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Friday, December 10, 2010

MDBA Submission

Submission in respect of the Guide to the proposed
(Murray-Darling) Basin Plan By Ian Mott

The original submission can be seen at

Comprising evidence and issues that are capable of establishing that the process outlined in the document described as the Guide to the proposed Basin Plan is;

A. A grossly improper exercise of power within the meaning of Sections 5 & 6 of the Administrative Decisions (Judicial Review) Act, 1977 and,

B. A planning process that is in serious breach of both the letter and the spirit of the Intergovernmental Agreement on the Environment, 1992." and,

C. Conduct that is in grossly negligent abrogation of Professional Duty of Care to take all reasonable and practical steps to prevent entirely foreseeable and avoidable harm to all persons with an equitable interest in the proper management of all waters of the Murray-Darling Basin.


The Murray-Darling Basin Authority (MDBA) has misinterpreted the objects of the Water Act, 2007 in a way that assumes that only the fresh water resources of the basin are available for achieving the purposes of that Act. The interaction of fresh and tidal waters of the Coorong and Murray mouth is the critical element in ecosystem health and end of system dynamics. Yet, the character, frequency and volumes of these tidal flows have not been included in the inventory of Basin water resources and no meaningful attempt has been made to consider the enhanced management and augmentation of this resource for achieving the objects of the Water Act, 2007.

This appears to have its roots in one of the most appalling intellectual cop-outs ever incorporated into a policy process, the second conclusion of Walker [1](2002) who said;
“The build-up inside the mouth is believed due to a combination of inadequate river flows and near shore coastal processes related to wave and tide climate. Engineers and managers have no control over the latter”.

The second sentence is a gross, and inexcusable, misstatement of fact, by omission of the incredible range of works carried out all over the world, and over more than 3000 years of history, to mitigate and manage the impacts of wave, tide and storm events.

Executive Summary:

A. The major determinants of the condition of the Murray River mouth are the asymmetric tidal patterns and storm induced wave heights that produce a build up of beach sediments in a standard “flood tide delta” inside the mouth.

B. Half of all daily tide patterns (week about) involve approximately 8 hours of rapid inflow that deposits sand, followed by 16 hours of slow outflow that doesn’t remove it.

C. The shear stress of a flow (its capacity to move sediment) increases at approximately the square of the flow speed. So an inflow that is twice as fast as the outflow will transport four times more sand than the outflow will remove.

D. Half of all river flows take place at times of each lunar cycle when the tidal variation is minimal and the capacity to remove sediment is severely retarded. So half of the 3 million ML of buy-back water will not do the job intended for it. Nor will half the 5 million ML of existing flows.

E. An increase in total river flows that removes sand will simply increase the capacity of tides and storms to put it back again.

F. The function required of increased outflows is purely hydrological. It can be done equally well by additional sea water that has not already come through the mouth. Sea water is in essentially unlimited supply and comes at zero cost.

G. Storm events compound the deposition problem by increased turbulence (transportability) and increasing inflow volume and velocity. Of the annual average 77 storm events, only 38 coincide with large tidal variances and only 14 of those have their storm surges coinciding with rapid tidal intakes. The latter can deposit up to 46,000m3 of sand in a single event and cause most of the deposition problem.

H. These events can only be countered by timely and fully proportionate outflows that negate the deposition multipliers. A continuous modest flow after or between these events cannot redress the original deposition problem.

I. Large dimension, unidirectional pipes under the dunes, with intakes below the wave zone and above sea bed sand, can passively deliver the volumes of clean sea water needed to ;
a. First, retard deposition through reduce volumes and velocities of river mouth inflows as a larger portion of the tidal prism is supplied via the pipes, and
b. Then produce the increased volume and velocity of outflows by blocking the reverse flows back out the pipes so the outflow is diverted to the Murray mouth where its greater volume and velocity will increase sand removal to equilibrium levels.

J. Two pipes at the far end of the Coorong, and one north of The Narrows, could produce a complete cyclical discharge of the hypersaline volume of both lagoons out through the Murray mouth, and its replacement with cool, oxygenated sea water.

