Executive Summary fails to mention or highlight World or National Heritage or Values.
National Heritage was gazetted in May 2007. Clearly these classifications are the prominent features of the proposed site and should be addressed. The following background statements are misleading. They are, not substantiated, incorrect as they appear and have no basis in fact and should be removed:-
“..the site ……initially identified by government as suitable for a marina”.
“The site …….as the most strategically and environmentally appropriate marina site…….”
The use of these statements in the background gives the reader the false impression that –
· Government initiated and has been the driver for a marina in this location;
· that a Government study has been completed eg MAUS;
· that a Government study has identified the site as environmentally appropriate for a marina;
We wish to lodge our strong objection to the release of this document bearing an image of a nearby property which as the lead descriptor is not the subject site. The use of this image could be at best described as misleading. We are both aware that the site, the subject of the EIS, is World Heritage and surrounded by National Park and as the Proponent has tagged in its marketing material “Iconic”. This site is known to be in need of attention but we are aware is awaiting the outcome of this and other applications before commercial decisions are made.
The acceptance on the part of your office to allow the release of the EIS with a lead image that is not part of the subject site and does not depict a hint of the significant environmental attributes, not only is a gross inaccuracy but is of grave concern. Needless to say we believe the Proponent has by the use of this irrelevant image introduced a tone of recklessness in relation to the quality and content of the document.
Section 1.4.3 Submissions
In this section the Proponent includes, as part of the process, for all submissions to be provided to them. It further states that it will consider all submissions and provide to the CG
A summary of submissions
A statement of the Proponent's Response to submissions
Any amendments to the EIS resulting from the submissions.
We strongly and vehemently object to the inclusion of this in the EIS. We require it be immediately withdrawn from the EIS and process on the following grounds –
1. It has no basis at Law
2. It does not comply with the SDPWO Act
3. It introduces a non-existent unacceptable tier of review to the process which is not covered under the Act
4. It facilitates a self assessment component not covered under the Act - this is unacceptable
5. It denies Natural Justice – ie it makes valueless the submission process as it becomes reliant on the Proponent in its summary to the Co-Ordinator General to interpret and assess those submissions
6. It replaces the Co-Ordinator General's responsibility of assessment and consideration of the submissions in their submitted form.
7. It introduces an amendment to the Legislation by virtue of an EIS document – there is nothing in the Legislation which permits this to occur.
8. It facilitates a process that is outside of the Law – ie it permits the Proponent to change the EIS prior to the CG Report
9. It is misleading and deceptive – as the document is stated as being completed in accordance with the SDPWO Act the reader has the right to expect that it complies – this does not. Not all parties reviewing the document will be conversant with the Legislation in its entirety.

The State Development and Public Works Organisation Act states -
35 Coordinator-General evaluates EIS, submissions, other
material andprepares report (1) The Coordinator-General must, after the end of the submission period, consider the EIS, all properly made submissions and other submissions accepted by the Coordinator-General about the EIS and any other material the Coordinator-General considers is relevant to the project.
s 35A 31 s 35A State Development and Public Works Organisation Act 1971
(2) The Coordinator-General may ask the proponent for additional information or comment about the EIS and the project.
(3) The Coordinator-General must prepare a report evaluating the EIS.
(4) In evaluating the EIS, the Coordinator-General may—
(a) evaluate the environmental effects of the project and any other related matters; and
(b) state conditions under section 39, 45, 47C, 49 or 49B; and
(c) make recommendations under section 43 or 52; and
(d) if division 8 applies to the project—impose, under that division, conditions for the undertaking of the project.
(5) After completing the report, the Coordinator-General must—
(a) give a copy of it to the proponent; and
(b) publicly notify the report.
In view of the requirements under the Act and the very serious issues raised above we believe this gives rise to question the merit of release of this EIS. As a result we believe and argue this document is not a proper EIS within the terms of the Law.
We require a written response and guarantee from the Co-Ordinator General that the process mooted in the EIS set out above will not be followed for this or any other submission made on SHMRD. The Co-Ordinator General's decision to release an EIS containing this level of misleading information is of grave concern.
The inclusion of these items highlights the documents inability to meet the TOR or be a proper EIS. This and any other areas that may be considered misleading or reckless in their approach must be remedied before any Supplementary document is released.
The draft Terms of Reference were reviewed by SHRA. It is noted that:-
i. The final Terms of Reference have been lessened from the original TOR;
ii. There is no provision in the TOR, (as outlined in the submission by SHRA in its response to the TOR) for Peer Review. The absence of Peer Review has lessened the TOR and hence the accuracy and weight of the EIS. The area stated in “The Proposal” 45.2 ha is incorrect as it does not equal the total area contained in the Leasehold Titles and Permit to Occupy currently held but rather what may be the outcome dependant upon other applications. The reference to the proposal being the result of planning studies is misleading and should be removed. The only planning study that gives credence to the proposed SHMRD is one done by the Proponent. The clear outcome of the workshops and the Strategic Planning Study conducted by the DLG resulted in a resounding NO MARINA AT SHUTE HARBOUR and LEAVE SHUTE HARBOUR ALONE. The statement “Proven support of Traditional Owners” is incorrect. Our enquiries have revealed that there has not been any consultation with the appropriate Traditional Owners. The traditional contact for Sea Country at this site, Irene Butterworth of the Girudala Association in Proserpine who was on the Reference Committee used by the former Whitsunday Shire Council (now part of Whitsunday Regional Council) as their Open Space planning reference was not included in consultations on traditional cultural values for this site. Until such time as the relevant traditional owners are consulted any reference to support or consultation of Traditional Owners cannot be included. It is noted from the key elements that there has been a major shift from the earlier proposal in that the 117 freehold allotments are portrayed as part of managed resort accommodation rather than residential. Some explanation or data clarifying this shift would have been helpful. In the absence of any detail on this it is left up to the reader to draw his or her own conclusions on why the change has occurred. However the shift does promote the view the project is largely Tourism based although there is little provided on how the Managed Resort Accommodation and sale of Freehold lots will work together to achieve what is promoted. More detail is required on this before it is possible to determine what the true purpose or workings of this component will be. As freehold lots what covenants will be placed upon these in order for them to work as “managed resort accommodation” and how this would affect their marketability for sale as this would differ greatly from say the saleability of freehold residential.

Objectives
The objectives have not been substantiated in the EIS.
· The demand study the subject of the EIS is incorrect and therefore cannot be substantiated (see accurate assessment of demand figures Figure 1 attached) hence –
· This project is not a valuable addition as it is not needed
· The strong growth in recreational boating evidenced by the DOT statistics is not in the size range catered for by the project – hence filling any need cannot be claimed.
