Category Archives: Climate change

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 

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Climate change will be catastrophic

I want you to act as you would in a crisis.
I want you to act as if our house is on fire.
Because it is.

Greta Thunberg

All the available evidence indicates that the planet is heading for a climate catastrophe but governments are not responding accordingly. In the words of UN Secretary-General, António Guterres, “Climate change is moving faster than we are.”

When considered over a geological timescale, atmospheric CO2 is increasing at an extraordinary rate. The lower line in the graph below shows that by 1960 the concentration of CO2 in the atmosphere was greater than it had ever been over 800,000 years. And since 1960 it has continued to soar.

It is generally accepted that we should be trying to keep the global temperature increase to 1.5°C. In 2017, the Intergovernmental Panel on Climate Change (IPCC) estimated the net amount of carbon that the world could add to the atmosphere through emissions and keep the temperature rise to 1.5°C, i.e. the remaining carbon budget. IPCC determined that if the world reduced annual emissions the carbon budget would not be used up until around 2050, the time by which global emissions would need to be net zero (emissions balanced by removals into carbon sinks, particularly forests).

The remaining carbon budget for a 1.5°C increase was estimated for 2017 with a 50% probability to be 580 billion tonnes of CO2 or, with a 66% probability, 420 billion tonnes.

Current estimates are that the remaining carbon budget will be used up within about a decade. That means the global temperature is expected to be 1.5°C above pre-industrial levels soon after 2030. And that will happen unless we take immediate and drastic action to reduce emissions. If we carry on ‘business as usual’ the global temperature rise will be greater, potentially much greater, than 1.5°C. Transformational change is required in virtually everything we do.

Since 2017, emissions have continued to increase thus reducing the remaining carbon budget. The increase in emissions in 2021 was the largest ever recorded. IPCC reported the remaining carbon budget in 2020 as 500 billion tonnes with a 50% probability or 400 billion tonnes with a 66% probability. A recent report, by 94 scientists from 70 research centres around the world including CSIRO, puts the remaining carbon budget in 2021 at 420 billion tonnes with a 50% probability.

Despite the warnings from IPCC and many others, our political leaders still talk about net zero emissions by 2050. We need to reach net zero by 2030 or very soon after. Or else!

At the COP26 Conference held in Glasgow in November 2021, the Parties were exhorted to not only commit to net zero emissions by 2050 but to raise their 2030 commitments. Australia declined to change the 2030 commitment of 26–28% reduction having just managed to get the National Party to agree to net zero by 2050.

The newly elected Labor government has a commitment to a reduction of 43% by 2030, far short of what is necessary.

It is virtually inevitable that global temperature will increase by more than 1.5°C. IPCC predicted a range of consequences, some of which have already been experienced, e.g. extreme weather events including severe bushfires in Australia, North America, the Amazon, Indonesia and Siberia, extreme temperatures (50°C in Canada), flooding in Asia and Europe, drought in eastern Australia followed by severe flooding. The Great Barrier Reef, along with other coral reefs around the world, is predicted to suffer severe impacts from a rise of 1.5°C with some damage being irreversible.

Given the likelihood of the temperature increase being 2°C or more, the Great Barrier Reef will almost certainly die.

The graph below which is reproduced from IPCC 2018 indicates the rate at which greenhouse gas emissions have to be reduced to reach net zero by 2040. An even greater rate of reduction is necessary to reach net zero by 2030 or soon after which now needs to be the objective.

Could anyone believe that governments around the world will turn emissions around within a couple of years and achieve a rate of reduction greater than that at which they have been recently increasing? According to Simon Sharpe, University College of London, we need to decarbonise five times faster than we have been carbonising. Catastrophe looks inevitable.

Australia’s role

Our political leaders like to tell us that Australia is responsible for just 1.4% of global emissions so it doesn’t matter what we do about emissions. It won’t make any difference! But that ignores the contribution we make to global emissions through coal and gas exports. These ‘Scope 3’ emissions are not counted in our Nationally Determined Commitment.

Coal and gas together are responsible for around 60% of total global greenhouse gas emissions. Australia is the world’s largest exporter of coal when thermal and metallurgical coal are combined and is now the world’s largest exporter of natural gas. A study by Climate Analytics in 2019 concluded that when emissions from our exported coal and gas are included, Australia’s contribution to global emissions was around 5%. And that is not counting the impact of flaring and methane leakages. Methane is 84 times more powerful than CO2 as a greenhouse gas and whereas it has a short life, around eight years, it is converted in the atmosphere by oxidative reactions to CO2.

