Australian Rainforest Conservation Society

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.

Summary

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.

2. 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 9.3.17.2 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”.

3. 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.

4. 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.

5. 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.

6. 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.

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!

B.  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.

2. 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 6.2.20.2 (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 6.2.20.2 (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 6.2.20.2 (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 3.8.2.1(2) 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.

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.)

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.

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.

Summary
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.

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.

Conclusion
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. https://www.nytimes.com/2019/09/15/opinion/bottled-water-is-sucking-florida-dry.html?searchResultPosition=1&module=inline

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. https://sustainability.uq.edu.au/projects/recycling-and-waste-minimisation/real-cost-bottled-water.