· Built form does not integrate with WHA and the natural environment that is the essence of the niche Tourism driver of the Whitsundays
· As Shute Harbour is a natural harbour the best plan for protection of the water quality would be to leave it in its natural state
· The existing link between the site and the transit terminal is well recognised as a “one of Australia's best scenic drives” and replacing this with built form in a space that is recognised worldwide for its natural attraction is not an improvement.
· The SHMRD does not include any form of independent transport system so this cannot be stated as an objective
Need - no need for marina berths no need for accommodation -
A central tenet of the approach to the SHMR development has been to ensure that clear net benefits are delivered by the project. As this approach is considered to be essentially the most fundamental test regarding the relative merits of a project.
The Net Benefit AEC as prepared does not provide any test for the data included and is flawed.
The report refers to the Brown and Roote Study on a number of occasions as justification for the proposed project – as a source relied upon in the EIS it should have been made available through the EIS. It relies on this study in identifying Shute and Muddy Bay as ideal locations but then fails, in the assessment of net benefit to refer to the number of berths identified as being needed through to 2023. It is clear from perusal of the B &R Study that the demand quantified has already been exceeded by current or approved supply. Particularly as the proponents extrapolation of demand is not substantiated in DOT figures. It would seem therefore the Proponent has omitted key findings in this Study when the data failed to meet the requirements of the EIS. The net benefit calculation is flawed on the following basis:-
The Proponent has based sections of the Net Benefit Assessment on References to the Brown and Roote Study. The NET BENEFIT ASSESSMENT does not include any calculation for any negative impacts contained in the study as follows:-
1. The B & R study although identifying both Shute and Muddy Bay as suitable locations it does not identify the need for both locations to be used for this purpose.
2. The B & R study outcome evidences the lack of need for this Marina based on its calculations and current availability and this has not been included in the NET BENEFIT ASSESSMENT calculations.
3. This B & R study identifies the poor score of Shute Harbour on the criteria of maintenance dredging which conflicts with the statements and outcomes contained in the EIS.
4. The use of the B & R study and the clear conflicts between its findings and those of the current study attest to the need for peer review as highlighted in the Shutehaven Residents Assn. response to the Terms of Reference.
5. The report highlights the appeal to boat owners evidenced by the large number of craft on swing moorings but fails to negatively quantify the loss to the boating community of the full use of the harbour in its natural state, the loss of appeal to use the harbour lessened by a massive development (if these vessels preferred a marina they would be in one of the existing mainland marinas
. 6. It relies on assumptions “it would appear inevitable that the Whitsundays will continue to attract increasing numbers of visiting and resident boats”.
7. It does not include any or sufficient negative adjustment for –
The loss of World Heritage Values
Loss of Natural Public foreshore areas
Loss of view corridors “Shute Harbour drive features in Australia's great drives!
Loss of Natural Harbour
Loss of moorings
Loss of natural habitat
Increased impact on GBRMP
Effect on amenity to mooring holders relocated to less preferred or usable sections of the harbour ie. more affected by weather conditions As demand has not been established accurately a negative calculation needs to be included for the resultant economic effect on other marinas.
The approval of yet another marina such as SHMRD will no doubt have an affect on the outcome for the already approved Port of Airlie and this need to be considered and quantified.
8. The outcome of the Shute Harbour Strategic Planning process attested to a clear decision that the widespread Community involved in that process which included many levels of Government opposed any marina construction and came out with a clear decision to “leave Shute Harbour alone”
9. The Shute Harbour community does not see any economic or social or environmental benefit in what is proposed and this has not been included in the calculation of negative effects.
10. The conflicts between statements contained in both reports highlights the value that would have been achieved by Peer Review on all studies requested by SHRA in its comments on the Terms of Reference. As the studies included in the EIS are not subject to Peer review the value of their outcomes is lessened and questionable – hence a negative calculation should be included to provide for the Precautionary Principle.
11. The Alternatives and the finding that the current proposal represents the highest and best use of the site is merely reflective of the Proponents desire to see the project proceed. It has not been accurately established in the EIS or in any independent way assessed. It is not in line with the Local Community views. The Strategic Planning Process did not arrive at this finding and as no Most Appropriate Use Study has ever been completed this statement is baseless.
12. The Shute Harbour community does not agree that the project in any way enhances “the quality of life” and accordingly this statement is baseless.
13. Replacing Natural World Heritage Listed Landscape with built form does not conserve Natural Landscape – this statement has no basis and is contradictory.
14. The Whitsunday Tourism Infrastructure Plan, Shute Harbour Strategic Planning process outcomes and many other studies identify Shute Harbour's greatest need as small craft facilities. The loss of allocation in funding to the community in the last round in 2007 pending the outcome of this process has not been quantified.
15. Increase in Insurance costs due to increased risk associated with development in coastal area inside Storm Surge Area
16. Increase in Insurance costs due to increased risk of Marine Incidents with volume of traffic in restricted waterways not conducive to prevailing weather conditions
17. NET BENEFIT ASSESSMENT has no value as it relies on assumptions and is not accurate.
Land - Existing Environmental Values
18. The report fails to highlight under this section the key identity of the land and water and is flawed and misleading and should be adjusted: a. Reference to the predominate World Heritage Areas is understated and confusing “part of the site within the outer margin……….” All water-based areas are within the WHA.
b. Reference to the land classification of State Significant Biodiversity or any other significant classification such as Heritage Listing is omitted
c. Reference to Figure 5 as illustrating the designation of the site as Marina under the current WSC Strategic Plan is incorrect- the site outlined on this figure has no classification or zoning with the exception of Public Purpose. This is misleading and should be removed.

Location of the Resort
The map showing the road reserve formerly excised from Conway National Park is shown in the Executive Summary as containing the Resort yet a map in the main EIS shows the Resort as along the Foreshore. This constitutes an improperly prepared EIS as it is not clear where the Resort will be located. The EIS should be re-submitted for public comment after it is cleared of ambiguous and any other incorrect materials.
Planning
We also question the legal basis for the submission of an EIS for a project that is not supported by the current Whitsunday Regional Council Transitional Planning Scheme, the regional WHAM Planning Scheme, or most policies of the Coastal Management Act and the draft Mackay Whitsunday Coastal Management Plan. We can find no federal or state legislation where it is supported except in some cases where an overwhelming need and public support is demonstrated. We found no overwhelming need or public support that would justify the project's impacts on a World Heritage Area and the adjacent Conway National Park. We will demonstrate these findings throughout this review of the EIS document.