While all evidence points to an urgent need to reduce the use of fossil fuels, Australia plans large-scale expansion of coal mining and gas extraction. And the newly elected federal Labor government has promised not to block any new coal mines.

Based on projected increases in Australia’s exports of fossil fuels, Climate Analytics found that Australia could contribute 13% of global emissions in 2030 assuming a 45% reduction occurs globally as determined by IPCC to be required to keep temperature increase below 1.5°C.


Burning wood for electricity production has been growing around the world, especially in the European Union. Advocates claim replacing coal with wood will reduce emissions. Burning wood from forests has been considered ‘carbon neutral’ because the trees regrow and sequester the carbon that is released by burning. An EU report in 2020 put the contribution of forestry to total renewable energy at 37%. The simplistic argument is that wood is a renewable resource so the energy produced by burning it is renewable energy.

But burning wood immediately adds CO2 to the atmosphere and it will not be removed by regrowth for decades. We don’t have decades to wait for the carbon to be removed.

European countries have been determining their CO2 emissions and hence their national commitments under the Paris Agreement on the assumption that burning wood for electricity generation produces zero emissions. Huge volumes of wood, largely from forests in USA and eastern Europe, are imported to be burned in European Union countries and UK. It is commonly claimed that the wood burned for electricity generation comesfrom ‘residues’ but there is ample evidence that whole trees are being used and forests devastated.

Whole logs stacked at Drax plant in Mississipi ready for conversion to wood pellets for export to UK.

Cutting down native forests for biofuels destroys the very carbon sink critically needed to remove the CO2already emitted which otherwise would remain in the atmosphere for up to tens of thousands of years.

Recently, the Environment Committee of the European Parliament voted in favour of removing subsidies for woody biomass and excluding it from counting towards renewable energy targets. The recommendation will go before the parliament possibly later this year. The overall process is amendment of the Renewable Energy Directive. This month, the parliament’s Energy Committee will make a separate recommendation.

In the UK, the Drax power station uses wood to generate electricity and is the country’s biggest carbon emitter. It is reported to use 7 million tonnes of wood every year.

We note the Queensland Government has been exploring harvesting native forests to produce biofuels (wood pellets).

Leadership is sorely needed

The world is in need of brave leaders. As teenage Swedish activist Greta Thunberg said, “What do we do when the politics needed are nowhere in sight?”

The forces against urgent climate action are strong. The fossil fuel lobby and the timber industry lobby affect government decisions. They affect the final reports of IPCC which are negotiated outcomes after the scientists have provided their input. We need political leaders with the strength to reject the lobbying.

In Australia we need politicians with the ability to lead the required just transformational change and to take the community with them, with the ability to show the coal community that they can have a different and better future.

We need a leader who understands that Australia can set an example, develop a plan that rapidly phases out fossil fuel production and exports and provides a just transition for industries and communities that have depended on fossil fuels. Gaining the support of the Australian people will require a true leader. Do we have one?

Aila Keto and Keith Scott

References for this article can be found at

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Can we avoid a “Hothouse” Earth?

Despite the threat of global warming having been clearly identified by NASA scientist, James Hansen, in his address to the US Congress in 1988, greenhouse gas emissions continue to rise. They have risen around 70 per cent since 1988. The first decrease was recorded early in 2020 as a result, not of human efforts, but of the Covid-19 pandemic.

That decrease was short-lived. By the end of 2020, the increase was back. It is expected that the focus on economic recovery around the world will lead to an even greater rate of increase.

At the time of Hansen’s address, fossil fuels accounted for around 79 per cent of global energy supply. In 2019, that figure was 84 per cent.

In 2018, Hansen told The Guardian “All we’ve done is agree there’s a problem. We agreed that in 1992 [at the Earth summit in Rio] and re-agreed it again in Paris [at the 2015 climate accord]. We haven’t acknowledged what is required to solve it. Promises like Paris don’t mean much, it’s wishful thinking. It’s a hoax that governments have played on us since the 1990s.”

Australian climate scientist, Professor Will Steffen, recently warned that we are facing a “Hothouse” Earth if we don’t act now and rapidly. His presentation is available on YouTube at

The Paris Agreement set a target for global temperature increase of not more than 20C and preferably below 1.50C. We are already at 1.10C. Under the current trajectory, the increase is likely to be more than 30C.

