Macquarie River - Orange Water Pipeline

as attached.

As attached.

As attached

as attached.

As attached.

As attached.

October 9 2012.

Mathew Hansen
5 Wentworth Street.
Dubbo NSW 2830
Phone: 0427 454 357

Dear Sir/Madam,

(Please also see further supporting documentation attached)

The proposed Orange pipeline goes against many recommendations of both the National and State Endangered Trout Cod recovery plans.

Ministers must act in accordance with such plans as follows:

FISHERIES MANAGEMENT ACT 1994 - SECT 220ZS
Ministers and public authorities to implement recovery and threat abatement plans 220ZS Ministers and public authorities to implement recovery and threat abatement plans

(1)Ministers and public authorities are to take any appropriate action available to them to implement those measures included in a plan for which they are responsible and must not make decisions that are inconsistent with the provisions of a plan.

TROUT COD reside in the immediate vicinity of the proposed Orange Pipeline water extraction point(s), and are classified as endangered as follows:

* Endangered under the Environment Protection and Biodiversity Conservation Act 1999 (Commonwealth)
* Endangered under the Fisheries Management Act 1994 (NSW)
* Endangered under the Nature Conservation Act 1980 (ACT)
* Threatened taxon under the Flora and Fauna Guarantee Act 1998 (Victoria)
* Endangered by the Australian Society for Fish Biology (ASFB)
* Endangered by the Australian and New Zealand Environment and Conservation Council (ANZECC)
* Endangered by the World Conservation Union (IUCN)

Reasons for concern if the Orange Pipeline is implemented:

*The natural range and abundance of trout cod has declined over the last 50-60 years. From once being widespread throughout the southern tributaries of the Murray-Darling system, the Murrumbidgee and the upper half of the Macquarie River, trout cod have contracted to just four isolated breeding populations. Such populations are generally less able to cope with or recover from, severe loss of critical habitat, threatening processes and natural catastrophic events, than larger, more widely distributed populations (Douglas et al. 1994).

Trout cod and Murray cod often occupy similar habitats including faster flowing water with rocky and gravel bottoms as well as slower flowing, turbid lowland rivers. However, Murray cod have a much wider distribution. Both species use the cover of large woody debris, however trout cod prefer higher flows in the middle of channels or downstream of bends.
(See direct link to plan)
http://www.dpi.nsw.gov.au/fisheries/species-protection/conservation/what-current/endangered-species/trout-cod/protecting-trout-cod

Key Threatening Processes:
Several `key threatening processes' (KTPs) of relevance to trout cod have been listed under the Fisheries Management Act 1994. These include:
* Removal of large woody debris from NSW rivers and streams;
* Degradation of riparian vegetation along NSW water courses;
* Introduction of fish to fresh waters within a river catchment outside their natural range;
* Installation and operation of in stream structures and other mechanisms that alter natural flow regimes of rivers and streams.
* Hook and line fishing in areas important for the survival of threatened fish species

Human Activities with the potential to have detrimental impact on Trout Cod:
(Point 2- Page 9- National Trout Cod Recovery Plan 2008)....
* Reduction in/alteration of flows, such as abstraction of more water from the system.
The plan suggests that reducing, or even altering the flow, will increase the likelihood of detrimental impacts on the endangered Trout Cod.

Threatening processes currently considered to be primarily
responsible for the decline in trout cod:

*4.2 River Regulation -Page 18 NSW Trout Recovery Plan:

"Large fish species such as trout cod are at the top of the aquatic food chain and rely on the full range of ecosystems processes. They are often the type of fish most vulnerable to changes in natural flow variability and habitat condition. While the impacts of river regulation are complex and interrelated, they fall generally into the three main categories of; altered flow regimes, barriers to fish movement and changes to temperature regimes...."

Increased Water Temperature due to lower flows, and effects on Endangered Trout Cod:
(Page 6 National Trout Cod Recovery Plan).
*"... Trout Cod were found to be more prone to bacterial or fungal infections if kept at temperatures of 25°C or above for more than a few days (Merrick & Schmida 1984")

Further Relevant information sourced from the "National Recovery Plan for the Endangered Trout Cod:
(Page 6 National Trout Cod Recovery Plan of 2008).
*"An assessment of habitat critical to survival has been carried out on the Trout Cod population in the Murray River (Koehn & Nicol 1998). Trout Cod used river positions where large woody debris is present in high quantity, close to deeper water and high surface velocity, further from the river bank (Koehn & Nicol 1998). These characteristics are distinct from those of Murray Cod and Golden Perch, and demonstrate that Trout Cod habitat requirements (at least in the Murray River) are specific rather than general"

The proposed pump site for the Macquarie River Pipeline is located at one of the exact release points where endangered Trout Cod fingerlings have been released as part of the National Trout Cod Recovery program. The five year plan will move to release more fingerlings to help re-establish the species which is on the verge of extinction.
The National Trout Cod Recovery Plan highlights that Trout Cod habitat requirements are "specific rather than general", with the Gardiners Hole area of the Macquarie River being selected for its abundant and "specific" trout cod habitat.

