and benchmarks for large trees based on data for regional ecosystems considered to be habitat for the Greater Glider. Data for southern Queensland were considered adequate to determine thresholds and benchmarks. In South East Queensland, Brigalow and New England Tableland bioregions, the DBH threshold for large trees averaged around 46 cm, ranging from 35 to 61 cm. The average density of large trees varied between bioregions, being 32 per hectare in South East Queensland and 15 per hectare in the Brigalow Belt.

       The Guide provides a number of recommendations, two of which have implications for timber harvesting regimes:

  • densities of hollow-bearing trees should not be used to define whether an area is greater glider habitat or not habitat,
  • improve reliability for indicating greater glider habitat or potential habitat by measuring densities of ‘large trees’.

Victorian Supreme Court decision

Environment East Gippsland Inc and Kinglake Friends of the Forest Inc sought declarations and permanent injunctions in the Supreme Court of Victoria to enforce VicForests to identify and protect greater gliders and yellow-bellied gliders in State forests in East Gippsland and Central Highlands. On 4 November 2022, Justice Richards handed down her judgment based on the expert ecological evidence presented in the hearings. The judgment, which can be downloaded at,  can be summarised as follows:

  • VicForests must carry out surveys to detect the presence of the gliders in any coupe proposed for logging,
  • harvesting operations must exclude from logging an area equivalent to the home range of the species (~3 ha) around the point of detection, and
  • harvesting operations must retain at least 60% of the basal area of eucalypts in the harvested area.

Climate change

The Conservation Advice (Department of Climate Change, Energy, the Environment and Water 2022) considers climate change as a major threat to the Greater Glider. The species is vulnerable to high temperatures and low water availability (Rübsamen et al. 1984). The sensitivity of greater gliders to heat may explain the species preference for higher elevations (Moore et al. 2004).

       This sensitivity to heat and preference for higher elevations indicates the importance of areas such as Bigge, Expedition, Dawson and Coominglah Ranges and the State forests that occur on those ranges (Presho, Theodore, Belington Hut, Mt Nicholson, Expedition, Shotover, Arthurs Bluff, Dawson Range, Coominglah (northern part) and Grevillea State forests). All these areas are mapped, at least in part, as greater than 80% greater glider habitat (Eyre et al. 2022 and Appendix 1). These areas in the Western Hardwoods supply zone may have been subject to 30 cm+ logging.

The Precautionary Principle

The Precautionary Principle has been the subject of numerous discussions. The Queensland Planning Act 2016 defines the Precautionary Principle thus: “the lack of full scientific certainty is not a reason for delaying taking a measure to prevent degradation of the environment if there are threats of serious or irreversible environmental damage”.

       Regarding the impacts of 40 cm+ logging on the endangered Greater Glider, it may be debated as to whether there is “full scientific certainty”. However, the evidence considered here clearly indicates a threat of serious damage to greater glider habitat. Whereas that damage may not be irreversible in the longer term, it is likely to persist for decades. Application of the Precautionary Principle requires measures to be taken to prevent further habitat degradation.

       The Precautionary Principle featured prominently in the Victorian Supreme Court case cited above. Justice Richards made the following judgment:

In order to apply the precautionary principle to the conservation of greater gliders and yellow-bellied gliders, VicForests must survey the whole of any coupe proposed for harvest which may contain glider habitat. It must do so using a survey method that is likely to detect any gliders that may be present in the coupe, so as to locate the gliders’ home ranges wherever practicable. This is necessary in order that their essential habitat can be excluded from timber harvesting operations, as the precautionary principle requires.

In contrast to the procedures now required to be followed by VicForests, in Queensland neither the Code nor the SMP for the Greater Glider require any assessment of the presence of the species prior to logging.

       It should be noted that VicForests has replaced clear-fell harvesting with variable retention harvesting which aims to retain key elements of stand structure in islands and patches. Justice Richards concluded that the available evidence is that variable retention harvesting is of no short- or medium-term benefit to the gliders.


It is well established that the Greater Glider is sensitive to logging (Lunney 1987, Lindenmayer et al. 1990, Incoll et al. 2001). The Conservation Advice that led to uplisting of the Greater Glider to endangered status defines timber harvesting as a major threat (Department of Climate Change, Energy, the Environment and Water 2022).

       The studies reviewed here have findings directly relevant to the impact of 40 cm+ logging on habitat for the Greater Glider:

  • in southern Queensland there is a deficit in hollow-bearing trees which are an essential habitat attribute for the Greater Glider,
  • even where sufficient hollow-bearing trees can be retained to meet the Code requirements, 40 cm+ logging will deplete the resource of larger trees required to develop hollows in the future,
  • greater gliders respond negatively to more intense logging,
  • tree species that are important in habitat selection by greater gliders, particularly species favoured for foraging, are species sought by the timber industry,
  • the Code does not include any specific provisions designed to maintain species mix,
  • greater gliders preferentially select trees greater than 30 cm DBH for foraging,
  • the foraging resource will be depleted by 40 cm+ logging (and especially by 30 cm+ logging).

The Guide makes a number of recommendations relevant to the issues being considered here. Whereas these recommendations are not directly related to logging, they define the habitat attributes that are necessary to maintain an area of forest as habitat for the Greater Glider.

       It can reasonably be concluded from available evidence that 40 cm+ logging in many areas will lead to a loss of essential habitat attributes for the Greater Glider and the species will no longer be able to occupy the logged forest.

       The recommendations in the Guide also have significant implications for the Code. It depends on assessment of tree hollows from the ground. Such assessment is shown to be unreliable and should not be used in assessing habitat attributes. Instead, the density of large trees (>46 cm DBH in southern Queensland) should be used. Given that 40 cm+ logging aims to remove all merchantable trees 40 cm DBH or larger (apart from the required number of habitat and recruitment trees), it is clear that the provisions of the Code will not maintain habitat for the Greater Glider where 40 cm+ logging occurs.

       Given that available evidence supports the conclusion that 40 cm+ logging is negatively impacting greater glider habitat, it can reasonably be considered that the Queensland Government is not meeting its statutory obligation regarding the management intent for endangered wildlife as defined in the Regulation (Schedule 1, section 26(i)), namely, “to protect the critical habitat, or the areas of major interest, for the animal”.


It is clear from the considerable volume of evidence available from studies in southern Queensland and elsewhere that 40 cm+ logging will have significant negative impacts on habitat of the endangered Greater Glider and the species is likely to become locally extinct in a significant part of its range in the Brigalow Belt South and South East Queensland bioregions.

       The evidence-based recommendations from the Queensland Herbarium require an urgent review of the Code of practice.

       The available evidence indicates that the State of Queensland is not meeting the statutory requirement “to protect the critical habitat, or the areas of major interest” in respect to the endangered Greater Glider.


Cox, N., Young, B. E., Bowles, P., Fernandez, M., Marin, J., Rapacciuolo, G., Böhm, M., Brooks, T. M., Hedges, S. B., Hilton-Taylor, C., Hoffmann, M., Jenkins, R. K. B., Tognelli, M. F., Alexander, G. J., Allison, A., Ananjeva, N. B., Auliya, M., Avila, L. J., Chapple, D. G., Cisneros-Heredia, D.F., Cogger, H.G., Colli, G.R., de Silva, A., Eisemberg, C.C., Els, J., Fong G, A., Grant, T.D., Hitchmough, R.A., Iskandar, D.T., Kidera, N., Martins, M., Meiri, S., Mitchell, N.J., Molur, S., Nogueira, C. de C., Ortiz, J.C., Penner, J., Rhodin, A.G.J., Rivas, G.A., Rödel, M.O., Roll, U., Sanders, K.L., Santos-Barrera, G., Shea, G., Spawls, S., Stuart, B.L., Tolley, K.L., Trape, J-F., Vidal, M.A., Wagner, P., Wallace, B.P. and Xie, Y. 2022. A global reptile assessment highlights shared conservation needs of tetrapods. Nature 605, 285–290.

Cosyns, H., Joa, B., Mikoleit, R., Krumm, F., Schuck, A., Winkel G., and Schulz, T. 2020. Resolving the trade-off between production and biodiversity conservation in integrated forest management: comparing tree selection practices of foresters and conservationists. Biodiversity and Conservation 29, 3717–3737.

Cosyns, H., Kraus, D., Krumm, F., Schulz, T. and Pyttel, P. 2018. Reconciling the tradeoff between economic and ecological objectives in habitat-tree selection: a comparison between students, foresters, and forestry trainers. Forest Science 65, 223-234

Department of Climate Change, Energy, the Environment and Water 2022. Conservation Advice for Petauroides volans (greater glider (southern and central)).

Eyre, T.J. 2006. Regional habitat selection of large gliding possums at forest stand and landscape scales in southern Queensland, Australia I. Greater glider (Petauroides volans). Forest Ecology and Management 235, 270–282.

Eyre, T.J., Butler, D.W., Kelly, A.L. and Wang, J. 2010. Effects of forest management on structural features important for biodiversity in mixed-age hardwood forests in Australia’s subtropics. Forest Ecology and Management 259, 534–546.

Eyre, T.J., Smith, G.C., Venz, M.F., Mathieson, M.T., Hogan, L.D., Starr, C., Winter, J. and McDonald, K. 2022, Guide to greater glider habitat in Queensland, report prepared for the Department of Agriculture, Water and the Environment, Canberra. Department of Environment and Science, Queensland Government, Brisbane. CC BY 4.0. Available at

Incoll, R.D., Loyn, R.H., Ward, S.J., Cunningham, R.B., Donnelly, C.F. 2001. The occurrence of gliding possums in old-growth forest patches of mountain ash (Eucalyptus regnans) in the Central Highlands of Victoria. Biological Conservation 98, 77–88.

Kavanagh, R.P. and Stanton, M.A., 2005. Vertebrate species assemblages and species sensitivity to logging in the forests of north-eastern New South Wales. Forest Ecology Management 209, 309–341.

Lindenmayer, D.B., Cunningham, R.B., Tanton, M.T., Smith, A.P., Nix, H.A. 1990. Habitat requirements of the mountain brushtail possum and the greater glider in the Montane Ash-type eucalypt forests of the Central Highlands of Victoria. Australian Wildlife Research 17, 467–478.