Steffen raises the issue of tipping points in the Earth System. We know that tipping points can come from melting of ice, changes in circulation in the ocean and loss of biomes such as the Amazon rainforest and boreal forest.

With increase in global temperature we can expect tipping cascades. How long have we got before these cascades begin? According to Steffen, not long:

  • Arctic sea ice — probably at the tipping point;
  • West Antarctic — maybe 10 years to a tipping point;
  • Amazon rainforest — maybe 15 years or less, depending on the rate of deforestation the Bolsonaro government inflicts;
  • Greenland ice sheet — 25 years is probably optimistic.

We cannot rule out the possibility of a tipping cascade beginning in the near future and well before the net-zero emissions target of 2050. Professor Steffen says that is “far, far too late”.

Direct human impact on the biosphere is obviously not limited to climate change. The Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services (IPBES) released in 2019 painted a grim picture of the state of Nature:

  • Nature is declining globally at unprecedented rates;
  • Around 1 million animal and plant species are now threatened with extinction, many within decades;
  • The web of life is getting smaller and increasingly frayed.

According to Steffen “We have a double whammy — a rapidly destabilising climate system and a rapidly degrading biosphere.”

Steffen refers to the work of Oxford University economist, Kate Raworth, known for her concept of ‘doughnut economics’, balancing human needs and planetary boundaries. Steffen summarises Raworth’s ‘doughnut — a safe and just place for humanity’ in three main points for an economy for the 21st century:

  • We need systems thinking — not linear cause-effect. We have to go out of GDP thinking and think about dynamic complexity.
  • Equity: our system should be distributive by design.
  • Biosphere: it should be regenerative, not exploitative, by design.

As Professor Steffen says, “our current neoliberal economic system is exactly the opposite of what we actually need”.

Steffen’s analysis shows that we need much more ambitious targets than those of the Paris Agreement. The target for 2030 needs to be a reduction in emissions of at least 50 per cent and net zero by 2040. And to reach those targets we need to act decisively now. We have a climate emergency.

Ahead of the next Conference of the Parties, COP26, to be held in Glasgow in November, around the world, parties to the Paris Agreement are beginning to set more ambitious targets. United Kingdom has committed to a 78 per cent reduction by 2035. USA has committed to a 50–52 per cent reduction by 2030. China has committed to a reduction of 65 per cent by 2030 and ‘carbon neutrality’ by 2060. Other countries have committed to net zero by 2050.

The problem with these commitments is how the emissions are calculated. A recent paper published in The Conversation, “Climate scientists: concept of net zero is a dangerous trap” exposes the flaws in modelling that has been used to verify targets. The paper can be viewed at

The authors, one of whom, Robert Watson, has served as Chair of both the Intergovernmental Panel on Climate Change (IPCC) and the IPBES, say they “arrived at the painful realisation that the idea of net zero has licensed a recklessly cavalier ‘burn now, pay later’ approach which has seen carbon emissions continue to soar” and that it “has also hastened the destruction of the natural world by increasing deforestation today, and greatly increases the risk of further devastation in the future.”

The Integrated Assessment Models involve a range of assumptions including changes in investments and technology that could lead to changes in emissions.

The modelling that suggest that it is possible to achieve net zero emissions by 2050 involve technologies that have never been successfully implemented on a scale anywhere near what would be required. A particular case is carbon capture and storage (CCS) where CO2 emitted when fossil fuels are burned is captured and pumped deep beneath the Earth’s surface.

There is essentially no possibility that CCS will be implemented at the scale required and in time to bring about the reduction in emissions that is needed.

The other problem is biofuels. In the UK, biofuels account for 12 per cent of the energy used to generate electricity. In the EU, biofuels account for 60 per cent of renewables.

The major source of biofuels in Europe is wood pellets imported from USA. The major producer in USA is Enviva which currently produces 35 million tonnes a year. These are produced from what Enviva calls “working forests” around the country. In other words, USA’s forests are being burned in electricity generating plants in Europe.

In calculating emissions, biofuels are counted as carbon-neutral. This is because they come from a renewable source. The argument is that the carbon released on burning will be balanced by carbon absorbed by the trees when they regrow. But, of course, the carbon released on burning is not ‘balanced’ by new growth for many decades. That doesn’t bother Enviva’s Jennifer Jenkins who says “we don’t need to worry about the short versus long term time frame”. Carbon-neutrality of biofuels is a fraud.