Fish Passage and effects of lowering Macquarie River flows:
Golden Perch have a recorded migration of up to 2,300km - which is the equivalent of swimming from Sydney to New Zealand. Murray Cod have been known to migrate over 100 kilometres to return to their favoured snag to breed. (Department of I & I 2011)
*It is documented by the NSW DPI that a fall of only 10cm is enough to create a barrier that will block fish passage.
*The further lowering of flow levels by OCC's pipeline pumps will make the many natural fish ladders in the Gardiners Hole section of the Macquarie River unpassable, making the fish retreat to refuge holes, and in turn further "delete" the preferred habitat of the endangered Trout Cod.

Effects on the Riparian Zone:
Insects falling into water out of overhanging vegetation can provide over 40% of native fishes' food intake.
When studies have been conducted by NSW I& I, the abundance of fish adjacent to well vegetated riverbanks was up to 13 times higher when compared with vegetated banks.
It is a major concern that the Riparian Zone will be unnaturally removed from the water's edge through extended periods of further reduced flows, thus damaging the entire food web that revolves around it. In a sense, the riparian zone will be artificially manipulated through water extraction at times of low flows by Orange City Councils plans to remove millions of litres of water in times of drought/low flows.

Lowered Water Quality due to pumping in times of drought:
(Page 7 & 8 National Trout Cod Recovery Plan 2008)
"Poor water quality can be caused by reduced flows through diversion, impoundment or sustained dry periods reducing run-off. Consequences include raised water temperatures, reduced dissolved oxygen levels, concentration of nutrients and environmental contaminants. Nutrient run-off from urban and agricultural areas can cause increased growth of phytoplankton, initiating plankton blooms and reducing oxygen levels. Fish kills can result from these conditions, and in just such an event in the Goulburn River in and downstream from Lake Nagambie (Vic) in January 2004, about 20 Trout Cod (most likely from stocked fish) were among thousands of native and introduced fish killed, apparently due to extremely low dissolved oxygen levels linked to poor water quality. This stocked population had bred in the wild in 2003 and possibly 2002 (Koster et al. 2004), the first solid evidence of reproduction in a recently stocked population. Subsequent surveys failed to detect any Trout Cod in the area affected by the fish kill (Koster et al. 2004) and it is uncertain if the population still persists there".

Endangered Trout Cod: Breeding
*Trout cod reach sexual maturity at approximately 350mm in males and 430mm in females, which corresponds to ages of 3-5 years and weights of 0.75 to 1.5kg.
Therefore, endangered Trout Cod fingerlings released in and around the intended extraction point for the Proposed Pipeline will reach breeding size at around the same time as the pumps are switched on for the first time.

Decline and Threats to the Endangered Trout Cod:
(Page 6 National Trout Cod Recovery Plan 2008 )
*"There appear to be at least some specific threats (eg. fishing, de-snagging, poor water quality) affecting Trout Cod. Other well-documented threats operating in the Murray-Darling River system (eg. reduced flooding and flows, low water temperatures, barriers) and affecting many native fish species, may also be impacting on Trout Cod, contributing to the substantial decline in range and abundance".

Undoubtedly, the Proposed Macquarie Pipeline is a major threat to the Trout Cod that have been released into the Macquarie River as part of the National Trout Cod recovery program, as it will further lower water levels in times of low flows, and in turn reduce water quality, therefore increasing the risk of native fish fatalities.

River Regulation and endangered Trout Cod breeding effects:
(Page 7 National Trout Cod Recovery Plan)
*"Since the habitats occupied by adult Trout Cod are patchily distributed, increased movement associated with breeding may be an important factor in successful pairing".
It will become increasingly harder for fish to move when the river is reduced to a series of un crossable sand and rock bars, and will become impossible for Trout Cod, and all native fish for that matter, to move up and down the natural fish ways that occur along this stretch of the Macquarie River.

Please see attached supporting documentation from Dr John Harris regarding the inadequacies of the EA relating to this project.

I strongly urge that this project is abandoned.

Yours Sincerely,

Matt Hansen
President- Inland Waterways Rejuvenation Association.
www.iwra.com.au

As attached.

As attached.

As attached.

As attached.

As attached.

As attached.

As attached.

As attached.

As attached.

As attached.

As attached.

As attached.

As attached.