Lunney, D. 1987. Effects of logging, fire and drought on possums and gliders in the coastal forests near Bega, NSW. Australian Wildlife Research 14, 263–274.

Moore, B.D., Wallis, I.R., Marsh, K.J. and Foley, W.J. 2004. The role of nutrition in the conservation of the marsupial folivores of eucalypt forests, in D. Lunney (ed) Conservation of Australia’s Forest Fauna. Second edition. pp 549–575.

Office of Environment and Heritage 2017. Native Vegetation Integrity Benchmarks: An information sheet.

Rübsamen, K., Hume, I.D., Foley, W.J. and Rübsamen, U. 1984. Implications of the large surface area to body mass ratio on the heat balance of the greater glider Petauroides volans. Journal of Comparative Physiology, B-Biochemical, Systemic, and Environmental Physiology 154, 105–111.

State of Queensland 2016. Queensland Forest and Timber Industry. An overview.

Smith, G.C., Mathieson, M. and Hogan, L. 2007. Home range and habitat use of a low-density population of greater gliders, Petauroides volans (Pseudocheridae: Marsupialia), in a hollow-limiting environment. Wildlife Research 34, 472–483.

Appendix 1

[1] Part A areas were initially considered for inclusion in the protected area additions. Conservation representatives accepted their exclusion given the ‘safeguards’ incorporated in the Agreement including the first-right-of-refusal for the State to buy out sawmills that came up for sale and a ‘logging as a last resort’ condition.

Leave a comment

Filed under Biodiversity, Forests

Save Cooloola — a letter to Hon Meaghan Scanlon MP

Dear Minister Scanlon,

I am an 85-year old scientist and conservationist but I write to you simply as a lover of nature.

In the 1960s, I climbed Federation Peak in Tasmania’s south west. From the top of the peak, looking across the Western Arthur Ranges, I saw a beautiful deep blue lake hemmed by a beach of pure white sand, nestled in a valley surrounded by rugged rocky peaks — Lake Pedder. When I returned to Hobart I learned the Hydro Electricity Commission planned to build a dam to flood the lake. That was when I became involved in conservation, joining the campaign to save Lake Pedder. In 1972, the dam was built and that strikingly beautiful vista was destroyed. Gone forever.

On returning to Queensland, I became involved in the campaign, led by poet Judith Wright, to stop the Bjelke-Petersen government approving sand mining at Cooloola. The campaign was successful and declaration of the area as Cooloola National Park followed. The dunes, the lakes, the forests and heaths were to be protected forever.

Many times, I walked into Lake Poona. The most recent was with my wife, six months pregnant at the time. We walked through the forest to Lake Poona, camped on the beach and swam naked in the lake. It was — and at this time still is — a truly pristine landscape, a real wilderness experience.

Minister, I understand that you are considering approval for private, commercial accommodation, a group of 10 cabins, being built in the forest on the slope just above the lake. The whole experience of Lake Poona will change —  lost! Memories of Lake Pedder flood back and I am filled with sadness and despair.

In 1969, Kathleen McArthur and Judith Wright initiated the first ‘postcard campaign’ in Australia to protect Cooloola. It is sad, indeed, that fifty-three years later, another postcard campaign has to be waged to again try to protect Cooloola.

Apart from Judith and Kathleen, there were others who worked tirelessly for decades to protect Cooloola — the late Dr Arthur Harrold, Bill Huxley and Mavis Huxley. The national park would not exist in its present form were it not for the selfless devotion of those beautiful people. And there were many others. The national park was not the initiative of the Queensland Government. It was the result of the sustained efforts of conservationists over decades. It saddens me deeply to think that the vision of Judith, Kathleen, Arthur, Bill and Mavis of a protected wilderness — the legacy they left for the people of Queensland — could be desecrated for private profit, luxury accommodation for a wealthy few and a little government revenue. Is that what Queensland has come to?

Minister Scanlon, you will go down in history as the one who destroyed the unforgettable wilderness experience of Lake Poona, who destroyed the vision of those devoted conservationists who were responsible for the national park as it is today, who destroyed the vision of Cooloola held by Judith Wright, arguably Australia’s greatest poet.

Please don’t do it!

Yours very sincerely,

Dr Keith Scott

And you
with sharks in your eyes
contracts in your hands
and balance sheets
that have to keep climbing

and you saying I know
but you can’t expect us
to do anything about it

Judith Wright

Leave a comment

Filed under Biodiversity, Forests, Government Policy

Cooloola threatened by commercial development

The Queensland Government is currently considering a proposal for five privately owned “eco-accommodation” camps along the Cooloola Great Walk in Great Sandy National Park. 

We have previously expressed our concerns about private development in national parks. The opportunity for private, commercial accommodation in national parks was created by the Newman LNP government in 2013. They amended the Nature Conservation Act 1992, firstly to broaden the Object of the Act from simply protecting nature to providing recreation and eco-tourism facilities and then to provide for leasing land within national parks to eco-tourism operators to provide accommodation for paying guests. 

The Queensland Ecotourism Trails program was initiated by the Department of Tourism, Innovation and Sport in 2018 when they called for expressions of interest from private investors in providing ecotourism experiences, including “low-impact structures” at three sites, the Thorsborne Trail on Hinchinbrook Island, the Whitsunday Island Trail and the Cooloola Great Walk. The processes for the Thorsborne Trail and Whitsunday Island Trail have been abandoned as they did not meet the expectations of the community and traditional owners. 

The Cooloola Great Walk Ecotourism Project is proceeding apparently with strong support from the government. A preferred proponent, CABN, has been appointed. 

Of the five proposed eco-accommodation camps proposed by CABN, two are of particular concern. One is at Lake Poona and the other alongside the Noosa River. 

Lake Poona 

Lake Poona is the only perched lake on sand on the Australian mainland. It is surrounded by rainforest including areas of a Threatened Ecological Community listed under the Environment Protection and Biodiversity Conservation Act 1999

Lake Poona

The proposed development would construct 10 cabins in the forest just 100 metres from the lake on the hillside overlooking the lake. This would fundamentally destroy what is now an essentially pristine environment — a true wilderness. 

A little history of Cooloola 

Cooloola is a sand mass essentially equivalent to Fraser Island, Bribie Island, Moreton Island and North and South Stradbroke Islands, but it happens to adjoin the mainland. 

Sand-mining companies became interested in the area around 1963 and mining for rutile and zircon began at Inskip Point in 1966. Noosa Parks Association, led by Dr Arthur Harrold, began the campaign against sand mining in 1963. 

In 1970, applications were made for 10 sand-mining leases on the dunes of Cooloola. The Bjelke-Petersen government was supportive. Arthur Harrold, with Bill and Mavis Huxley, formed The Cooloola Committee to fight sand mining. A major campaign began, led by Arthur and the Huxleys together with Ca-loundra wildflower artist, Kathleen McArthur, and her friend, Judith Wright, arguably Australia’s greatest poet. The campaign was successful with a small group of Liberal Party members of the government opposing the granting of the new sand-mining leases. Sand mining was still occurring between Double Island Point and Freshwater Creek on the eastern side of Cooloola under the earlier leases. Cooloola National Park was finally declared in 1975 but it excluded the central core which remained as State Forest. It also excluded the western catchment but that was added later as a re-sult of the continued efforts of Arthur Harrold and Bill Huxley. In 1990, the Commission of Inquiry into the Conservation, Management and Use of Fraser Island and the Great Sandy Re-gion led by Tony Fitzgerald QC recommended logging cease in the region and as a consequence the State Forest “hole in the heart” was transferred to national park. Tony Fitzgerald recommended the Great Sandy Region be nominated for World Heritage listing and ARCS was commis-sioned by the Queensland and Federal governments to prepare the nomination. The nomination included both Fraser Island and Cooloola but assessment by IUCN recommended Cooloola be excluded essentially because Fraser Island was an easily defined geographical area. There is no dispute that Cooloola is of World Heritage value.

The proposed development

The national park on the Cooloola sand mass was not an initiat-ive of government. It did not become national park because the government recognised its conservation values. It became na-tional park as a result of the devotion of conservationists, Arthur Harrold, Bill and Mavis Huxley, Kathleen McArthur, Judith Wright and many others. It is greatly distressing that their vision of Cooloola permanently set aside for the protection of nature could be destroyed for private profit, accommodation for a wealthy few and a little government revenue. Greg Wood, with whom we worked in the lead up to the SEQ Forests Agreement, is co-ordinating a campaign to try to stop the development. A web site has been set up where you can download postcards to email government ministers and there is a petition on

Please visit the web site, send an email to ministers and sign the petition. 

Proposed commercial development beside Lake Poona

Keith Scott

1 Comment

Filed under Biodiversity, Government Policy

Native forest logging adds to the climate-biodiversity crisis

Industry advocates commonly refer to statements in reports of the Intergovernmental Panel on Climate Change (IPCC) that sustainable forest management for timber can contribute to mitigation of Greenhouse Gas (GHG) emissions. Those statements are based on misleading accounting. It is only a matter of time before the new accounting standard formally accepted by the UN SEEA-EA in March 2021 is adopted in IPCC reports and hence the accounting standard for Nationally Determined Commitments (NDCs). It is clearly important to have credible, transparent statistics for the Global Stocktake (GST), a process for taking progressive stock of the world’s collective progress towards achieving the purpose of the Paris Agreement and its short- and long-term goals . It is also important to note that IPCC reports are conservative representing compromises resulting from (a) heavy lobbying from vested interests, (b) various necessary assumptions and (c) simplifications due to the complexity of issues considered.

Native forest logging in Queensland

In Queensland, it is likely that only around 50% of the wood harvested in a native forest operation finds its way to a sawmill . In the harvesting process, only around 40% of the log is recovered as sawn timber. Hence, no more than 20% of the carbon removed from the forest in a native forest logging operation ends up in anything that could be called long-term storage. Up to 80% of the harvested carbon will contribute to GHG emissions and will not be recovered through future growth for many decades. As discussed in the climate change article on pages 1 and 2, reduction in emissions has to occur urgently. Added to the direct emissions are those produced by harvesting machinery, transport and sawmilling. Native forest logging is a direct contributor to Queensland’s GHG emissions. In 2018 Queensland’s GHG emissions were by far the highest of any state or territory in the country. In the same year, Tasmania’s total emissions were negative which represents a 111.2% reduction compared to the year 2005. That reduction is recognised as being the result of reductions in native forest harvesting. In 2018, all states and territories except Queensland and Northern Territory had negative emissions from the Land Use, Land Use Change and Forestry (LULUCF) sector.