In addition, burning wood for electricity generation is inefficient and produces 65 per cent more CO2 than burning coal.

Under the Paris Agreement, Australia’s emissions target is a reduction from 2005 levels of 26–28 per cent.The Minister for Energy and Emissions Reduction, Angus Taylor, had declared that Australia will reduce emissions through technology, principally carbon capture and storage.

At the recent G7 meeting in UK, the G7 countries agreed to pursue a phase-out of coal, but Prime Minister Scott Morrison told the world that Australia would not be moving away from coal anytime soon.

While the scientists recognise that we need to stop burning fossil fuels and we need to start now, the Australian Government proposes to build a new gas-fired generator in the Hunter Valley.

It is difficult to avoid the conclusion that the Coalition is beholden to the fossil fuel lobby while Labor, whose position is not much better, is divided over coal mining.

Can we avoid a ‘Hothouse’ Earth? Yes. But will we? Given the trickery, deceit and fraud perpetrated by decision makers and vested interests, the answer is probably No!

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The Climate Emergency

The next United Nations Framework Convention on Climate Change (UNFCCC) conference, COP 25, will be held in Chile in December. In a prelude to COP 25, the UN Secretary-General, Antonio Guterres, organised a Climate Action Summit in New York in September.

The Summit was attended by world leaders but not by Prime Minister Scott Morrison despite the fact that he was in USA at the time. Australia was represented at the Summit by Foreign Affairs Minister Marise Payne, but she did
not speak.

Antonio Guterres had asked countries to come with a more ambitious plan than that to which they had already committed. If they didn’t, they were requested not to speak. Hence, Marise Payne’s silence.

Griffith University’s Professor Ian Lowe said “Australia’s disinterest in the UN Climate Summit is, frankly, a national embarrassment. Our Government’s encouragement of new coal mines and expanded gas exports runs directly counter to the necessary global efforts.”

One of the speakers at the Summit was Swedish teenage climate activist, Greta Thunberg. Greta gave an impassioned speech extorting world leaders to act on climate change. She said “You have stolen my dreams and my childhood with your empty words. We are in the beginning of a mass extinction, and all you can talk about is money and fairy tales of eternal economic growth. How dare you.”

Greta’s role in bringing the Climate Emergency into greater focus internationally is to be applauded. As an independent teenager she is able to express her views in straightforward terms. On the other hand, official representatives are more likely to feel bound by diplomacy or engage in obfuscation and gobbledygook.

Prior to the Summit, the World Meteorological Organization released a report, The Global Climate in 2015–2019. Compared to the previous period 2011–2015, the current period 2015–2019 has recorded

  • continued increase in CO2 emissions
  • an accelerated increase in greenhouse gas emissions
  • increase in oceanic CO2 concentrations with increased ocean acidity
  • the warmest of any equivalent period on record globally with a 1.1℃ increase since pre-industrial period and a 0.2℃ increase compared to 2011–2015
  • an accelerated rising sea level
  • a continued decline in the Arctic sea-ice extent
  • an abrupt decrease in Antarctic sea ice
  • continued mass loss of glaciers and the Greenland and Antarctic ice sheets
  • the largest ocean heat content on record in 2018
  • heatwaves affecting all continents resulting in record temperatures for many countries
  • unprecedented wildfires.

The Australian Government remains unmoved by the science that is becoming increasingly worrying. Whereas Scott Morrison did not attend the Climate Action Summit he did address the UN General Assembly in New York and said “Australia is taking real action on climate change and getting results …. We are successfully balancing our global responsibilities with sensible and practical
policies to secure our environmental and economic future.”

Clearly, Scott Morrison and his colleagues have not recognised the seriousness of the issue. As we reported in a previous post, the Intergovernmental Panel on Climate Change (IPCC) provided evidence for the need to limit global warming to 1.5ºC and noted that this “would require rapid, farreaching and unprecedented changes in all aspects of society” and “rapid and far-reaching transitions in land, energy, industry, buildings, transport and cities”.

The IPCC concluded that to limit global warming to 1.5℃, it would be necessary to reduce emissions by 45% from 2010 levels by 2030 and reach zero emissions by 2050. A middle-of-theroad scenario requires a 75% reduction in coal use as the primary energy source by 2030 (IPPC Special Report (SR15), Summary for Policymakers, p. 14).