K. Less than 13 pipes either side of the Murray mouth could negate the deposition of all major storm events and do a better job, much cheaper, than all current river flows and additional buy-back water combined. Dredging will reduce the number of pipes required.
2.44 Pipes under the dunes, on the other hand, have major advantages over open channels for delivery of additional sea water to barrier estuarine systems;

- They can deliver precise and standardised volumes of sea water over a much shorter distance in a fraction of the time taken by passive tidal systems,
- They can be replicated to deliver sea water to any desirable location along a barrier system,
- They can provide variable delivery of sea water to optimise flows in the system,
- They can be completely covered once in place to restore visual values,
- Their oceanic intake can be placed lower than the wave zone to reduce risk of storm damage,
- The oceanic intake can project a sufficient distance out of the sand body to ensure that it free of sand in suspension and hence, sand will not be transported through the pipes in any sea condition or intake velocity.
- The pipe will not form a groyne-like barrier to lateral movement of sand along the beach and no (internal) flood tide deltas will form at the other end that would otherwise continually restrict the pipes function.

2.45 Such a system would operate passively, responding immediately to various levels of tidal flux without management input and in direct proportion to the height of any storm surge. But the presence of a simple valve system would also enable complete or partial shutdown if or when required.

2.46 The system could function at a number of levels;
- As a simple source of fresher water to overcome seasonal hyper salinity and replace evaporation losses in the closed end system.
- As a general augmentation of existing volumes into the far reaches of the Coorong to produce an increase over normal water levels and create a net outflow which will discharge excessive and unsustainable saline build-up out through the river mouth.
- As a tool for accurate, timely and proportionate adjusting of flows in and out of the mouth so normal rates of sand deposition can be reduced and countered by increased rates of sand discharge.
- As a tool for timely and proportionate responses to reduce the extent of major storm surge sand deposition events as and when they occur.

2.47 The Coorong is now a closed end system. Variations in water levels at the front of it have minimal impact at the far end. In the absence of pre-settlement flows along its length from the South East Drainage System, no amount of fresh water flows adjacent to the northern end can deliver adequate ecosystem services.
2.48 The North Lagoon is 48km long. Its average width at AHD is 1.5km, depth is 1.2m, surface area is 7,200ha and volume is 86,400 ML (CFMI[10], 1992). Mean annual pan evaporation is 16 ML/ha so the actual (80%) is more like 12.8 ML/ha. Mean annual rainfall is 5 ML/ha giving a net evaporative loss of 7.8 ML/ha. It requires an average 56,160 ML each year (65% of volume) to replace net evaporation losses.

2.49 Even if all this volume came from fresh water delivered over the Tauwitcherie Barrage in the upper left corner it would only serve to temporarily dilute saline levels rather than reduce existing salt loads. The current, totally inadequate, policy of reliance on tidal “sloshing” of fresh water to maintain water quality requires a much greater volume of fresh water that is delivered in a poorly targeted manner by an extremely inefficient method.

2.50 Year round direct injection of tidal water to the southern end of the North Lagoon, in volumes capable of keeping pace with mid summer evaporation rates, by pipes will fully restore and maintain all ecological values and ecosystem services through a complete replacement of water volume.

2.51 Summer evaporation is 0.056 ML/ha/day with a gross loss of 403 ML/day. In the absence of storm surges only half the days of each cycle will have tidal variation capable of producing useful inflows so the daily pipe flow must be in the order of 806 ML/Day, over an 8-9 hour high tide interval.

2.52 The passive flow rate will vary as the tide height outside the dunes rises and falls in relation to the mean sea level inside the dunes. An average cycle of the type shows at left of the graph at 2.13 above would have two hours (first and last) of a 10cm drop, 2 hours each of a 20cm, 30cm and 40cm drop, and a peak hour of 50cm drop that defines the rate of inflow.

2.53 Over a single1000m pipe of 3.6m diameter this would produce passive flow of;
2 hours @ 7.83m3/sec for 56 ML
2 hours @ 11.39m3/sec for 82 ML
2 hours @ 14.18m3/sec for 102 ML
2 hours @ 16.56m3/sec for 119 ML
1 hours @ 18.68m3/sec for 67 ML
For a total discharge of 426 Megalitres a day.