State and Territory Greenhouse Gas Inventories 2018, Australian Government
Department of Industry, Science, Energy and Resources

Biodiversity impacts

The Koala and Greater Glider are now listed as ‘Endangered’ in Queensland and nationally. The south-east subspecies of the Yellow-bellied Glider has been listed as ‘Vulnerable’. The Conservation Advice provided in relation to the Environment Protection and Biodiversity Conservation (EPBC) Act specifies logging as a ‘Severe’ threat to the Greater Glider. All three species occur in State Forests subject to logging. The ‘Code of practice for native forest timber production on Queensland’s State forest estate 2020’ includes requirements for retention of habitat trees for Greater Gliders (and other hollow-dependent species) and feed trees for Yellow-bellied Gliders but otherwise makes no provision for these threatened species. The Koala is not mentioned in the Code. 

Greater Glider — Photo: Esther Beaton

The climate-biodiversity crisis

It is now clear that the climate crisis cannot be solved without solving the biodiversity crisis . They are linked as part of complex adaptive systems which requires systems thinking rather than traditional linear thinking. 

Biodiversity loss is projected to be one of the largest environmental crises of all times and will collapse economies and societies. Swiss Re, the insurance group, estimated the global value of biodiversity at $33 trillion a year, close to the combined GDP of the US and China, with more than half of global GDP dependent on biodiversity and ecosystem services. Urgent and unprecedented transformational change is required across all sectors of society including governance.

Native forest logging must stop

The required transformational change involves considering the future of all activities that are currently contributing to climate change and biodiversity loss. One such activity is native forest logging. As a result of negotiations between the timber industry and the Queensland Government, the ‘Native timber action plan’ was announced in November 2019. The plan aims to provide a sustainable future for the native timber industry. It is inappropriate and unfair to workers in the industry to be giving false hope of security by promoting the objective of a long-term sustainable future for a declining industry fraught with uncertainty. Now is the time to plan for alternative opportunities for both businesses and workers. A key feature of complex adaptive systems is uncertainty and the potential for hard-to-predict, likely irreversible, phase shifts or “tipping points”. For example, populations of common species, even whole ecosystems can suddenly collapse if positive, reinforcing feedback mechanisms become dominant including through management interventions such as logging. 

Keith Scott & Aila Keto 

Leave a comment

Filed under Biodiversity, Climate change, Forests

Federal Court overturns ruling against logging in Victoria’s Central Highlands

In Rainforest News 68, we reported the decision of the Federal Court that logging in the Central Highlands of Victoria required approval of the Federal Minister for Environment. The decision was handed down in May 2020.

The agency responsible for management and sale of timber resources in Victoria, VicForests, appealed the decision. On 10 May 2021, the Full Bench of the Federal Court handed down its decision upholding VicForests’ appeal ruling that forestry operations in the Central Highlands did not require Federal approval.

Central to the issues are (1) the fact that logging is being carried out under the Central Highlands Regional Forest Agreement (CH RFA), and (2) the impact of logging on the Greater Glider and Leadbeater’s Possum. The Greater Glider is listed as ‘vulnerable’ and Leadbeater’s Possum as ‘critically endangered’ under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act).

The figure below illustrates the decline in the populations of Greater Glider in the Central Highlands.

Source: Lindenmayer & Sato (2018)

Section 38(1) of the EPBC Act requires that forestry operations must be undertaken “in accordance with an RFA” in order to be exempt from the provisions of the Act requiring approval by the Minister, including Section 18 which relates to listed threatened species and endangered ecological communities. In the original court proceeding, the parties agreed to consider the question whether forestry operations in the Central Highlands were being carried out “in accordance” with the CH RFA and therefore were exempt from Section 38 of the EPBC Act.

The CH RFA states “The Parties agree that State Forest outside the CAR Reserve System is available for timber harvesting in accordance with the Central Highlands Management Plan and the Code of Forest Practices for Timber Production.”

The Federal Court action was taken against VicForests by Friends of Leadbeater’s Possum. In her decision, Justice Debra Mortimer SC found that “in accordance with an RFA” as required by Section 38(1) of the EPBC Act included conforming with the Forest Management Plan and the Code of Forest Practices for Timber Production which are accredited by the Commonwealth under the RFA. Clause of the Code, which is a Mandatory Action under the Code, refers to application of the precautionary principle:

The precautionary principle must be applied to the conservation of biodiversity values. The application of the precautionary principle will be consistent with relevant monitoring and research that has improved the understanding of the effects of forest management on forest ecology and conservation values.

Greater Glider © Esther Beaton

Judge Mortimer considered that VicForests should have, but did not, apply the precautionary principle with respect to the impact of logging on the Greater Glider and Leadbeater’s Possum. Hence, she concluded that the forestry operations were not carried out in accordance with the RFA and therefore were not exempt from Section 38(1) of the EPBC Act.

The judges determined that the words “in accordance with” were meant to be descriptive of the forestry operations and that as long as the forestry operations were carried out within the RFA area they would be “in accordance with an RFA”.

That is to say, a contravention of a condition of permissibility of the conduct of the forestry operation does not mean that the operation is prohibited by the RFA. Again, the focus of the statutory text is on the geographical area on which the RFA permits forestry operations and not the restrictions, limits, prescriptions, or contents of the Code or an RFA.

In light of these reasons, the primary judge’s finding (Separate Question reasons at [155]) that the actual conduct of forestry operations (being an action for the purposes of the EPBC Act) must be undertaken in accordance with the contents of the CH RFA – that is, in accordance with any restrictions, limits, prescriptions, or contents of the Code – in order to secure the benefit of the exemption in s 38(1) cannot be sustained.

The Court noted the Objects of the EPBC Act are, inter alia, “to provide for the protection of the environment, especially those aspects of the environment that are matters of environmental significance” and recognised that the Greater Glider and Leadbeater’s Possum are “matters of national environmental significance”. These species therefore should be protected by provisions of the EPBC Act. However, the Court noted another of the Objects of the Act is to “to assist in the co-operative implementation of Australia’s international environmental responsibilities”. They argue that it is the responsibility of the Victorian Government to ensure that it complies with the expectations of the Commonwealth. The conclusion is that compliance with the Code of Forest Practices is not a matter for the Federal Court.

Friends of Leadbeater’s Possum are considering appeal to the High Court.

Prior to the decision of the Full Bench, Senator Bridget Mackenzie introduced a Bill into the Senate which proposes to remove the words “in accordance with an RFA” from both the EPBC Act and the Regional Forests Agreements Act (2002).

Leave a comment

Filed under Biodiversity, Forests

Federal Court rules logging in Victoria’s Central Highlands requires Federal approval

 On 27 May, the Federal Court handed down a decision that could have very significant implications for native forest logging in Australia. The case was brought by Friends of Leadbeater’s Possum against VicForests, the agency responsible for management and sale of timber resources in Victorian State Forests. 

The legal action related to the impact of forestry operations on the Greater Glider and Leadbeater’s Possum in 66 coupes in the Central Highlands. The Greater Glider is listed as ‘vulnerable’ and Leadbeater’s Possum as ‘critically endangered’ under the Environment Protection and Biodiversity Conservation Act 1999 (Cth). 

The areas in question are covered by the Central Highlands Regional Forest Agreement (RFA). 

 Background to RFAs 

There are 10 RFAs around Australia, five in Victoria, three in New South Wales, one each in Tasmania and Western Australia. They are agreements between the Commonwealth and the State Governments and were signed between 1997 and 2001. There was an RFA process for South East Queensland but it did not end in an agreement— conservation groups led by ARCS rejected the Federal Government’s proposal and persuaded the Beattie Government to develop a State agreement which eventuated as the South East Queensland Stakeholder/Government Forests Agreement. 

The RFAs came out of the National Forest Policy which was agreed between the Commonwealth and the States in 1992. The 1980s and 90s were the times of the “forest wars”. In 1995, a convoy of logging trucks blockaded Parliament House.

Prime Minister Paul Keating was determined to get the Commonwealth out of the picture and instituted the RFA process. The intention was that these agreements would put an end to the “forest wars”. That was not to be. 

The EPBC Act 

A contentious component of the agreements was that forestry operations carried out under an RFA would be exempt from provisions of the Federal Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) including provisions relating to the protection of threatened species. Such species were supposedly to be protected by provisions within the RFAs. These matters were central to the Federal Court’s deliberations. 

 The decision 

Presiding over the Federal Court case was Hon. Justice Debra Mortimer SC. The case involved numerous hearings and stages. In 2018, Judge Mortimer set up a “Separate Question” which was whether VicForests’ forestry operations had the benefit of the exemption in section 38(1) of the EPBC Act. Under the RFA, the Commonwealth accredits the forest management system which includes the Forest Management Plan and the systems and processes established by the Code of Forest Practices for Timber Production. This is the basis for the exemption from section 38(1) of the EPBC Act. 


Central Highlands logging Photo: Chris Taylor

In relation to the Separate Question, Friends of Leadbeater’s Possum argued that the five-yearly reviews required by the RFA had not been carried out and therefore the exemption did not apply. VicForests argued that as long as forestry operations are conducted within the RFA region the exemption of s 38(1) applies. 

Judge Mortimer rejected both arguments noting in regard to VicForests’ argument that, for the exemption to apply, forestry operations must be undertaken in conformity with the systems of forest management accredited by the RFA. 

A significant focus of the court proceedings was the Code of Practice for Timber Production. Clause of the Code states “The precautionary principle must be applied to the conservation of biodiversity values.” 

For the purposes of the court process, the 66 coupes were divided into Logged Coupes and Scheduled Coupes. Judge Mortimer made the following decision: 

In undertaking forestry operations in the Logged Glider Coupes, VicForests did not apply the precautionary principle to the conservation of biodiversity values in those coupes, as it was required to do by cl of the Code of Practice for Timber Production 2014. Specifically, on the applicant’s case, VicForests did not apply the precautionary principle to the conservation of the Greater Glider as a threatened species present in, and using, the forest in thosecoupes. Accordingly, in relation to the forestry operations undertaken by VicForests in the Logged Glider Coupes, its conduct was not covered by the exemption in s 38(1) of the EPBC Act.