The proposed Shute Harbour Marina Resort site is not zoned for use as a possible Tourist Facility yet the EIS is written as though this zoning has already been approved.
The current zoning for the proposed marina resort site is Public Purpose Zone and Scenic Management Zone B. In the town planning scheme the foreshore area between the marine area of Shute Harbour and Conway National Park is described as a Public Purpose Zone and Scenic Management Zone B. Uses are for public or community purposes. None of the permitted public use purposes in Table 5.9.2 includes a marina or resort.
Any type of building within Scenic Management Zone B is severely restricted, the primary aim being to conserve natural scenic values i.e.
“to achieve development that does not diminish the visual or ecological integrity of the (Whitsunday former) Shire's main coastal landscape features.” http://www.bowen.qld.gov.au/Portals/0/06-Services/S-Town%20Planning/TPWhitsunday/WSC_Planning_Scheme.pdf
Port Binnli proposes a 5 storey high resort which would not be permitted under current Scenic Management Zone B zoning for the site.
The scenic drive along Shute Harbour Road from where Shute Bay is first viewed to the Council jetty is 1.9 km. Of this distance the Marina Resort would occupy ~ 682 m, or 36% of the foreshore drive's distance. The marina would occupy 983 m or 52% of the scenic drive's views from the foreshore.
Where Shute Harbour Road enters the marina resort, views to offshore islands and Shute Harbour would be blocked. If Shute Harbour Road was raised to compensate for the loss of those scenic views, it would block views of Conway National Park behind the road, so there would still be a substantial loss of viewscape and natural amenity which we have already shown would be also an economic loss. Public enjoyment of the natural foreshore would also have been lost along 36% of the scenic drive's length.
The proponent has said they will return the road reserve back into Conway National Park from where it was originally excised. This road reserve could only be used for public purposes related to the road so the resort could never have been built on it. The return of the road reserve to the National Park means that the park's boundaries would extend to the edge of the new re-aligned Shute Harbour Road. This would leave no buffer zone between this National Park and the Shute Harbour Marina Resort. Shute Harbour Road does not fit the federal government's definition of a buffer zone for areas of high conservation.
“In a reserve, an area of moderately utilised land that provides a transition into the unmodified natural habitat in the core reserve where no human disturbance is allowed'. Buffer zones are essential for all conservation areas and provide a degree of protection from threatening processes and impacts. They are especially important for those areas where the small size of the reserve is already compromising conservation objectives. Buffer zones should be implemented outside reserve boundaries to prevent part of the reserve being sacrificed from its primary conservation purposes.” http://deh.gov.au/biodiversity/publications/nbccap/glossary.html
According to the above definition, the Shute Harbour Marina Resort will need a buffer transition zone to eliminate or mitigate the impacts of the development on Conway National Park. Is a similar conservation transition buffer zone required between the development and Great Barrier Reef Marine Park Habitat Zone in which the development is located? Even if the EIS was approved Whitsunday Regional Council would require the proponent to meet the following criteria to meet re-zoning requirements for a resort under a Possible Tourist Facility Focus criteria under their Transitional Planning Scheme.

Need for the Development
The proponent stated in the EIS: “A shortfall of 738 marina berths is predicted by 2010 and 3,133 by 2020.”
In its Mackay Whitsunday Regional Tourism Investment and Infrastructure Plan 2006 – 2016, Tourism Queensland and the Department of Tourism, Fair Trading and Wine Industry Development stated in December 2006 “The expansion of the regions' marinas will likely meet forecast demand out to 2016.” p.12
http://www.tq.com.au/tqcorp_06/fms//tq_corporate/destinations/mackay/TQ_RTIIP.pdf
The tourism plan included marina berths from the proposed Shute Harbour Marina Resort. But we found that even without marina berths from this proposed development there is sufficient approved and built capacity to meet demand through 2020 in the Bowen, Whitsunday Mackay region.
We reviewed Queensland Department of Transportation (DOT) statistical data on vessel registrations in size classes for each June from 1998 through 2008 for vessels 8.1-10.0 m; 10.1 –15.0 m, and 15.01-20 m. The vessel class sizes most likely to be found in marinas are actually greater than 10 m.
The DOT data refer to all of Queensland by region. From this we projected future demand to 2020 for marina berths in the region that included the Mackay, Whitsunday, Isaac and Bowen regional council areas. We also projected future numbers by 2020 for marina berths for interstate vessels. This was done for vessels ranging from 8.01 – 20.00 m. Marinas generally cater for vessels 9-20m. Calculations of extrapolations are in Appendix 1.
Table 1. Predicted vessel registrations by 2020
Vessel Size Class Bowen/Whitsunday/ Isaac/Mackay Region Interstate Queensland
8.01 – 10.00 m 544 45 6580
10.01 – 15.00 m 480 175 10386
15.01 – 20.00 m 169 70 1521
8.01 – 20.00 m 1193 290 18487
Total Region & Interstate 1483

Table 2. Status of Built, Approved and Proposed Marina Berths in the Whitsunday, Mackay Regional Council Areas
Marina Status Berths for vessels 9m
Abel Point Built 500 wet berths
Port of Airlie Under construction 240 wet berths
Hamilton Island Built 180
Keswick Island Existing approval 200 planned 20 existing
Laguna Quays Built 110 existing
Bowen Marina Existing approval 600 wet 300 dry
Mackay Marina Built 479 capacity
Shute Harbour Proposed 669
3298 or 2629 without Shute Harbour marina
There is currently a surplus of supply of marina berths. Available capacity at 2629 marina berths is 1145 greater than vessel registrations of 1483 (region and interstate visits to Queensland).
To fully use 2629 marina berths already built, under construction or having an existing approval in the Mackay Whitsunday region numbers of all vessels in the 8.01 – 20.0m range would need to grow annually to 2020 by:
8% p.a. from a 2008 base of 1,042 vessels (Whitsunday to Broadsound vessels), or
6.5% p.a. from a 2008 base of 1,238 (i.e. 1,042 region vessels plus 196 interstate vessels registered in Queensland and all assumed to use the Whitsunday marinas)
To fully use the additional 3,133 marina berths Port Binnli claims are needed in the Whitsunday region, annual growth of vessels in the Mackay, Whitsunday and Isaac council regions and interstate vessels in Queensland would need to be 12.5% from a 2008 base of 1238 vessels (8.01-20m) i.e. 5,762 marina berths by 2020.
From 1998 – 2008, average annual growth rate for vessels 8.01 – 20.0m Mackay Whitsunday Isaac council regions) plus all Queensland interstate vessels was 8%, so a predicted average annual growth of 12.5% to 5,762 vessels needing marina berths in the future is unrealistic, especially in light of the current economic downturn.