2.54 A 20cm storm surge on such a day is likely to add another 295 ML to the peak flow and 168 ML to the lower flows, taking the daily discharge to 890 ML.

What else do we need to know?

4.01 The average duration of storm surges, (i.e., the time taken for frontal systems to pass) and their range of variation, needs additional study, as does their mean height and their range of variation in height. Without this information the more accurate determination of the likely range of passive flow pipe yields cannot be made.

4.02 For the proper management of Murray mouth sand deposition we need to know the proportion, number, and range of scale variations, of storm surges that coincide with the periods of peak tidal variation. Storm surges that coincide with ebb and neap tides are likely to produce much less deposition because their rising inflows counteract the tidal outflows. Storm events where maximum surge takes place during maximum tidal inflow will present the highest volume and velocity inflows and produce the highest volumes of sand deposition.

4.03 We then need to know the extent to which these major deposition events must be negated and the extent to which their deposition volumes can be carried forward for remedial action by subsequent normal tidal outflows and benign phase storm surge outflows. This information will be essential for the ultimate design specification.

4.04 We need to know the proportion of total inflows that will need to come via conduits other than the Murray mouth to ensure equal deposition and removal on each tidal cycle. That is, when the combined outflows through the mouth can remove the deposition that took place on the previous inflow. At Alternative 5.50 below, we have assumed this to be 50% but the actual is likely to be much less because a unidirectional diversion system reduces deposition by diverting mouth inflows to the alternative conduit and increases sand removals by increasing the total volume of mouth outflows via improved efficiency of the tidal prism.

4.05 We need to know the optimum size, volume, cost relationships in both pipe construction and installation. This analysis has used 3.6m diameter pipes as a standard but we need to know, for example, if smaller ones provide substantially lower cost advantages that outweigh the resulting reduced flow volumes. It may also be possible that larger pipes produce flow gains that outweigh their increased cost and installation difficulties.

4.06 Optimum pipe size will also be influenced by installation issues on the seaward side with questions over a single large prefabricated sub-surface interface or an on-site construction with coffer dams etc.

4.07 The trade-offs between large capacity passive flow systems that only function for part of the time, and smaller capacity pump based systems that can function all of the time would also merit detailed consideration.

4.08 The full evaluation of alternatives for keeping the Murray mouth open, carried out by the Sand Pumping Technical Committee in 2002 must be made public to properly inform the policy process. Some of these options, while appearing to be more costly than dredging appeared to be in 2002, may prove to be valuable contributors in a combined approach. For example;
“The Southern Alexandrina Business Association[19] has sent (9/04/09) a proposal to SA Water Security Minister Karlene Maywald for a break-water for the neighbouring Coorong. Association president John Clark says the cost would be roughly the same as dredging but would have longer-term benefits for the internationally-recognised Coorong wetlands”.
If the local Business Association’s costing is anywhere near the reality then a mix of pipes, dredging and breakwaters is likely to be even more effective than each option in isolation. And the cost is certain to be substantially less than the MDBA’s perverse fresh water fetish.

5.00 Alternatives:

5.10 The Buyback of 3 million ML of irrigation water to maintain a higher continuous outflow. This option has a total cost in the order of $6 billion, with annual costs of $600 million. It uses high value, and highly variable supplies of fresh water to do a simple hydrological function. It wastes more than half the total volume supplied because it is delivered at a time when there is next to zero assistance in sand removal from tidal outflows.

5.11 It is incapable of responding in the time and scale needed to deal with the key storm surge deposition events. It is a continuous, static solution to a set of dispersed, variable impacts. And it will not alter the fact that the capacity of the tides to fill-in the Murray mouth is in direct proportion to the degree to which the river flows might open it.

5.12 In economic terms it is an even bigger waste. It takes water that is currently put to profitable use in an important national value chain. It involves water that must be purchased at considerable cost to the Commonwealth and it involves a significant ongoing reduction in the tax base and a serious undermining of the cost base for major storage infrastructure like Dams etc.

5.13 It will achieve little additional benefit to what has been delivered by a single dredge for the past three (worst case) years at an annual cost of $2.33 million.