Judge Mortimer made a similar decision regarding the Scheduled Coupes arguing that VicForests “is unlikely to apply the precautionary principle to the conservation of biodiversity values in those coupes”. 

Based on those arguments, Judge Mortimer concluded that each forestry operation in each of the 66 coupes is an “action” under the EPBC Act. That means that the forestry operations require the approval of the Federal Minister for Environment, presently Hon. Sussan Ley MP. 

Judge Mortimer has given the parties an opportunity to agree on the appropriate orders the court should make. If there is no agreement, the parties may make short submissions and the court will decide on the final orders. 

Other observations by the Judge 

Judge Mortimer made some general observations that illustrate common issues with native forest logging. At the risk of boring readers with details, they are reproduced below. 

First, what the evidence in this proceeding has demonstrated is that the protection and conservation of biodiversity values – in this case relevantly the two listed threatened species in issue – is essentially a practical matter. Although policies and planning are important precursors and elements in protection and conservation, what happens on the ground in the native forest which supports and encompasses those values is how protection and conservation are achieved. Relevantly to the issues in this proceeding (rather than the wider biodiversity values protected by other aspects of the EPBC Act), understanding a native forest as a living, changing, finely balanced and often vulnerable ecosystem, and understanding the way in which all flora and fauna species in fact (rather than theory) use and depend on that native forest, are what best informs protection and conservation of, and the avoidance of adverse impacts on, those species. The evidence demonstrates the need for this approach is acute when dealing with listed threatened species. 

The second observation addressed the argument put by VicForests that their decisions had “struck a balance between conservation measures and those that relate to the commercial use and exploitation of forest resources in State Forests” and that where there were “value judgments” to be made about that balance, those judgments were the “province of the legislature or the executive rather than the judiciary”. The judge responded arguing that 

the Court’s function is to determine, on the evidence, whether the applicant has proven, on the facts and on the law as applied to those facts, its allegations against VicForests …. Contrary to VicForests’ submissions, there is a significant factual aspect to the applicant’s allegations, which as a trial court, the Court must decide. It necessarily involves examining the competing evidence (including expert opinion evidence) about topics which are the product of wider policies and practices, and factual topics of more general application. In performing its task, the Court acts on the evidence before it, taking account of the submissions made. Where the legal and statutory framework which the Court must consider, by reason of the parties’ respective cases, includes matters of degree, or has some qualitative or evaluative element, the determination of those matters is part of the exercise of judicial power, and not outside it. 

The third observation related to the inherent contradiction in the role of VicForests — and all other forestry agencies. 

On the one hand, it is required to conduct forestry operations in Victoria’s native forest, rather than only in plantations. That native forest is identified as an available timber resource, indeed a principal available timber resource in Victoria, for VicForests to perform its commercial forestry function, as conferred by statute. On the other hand, VicForests is required by law to conduct those forestry operations in a way which avoids and mitigates adverse impacts on a wide range of biodiversity values, a range that is much wider than listed threatened flora and fauna species, but includes them. As I explain later in these reasons and as both VicForests and various reviewing bodies have recognised, for listed threatened species which are highly dependent on the very native forest which is to be subject to forestry operations, and for whom recovery out of the status of being a threatened species is expressed to be an objective, the avoidance of adverse impacts in a real world sense (rather than just an aspiration) inevitably involves compromising available commercial timber resources. Hence the conflict, which may explain (but not necessarily justify) why the actual conduct of forestry operations on the ground often cannot meet the conservation and protection obligations imposed by law.” 

Broader implications of the decision 

Implications for forestry operations in other RFA areas in Victoria, New South Wales, Tasmania and Western Australia arise from the finding that where forestry operations do not conform with management prescriptions included in the RFA, they could be found to be “actions” under the EPBC Act and require approval of the Federal Minister, Sussan Ley. 

According to The Guardian, a spokesman for Minister Ley said the Department would “carefully consider the Federal Court’s 450 page judgment, noting that formal orders are yet to be made” and that the findings “will require detailed consideration before the department can discuss possible implications”. 


Toolangi State Forest, Central Highlands     Photo: Peter Campbell

Keith Scott

Leave a comment

Filed under Biodiversity, Forests

Vale Norman Myers

NormanMyersOne of the world’s leading conservation scientists, Dr Norman Myers, died on 20 October 2019 from dementia.

Norman Myers’ most well known scientific contribution was developing the concept of “biodiversity hotspots”. Hotspots were defined as (a) areas with exceptional concentrations of species with high levels of endemism, and (b) areas experiencing exceptional levels of threat. Protecting such areas offered a very effective means of conserving biodiversity.

Norman was born in Lancashire in 1934 to a poor family on a sheep farm but Norman’s mother ensured he had an education and after graduating from grammar school he studied modern languages at Oxford University.

Norman has described developing a great interest in African wildlife as a result of reading Rider Haggard as a boy. In 1958, during the last days of the British Empire, he joined the Colonial Service and took up a post in Kenya. After two or three years, Kenya became independent and Norman lost his job. He became a high school teacher and later a professional wildlife photographer. It was while photographing African wildlife that Norman became interested in species generally.

His studies on cheetah and leopard populations in Kenya earned him a PhD from University of California Berkeley in 1973.

Norman did not have a typical background to being a scientist and never held an academic appointment. Despite that, his scientific contributions have been outstandingly significant. But his contributions were not initially recognised. His first paper on ‘hotspots’ was rejected by mainstream ecology journals but was eventually published in 1988. He developed the concept further and his major paper, Biodiversity hotspots for conservation priorities, published with colleagues in Nature in 2000, has been cited more than 13,000 times.

In that paper, Myers et al. noted that 44% of all species of vascular plants and 35% of all species in four vertebrate groups are confined to 25 hotspots comprising only 1.4% of the land surface of the Earth.

Norman Myers was particularly interested in tropical forests. His paper, Threatened biotas: “hot spots” in tropical rainforests, published in Environmentalist 8 in 1988, noted that tropical forests contain at least half of all Earth’s species but are being depleted faster than any other biome. In that paper he refers to the tropical rainforests of Queensland as an example of a hot spot area in a developed country, citing ARCS publications on their conservation significance and noting that “despite the scientific value of the area, it continues to be logged, with support from the Queensland Government in the form of abundant subsidies.”

Norman Myers was among the first scientists to draw attention to the increasing rate of species extinctions. In 1979, he published a book The Sinking Ark, A New Look at the Problem of Disappearing Species. At the time, it was general considered that the rate of species extinction was one a year. Myers determined that it was more like one a day. For that he was attacked by the scientific community but was later proved to be right. Leading conservation scientist, Dr Peter Raven of Missouri Botanic Gardens and a friend of ARCS, told science writer Tim Radford “I don’t think Norman’s been seriously wrong on anything.”

Norman Myers produced a ground-breaking and highly influential report in 1980 on the loss of tropical rainforests for the National Research Council, National Academy of Sciences.

Norman Myers was a consultant to the Food and Agriculture Organisation (FAO) and advised FAO on the loss of tropical forests noting the impacts of the “displaced peasant or landless farmer” on deforestation. In 2008, Myers told FAO “What we do – or don’t do – in the next few decades, will determine the future of our planet for at least the next five million years”.

In 1987, ARCS arranged for Norman Myers to visit Brisbane and he gave a talk at an ARCS meeting to a capacity audience in Brisbane City Hall. This event was a peak in our public campaign to protect the rainforests of Northeast Queensland — the Wet Tropics.

Over his lifetime. Norman Myers received many honours. He was appointed foreign member of the US National Academy of Sciences, named by Time magazine as one of its Heroes of the Environment and made a Companion of the Order of St Michael and St George by the British Government. In 1992, he shared the prestigious Volvo Environment Prize with Peter Raven. He was also appointed distinguished or visiting professor at numerous universities around the world.

His contribution to biodiversity conservation will be sorely missed. He will forever live in our own hearts as a good friend and unstinting supporter.

Leave a comment

Filed under Biodiversity, Forests, Sadness

Groundwater mining at Springbrook

High on the ridgeline in the highest part of Springbrook Plateau, south-east Queensland, there is a proposal to extract groundwater for bottling as ‘spring water’.

The development application is currently being considered by Gold Coast City Council. ARCS has lodged an objection, a copy of which follows.