The proponent has not demonstrated a clear need for this development on the basis of unmet demand. Too many berths in the region will contribute to economic loss in this sector during periodic economic downturns, affecting profitability and maintenance of the marinas and their associated residential and resort infrastructure.
The only way such a rapid growth rate might occur would be if residential and resort accommodation that includes marina berths was an acceptable common form of coastal growth in regional and town planning schemes. This type of residential housing apartment and resort growth outside the urban footprint along coastal areas of high scenic and environmental values is not viewed as appropriate under the Queensland State Coastal Planning Act, and the draft Mackay Whitsunday Coastal Management Plan as it contributes to linear urban sprawl along the coastline. This proposed private development would occupy ~ 22% of the Shute Harbour area and 22% of the length of the northern foreshore of Shute Harbour.
The regional WHAM Plan clearly excludes Shute Harbour from marina development, possibly because this harbour is part of a GBRMPA marine park marine life habitat protection zone. Both Port of Airlie and Abel Point marinas are located in lower impact GBRMPA marine park general use zones.

Table 3. Changes in Vessels 8.01 m and 8.01m in the region
Year Mackay, Whitsunday, Isaac & Bowen Region 8m Mackay, Whitsunday, Isaac & Bowen Region 8m plus annual percent changes Mackay,
Whitsunday, Isaac & Bowen Region Total 8m as % of Total
1998 10,610 352 10,962 3.29
1999 10,693 468 11,161 4.19
2000 10,972 558 11,530 4.84
2001 11,883 544 12,427 4.38
2002 12,945 665 13,610 4.89
2003 13,746 711 14,457 4.92
2004 14,375 762 15,137 5.03
2005 15,268 822 16,090 5.11
2006 16,183 938 17,121 5.48
2007 18,163 999 17,164 5.82
2008 17,649 1,042 18,691 5.57

In terms of need it is the recreational smaller boats 8m which have far greater numbers and need for supporting infrastructure and management (Table 3). Yet no additional boat ramp or other public infrastructure is planned for Shute Harbour.
Alignment with Policy and Regional Planning
Draft Mackay Whitsunday Regional Coastal Management Plan
The proposed Shute Harbour marina resort does not fit any of the criteria in the above Plan except the marina is a coastal-dependent land use. The location for the resort as already demonstrated in this submission is not suitable for the resort and other accommodation. The marina would impact on the economic viability of other marinas existing or approved in the region, as need is already being met. It would also crowd out smaller craft, the boat ramp and other businesses necessary for the region e.g.the barge jetty and the boat salvage operation which needs fast and easy access for emergencies in the Great Barrier Reef.
Unfortunately neither a Local Area Management Plan nor a Most Appropriate Use (MAU) Study for Shute Harbour has been done. The draft Mackay Whitsunday Regional Coastal Management Plan identified Shute Harbour as a priority site for a MAU study in 2007. EPA coordinated community meetings to get community input on a Shute Harbour Foreshore Plan in 2007 and this could have contributed to a Local Area Management Plan. But after the community stated overwhelmingly that they wanted Shute Harbour left in as natural a state as possible the SHFP was never finished. This has left a planning vacuum which needs to be filled, starting with a MAU for unallocated state land to decide to most sustainable long-term use for the foreshores of Shute Harbour and Shute Bay.
The Whitsunday Regional Council's Coastal Settlement zone is in the adjoining eastern section of Shute Harbour which contains the township of Shutehaven, zoned as Airlie Village Residential. The foreshore where the proponent proposes to build the marina resort is zoned as Scenic Management Zone B in Council's Strategic Plan, with the original lease area for the marina described as Marina with no specific further planning information. Immediately adjoining the Marina is the Mainland Urban zone.
The inclusion of a Resort into the proposed marina development would constitute a form of Urban expansion outside of the Urban zone and is not supported by this State coastal management policy.
Growth of urban settlements should not occur
on or within erosion prone areas,
significant coastal wetlands,
riparian areas,
sites containing important coastal resources of economic, social, cultural and ecological value, or
areas identified as having or the potential to have unacceptable risk from coastal hazards (refer to policy 2.2.4).
on or within erosion prone areas
Although the site is not mapped as an erosion prone Coastal Management District will it become one after sand and dredge spoil fill is placed behind a retaining rock wall? Rocks from the rock wall in Mackay Harbour are often dislodged during inclement weather. That structure is allowed because it is State Significant (Social and Economic). But should a private resort and other accommodation infrastructure that is not in any current planning schemes have the same right to be built in an area of high natural hazard i.e. high risk of cyclone and storm surge damage?
significant coastal wetlands,
As part of the GBRWHA the site is in the Directory of Important Wetlands in Australia. Extensive seagrass beds (within and around the site) and nearby coral reefs are listed as State Significant (Marine and Wetland Habitat). The draft Mackay Whitsunday Coastal Management Plan also maps coastal estuarine and freshwater wetlands west of the site under Coastal Wetlands. riparian areas,
The site contains bordering riparian Of Concern regional ecosystem 8.12.11 which ~ 682 m of foreshore would be cleared. That represents a significant 36% of the scenic drive along Shute Harbour Road that borders Shute Bay and Shute Harbour. This R.E. is mapped as Essential Habitat for the Proserpine Rock Wallaby.
sites containing important coastal resources of economic, social, cultural and ecological value
The site is within the GBRWHA and GBR Coast Marine Park (Habitat Protection Zone), and is surrounded by Conway NP and GBRMP. Threatened species include the Proserpine Rock Wallaby and the Dugong. Marine birds nest within the foreshore vegetation.
There are extensive seagrass beds (within and around the site) and nearby coral reefs are listed as State Significant (Marine and Wetland Habitat). According to Fig. 18 in the EIS about one quarter of these seagrass beds would be covered by the marina resort. The consultant's report says 10% of the seagrass beds would be affected. This appears optimistic given Fig. 18.
There is no appropriate buffer transitional zone between the site and Conway National Park which is State Significant (Natural Resources) and State Significant (Scenic Coastal Landscapes).
The site is not in an area of State Significance (Social and Economic) but adjoins one i.e. the Whitsunday Regional Council Shute Harbour Transit Facility, so its social and economic impacts on that facility must be identified.
State Significant Terrestrial Habitat containing essential habitat for endangered, vulnerable or rare species is also mapped from Conway National Park and includes the foreshore. That habitat is for the Proserpine Rock Wallaby.
