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Submission on the Environmental Impact Statement (EIS) – Thomas J. Goreau, PhD President, Global Coral Reef Alliance September 6 2012 To: GKIR@coordinatorgeneral.qld.gov.au
Please see submitted comments reviewing the EIS below: 1) Overview The proposed Great Keppel Island Resort Project poses a serious threat to coral reefs that are of crucial importance to the future of the Great Barrier Reef ecosystem. The proposed Golf Course and Marina should be rejected outright because they would certainly severely damage the coral reefs. The EIS is seriously deficient and inadequate. It shows complete failure to understand the impacts of increasing nutrients and temperatures on the coral reefs, and failure to correctly interpret the clear ecological information presented in the EIS that shows that these ecosystems are already stressed. These key concerns are superficially glossed over at best, or ignored completely at worst. This assessment of the EIS focuses entirely on the impacts to coral reefs, and is based on careful consideration of the data analyzed in Technical Appendices: O Environmental Management Plan W Aquatic Ecology Technical Report X Climate Change Technical Report Y Coastal Environment Technical Report Z vii Groundwater Nutrient Transport Modeling 2) Specific comments
a) Failure to use coral reef-specific nutrient limits. Coral reefs are the most sensitive of all ecosystems to nutrients, and turn eutrophic (overgrown by nuisance weedy algae) at nutrient levels that would affect no other ecosystem. The acceptable limits for nitrogen and phosphorus, the critical nutrients that control algae growth rates, were first determined by Peter Bell of the University of Queensland in the Great Barrier Reef 20 years ago, but the critical levels used in the EIS do NOT reflect the scientific knowledge. In fact the values used in this report for nutrient levels of concern are way too high, and about 10 times higher than the levels at which algae overgrow and smother corals! b) Failure to recognize Eutrophic water quality conditions. The water quality data in the EIS indicates that productivity of this ecosystem is strongly limited by nitrogen, but that nitrogen is already excessive in many locations, although not as excessive as phosphorus. But this is not pointed out in the EIS, even though it means that any further nutrient inputs, especially nitrogen, will greatly increase algae overgrowth of the corals. The EIS does not present data that allows the nutrient sources to be identified, but it is most likely that high nutrients and sediments from the agricultural hinterlands in the Fitzroy River watershed have created chronic high nutrient and sediment stress conditions in these reefs. As a result of this high background, any local additions of land-based nutrient and sediment sources from development on Great Keppel Island could trigger rapid and irreversible deterioration of the coral reefs. c) Failure to recognize eutrophic ecological conditions. Along with the water quality data, the ecological information provided in the EIS Appendices clearly indicates that this system is currently in low to middle stages of eutrophication, but that is not pointed out in the EIS. This is shown by the fact that algae bottom cover exceeds that of live coral at almost all sites, and is supported by turf algae overgrowing dead corals and the abundance of high nutrient-indicating species, in particular the toxic and slimy cyanobacteria Lyngbya. This species is most abundant around sewage outfalls, is very effective at killing corals, and algae-eating fish and invertebrates will not touch it. Nevertheless the live coral cover on these reefs is still relatively high, close to average conditions for the GBR as a whole. These conditions will deteriorate rapidly if new land-based nutrient sources result from the Great Keppel Island Resort Project. d) Failure to account for groundwater nutrient flow from the golf course. No clear description is given in the EIS of where the nutrients from the sewage effluents or golf course fertilizers will go, although it is implied that these will all be applied to the golf course and be completely absorbed there. It is simply claimed that “golf course design and operation ensures that no nutrients enter the marine environment”! There is no discussion of the fate of these major sources of nutrients from the proposed development although there is a great deal of discussion about how surface runoff from storms (a sporadic input with much lower nutrient levels than chronic groundwater inputs) will be channeled to ponds and the golf course, and that excess runoff from heavy rain events will be pumped through a pipe outfall to the sea, where it is claimed it will dissipate with no ecological impact. It is claimed that no fertilizer or sewage nutrients applied to the golf course will ever leach down into the groundwater, although this claim is clearly impossible. Nevertheless models are presented which indicate that at high fertilization rates nutrients will get into the groundwater, but it is claimed that the nutrient loading rates will be kept low, with the claim that leaching to groundwater will then not take place. The mathematical model appears to include only vertical downward flow, and there is no mention at all of groundwater flow downslope along the hydraulic gradient to the sea, even though the aquifer is composed of porous and permeable sands that have almost no ability to retain nitrogen and phosphorus. This model is totally unrealistic, high leaching and horizontal transport to the coastal zone is inevitable under such circumstances, but it is never mentioned in the EIS. In fact the location of the golf course on the high part of the sand ridge means that the nutrient rich ground water will drain into the coastal zone on BOTH sides of the island: the coral reef areas along the south coast, and the mangroves and wetlands on the north coast. The entire issue of coastal zone nutrient inputs from sewage and fertilizers is simply ignored, even though this would be the major chronic long-term environmental impact to marine ecosystems, and far greater than the short-term impact of turbidity from dredging, which is discussed at great length. It is not clear if this is an unwitting omission due to failure to consider the impacts on the reef, or if it is being deliberately ignored in order to focus at length on far lesser impacts as a distractive tactic. Hundreds of golf courses have been built next to coral reefs, and in every case the environmental impact assessments paid for by the golf course developers simply asserted that no harm could possibly result. In NONE of these cases were before and after comparisons made. There is only one case where the environmental effects of groundwater and nutrient runoff from golf course fertilizers on the coastal zone has ever been studied before and after. That study immediately found high levels of eutrophication-indicating algae in areas nearest the golf course, even though the developers claimed that they had “managed” the golf course to make any leaching of golf course nutrients to the sea totally impossible! It is certain that such impacts would have been found in ANY other tropical coastal golf course had people bothered to look. Details and photographs can be seen in Damage to Guana Cay coral reefs, Abaco, Bahamas from Baker’s Bay golf course, T. Goreau, T. Albury, & J. Cervino, 2011, at: http://www.notesfromtheroad.com/sgcr/Further work at that site has shown that highly elevated levels of nitrogen are found in algae all around the half of the island with the golf course, and that these elevated nutrients are not found in the populated opposite half of the island. Yet that island is drier and much flatter than Great Keppel Island, where the groundwater nutrient flows to the sea would be higher.