  1. Essence of the application
  • All work carried out on the property has been to prepare the site for commercial groundwater extraction. Approval for construction of a house was granted in September 2016 but no work has been carried out in that regard. Australian Rainforest Conservation Society (ARCS) contends that this application for groundwater extraction should be taken to have involved major vegetation clearing.
  1. The proposed use conflicts with the City Plan.
  • The application prepared by Michel Group Services fails to include the associated movement of 8 heavy vehicles per day in and out of the property as part of the proposed use. The proposed use, taken as a whole, will clearly impact the landscape character and rural amenity and is therefore not compatible with the Rural Zone Code.
  • The associated movement of 8 heavy vehicles per day in and out of the property, which is within the ‘Rural landscape and environment precinct’, will clearly cause a loss of scenic amenity values of this hinterland ridgeline and is in conflict with the Rural Zone Code.
  • The Rural Zone Code requires that non-rural activities (extractive industry) provide goods and services that directly support the rural community. The proposed use is primarily, and probably wholly, to provide water to water-bottling companies. It will not support the rural community.
  • The Rural Zone Code requires that non-rural activities (extractive industry) do not conflict with the landscape character of the area. The proposed use involves eight heavy vehicle movements in and out of the property each day. That would clearly impact on the landscape character.
  • The proposed development does not conform to Rural Activity Code 9.3.17. It does not conform to the overall purpose of Code being to “provide a level of amenity reflective of rural areas and to protect the environment” and to “provide a reasonable level of amenity for the surrounding area.” As owner of the two properties directly opposite the proposed site, purchased specifically to protect their outstanding World Heritage values, ARCS contends that the daily movement of 8 heavy vehicles in and out of the property will in no way “provide a reasonable level of amenity for the surrounding area”.
  1. The proposed use will significantly increase the risk of serious, head-on collisions on Repeater Station Road
  • The traffic engineers’ report notes that sections of the road “narrow to less than the ideal width for two vehicles to pass”. Given that, it is thoroughly inappropriate to propose introducing a new use with heavy vehicles whose width is only slightly less than half the width of these narrow sections of the road.
  • Given blind corners and frequent low visibility due to cloud immersion on this narrow section of Repeater Station Road, used largely by visitors likely to be unfamiliar with the road, 8 heavy vehicle movements a day would significantly increase the risk of serious head-on collisions.
  • This particular section of Repeater Station Road is not currently used to any significant extent by heavy vehicles. Survey data provided in the Traffic Impact Assessment did not record any heavy vehicles over two full days of recording.
  1. The proposed additional extraction from this aquifer has the potential to impact on matters of environmental significance
  • The extraction of groundwater at this site, adding to existing extraction from the same aquifer, has the potential to impact on matters of environmental significance (World Heritage area, protected areas, biodiversity areas, Hinterland to Coastal Corridors, Hinterland Core Habitat System) and thus conflicts with the Rural Zone Code (Rural landscape and environment precinct).
  • The proposed bore site is less than 400 metres from the Springbrook National Park section of Gondwana Rainforests of Australia World Heritage Area.
  • The aquifer from which water will be pumped feeds major attractions in the World Heritage Area including Twin Falls and Natural Bridge.
  • The application does not consider the likely impacts of climate change. Predicted changes for the World Heritage Area include an increase in average annual temperature, an increase in the number of hot days, a drop in average annual rainfall with increasingly severe dry seasons and extreme weather events, increasing annual moisture seasonality, higher evaporative demand and increasingly severe and frequent droughts and fires (Australian National University 2009). Another predicted change is a lifting in the cloud base.
  • Of particular concern is the potential impact on springs and streams during extended dry periods. For example, rainfall from July through September 2017 was just 48 mm. Streams such as Cave Creek and Boy-Ull Creek would have been wholly dependent on groundwater discharge from the aquifer. During such a period, the proposed extraction could be as much as 4 million litres (8 large tankers per day).
  • There is the potential for impacts on endangered plant species including the highly significant Eucryphia jinksii. This tree species is recorded at lower elevation below the escarpment approximately 1.3 km west of the bore site and likely to be within the drawdown zone.
  1. The application is inconsistent with the State Planning Policy
  • State Planning Policy requires consideration of the projected impacts of climate change with respect to natural hazards. The proposed extraction of groundwater has the potential to increase the likelihood of bushfire in an area that the Bureau of Meteorology predicts will spend more time in drought over the course of the century. BOM also predicts with high confidencethat climate change will result in a harsher fire-weather climate in the future in the area. Recent fires in rainforest in Lamington National Park confirm that this hazard already exists.
  1. The proposed use conflicts with Gold Coast City Council policy
  • Approval of this proposal, which would generate more than 30 million half-litre plastic bottles of water annually, would fly in the face of the Council’s “Choose tap” campaign.

A.  The Essence

Site at 18 August 2014
Commercial Groundwater Extraction would not have been approved by Council as the property lies within the Rural Landscape and Environment Precinct which excludes vegetation clearing for rural activities.
Site at 15 May 2016
Site already prepared for MCU Commercial Groundwater Extraction application made 27 April 2018. Preparation works were carried out under MCU201601209 for Detached Dwelling and Treeworks.Some clearing was illegally carried out before the MCU was approved. GCCC issued show cause notice. The report by Rytenskild Traffic Engineering states “The proposed driveway arrangement is in place, together with a shed that will be used for the proposed operation.”

Clearing/widening of the southern exit continues (ground observations to 10 November 2018).

Rytenskild recommended some trees be removed. The owner has already removed some of these trees without approval.

Hoffmann Drilling would be ready to extract and truck water tomorrow with all preparatory work having been carried out under the MCU for a dwelling.

Since the original application for Commercial Groundwater Extraction, further work has been carried out to prepare for groundwater extraction. Several more bores have been drilled, possibly up to 12.

There is no sign of any work being carried out in relation to the construction of a house.

bore_drilling Drilling

In summary, works carried out on the site to date include

  • clearing an area of 2500 sq.m. (GFA of proposed house is 271 sq.m., shed is 72 sq.m.)
  • numerous bores
  • pump & shed
  • storage tanks
  • road designed for entry and exit of large trucks.</li

The site has been fully prepared for groundwater extraction before Council has made a decision but there has been no work at all done on construction of a house despite approval being granted in September 2016.

As shown on the approved plan below, the proposed house extends over the lower driveway. So fully laden water trucks would be driving under the bedroom and living room daily starting at 6.30 am!

House_planB.  Basis of this objection

  1. Vegetation clearing

As detailed in Part A ‘The Essence’, there has been a lot of work carried out on the site. However, it is reasonable to conclude from the nature of the work that it has all been directed towards preparation of the site for groundwater extraction. No work has been carried out on construction of a house despite approval having been granted in September 2016. It is therefore reasonable to propose that this application for groundwater extraction includes major clearing of vegetation.

The application repeatedly claims that it is consistent with various provisions of the City Plan as no vegetation clearing is involved. ARCS contends that all such claims should be taken to be false.

  1. The proposed use conflicts with the City Plan

(a)       The proposed use conflicts with the Rural Zone Code

(i) The proposed use will not directly support the rural community

The Rural Zone Code (2)(a)(iii) provides that land uses “may include a range of small-scale, compatible non-rural activities where they provide goods and services that directly support the rural community.”

It is claimed that the proposed use will support the community through water deliveries. Sale of water to local residents is likely to be minimal. Springbrook residents have rainwater tanks or bores and would only need delivery of water in exceptionally dry periods. Local supply would be a minor part of the business if it occurred at all. Water supplied for drinking would require processing to meet drinking water standards. We understand that would not be possible under this application.

It can be concluded that water supply to local residents will either not occur at all or will be a very minor part of the proposal and therefore it does not meet the code requirement of providing goods and services that directly support the rural community.

If the broader community is considered, it can be argued that the supply of water in plastic bottles is not in the best interests of the community (University of Queensland 2019, Australian Broadcasting Commission 2018). This has been recognised by GCCC in its “Choose tap” campaign which reports that plastic bottles are the most littered items in Gold Coast waterways.

In response to the previous version of this application to extract groundwater, there were more than 320 objections but no supporting submissions. Whereas Council, in making its decision, is not required to consider public support, this level of objection can surely be taken to mean that supply of water to the Springbrook community is not required.

Internationally, there are growing local government and community concerns about commercial groundwater extraction for bottled water. In Florida, which has the largest concentration of freshwater springs in the world, many of its springs are running dry from overextraction (Sainato and Skojec 2019).

 (ii) The proposed use poses a threat to matters of environmental significance

This is covered in detail under 3. Impact on groundwater.

 (iii) The proposed use will conflict with the landscape character

The Rural Zone Code (2)(a)(iii) provides that land uses “may include a range of small-scale, compatible non-rural activities where they provide goods and services that … do not conflict with the landscape character.”.

The applicant, through Michel Services Group, repeatedly refer to the proposed use as involving small structures and argue no impact as the structures will not be visible from the road. That completely ignores the essential component of the proposed use being transport of the extracted water. The most obvious impact will come from 8 heavy vehicle movements in and out of the property each day. That would unquestionably impact on the landscape character of the area. That section of Repeater Station Road will become anindustrial site.

 (iv) The proposed use will conflict with the rural amenity

The Rural Zone Code (2)(a)(iii) provides that land uses “may include a range of small-scale, compatible non-rural activities where they provide goods and services that … do not conflict with .. rural amenity..”.

Again, the applicant argues the proposed use will not impact rural amenity because it will not be visible from the street. The associated 8 heavy vehicle movements in and out of the property each day will significantly impact on the rural amenity.

The acoustic report did not provide any measurements of the noise that would be created by fully laden water tankers climbing up the exit track and turning out onto Repeater Station Road

 (v) The proposed use will conflict with the purpose of the Rural Landscape and Environment Precinct

The property also lies within the Rural Landscape and Environment Precinct. The relevant code requires that “Land uses do not impact on matters of environmental significance, landscape and scenic amenity values of the land”. The code also aims to protect the “natural landscape .. particularly on the Hinterland ranges .. which contributes to the city’s distinct form, visual attractiveness and role as a major tourist destination.” Code part 6.2.20-2 PO5 requires that activities do not result in “loss of the scenic amenity values of hinterland ridgelines”. Prior to the partly unauthorised vegetation clearing on the property, the landscape character was one of old-growth forest. The clearing adds to cumulative impacts on the landscape character of this area, in particular canopy integrity essential to viability of rare, threatened and phylogenetically significant species contributing to Outstanding Universal Value of the World Heritage precinct.

We contend that 8 heavy vehicle movements in and out of the property on the road to a major tourist destination, Best of All Lookout, in a World Heritage Area would significantly impact on the landscape and scenic amenity values and the visual attractiveness of a popular tourist destination.

As discussed below, we also contend that the proposal runs the risk, during extended dry periods, of depleting the water source for other major tourist destinations, Twin Falls and Natural Bridge.

 (b)      The proposed use conflicts with the General Development Provisions Code

The site of the proposed development is plainly not an appropriate location for extractive industry.

The General Development Provisions Code PO13 requires that “Development is designed to ..complement the character … of the local area.” An extractive industry is the antithesis of the character of the area, not only because of the commercial water extraction itself but also because of the very visible presence of heavy vehicles making 8 trips per day on the road to a major tourist attraction in the Gondwana Rainforests of Australia World Heritage Area. The property and its road frontage will effectively be turned into an industrial site.

The General Development Provisions Code PO2 requires that proposed development prevents loss of amenity and threats to health and safety, having regard to, inter alia, traffic and visual amenity. We contend that there will be significant impacts on safety (See 4. Traffic issues.) and visual amenity (See B2(a)(iv).)

 (c)       The proposed use conflicts with the Strategic Framework of the City Plan

Specific Outcome within Element — Landscape Character requires that “The city’s natural, non-urbanised appearance is protected for its contribution to the city’s outstanding scenic amenity, image and role as a major tourist destination.”