State Significant Beach and Foreshore Habitat for shorebirds exists in the foreshore of the eastern part of Shute Harbour east of the site. There is a seagrass bed identified as State Significant Beach and Foreshore Habitat also in the eastern part of Shute Harbour east of the site in the nearshore area. The seagrass beds in Shute harbour and Shute Bay are almost as large as those in the Dugong Protection Zone in Repulse Bay 75 km south along the coast. The massive disturbance of the site for infill, ongoing dredging and the marina will have some impacts, especially from increased sediment loads (as demonstrated in the similarly sized Port of Airlie construction) on nearshore areas s to the east of the site, as longshore currents flow east and north and along the coast.
According to the seagrass consultant's report “the majority of works will be confined by sheet piling (so sediment) peak concentrations may be lower.” Sheet piling did not prevent large and long sediment plumes flowing into surrounding waters at Port of Airlie. We have the images to show those plumes which were worse after rainfall.
Table 7 of the EIS consultant's report on significant species states:
“Some of the listed migratory marine species may use the seagrass beds and coastal waters within and adjacent to SHMR site as foraging habitat.”
“Natural Solutions (2008) report that “the project site at Shute Bay does not appear to provide regionally significant habitat or feeding resource to dugong”. While the site contains preferred species of seagrass that dugong feed on, their cover is sparse (0.5 %) within Shute Bay, with only small patches up to 5% cover, and Feeding trails have not been observed by previous marine ecological studies within the bay.” (FRC Environmental 1999, 2008).
As Dugongs and Turtles migrate along the coast to feed on seagrass, what effect would the full or partial loss of seagrass beds in the Shute Harbour and Shute Bay have on dugong populations and dugong health? We are very aware of the huge loss of seagrass dugong feeding grounds when the Port of Airlie filled in much of Boathaven Bay for tourist residential accommodation. Dugongs are now at critically low numbers in the Whitsundays. Not only is the loss of feeding grounds and habitat a threat to dugongs from this proposed development, but also so is the increased threat of boat strikes because of increased vessel traffic in and out of the marina. The Dugong is a migratory species listed under the EPBC Act 1999 and Bonn Convention for migratory species. The Integrated Planning Act and Coastal Management Plan commit to the Precautionary Principle, and this principle should be followed in reviewing the impacts of this development. The threat of additional harm to this species appears real from this development.
In Table 7 the consultant says that the site does not contain important habitat for the dugong and other migratory species in the sense that EPBC defines important habitat. But the statement is not supported by long-term studies. Seagrass cover can fluctuate widely depending on environmental and weather conditions. What does EPA say about the importance of this habitat to a species that is declining rapidly in numbers in the Whitsunday region? We have seen similar claims of low EPBC value habitat made for habitat in Mackay for migratory birds which were simply wrong as the area in question was used heavily for feeding and resting by the birds. Without the long-term studies such claims have less credibility. This is after all a species listed internationally as Endangered and Vulnerable under the Nature Conservation Act (This listing should be checked with EPA as dwindling numbers in the region make in now locally Endangered).
2.1 .2 Regional policy
Development assessment
1. Development of residential, rural residential, commercial, industrial, or tourist developments incorporating a residential component, outside an existing urban area must: (a) have a demonstrated need2 for the proposed development to occur on the coast 3;
2. In relation to policy 2.1.2 of the Mackay-Whitsunday Coastal Plan, a demonstrated need requires that: • there are no alternative existing urban areas (either on the coast or elsewhere) that are suitable for the proposed new urban development;
• there are no opportunities for the proposed new urban area or development to be located away from the coast; and • assessment of the social, economic and environmental outcomes of the development has been undertaken, and supports the location of the proposed new urban area or development.
(b) result in existing urban areas remaining compact;
(c) avoid scattered satellite development along the coast;
In the EIS the proponent indicates they will apply for a Material Change of Use to change zoning so that the Marina Resort can be built. Yet they will not be able to meet the above requirements for a tourist development:
1(a) Please read our comments under the Need section to show that there is no current or future unmet need for additional marina berths in the Bowen Whitsunday Mackay Region. If the marina is built the resulting oversupply is likely to impact the economic viability of already existing marina resorts.
2. (a)There is an existing alternative. An already approved unbuilt private marina complex is approved on the coast in Bowen in an approved tourist transport hub.
The many environmental and scenic values of the Shute Harbour site, the community overwhelming desire to retain the natural values of the site, and the threat of economic loss from tourism if the region is overbuilt with marina resorts, and Shute Harbour and Shute Bay loses any more of its scenic values all indicate that the location does not support this type of urban development. 2(b) The development of tourism resort and accommodation facilities would be an extension of the urban component adjacent to the Transit Center. Compactness of the Shutehaven community would be lost.
… (d) demonstrate consistency with State Coastal Plan policy 2.2.4 Coastal hazards;
The EIS does not demonstrate consistency with the Coastal Hazards policy. See information on flooding on Shute Harbour Road; Landslides, Stormwater and Storm Surge.
(e) be located outside, and adequately buffered from, areas of state significance (natural resources) (refer policy 2.8.1); See information in this document on the need for adequate transitional buffer zones between the development site and surrounding areas of state and national significance.
(f) maintain or provide a vegetated buffer to coastal waterways to maintain habitat linkages (refer policy 2.8.3) and water quality (refer policies 2.4.4 and 2.8.2);
The design and location of this project means the loss of vegetated buffer zones.
a) be located outside areas of state significance (natural resources) (refer policy 2.8.1);
a. The development is in an area of state significance (natural resources)
b) not facilitate further urban development that would be inconsistent with this policy.
c) The development would facilitate further urban development along the foreshore if a MCU was granted by Council. It would set a precedent for expansion outside the declared urban area of Shutehaven in spite of not meeting planning requirements in Whitsunday Council's Transitional Plan, and being outside the urban footprint for this type of marina tourist development in Airlie which was approved in the WHAM Regional Plan.
2.1.5 Maritime infrastructure
d) 2.1.8 Dredging
e) This policy seeks to achieve the following 'Coastal use and development' principles: 1A, 1C, 1D, 1E, 1F.
f) Policy context
g) Dredging for navigation is of economic and social importance to maintain access for water based transport (refer to policy 2.1.1). However, dredging can result in adverse impacts on coastal resources and their values, if the dredging process is not appropriately managed.
h) Dredging activities within coastal waters will be undertaken so as to:
i) (e) maintain:
j) (i) water quality (in accordance with policy 2.4.1);
k) (g) maintain coastal habitats (including their protection from potential adverse impacts from the disturbance of acid sulfate soils);
l) (h) not cause unacceptable risk to existing land uses from coastal hazards (in accordance with policy 2.2.4);
m) Disposal of dredge spoil should be located so as not to adversely affect 'areas of state significance (natural resources)' (refer to policy 2.8.1). If placed at sea, the ANZECC Interim Ocean Disposal Guidelines are to be followed.
n) For any dredging operations, consideration will be given to:
o) (a) whether the sediment contains toxicants (listed under the Australian Water Quality Guidelines for Fresh Water and Marine Waters);
p) (b) the level and nature of the toxicant; and
q) (c) whether disturbance of the contaminated sediment is likely to result in unacceptable impacts on coastal resources and their values.