5.14 And none of the wealth transfers involved appear to be incorporated into the Commonwealth Grants Commission processes, the body responsible for the fair and equitable distribution of Commonwealth funds between the states.

5.15 And it will not go anywhere near to restoring the ecological values of the lower Coorong, the very wetland used to justify the use of this water.

5.20 Removal of the Barrages to restore the tidal prism. This option has been promoted as the obvious solution to the major evaporative losses that take place within the lower lakes in severe drought.

5.21 But in a context of a current 5 million ML mean annual discharge of fresh water out the Murray mouth, and the prospect of an additional 3 million ML from buy-backs for the same end, the increase from a pre-settlement 400,000 ML fresh water evaporation to a current 500,000 ML net figure, makes this very much a second order issue.

5.22 The contribution of partial openings during drought to maintain internal water levels etc is certainly an option that needs proper consideration.

5.23 However, the permanent opening of the Barrages will actually exacerbate problems of excess deposition in the mouth by increasing the volume and velocity of the tidal inflows.

5.30 The construction of open channels through the dunes to introduce more sea water into the Coorong Lagoons. This option would be comparatively cheap to implement but would be quite short lived. If the Murray mouth, with its additional discharges of fresh water, cannot combat the internal sand build-up from tidal inflows and storm surges then additional man made channels will be closed by the same forces in even less time. Open channels must function in the same littoral zone as the Murray mouth and the resulting exposure to the forces at play in that zone would require continual maintenance expenditure and render the option unviable.

5.31 The closure of open channels would take place even faster if gates were fitted to allow for unidirectional flows.

5.40 The installation of large diameter, in-flowing pipes under the dune system to the Coorong, one supplying the North Lagoon and two supplying the South Lagoon, each delivering approximately 100,000 ML of sea water each year, sufficient to produce a net flow along the full length of the system and ultimate discharge through the Murray mouth.

5.41 The two, located near Fig Tree Crossing, would be capable of replacing all annual evaporation losses and, within a single year, push the entire hypersaline volume into the North Lagoon. The third pipe, just north of the Narrows, could then push the remaining volume out through the Murray mouth.

5.42 It is the first step in restoring the essential ecological values, especially normal salinity levels, to the system. The reliance on “tidal sloshing” has proven to be a consistent failure, especially for the South Lagoon. The delivery of fresh water from the Murray to the most useful parts of this system cannot be achieved without considerable additional capital outlays. And the volumes required cannot be sourced from the Upper South East Drainage Scheme.

5.43 This option substitutes a comparatively small amount of cheap, well targeted, sea water for a very large and indeterminate volume of expensive, poorly targeted fresh water that does not even perform the function assigned to it.

5.44 With this direct injection of tidal water into the Coorong system the full suite of environmental values and ecosystem services can be maintained with a substantially higher level of certainty. And the system can be maintained in a circumstance that remains connected too, but is no longer dependent on, the vagaries of Murray mouth hydrodynamics.

5.45 If the overriding aim of the MDB Guide’s requirement for 3 million ML of expensive buy-back water is to keep the Murray mouth sufficiently open so tidal sloshing might keep the Coorong ecosystem just above the point of ecological collapse then the need for this entire mouth open objective can be negated by just 300,000 ML of cheap sea water delivered directly to its point of maximum benefit.

5.46 The capital buy-back value of fresh water is $2000 per megalitre so the opportunity cost of a pipe that delivers 100,000 ML of sea water to do a better job is $200 million. Any capital outlay less than $600 million on these three pipes represents good value. Given that the concrete in a 1000m pipe of 3.6m diameter and 20cm thick only amounts to 2,400m3, and costs only $720,000 at retail prices, one must conclude that it would take some seriously monumental departmental bungling to push the installed cost above $100 million a pipe.

5.47 This option serves the first two functions outlined at 2.46 above, that is;
- As a simple source of fresher water to overcome seasonal hyper salinity and replace evaporation losses in the closed end system.
- As a general augmentation of existing volumes into the far reaches of the Coorong to produce an increase over normal water levels and create a net outflow which will discharge excessive and unsustainable saline build-up out through the river mouth.
5.50 The provision of additional pipes under the dunes either side of the Murray mouth to improve the management of normal flows and to respond in time and scale to retard the impact of storm surge deposition events.