The application claims that “the use will not impact upon the existing scenic amenity of Repeater Station Road” again considering only the on-site buildings associated with extraction and not the associated transport. Eight heavy vehicle movements per day in and out of the property will clearly impact on the scenic amenity and the image of Springbrook as a tourist destination and a World Heritage site.

road to best of all

Dark green areas in this photo are conservation areas, mainly national park, illustrating the fact that the major land use in this locality is nature conservation. The two properties directly opposite the MCU property are private wildlife sanctuaries purchased by ARCS to protect their World Heritage Values.

The application also states that “the use is consistent with other properties on Repeater Station Road”. That is presumably a reference to the two (or three) existing commercial water extraction sites. We contend that those properties are anomalous and should not be regarded as providing a precedent. Almost all other properties on Repeater Station Road are used for residential purposes or nature conservation. (The exceptions are a horse paddock and a few communications towers.)

road at 263

This section of Repeater Station Road, just 1.3 km from Best of All Lookout, would be converted into an industrial site with 8 heavy vehicle movements per day.

3. Impact on groundwater

The application depends significantly on the assertion that there are already two groundwater extraction businesses on Repeater Station Road and they have had no impact on the aquifer. We contend that it has never been shown that that there has been no impact on groundwater discharge in the locality. Further, the assumption completely ignores cumulative impacts. The fact that there are already two current groundwater extractions occurring should raise concerns about a third extraction rather than providing assurance of no impact.

The hydrogeologists’ report notes that “Depletion of springs, waterfalls and streamflows occurs from time to time due to prolonged drought conditions.” That statement illustrates the issue. During prolonged drought conditions, springs, waterfalls and streams in this area are wholly dependent on discharge from this aquifer from which Hoffmann Drilling would be extracting more than 300,000 litres per week.

Whereas Council might consider approval with a condition on the volume to be extracted, that would be of great concern given the impact on the environment is unknown but potentially significant.

The report by Douglas Partners provides no confidence that the potential impact on the groundwater system has been adequately assessed.
The report rests heavily on long-term average rainfall and consequent recharge of the aquifer. Given that the proposed groundwater extraction would be expected to occur year after year no matter what the annual rainfall might be, it would have been prudent to look at the range of annual rainfall and especially the minimal annual rainfall.

The long-term average annual rainfall is quoted by Douglas Partners as 3053.4 mm. However only 44 of the 104 years of rainfall data (1915–2018) have recorded annual rainfalls of ≥ 3000 mm. Years where annual rainfall exceeds 3000 mm are often associated with cyclone activity where the majority of falls are high rainfall events over a short space of time. Even in such years, such as in 1956, five consecutive months were classified as dry, i.e. less than 100 mm of rainfall during a month. There are nine years where annual rainfall is less than 2000 mm. In many years there have been six or more consecutive months in a year classified as dry. In 2002, the annual rainfall at Upper Springbrook was just 1569 mm and in 2014 it was 1927 mm. Rainfall over the four months from May to August 2018 was 224 mm. In January 2019 rainfall at Upper Springbrook was only 17 mm, the lowest ever recorded.

However, only 44 of the 104 years of rainfall data (1915–2019) have recorded annual rainfalls of ≥3000 mm.

The test pumping done by Douglas Partners shows a fall in the aquifer level of 4.5 meters over 24 hours and a significant recovery over the following 2 hours. There was no attempt to mimic the pumping for 12 hours per day every day during an extended dry period.

Potential impacts of climate change
We find it surprising that the specialists did not consider the impacts of future climate change, given that the proposed extraction would continue “forever”.

Predicted changes for the World Heritage Area include an increase in average annual temperature, an increase in the number of hot days, a drop in average annual rainfall with increasingly severe dry seasons and extreme weather events, increasing annual moisture seasonality, higher evaporative demand and increasingly severe and frequent droughts and fires (Australian National University 2009).

The State Interest “Natural hazards, risk and resilience”, as defined in the State Planning Policy, has not been integrated in the City Plan. Hence, “the applicable assessment benchmarks, relevant guiding principles, state interest statements and state interest policies contained in the State Planning Policy applies to development, to the extent relevant.”

The State Planning Policy defines this State Interest as follows: “The risks associated with natural hazards, including the impacts of climate change, are avoided or mitigated to protect people and property and enhance the community’s resilience to natural hazards.”

Relevant to this proposed use, taking account of the likely impacts of climate change, is the natural hazard of bushfire. The State Planning Policy requires development to “maintain or enhance natural processes and the protective function of landforms and vegetation that can mitigate risks associated with the natural hazard”.

Under the planning legislation, Council is required to consider the likely impacts of climate change.

Recent fires in the Beechmont area and Lamington National Park show that extended dry conditions and higher temperatures can lead to fires occurring in rainforest. The Bureau of Meteorology’s (BOM) prediction for the East Coast (Northern) region in which Springbrook occurs is for time spent in drought to increase over the course of the century. BOM also predicts with high confidence that climate change will result in a harsher fire-weather climate in the future in this region.

Research has shown impacts of wildfire can be related to groundwater (Taufik et al. 2017). Groundwater extraction can be expected to increase the likelihood and impacts of wildfire and this needs to be considered in assessing this application.

Approval of this application has the potential to increase the risk of bushfire in the Springbrook rainforest, an outcome that would be disastrous for the community and for Gold Coast City.

There is evidence that climate change may already be having an impact on fauna in this very locality. The black-tailed dusky antechinus (Antechinus arktos) was discovered in 2014 and last year placed on the Federal endangered species list. Dr Andrew Baker, from QUT’s Science and Engineering Faculty, said his research team spent time earlier this year around Best of All Lookout at Springbrook National Park as part of their ongoing study of the rare antechinus. The area is one of the marsupial’s four known Scenic Rim mountain habitats. They had done trap-and-release studies in the same area annually from 2013 to 2017 between May and September. During those visits, it has been teeming with small mammals of various species easily caught, and that was what they expected to see again this year. However, in the 1750 traps set in 2019, no rare black-tailed dusky antechinus were captured, nor any of the very common brown antechinus (Antechinus stuartii). Based on past studies, they had expected to see up to 10 black-tailed dusky antechinus captures and about 250 brown antechinus captures. The results were very concerning.

Dr Baker said climate change and extreme weather plausible explanation. Research has shown a strong link between the amount of rainfall and insect availability. The 17 mm of rainfall in Upper Springbrook in January, 2019 was the lowest on record. Rainfall levels in February were 32% of the long-term average, followed by March levels that were 20% lower than the long-term average. Commercial water extraction, through impacts on groundwater discharge, could be expected to reduce leaf litter insect populations upon which Antechinus arktos depends. Extinction of this animal would be the first antechinus extinction recorded in the world.

Of further concern is the potential impact on springs and streams during extended dry periods. The hydrogeologists’ report depends on the assumption of high recharge. But that can not be assumed. For example, rainfall from July through September 2017 was just 48 mm. Streams such as Cave Creek and Boy-Ull Creek would have been wholly dependent on groundwater discharge from the aquifer. During such a period when recharge is negligible, the proposed extraction could be as much as 4 million litres (4 large tankers per day). It is these extreme conditions/events compounded by several co-occurring stressors that have the most significant impact rather than considerations of just average annual rainfall as is the case for the hydrogeological specialists.

Twin Falls

Twin Falls at moderate flow

Twin Falls

Twin Falls, September 2018

The application includes the statement “It is also important to note here that due to the depth of aquifer (84 m below the natural surface level) the terrestrial trees do not rely on it as a source of water, and therefore extraction of ground water will not impact upon said trees.” This is further argued by Element Ecology in their specialist report. According to the specialists’ report, the aquifer is actually around 60 m below ground level at the bore site. However, at lower elevations on the property and beyond the property boundaries, the aquifer is closer to or at the surface where vegetation (as well as fauna such as frogs) may well depend on this source of water.
Lowering the aquifer would be expected, through lowering pressure, to reduce the level of discharge with likely impacts on the overall hydroecology of the adjoining catchments. Many macro-invertebrates that are either important components of the broader foodweb or have other essential ecosystem functions, have part or whole of their life-cycle associated with streams, springs or soaks.

In the vicinity of the property there are springs occurring at an elevation of >900m. On the property itself, there are springs, intermittent streams and a permanent stream above 800m. These springs and streams indicate the presence of groundwater close to the surface at this elevation. There is the potential for extraction from the aquifer at the proposed site to affect this groundwater and hence ecosystem integrity.

Large, old trees, apart from being critical carbon sinks that help mitigate climate change, are keystone species within rainforest communities. Their capacity for hydraulic redistribution of moisture from lower levels fed by aquifers keeps soils moist during dry periods for the benefit of other species. Commercial ground water extraction from the aquifer has the potential to interfere with this process with long-term consequences for the ecosystem and its characteristic diversity.

Three frog species that contribute to World Heritage values, Assa darlingtoni, Kyarranus loveridgei and Lechriodus fletcheri are not dependent on streams but do depend on moist soil or ephemeral pools. They are likely to be impacted by any reduction in available moisture. K. loveridgei has been recorded on 263 Repeater Station Road.

There is the potential for impacts on endangered plant species including the highly significant Eucryphia jinksii. This tree species is recorded at lower elevation below the escarpment approximately 1.3 km west of the bore site and likely to be within the drawdown zone. There is evidence that the main large canopy trees such as Argyrodentron trifoliolatum, essential for ecosystem integrity, are declining as a result of longer spells of drier microclimate and soils followed by high rainfall events accompanied by strong winds. Moreover, depletion of water levels of interconnected aquifers within the local fractured basalts has the potential for diminishing hydraulic redistribution by these large canopy species with flow-on impacts on other surrounding moisture-dependent species.

Douglas Partners assessed the impact of extraction on the aquifer by estimating the impact on flow into Little Nerang Dam. Not surprisingly, the impact was insignificant. What is required is information on the impact of extraction on the local environment gained through research into the ecophysiological responses of vegetation, in particular trees, to the extraction of groundwater in order to determine a baseline from which changes can be observed over time. Such research includes the use of dendrometers and sap flow meters, measurement of Leaf Area Index (LAI), comparison of the stable isotope composition of water in the xylem and the water table, determination of the root depth of trees with regards to the water table, and calculation of leaf water potential and water balance. Scientists would subsequently use a subset of these tools to monitor the ecophysiological responses of vegetation over time, often many years.