Even in the EIS the proponent acknowledges impacts from dredging. The issue of impacts on acid sulfate soils is not settled to our satisfaction as needs further consideration as does disposal including specific data on access channels. See further detail on ASS and dredging below.
Storm Surge and Wave Heights
What is also not taken into account is the already occurring dissolution of coral in the Great Barrier Reef because of rising acidity concentrations in marine waters due to increasing carbon dioxide levels. If we lose the Reef we lose protection from the large ocean waves of the outer Reef.
Because of such climate change impacts any coastal infrastructure will be much more vulnerable to damage and loss from storms and cyclones than in the past. Storm surges will be much higher and more devastating, and are likely to exceed current design specifications for barriers to protect oceanfront built environments from severe damage. Galveston Texas and the Gulf coast region of the U.S. lacks coral reef protection from cyclone wave damage. The Galveston Texas seawall built after the 1900 hurricane was 5m. It protected much of Galveston in the Sept. 13 2008 hurricane but waves and flooding still exceeded that height. The Galveston seawall is built of poured concrete, and is much sturdier than rock walls. Rock walls at Mackay Harbour frequently suffer some damage in storms. It is the future frequency and intensity of large storm surge events that is unknown, and will not be predicted by current 1/100 year flood estimates based on less than one hundred years of flood records.
Table 1 shows JCU's Marine Modeling Unit's wave height simulations for Return Periods of 20, 50 and 100 years for the outer Reef.
Table 1 Significant Wave Heights on the Outer Great Barrier Reef
Return period (yrs) Wave Heights (m)
20 7-10
50 10-12
100 10-13
Source: mmu.jcu.edu.au/atlas/r08127shtml
If we lose the Reef we can expect wave and storm surge heights to significantly increase and should invoke the Precautionary Principle which underpins environmental and planning legislation in Queensland i.e. no future built infrastructure save that necessary for maritime activities should be located close to foreshores.
The latest findings from studies undertaken by CSIRO have resulted in major tightening of Policy throughout Australia in relation to Coastal Development and sea level heights. It has been recommended Local Governments review Development Codes and the effect of the CSIOR study and that a minimum 0.8 be added to existing heights. It is understood that Queensland Government has also introduced its own Policy however there has been insufficient time to explore this. Victoria has recently overturned previous and new Development Approvals that cannot demonstrate an ability to comply with this.
EIS needs to better address and demonstrate (including Peer Review) the proposed projects ability to deal with the latest known impacts.
The Accommodation Demand Study is flawed and should be removed for the following reasons.
In view of the continued ongoing cost to community in reviewing yet again another EIS for this project and the flaws highlighted below we believe it is essential for all data to be the subject of independent peer review.
A number of properties do not appear to have been taken into account when calculating supply eg. Summit, Searene, Mantra Reflections, Boardwalk, Oasis and others. In view of its proximity to the mainland Peppers Palm Bay is generally included in mainland accommodation figures. With the addition of these properties as well.
The figures stated do not take into account figures available from Tourism Queensland and Tourism Whitsunday for the year ended June 2008, these figures have been available since August and widely reported in the press. Included in these current figures are –
17% decline in domestic visitors (reported as being among the worst in the State)
19% decline in visitor nights
5% decline in international visitor nights
It would be impossible, given these two resounding effects on the Study, that any form of justification of demand could be demonstrated . The Minister for Tourism identified that the reduction in flight capacity by Jetstar (axing direct flights from Sydney) in July and Virgin (axing weekly flight from Sydney) in August can only result in a decline in visitors and hence the latest figures will reflect a further decline. The Study openly states it is based on assumptions in a number of areas and contains some outstanding errors – some of which are “This analysis, especially the demand section, has been prepared using a series of conservative assumptions”
“ it is assumed that construction will have only limited impact on visitation”
It states that the SHMDR competitors are Sunshine Gold Coast etc. etc.
The Whitsunday Destination Management Plan 2004 prepared by Tourism Queensland highlights –
§ “The chief competitive strengths of the Whitsundays in the domestic environment are identified as the pristine natural attractions of the reef and islands and the friendly accessible sailing/cruising waters.”
The Regional Plan also identified the key issue for the Whitsundays as
§ “managing sustainable tourism and monitoring the social, economic and ecological impacts of localised growth in the region.”
All tourism studies completed by Government evidence the niche market of the Whitsundays. It is identified widely that it is this niche that sets it apart from other regions and is the basis of its popularity. It is based on environmental features, village type atmosphere and differs vastly from the key features that make the Gold and Sunshine Coast what they are.
The SHMRD is a stand alone product openly stated as competing with Gold and Sunshine Coast. However as Shute Harbour could never have the key features that fit with the requirements of that visitor type proper evaluation needs to be included on its ability to compete successfully in that market.
The extrapolation of figures contained in the analysis is incorrect and not up to date and does not take into account the 2008 year in any way. Our survey of accommodation properties reveal an occupancy level at best for 2008 of 50% and less in the stand alone feature operating at around 37-45%. The figure of 82.4% is not indicative of the current or past occupancy level. Also our survey revealed the rack rates used in the study are just that and are not indicative of the true rate being achieved.
Consideration needs also to be given to the effect of a shift in market appeal and how that relates within the context of the Whitsunday Niche. Also there is no discussion on the effect of the distance from Airlie Beach nor the affect of air traffic from the enlarged Whitsunday Airport and its flight path on the appeal of SHMRD.
Marine Traffic Plan
SHRA reject the Plan. The Plan does not provide, as stated, a solution to separate commercial and recreational traffic. Prepared by the Proponent, it is biased in favour of the Marina, cannot work long term and does not take into account the current value of the Harbour in its natural state. The EIS also identifies the possibility of shortcomings in its ability to work and the future potential of specific users to be removed or the installation of channel markers on the southern entrance in the hope of increasing its appeal as an alternative to the northern channel. Further the EIS reveals that one particular User ie Barges have vehemently opposed any idea of their relocation. The EIS has openly identified the possible inability of the Plan to work with the addition of the Marina users and offers the resolution to this by removal of a current user and the forced unacceptable diversion of smaller craft.