5.51 These would need to be in sufficient number to deliver half the total tidal prism that would result from the onset of a 0.5m storm surge during the nine hour inflow phase of a 1.1m peak tide or 16 ML/ha. The total inflow would be 13,000 ML so the capacity of the pipes must be 6,500 ML over the same period to ensure that the volume flowing out the river mouth is double the volume flowing in the mouth.

5.52 Unlike pipes flowing into the Coorong where the outlet water level remains near AHD, pipes near the mouth would start inflows from the moment the low tide turned, and would continue to the tidal peak. The water velocity and discharge rates would be defined by the slope obtained from the water levels on either side of the dunes. And in the absence of more detailed analysis we should assume this to be a drop of 0.1m over 700m of pipe.

5.53 This would discharge 9.5m3/sec, or 34.2 Ml/hour, or 308 ML over a nine hour tidal inflow. The 6,500 ML capacity in that circumstance would require 21 pipes. This would mean one pipe for each 39ha of tidal area so the Goolwa channel would need 8 while the Tauwitcherie channel would need 13 pipes.

5.54 This would reduce the storm surge flow through the mouth to the same volume as a modest 0.8m tidal flow under natural conditions. A normal peak tide of 1.1m range would produce the even more modest 0.55m tidal inflow through the mouth with the full 1.1m outflow.

5.55 This across the board halving of river mouth inflow volume and velocity would produce a much more than proportionate decrease in sand deposition. The increase in river mouth outflow volumes and velocity through improved efficiency of the tidal prism would also produce an increase in sand disposal. And this gives us strong grounds for suspecting that this number of pipes may be significant over-kill.

5.60 Maintain dredging in a post flood open Murray Mouth. Once the mouth is open, it is an incontestable fact of history that a single dredge was able to maintain that open mouth during a period of zero fresh water discharges at a cost of only $2.33 million a year. The current capacity to move a minimum of 2000 m3 of sand in a 24 hour day along a pipeline up to 2km in length, is an asset that could be used elsewhere in the estuary to enhance the tidal prism. The sand bank just outside the Eastern end of the Tauwitcherie Barrage is a good first candidate and modification of The Narrows would also be justified. A system of pipes and breakwaters may produce additional need for dredging too.

5.61 It is obviously more economical to prevent a channel from degrading than it is to open a channel that has already closed. The current flood discharges have already opened the channels much wider than the dredge ever could but in subsequent years this maximum opening must contract. In a $10 Billion budget with $1 billion annual outlays, this $2.33 million punches well above its weight.
6.00 Conclusions

6.01 The option that least serves the purposes of the Water Act 2007 is option 5.20 Removal of the Barrages. The restoration of the original tidal prism may provide a temporary improvement in tidal sloshing into the North Lagoon but this would be a very short lived improvement as the asymmetric tidal patterns will increase deposition at the Murray mouth and substantially retard the efficiency of that enlarged tidal prism. Any benefits to be gained by introducing sea water into the Lower Lakes during drought can be achieved by simply opening the Barrages. Their removal is not necessary.

6.02 Option 5.30 Construction of open channels to the Coorong does not serve the purposes of the Water Act 2007 any better. The benefits of direct injection of sea water into the hypersaline ecosystem would be very short lived as the same processes at play at the Murray mouth would close any open channels even faster. This option would require continual maintenance at great expense.

6.03 Option 5.10 the buy-back of 3 million megalitres to increase regular flows is a static, continuous response to a variable, intermittent need. It also demands the scarcest and most valuable water to do a simple hydrological task that can be done better by cheap, abundant and reliable sea water. The scientific community has made no secret of their view that the volume is totally inadequate for the requirement. But the need to balance ecological, social and economic values for the up-stream communities will ensure that the required amount will not be forthcoming.

6.04 Option 5.60, Dredging, has already demonstrated its capacity to maintain an open Murray Mouth, at very low relative cost, and in worst case river flow circumstances. It has clearly earned the right to be included in any mix of solutions and is entirely compatible with other options as an outcome multiplier.