A realistic assessment process should be based on a systems approach particularly when dealing with complex, dynamic ecosystems potentially exhibiting non-linear threshold dynamics with alternative stable states, driven and maintained by bi-directional interactions and feedback loops between species, resource fluxes and disturbance regimes. Such systems are capable of threshold behaviour characterised by tipping points to different states including ecosystem collapse as defined by the IUCN Red List of Ecosystems Categories and Criteria, Version 1.1. Gland, Switzerland: IUCN. ix + 99pp. Consideration of impacts involving a linear approach of direct causality is inappropriate especially when medium- and long-term impacts are concerned.

The ridge comprising Repeater Station Road is ecologically significant given it uniquely receives both morning and afternoon sunlight leading to a higher ecologically productive zone relied upon during extreme dry periods by a range of fauna including especially Albert’s Lyrebird and Noisy Pitta. It is likely that during these extreme events road kills from increased traffic from the development would result in long-lasting impacts on population numbers.

Douglas Partners provide a chart of drawdown versus distance from the bore. Their report includes an image with a circle showing the approximate extent of drawdown to 1.5 metres. The image below shows the approximate extent of drawdown to 1 metre. Clearly, the image is indicative only as the drawdown extent would not be circular. This modelled result was based on pumping for 24 hours per day with no rainfall. Whereas that is an unlikely situation, a drawdown of anything like 1 metre would have disastrous effects on vegetation and streamflow.


Australian Rainforest Conservation Society (ARCS) owns the group accommodation business, Koonjewarre, which operates on the property adjoining the eastern boundary of 263 Repeater Station Road. A feature of the property is a lake on a tributary of Boy-Ull Creek fed by a spring which derives from the up-slope aquifer. The lake is a feature of our business and is used for canoeing activities for schools and other groups including State Emergency Services. There is the potential for the flow in this watercourse to be impacted by extraction from the aquifer by the applicant. This would significantly affect our business. All profits from the business are directed to rainforest restoration on areas adjoining the World Heritage Area on Springbrook Plateau.


We can also provide some anecdotal evidence that groundwater extraction currently occurring on Repeater Station Road depletes the aquifer to the point where water ceases to be available at other sites. ARCS has management responsibility for a property at 74 Repeater Station Road which is at a lower altitude than the three existing extraction sites. Water is supplied to the buildings on that property from a bore pump which, given the location, derives water from the same aquifer as the commercial extraction sites further south on Repeater Station Road. In late 2017, we had to replace the bore pump to restore water supply to the property. However, when the new pump was installed, very little water could be pumped and it took several days for a reasonable volume of water to be obtained.

The application makes reference to the fact that commercial groundwater extraction has been approved at three other sites in Repeater Station Road. The reference is presumably making the point that commercial groundwater extraction is a legitimate activity in the area. But, as noted above, cumulative impacts need to be considered. Given that it is distinctly possible that existing commercial extraction is significantly affecting the aquifer, it would be irresponsible to add a third (or fourth) commercial extraction in the absence of definitive data on the impact on the environment.

The previous response to Council’s information request states “there are similar uses located elsewhere along Repeater Station Road that have been operational for many years without issue”. We provided anecdotal evidence above that suggests that there has been an issue.

The response states that a “private individual could take the same or greater amounts of water without any approvals or restrictions.” The argument is hollow. No individual could possibly require 60,000–224,000 L per day. Further, water extracted for domestic purposes is returned to the environment following on site treatment.

Further still, if there were a significant drawdown from future bores, it would be prudent to allow for that prospect and ensure that groundwater is available for future additional household use and not used for the financial benefit of one business and producing more of an environmentally undesirable product.
The response to Council’s request for more information includes a response from the hydrogeologists, Douglas Partners. They argue that “Limiting drawdown to a property is not considered to be a relevant requirement in managing groundwater resources in the Springbrook area.” We contend that it is a completely relevant requirement if the extraction causes an environmental impact beyond the boundary of the property, e.g. in the World Heritage Area. The City Plan requires such a consideration.

It is also noted that the highest pre-clearing density of modelled threatened flora and fauna habitat in Queensland is found at Springbrook (M.Laidlaw pers. comm, Department of Environment and Science 2018). This finding significantly elevates the importance of Springbrook, including the area relevant to the proposal, to the State’s and Australia’s threatened biodiversity.

Given that

  • the recommendations of Douglas Partners are apparently based on long-term average annual rainfall which is twice the minimum annual rainfall over that period, and
  • future climate change is predicted to lead to lower rainfall, increasingly severe dry seasons and generally drying conditions, and
  • the proposal involves removal of around 7 to 10 times the maximum recommended by Douglas Partners, and
  • there are already two (or three) commercial groundwater extractions drawing on the aquifer with some evidence that they are significantly depleting the aquifer,

it is reasonable to conclude that the proposal will have a significant impact on the groundwater system. That, in turn, could be expected to impact on the World Heritage Area part of which is only 400 metres from the bore site. The aquifer from which water will be pumped feeds Boy-Ull Creek (850 m from the bore) and a tributary of Boy-Ull Creek (200 m). Boy-Ull Creek feeds Twin Falls, a major attraction in this section of the World Heritage Area. The aquifer also feeds Cave Creek (480 m) which flows through Natural Bridge within the World Heritage Area. Natural Bridge is a highly visited site because of the presence of glowworms.

Studies on Tamborine Mountain showed that 72–80 % of stream flow was derived from groundwater discharge (Todd 2011).

Considering the likely impact on the groundwater system, it is clear that the application should be rejected. Indeed, applying the Precautionary Principle, the application must be rejected.

4. Traffic issues

Australian Rainforest Conservation Society (ARCS) has operated a field office at two locations on Repeater Station Road since 2008. Currently, our office is at 250 Repeater Station Road directly opposite 263 Repeater Station Road. Officers of ARCS have been driving on the relevant section of Repeater Station Road essentially daily for the past decade and are very familiar with the nature of the road. We know this section of the road as well as anyone.

The narrowness of the road and absence of centre line marking are likely factors contributing to the frequent experience of meeting an oncoming vehicle travelling near the centre of the road.

It is also noted that this section of the road, being above 800 metres elevation, is often submerged in cloud and visibility is low.

Of particular concern is the corner shown in the report by Rytenskild Traffic Engineering at the top of page 36. The relevant image from the Rytenskild report is shown below.


This corner is blind and whereas a convex mirror is installed, the experience of ARCS officers is that the mirror is of no value.

The bitumen surface is 5.3 m wide at this corner. The trucks proposed to be used are described in the Rytenskild report as being 2.5 m wide. That leaves no room for error should a vehicle approaching this blind corner from the north meet a fully laden water truck coming from the south, or vice versa.

The Rytenskild report (pp. 20 & 26) states “Whilst there are some sections of the road which narrow to less than the ideal width for two vehicles to pass, visibility is satisfactory and there is provision for two vehicles to pass at each end of these sections.” The corner illustrated above is a section of the road that is “less than ideal for two vehicles to pass” but where visibility is far from satisfactory. Further, the statement that two vehicles are able to pass at the end of these sections implies a voluntary one-lane section where one vehicle stops to let the other pass. That could not be considered a satisfactory solution to the issue. The engineers’ statement must be considered unqualified: the road is “less than ideal” for two vehicles to pass. It is therefore thoroughly inappropriate to propose introducing a new use of this section of the road by heavy vehicles with a width that is just slightly less than half the width of the road.

The engineers consider the possibility of widening the road but dismiss it as inappropriate. It would certainly be inappropriate to widen this scenic road in order to allow an increase in the supply of an undesirable product – bottled water.


This photo of a crest in the road was taken just 30 metres north of 263 Repeater Station Road.

In response to the Extractive Industry Development Code, Michel Group Services state “It is important to note here that Repeater Station Road has approved similar uses and therefore the immediate residents are conditioned to the impacts of commercial water extraction.” The statement has no basis. The traffic report by Rytenskild Traffic Engineering provides the results of traffic survey which show no heavy vehicles during the full two-day survey period. The currently operating water trucks do not use the road south of 166 Repeater Station Road. The proposal represents a completely new and high-impact use of this section of the road.

The statistics record a vehicle travelling on this section every two minutes at peak times. As the road leads to the very popular Best of All Lookout, it is likely that most of these vehicles are carrying visitors unfamiliar with the road which will raise the risk of a collision, not to mention the fact that these visitors, on a scenic drive to a World Heritage Site would not be expecting to meet a 10-metre long fully-laden water truck coming towards them around a blind corner.

We also note that this road is regularly used by cyclists for training.

The Traffic Impact Assessment Report provides no convincing evidence to support the recommendation in favour of the proposed groundwater extraction operation. On the contrary, all evidence suggests that the proposed 8 heavy vehicle movements per day on this road present a significant risk that serious, possibly fatal, head-on collisions will occur.

Therefore, the proposed development does not conform to the Transport Code requirement (PO20) that development is “designed to reduce impacts on the amenity, safety and operation of the road network through appropriate measures to ensure that the function and capacity of the road network is not compromised.”

D. References

Australian Broadcasting Commission 2018. War on Waste. July 2018.

Australian National University 2009. Implications of Climate Change for Australia’s World Heritage Properties: A preliminary assessment.

Department of Environment and Science 2018. Queensland State of the Environment 2017.

Sainato, M. and Skojec, C. (2019). Bottled Water is Sucking Florida Dry: The state’s aquifers are shrinking, yet corporations want to appropriate even more of them. The New York Times.

Taufik, M., Torfs, P.J.J.F., Uijlenhoet, R., Jones, P.D., Murdiyarso, D. and Van Lanen, H.A.J. (2017). Amplification of wildfire area burnt by hydrological drought in the humid tropics. Nature Climate Change, 7 (6). 428–431. ISSN 1758-678X

Todd, A. 2011. Groundwater Investigation, Tamborine Mountain, South East Queensland. Institute for Sustainable Resources, Queensland University of Technology technical report to South East Queensland Catchments Ltd.

University of Queensland 2019. The real cost of bottled water.

Leave a comment

Filed under Biodiversity, Climate change, World Heritage

Vale Peter Hitchcock AM

PeterHitchcock_John Benson_croppedInternationally recognised conservationist, Peter Hitchcock AM, died on 20 May 2019.