Australia needs to start planning for a phase-out of coal mining and coal use. But we are actually doing the opposite.

In a surprise move, Labor front-bencher Joel Fitzgibbon recently called for the party to adopt the Coalition’s climate policy. That means accepting an emissions reduction target of 26–28% by 2030 rather than the 45% target that Labor took to the last election. His argument is that Australians are “inherently conservative” and will continue to support the Coalition leaving Labor in Opposition for a further six years.

Fortunately, Fitzgibbon’s colleagues rejected his proposal. Labor joined the Greens and cross-bench members in a motion in the House of Representatives to declare a “climate emergency”. It was, of course, defeated.

Scott Morrison’s speech to the UN General Assembly was an exercise in cherry-picking. For example, he noted that emissions from Australia’s electricity sector had fallen 15.7% compared with the peak in 2009. That figure doesn’t even apply Australia-wide — just to the East Coast. Overall Australia’s emissions continue to increase. And according to The Climate Council, if you include our fossil-fuel exports, Australia is the fifth largest emitter in the world, after USA, China, EU and India.

Things need to change.

Keith Scott

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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.

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Filed under Biodiversity, Climate change, 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


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The Biodiversity Crisis

1 Million species threatened with extinction

Last month the Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services (IPBES) released a landmark new report IPBES Global Assessment Report on Biodiversity and Ecosystem Services. The report begins with these headlines:

  • Nature’s dangerous decline ‘Unprecedented’
  • Species extinction rates ‘Accelerating’
  • ‘Transformative changes’ needed to restore and protect nature
  • Opposition from vested interests can be overcome by public good
  • 1,000,000 species threatened with extinction

Following several years of preliminary meetings, IPBES was ‘established’ in 2012. The IPBES report was produced in response to an invitation from the Conference of the Parties, Convention on Biological Diversity to prepare a global assessment on biodiversity and ecosystem services, “focusing on status and trends, the impact of biodiversity and ecosystem services on human well-being, and the effectiveness of responses, including the Strategic Plan and its Aichi Biodiversity Targets”. The 20 targets can be found at

The report finds that nature is deteriorating worldwide and biodiversity is declining faster than at any other time in human history.

It would be of no surprise to most people that nature across the globe has been significantly altered by human activities. Seventy- five per cent of the land surface is significantly altered, 66 per cent of the ocean area is experiencing increasing cumulative impacts, and over 85 per cent of the area of wetlands has been lost. Across much of the highly biodiverse tropics, 32 million hectares of primary or recovering forest were lost between 2010 and 2015.

The authors find that human actions threaten more species with global extinction now than ever before. They estimate that around 25 per cent of animal and plant species are threatened, indicating that around one million species already face extinction, many within decades, unless action is taken to reduce impacts. The authors conclude that without such action there will be a further acceleration in the global rate of species extinction, which is already at least tens to hundreds of times higher than it has averaged over the past 10 million years.

The report provides statistics to support their conclusion. More than 40 per cent of amphibian species, almost a third of reef-forming corals, sharks and shark relatives and over a third of marine mammals are currently threatened. The proportion of insect species threatened with extinction is a key uncertainty, but available evidence supports a tentative estimate of 10 per cent. Those proportions suggest that, of an estimated 8 million animal and plant species (75% of which are insects), around 1 million are threatened with extinction. A similar picture also emerges from an entirely separate line of evidence. Habitat loss and deterioration, largely caused by human actions, have reduced global terrestrial habitat integrity by 30 per cent relative to an unimpacted baseline; combining that with the longstanding relationship between habitat area and species numbers suggests that around 9 per cent of the world’s estimated 5.9 million terrestrial species – more than 500,000 species – have insufficient habitat for long-term survival, are committed to extinction, many within decades, unless their habitats are restored.

Ecosystem structure

A critical conclusion from the IPBES report is that goals for conserving and sustainably using nature and achieving sustainability cannot be met by current trajectories, and goals for 2030 and beyond may only be achieved through transformative changes across economic, social, political and technological factors.