Its approval cannot be seen as independent. The ability for the proponent to Appeal a negative decision on the Plan against the Harbour Master personally creates a climate of concern on whether a fair decision can be made and a perception of weighing judgment in favour of the project. We believe this removes any realistic measure of the ability for the Plan to work particularly in light of proponent's inclusion of remedies. In view of this and the tone of the EIS on measures that could be taken if it were found to be unworkable, ie relocation of users or installation of southern channel markers to enhance the (theoretic) appeal for smaller craft, independent Peer Review on this Plan is essential and should be required under any Supplementary EIS.
Moorings play a vital role in ensuring access to the Marine Park by smaller craft. Their availability in Shute Harbour (the only safe harbour on the mainland in the region for moored vessels) is vital and unique. Any removal or relocation is an impost on smaller craft owners to make way for the wealthier high end market and is unacceptable.
Most definitely the number of moorings to be removed portrayed throughout the EIS is not entirely indicative of the effect and is likely to be understated. To the reader the number to be removed or relocated may appear moderate – however there is no reference to the number of moorings that are actually operational at present in the harbour so that the number being removed or relocated can be viewed in this context. There is no discussion included or consideration given to the effect that relocation will have of the small craft currently using the moorings. The effect will be –
· exposed location
· lessened tenability
· increased travelling to and from mooring - not only in distance but additional trips occasioned due to lessened ability to carry loads in dinghies due to fetch
· the mooring type proposed does not have any/adequate cyclone rating suited to this region
The suggestion of replacing moorings with the type identified is not feasible. This leads us to the view there is no serious intention by the proponent to ensure this facility is maintained as they would simply not be replaced. It would also result in an inability for uses to achieve the existing level of insurance available. This not acceptable as it will severely impact access by the smaller craft to the Marine Park as this facility is not replicated elsewhere in the region. The high end user is already well catered for in already existing Marinas.
The assumption that the reason for lack of use of the southern entrance is due to the absence of channel markers is just that an assumption. It is well known in the boating community and backed up by our survey of small craft users on Shute Harbour that the preference is for the Northern Entrance for the following reasons:-
sea conditions as a result of the prevailing winds and”fetch”
lesser distance to exit harbour
lessened affect of wind against tide
lesser tidal effect
The only occasion that resulted in a preference to use the southern channel was when travel was to Long Island or to the Reefs surrounding White Rock and Tancred.
It is feared by the Association and the boating community through our study that should the project get up and the Marine Traffic Plan fail to achieve its goal (ie safe navigation within the Harbour for the mix of current/future users) then the only alternative to remedy will be to limit access to the Northern Channel. This would have the affect of removing the practicality of using the Harbour by smaller craft by forced usage of the southern channel and result in dramatically lessened access to the islands. The Association is aware that this was at one time being considered as a possible scenario to enable the mix of users resulting from the outcome of the proposed marina and hence it is clear our fears are valid. A Plan that will result in a mix of large craft in restricted waters with a predominate wind that increases the navigational issues will no doubt have ramifications in other areas. It is accepted that underwriters when evaluating risk take into account the operating area of the craft. The regular moderate/strong southeast conditions, the varied mix of users and the introduction of a large number of the size of vessel suited to the marina all in a restricted waterway will no doubt lead to an increase in marine incidents. This will have the undesirable effect on increasing Insurance premiums for vessels using/housed in Shute Harbour.
We have not had sufficient time to disseminate all data in the Stakeholder consultation. However a cursory view suggests insufficient weight has been given to the resounding voice of the local residents against the project nor the clear outcome of the Strategic Planning Process leave Shute Harbour alone. Most certainly two meetings with the SHRA are not included in the summaries and in view of the time frame allocated we have no alternative but to reject any findings in support of the marina.
The Alternatives
The alternative of not proceeding has not been given sufficient consideration in the document.
The arguments to proceed have not achieved accurate or resounding justification. We reject the claim that not to proceed will affect our quality of life. This section identifies quite correctly the regions growth and popularity are dependent on conservation of the natural landscape and environmental values.
Maintenance Dredging - Within the time frames provided to review it is not possible to determine the value of the material. In view of precent set on surrounding sites and the already known silting problems experienced at Shute Harbour just from Barge traffic the schedule of Maintenance Dredging is questionable. We would request this area be put to independent Peer Review. The ramifications of an understatement of spoil allocation areas and dredging requirements to communities, council and landowners are well recognised and there is a clear duty of care to avoid any similar situation for this proposed project.
Acid Sulphate Soils
Within the time frames provided a qualified review it is not possible to determine the value of the material. However we assume and require the EIS complies with the QASSIT standards. If management of ASS is reliant in the EIS on the natural buffering capacity of sediment to neutralise size fractioning of material must be undertaken. The Plan must be prepared in accordance with Appendix 4 of the Guideline that supports State Planning Policy 02/02 and any QASSIT Soil Management Guildline. The Plan must specify all potential impacts and identify performance criteria.
Should the area of disturbance alter or incorporate areas not previously investigated our outside the current scope of the plan sampling and analysis needs to be completed in accordance with the guideline.
The EIS refers to the rigorous assessment process. The figure contained in the EIS depicting the process is not accurate as it portrays the final decision being made following Council development approval. Under the SDPWO Act Council Development approval is not required for a decision to be made for the project to proceed. This figure should be removed or corrected to show the true effect of the relevant Legislation including bilateral arrangements between State and Federal Government.
As a controlled action under EPBC it must comply with World heritage criteria. The EIS does not establish it can do this. The claim in Appendix E of “creating a diversity of habitats” is not in line with the EPBC. The EPBC Act is clear on the value of World Heritage and the Great Barrier Reef. The benefit of removing natural habitat and replacing it with artificial does not seem to be covered.
The result of this replacement undoubtedly has an effect on existing ecological biodiversity.
The EIS needs to fully address this claim and the effect on biodiversity in the context of its performance under the EPBC Act and generally.
SHRA reserves the right to expand on comments, appeal or comment further on items contained in the EIS and Appendices. The time frame permitted for comment on such a complex document is unworkable and hence many items in need of review have not been be to be completed.