In 1988, Peter Hitchcock was appointed Executive Director of the interim body that later became the Wet Tropics Management Authority (WTMA). Peter had a close association with ARCS through President Aila Keto who was a member of the interim body and later the WTMA Board.

World Heritage listing of the Wet Tropics of Queensland followed years of campaigning and negotiation and was strongly opposed by the Queensland Government led by Joh Bjelke-Petersen. Peter recorded being told by the then State Environment Minister that he had no chance of success and that no-one in North Queensland wanted the World Heritage Area. “It was like walking into an ants’ nest that had been stirred up.” But Peter started talking to local landholders and found the mood to be quite different.

Peter began his career as a forester in the NSW government in the 1960s. When he became more interested in conserving forests rather than logging them, he moved to the NSW National Parks and Wildlife Service where he rose to the position of Deputy Director (Policy and Wildlife). Over his years in the NPWS, Peter was responsible for the establishment of numerous national parks many of which are now part of the Gondwana Rainforests of Australia World Heritage Area. Peter worked closely with the Wran Government and would have had a significant influence on the 1982 decision by Neville Wran to protect rainforests in northeast NSW.

In 1987, Peter was seconded by the federal government led by Bob Hawke to serve on the Commonwealth Commission of Inquiry into the Lemonthyme and Southern Forests of Tasmania to inquire into the possible World Heritage values of the areas and how they could be protected. Peter produced a dissenting report recommending protection of the forests and World Heritage nomination. Most of Peter’s recommendations were accepted by the Commonwealth and in 1989 the areas were added to the Western Tasmanian Wilderness National Parks World Heritage Area created in 1982 to become the Tasmanian Wilderness World Heritage Area (TWWHA).

Peter was also instrumental in achieving additions to TWWHA in 2013.

In 2014, the Australian Government led by Tony Abbott put a proposal to the World Heritage Committee to de-list 74,000 hectares of the TWWHA in order to allow logging. The Committee took less than 10 minutes in making a decision to reject the proposal. ARCS was officially represented at the meeting by a delegation headed by Alec Marr, Director of ARCS International World Heritage Programme, and including Peter Hitchcock.

When Peter left WTMA, he established a consultancy practice in Cairns with a focus on natural heritage.

Peter’s contribution to World Heritage was recognised in a tribute by IUCN: “With decades of contributions, both internationally and in his native country of Australia, Peter Hitchcock served over many years as a senior advisor on World Heritage for IUCN. During this time, he undertook numerous missions throughout the globe to monitor the state of conservation of World Heritage sites and evaluate sites nominated for the World Heritage List. He continued to contribute to the reviews of potential new sites up to this very year.”

Peter received a range of awards including Member of the Order of Australia (AM) in 1990, the IBM Award for Environmental Excellence in 1993 and the IUCN Packard International Parks Merit Award in 1996.

Peter will be sorely missed around the world.


Australian delegation at the World Heritage Committee meeting in Doha, Qatar, June 2015.
Left to right: Peter Hitchcock, Lincoln Siliakus, Alec Marr, Jenny Weber.

Keith Scott

Leave a comment

Filed under Biodiversity, Forests, Sadness, World Heritage

The Climate Crisis

Governments must acknowledge that ‘Business as Usual’ is unacceptable

The IPCC Special Report

In October 2018, the UN Intergovernmental Panel on Climate Change (IPCC) released a Special Report (SR15) on the impacts of global warming of 1.5°C. Human activities are estimated to have caused approximately 1.0°C of global warming above preindustrial levels. Global warming is likely to reach 1.5°C between 2030 and 2052 if it continues to increase at the current rate.

In 2016, more than 160 parties to the Paris Agreement reaffirmed “the goal of limiting global temperature increase to well below 2 degrees Celsius, while pursuing efforts to limit the increase to 1.5 degrees”. The IPCC report provides assessments of the difference in impacts likely to occur between 1.5°C and 2°C temperature rise. For example,

  • global sea level rise by 2100 would be 10 cm lower at 1.5°C compared with 2°C,
  • the likelihood of the Arctic Ocean free of sea ice in summer would be once a century at 1.5°C compared with at least once per decade at 2°C,
  • coral reefs would decline by 70–90 per cent at 1.5°C compared with greater than 90 per cent at 2°C,
  • of 105,000 species studied, 6 per cent of insects, 8 per cent of plants and 4 per cent of vertebrates are projected to lose over half of their climatically determined geographic range for global warming of 1.5°C, compared with 18 per cent of insects, 16 per cent of plants and 8 per cent of vertebrates for global warming of 2°C.

The graph below illustrates the impacts on a range of natural, managed and human systems.


In order to limit global warming to 1.5°C, CO2 emissions will need to be reduced by 45 per cent from 2010 levels by 2030 and reach net zero by 2050. The IPCC report emphasises the need for essentially drastic change: “Limiting global warming to 1.5ºC would require rapid, far-reaching and unprecedented changes in all aspects of society” and “rapid and far-reaching transitions in land, energy, industry, buildings, transport and cities”. It has been increasingly recognised over recent years that natural systems such as forests will play an essential role in achieving a reduction in Greenhouse Gas Emissions.

Native forests, especially primary (undisturbed) forests, need to be left alone to allow them to continue absorbing CO2. Trees remove CO2 from the atmosphere, accumulate carbon and store it for up to hundreds of years. In the light of the likely impacts of climate change, logging and clearing native forests is simply irresponsible.

ARCS is a partner in the Griffith University project, Information, Policy and Onground Action for Primary Forest Protection. The project is led by Professor Brendan Mackey who is Co-ordinating Lead Author for a chapter in the next IPCC report.

Planting trees, such as the Federal Government’s “20 Million Trees Program”, while helpful in the long-term, will not have an impact within the required timeframe. We have just 11 years to halve net CO2 emissions. It is essential that existing carbon stores in our native forests be protected and allowed to increase. It will not be possible to meet the 1.5°C target without the protection of existing primary forests. And that protection must start now.

 Sustainable Development Goals

In 2015, 129 countries signed a UN agreement on Sustainable Development Goals (SDG) with 17 goals being defined. The SDG Index, which ranks countries on each goal and overall on all goals, is published annually.

In the 2018 SDG Index, Australia’s overall performance was ranked at 37 out of 156 countries ranked. On the goal of Climate Action, Australia ranks last when exports (coal and gas) are included.

 Australia’s response to IPCC

Clearly, we are facing an extremely serious situation. Unfortunately — distressingly — the Australian Government, along with many other governments, notably USA, has not acknowledged the unavoidable disaster that will result from ‘Business as Usual’. In fact, government ministers have essentially rejected the scientific findings in the IPCC report.

When in October 2018 then Federal Environment Minister, Melissa Price, was questioned about the IPCC report, she questioned the conclusions reached by the 91 scientists involved. In response to the IPCC finding that coal needs to be phased out by 2050, Minister Price said “To say that it’s got to be phased out by 2050 is drawing a very long bow” and “That would be irresponsible of us to be able to commit to that.” She expressed confidence in technology being developed to allow ‘clean coal’. In July 2017, Queensland Labor Government committed to achieving net zero emissions by 2050. Federal Resources Minister, Matt Canavan, responded saying “Instead of trying to save the planet in 2050 the QLD labor should just concentrate on saving jobs today!”.

And Matt Canavan is leading the push for a new coal-burning power station in North Queensland.

Australia and Coal

Australia is the world’s largest exporter of coal. That coal is burnt somewhere in the world, contributing to climate change. But our commitment to the Paris Agreement does not include our contribution through our coal exports.

It is commonly argued that Australia produces only 1.3 per cent of global emissions and reducing our emissions will not make much difference. But Australia produces around 7 per cent of the world’s coal, all of which is burnt somewhere in the world. Australia is actually a significant contributor to global warming through our exports of coal and LNG. And Australian governments including the Queensland Government are hell-bent on increasing our exports of both coal and LNG.

In the lead up to the Conference of the Parties (COP21) in Paris in 2015, Anote Tong, President of the Pacific Island nation of Kiribati, wrote to world leaders seeking support for a global moratorium on new coal mines.

Just prior to the Paris meeting, President Tong was in Australia to promote the moratorium. In response, the then FederalResources Minister, Josh Frydenberg, said “Well we’re opening new mines where there’s the necessary investment because there’s global demand for it.”

Apart from the recently approved Adani Carmichael coal mine, there are several new coal mines being considered in the Galilee Basin and the Queensland Government is supportive.

Australia’s Paris Agreement commitments

Federal Government Ministers repeatedly claim that Australia will meet the 2030 target of 26–28% reduction in emissions. But the data produced by the Federal Department of Environment and Energy (released late on 7 June) show we are not at all on target. The graph provided by the Department is reproduced below.


When confronted with that fact, the Minister for Energy and Emissions Reduction, Angus Taylor, asserted that the government had developed a plan since the Department provided its forecast. In an interview on ABC RN Breakfast, Angus Taylor claimed that since December the Coalition had laid out a plan “to the last tonne” which would have Australia meeting its target. He specified a saving of 328 million tonnes but the Department’s data show a requirement for 695–762 million tonnes.

Whatever the situation is, our target is not only grossly inadequate but fails to address the much greater contribution of coal exports.

Burning wood from native forests is a double disaster

Burning wood from native forests to generate electricity is a threat to both biodiversity and climate.

Forests in southeast USA are being destroyed to produce pellets exported to Europe as fuel. And there is mounting pressure from the Australian timber industry to follow suit.

The European Union counts burning wood for electricity generation as carbon-neutral and fuel wood as a renewable source. These are myths which are being perpetuated around the world. The fact is that burning wood causes immediate release of carbon to the atmosphere but replacing that carbon through growth of trees will take decades. We don’t have decades.

Further, burning wood to produce electricity releases 50 per cent more CO2 than burning coal.

 What can we expect from our political leaders?

What can we expect from our political leaders? Based on current indications, very little! Implementation of the Paris Agreement, through development of the Rule Book, has not gone well. The outcomes of the Conference of the Parties in Poland in November were disappointing. We may well have to depend on voluntary market decisions based on investment outlook.

The planet is in dire straits.

Keith Scott


Leave a comment

Filed under Biodiversity, Climate change, Forests, Government Policy