Climate change is, and will continue to be, a significant contributor to biodiversity loss. As noted in the article on The Climate Crisis on page 2 of this newsletter, nature conservation and climate change are intrinsically linked. Mitigating climate change will help nature while nature-based measures are essential for mitigation of climate change. The IPBES report concludes that “nature-based solutions with safeguards are estimated to provide 37 per cent of climate change mitigation until 2030 needed to meet 2°C goals with likely co-benefits for biodiversity” and “land-use actions are indispensable, in addition to strong actions to reduce greenhouse gas emissions from fossil fuel use and other industrial and agricultural activities.”

However, the report includes a caution that “large-scale deployment of intensive bioenergy plantations, including monocultures, replacing natural forests and subsistence farmlands, will likely have negative impacts on biodiversity and can threaten food and water security as well as local livelihoods, including by intensifying social conflict”. The report emphasises the importance of strong legislation for the protection of threatened species. In this context, the Australian Environment Protection and Biodiversity Conservation Act (EPBC Act) is given as an example of “weaker laws” and “less rigorously implemented and enforced”, and therefore less likely to achieve recovery goals.

Australia’s own extinction crisis

Since European settlement, 28 mammals have been declared extinct in Australia, more than in any other country. In recent years, three mammal species — Christmas Island Forest Skink, Christmas Island Pipistrelle and Bramble Cay Melomys, a Great Barrier Reef endemic. The melomys is the first mammal extinction caused by climate change. Sea level rise destroyed the melomys and its habitat.

The EPBC Act is failing. University of Queensland researchers have concluded that up to 7.47 million hectares of threatened species habitat – an area larger than the state of Tasmania or 3.7 million Melbourne Cricket Grounds – has been destroyed since the operation of the EPBC Act (from 2000-2017).

The Senate Environment and Communications References Committee is currently undertaking an inquiry into Australia’s faunal extinction crisis. The scope of the inquiry includes the adequacy of environment laws.

Keith Scott


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ARCS dismayed at COP24 outcomes

VirginiaYoungThe Australian Rainforest Conservation Society (ARCS) has expressed its dismay over the outcomes of the UN climate conference COP24. Speaking during her return from Katowice in Poland, Director of ARCS Climate and Forests Programme, Virginia Young, expressed shock and disappointment at  the retreat from ambition represented in the COP24 outcomes.

The UN-commissioned IPCC Special Report released in October warned that keeping the Earth’s temperature rise to 1.5C would need “unprecedented changes” in every aspect of society. COP24 has failed dismally to respond to that call.

The most shocking examples of this retreat are the limiting of the scope of Nationally Determined Contributions to just mitigation, in clear violation of the requirements found in Articles 7, 9, 10, and 11 of the Paris Agreement; the systematic purging of all references to human rights and ecosystem integrity in APA3 and APA5 texts; and a Paris Rulebook held hostage to the use of highly questionable Kyoto CDM carbon credits and weak accounting rules.

The decision fails absolutely to reflect the desire of the overwhelming majority of countries for comprehensive and balanced outcome reflecting all elements of the Paris Agreement.  They fail to address the mandate given in APA Article 3.  A comprehensive and balanced outcome should include cross-cutting principles on rights; a central place for equity, that acknowledges differing country capacity and responsibility, including with respect to the Global Stocktake; and a differentiated Transparency Framework.

It is also highly problematic that progress on developing market- and non-market-based responses to combatting climate change, as contained in Article 6, have been left hanging, for determination at another COP.  We are deeply concerned that Brazil is refusing to show ambition, and preventing the adoption of mechanisms in both 6.2 and 6.4 that would deal with problems of environmental integrity and double-counting.  Finally, while a grievance mechanism is established under article 6.4, the deletion of references to human rights under article 6.2 suggests that further environmental, social and governance safeguards still need to be addressed in any future work plan.

Civil society had hoped that in these respects pertaining to NDCs and Transparency, as well as in advancing ambition consistent with the findings of the IPCC Special Report on the 1.5 Degree goal, the development of a Paris Rulebook would strengthen, rather than weaken, the Paris Agreement.  Instead, we are dismayed by documents that are not only unbalanced with respect to outcomes, but that also downgrade the importance of Paris Agreement preambular elements, weaken the commitment to environmental integrity and the prevention of double-counting, and fail to safeguard ecosystem integrity, food security and respect for human rights, including the rights of indigenous peoples.

After three years of negotiations, it is unconscionable that Parties are considering the adoption of such a weak, unbalanced, and loophole-riddled outcome.  We all can, and must, do better.

Virginia Young 0417 223 280


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