Appendix I
Vessel Registrations. Queensland Department of Transportation
Table 4(a). Queensland: 8.01-10.0 metre vessel registrations 1998 – 2008 Annual June data
Year Mackay, Whitsunday, Isaac & Bowen Region Queensland Interstate Unknown & Overseas Total
1998 218 2,752 41 1 2,794
1999 228 2,844 77 78% 0 2,921
2000 244 2,893 57 -26% 0 2,950
2001 235 2,990 62 9% 0 3,052
2002 273 3,151 42 -32% 0 3,193
2003 329 3,346 32 -24% 0 3,378
2004 318 3,577 41 28% 0 3,618
2005 318 3,906 34 -17% 0 3,940
2006 358 4,163 30 -12% 0 4,193

2007 364 4,312 43 43% 0 4,355
2008 366 4,492 43 0% 0 4,535
EXTRAPOLATION THROUGH 2020 OF NUMBERS OF 8.01-10.0M VESSELS IN THE WHITSUNDAY TO BROADSOUND REGION
8.01-10m vessels extrapolating from 1998 to 2020 (22yrs)
1998-2008: 366-218 = a difference of 148 vessels over 10 years.
2020-1998 = 22 or an av. of 2.2 over 10 years.
2.2 x 148 = 325.6 + (218 vessels in 1998, the starting point for calculations) = 543.6
Estimate of ~544 interstate vessels in the 8.01-10.0m class by 2020
INTERSTATE 8.01-10.0M VESSELS IN THE WHITSUNDAY TO BROADSOUND REGION by 2020
8.01-10m Interstate vessels extrapolating from 1998 to 2020 (22yrs)
1998-2008: 41-43 = a difference of 2 vessels over 10 years.
2020-1998 = 22 or an av. of 2.2 over 10 years.
2.2 x 2 = 4.4 + (41 vessels in 1998, the starting point for calculations) = ~45
Estimate of ~45 interstate vessels in the 8.01-10.0m class by 2020
ESTIMATE FOR 8.01-10.0M VESSELS IN QUEENSLAND BY 2020
8.01-10m vessels extrapolating from 1998 to 2020 (22yrs)
1998-2008: 4,492-2,752 = a difference of 1740 vessels over 10 years.
2020-1998 = 22 or an av. of 2.2 over 10 years.
2.2 x 1740 = 3828 + (2752 vessels in 1998, the starting point for calculations) = 6580
Estimate of 6580 vessels in the 8.01-10.0m class in Queensland by 2020
Table 4(b). Queensland: 10.01-15.0 metre vessel registrations 1998 – 2008 Annual June data
Year Mackay, Whitsunday, Isaac & Bowen Region Queensland Interstate Unknown & Overseas Total
1998 208 3,278 69 3 3,347
1999 216 3,409 159 130% 0 3,568
2000 259 3,524 127 -20% 0 3,651
2001 275 3,784 118 -9% 2 3,904
2002 356 4,164 87 -26% 1 4,252
2003 384 3,475 87 0% 1 3,562
2004 358 4,909 73 14% 2 4,982
2005 439 5,372 87 19% 0 5,459
2006 520 5,812 99 14% 0 5,911
2007 556 6,158 116 17% 0 6,274
2008 317 6,510 117 1% 0 6,627
EXTRAPOLATION THROUGH 2020 OF NUMBERS OF 10.01-15.0M VESSELS IN THE WHITSUNDAY TO BROADSOUND REGION
10.01-15.0m vessels extrapolating from 1998 to 2020 (22yrs)
1998-2008: 317-208 = a difference of 109 vessels over 10 years.
2020-1998 = 22 or an av. of 2.2 over 10 years.
2.2 x 109 = 239.8 + (208 vessels in 1998, the starting point for calculations) = 479.8
So estimated ~480 interstate vessels in the 8.01-10.0m class by 2020
INTERSTATE VESSELS IN QUEENSLAND: 10.01-15.0m BY 2020
10.01-15.0m Interstate vessels extrapolating from 1998 to 2020 (22yrs)
1998-2008: 117-69 = a difference of 48 vessels over 10 years.
2020-1998 = 22 or an av, of 2.2 over 10 yrs.
48 x 2.2 = 105.6 + (69 vessels in 1998, the starting point for calculations) = ~175
So ~175 interstate vessels in the 10.01-15.0m class by 2020
QUEENSLAND VESSELS: 10.01-15.0m BY 2020
10.01-15.0m Interstate vessels extrapolating from 1998 to 2020 (22yrs)
1998-2008: 6510-3278 = a difference of 3232 vessels over 10 years.
2020-1998 = 22 or an average of 2.2 over 10 yrs.
3232 x 2.2 = 7110.4 + (3278 vessels in 1998, the starting point for calculations) = 10,388
So ~10,388 vessels in the 10.01-15.0m class in Queensland by 2020
Table 4(c). Queensland: 15.01-20.00 metre vessel registrations 1998 – 2008 Annual June data
Year Mackay, Whitsunday, Isaac & Bowen Region Queensland Interstate Unknown & Overseas Total
1998 14 219 8 0 227
1999 14 265 18 125% 9 279
2000 24 265 19 1% 11 284
2001 29 266 15 -21% 3 315
2002 46 384 11 - 27% 0 430
2003 42 390 4 -64% 0 432
2004 48 442 12 200% 0 490
2005 44 557 9 -25% 0 566
2006 59 639 18 100% 0 657
2007 69 731 22 22% 0 753
2008 83 811 36 64% 0 847
EXTRAPOLATION THROUGH 2020 OF NUMBERS OF 15.01-20.0M VESSELS IN THE WHITSUNDAY TO BROADSOUND REGION
15.01-20.0m vessels extrapolating from 1998 to 2020 (22yrs)
1998-2008: 83-14 = a difference of 69 vessels over 10 years.
2020-1998 = 22 or an av. of 2.2 over 10 years.
2.2 x 69 = 151.8 + (14 vessels in 1998, the starting point for calculations) = 165.8
So estimated ~169 interstate vessels in the 15.01-20.0m class by 2020
INTERSTATE 15.01-20M VESSELS IN QUEENSLAND BY 2020
1998-2008: 36-8 vessels = an increase of 28 vessels over 10 yrs.
2020 –1998 = 22 or an av. of 2.2 over 10 yrs.
28 x 2.2 = 61.6 + (8 vessels in 1998 the starting point for calculations) = 70
ESTIMATE: 70 interstate vessels in the 15.01 – 20m class by 2020
QUEENSLAND VESSELS: 15.01-20.0m BY 2020
15.01-20.0m Interstate vessels extrapolating from 1998 to 2020 (22yrs)
1998-2008: 811-219 = a difference of 592 vessels over 10 years.
2020-1998 = 22 or an average of 2.2 over 10 yrs.
592 x 2.2 = 1302.4 + (219 vessels in 1998, the starting point for calculations) = 1,521
ESTIMATE: 1,521 vessels in the 15.01-20.0m class in Queensland by 2020