The red x marks the Baker's Bay site of the red and green algae bloom where the golf course green is near the shore. High levels of nitrogen are found in algae all around this end of the island, but not at the opposite end of the island where all the people live. Golf courses simply should not be permitted in coastal areas with coral reefs, not in Great Keppel Island or anywhere else, if the reefs are to be properly protected. e) Failure to account for coastal zone nutrient transport to reefs. The implications of the wind, current, tidal, and wave data presented for transport of land derived nutrients and sediment are nowhere explained in the EIS. During the summer rainy season, when most of the nutrient flushing from land will take place, the currents are strongest, and will carry land-derived nutrients directly to the reefs during the rising tide. Those coral reefs closest to the surface runoff and groundwater sources from the golf course along the south coast will be the worst affected, but these nutrients will be transported by currents directly to the west of the island, where additional nutrients will be added from the populated areas of the southwest and the marina to the northwest, before flowing to the best reefs at Passage Rock and Middle Island. Strong scour by tidal currents is clearly visible from the bathymetry and aerial images, which will add turbidity from re-suspended sediments to the mix. These serious threats to the health of the reef are not mentioned at all in the EIS. f) Failure to properly assess global warming impacts on corals. Even though the EIS mentions at least three separate incidents of severe coral bleaching and mortality, it does not make clear that these events are known to have been caused by excessively high temperatures, and that such large scale high temperature bleaching mortality events were unknown before the 1980s. Coral death from bleaching is not connected to global warming in the climate change impact sections, nor is it pointed out that such high temperature damage will become more frequent and severe in the future. Nor is it pointed out that these coral reefs are of unique conservation importance due to being some of the southernmost diverse coral reefs in the GBR. As global warming continues, the southernmost reefs will play a critical nursery role if coral reefs and coral reef organisms are to be able to migrate into newly warmer waters to the south. This makes it crucial to prevent any additional stress to them, and will require much stronger protection and abatement of environmental stresses to them. Loss of them will slow or block southward migration of species when global warming accelerates. g) Failure to account for sea level rise The loss of large areas of beach documented in the EIS, and the photos showing erosion scarps landward of the beaches are dismissed as “natural variability”, but long-term global sea level rise and increasing storm intensity due to global warming must be playing a role. h) Failure to explain loss of seagrasses. Sea level rise could also play a role in the dramatic long-term loss of seagrass beds around Great Keppel Island mentioned in the EIS, although excessive turbidity from the island following clearance of land for development, increased erosion in the watershed of the Fitzroy River, and increasing nutrients from the island or from the mainland could also be factors. It is impossible to clearly identify a cause from the information given, but loss of seagrass could lead to increased beach erosion. i) Inappropriate materials for breakwater. The Marina breakwater is proposed to be geotextile fabric bags pumped full of sand. Although the manufacturers of these materials tout them as a “permanent solution” it is well known to coastal engineers that they are ripped apart by large storms, losing all the sand and leaving shredded plastic or rubber coated fabric all over the beach and bottom. This has happened repeatedly in many places, to my knowledge in the United States, Mexico, India, and elsewhere. Coastal engineers who formerly used them in shore protection projects say that they now refuse to use them because material failure in storms gave them a very bad reputation for peddling solutions that were expensive and only temporary at best. 3) Conclusions The coral reefs of Great Keppel Island and surrounding areas are of great conservation importance, and are inadequately protected. They are already suffering from land-based sources of nutrient pollution and global warming. No further local land-based sources of stress should be permitted to them. The proposed golf course and marina would greatly increase stresses and would almost certainly tip them into irreversible degradation. The EIS completely fails to point this out, due to failure to adequately interpret the information it provides. The proposed golf course and marina should be rejected as the death knell for these coral reefs. Failure to do so will raise questions about the seriousness of Australia’s protection and management of the Great Barrier Reef. ADDITIONAL INFORMATION: Land-Sourced Pollution with an Emphasis on Domestic Sewage: Lessons from the Caribbean and Implications for Coastal Development on Indian Ocean and Pacific Coral Reefs, A. DeGeorges, T. J. Goreau, and B. Reilly, Sustainability 2010, 2:2919-2949 http://www.globalcoral.org/sustainability-02-02919[1].pdfTourism, water quality, and coral reefs, short documentary video by T. Goreau showing the algae impacts on coral reefs from local nutrient sources http://www.youtube.com/watch?v=xDT_q1LwGmA
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