6.05 Option 5.40, Pipes under the dunes to the two Coorong lagoons, deals directly with the need to restore and maintain ecosystem services by delivering sufficient volume of fresh, fully oxygenated sea water to the exact locations that will meet the obligations under the Water Act 2007. It does so in a way that is in direct proportion to the need and it considers the highly relevant matters of timing, flow direction, adequacy and efficacy of water volumes delivered. It maintains the ecological integrity of the whole system but with a fully flexible stand alone management system. It operates in an incremental framework that deals with the most pressing ecological problem, South Lagoon hypersalinity, first and can then play its part in the broader issue of maintaining the Murray mouth.

6.060 Option 5.50, Pipes under the dunes to manage the Murray mouth, becomes a lesser priority once the ecological integrity of the Coorong has been restored by Options 5.40 and 5.60. The health of the Coorong need no longer be dependent on the state of the Murray mouth.

6.061 However, any pipes near the mouth will be better than no pipes because every pipe will enhance the contribution already made by river flows. The economics of trenching and subsequent dune restoration dictate that three or four pipes should be installed in each excavation. And the need for balanced hydrology in both channels would demand a minimum of eight pipes with four on each channel. The reality is that sea water is a superior, more abundant, lower cost, less disruptive and more proportionate substitute for all fresh water discharges through the Murray mouth. And there is no excuse for not doing so.

6.062 If the Australian community has already accepted a budget in excess of $6 billion for the buy-back then the mandate is already in place to spend up to the same amount on pipes to do a much better job.

6.063 When that $6 billion opportunity cost of the 3 million megalitre buy-back is spread over the estimated 16 pipes needed to completely restore the Coorong and keep the Murray mouth wide open we get an extraordinary $375 million for each pipe. The $200 million/pipe figure used in 5.46 above does not factor in the improved water use efficiency delivered by proportionate sea water over disproportionate fresh water.

6.064 And given the savings to be gained from placing 3 or 4 pipes side by side in the one excavation we can safely conclude that the cheapest and best option is undoubtedly the pipes.

6.065 In fact, with the Barrages in place for more than 70 years now, the demarcation of sea and fresh water ecosystems is well established. And this means that further substitution of sea water for existing flows is also feasible as a source of additional fresh water for up-stream wetlands. With adequate sea water systems in place there is no longer any justification, either logical or ecological, for a single drop of fresh water to go over the Barrages. All of existing fresh water outflows (up to 5 million ML) could be used for delivery of up-stream ecological services at zero cost to the economic, social and ecological values of the Basin.

6.066 I advise accordingly, and request that the MDBA considers all relevant matters outlined in this submission, and takes all reasonable and practical steps, to ensure that it does not;
- give effect to any improper exercise of power, or
- apply measures that are not cost effective, or
- apply disproportionate measures, that may
- cause entirely foreseeable, and avoidable detriment to people or communities in the Murray-Darling Basin.

Copyright: Ian Mott, 8th December 2010.
38 Jellicoe Street Manly West QLD 4179
Ph. (07) 3893 0612

[1] Walker, DJ. (2002) ‘The Behaviour and Future of the River Murray Mouth’ pp 14

[2] Harvey, N. (1996) ‘The significance of coastal processes for management of the River Murray Estuary’, Australian Geographical Studies, vol.34, no. 1, pp 45-57.

[3] Walker, DJ. (1990) ‘The role of river flows in the behaviour of the Murray Mouth’. South Australian Geographical Journal, vol. 90, pp. 50-65.

[4] Webster, IT. (2005) An Overview of the Hydrodynamics of the Coorong and Murray Mouth. Technical Report #/2005. CSIRO Water for a Healthy Country National Research Flagship. pp 4

[5] WBM Oceanics (2003), Murray River Mouth – Morphological Model Development Stage 2 – Model Set Up, Calibration and Verification, Report prepared for Murray-Darling Basin Commission & SA Dept. for Water, Land & Biodiversity Conservation.

[6] Chappell, J. (1991) Murray Mouth Littoral Drift Study, Report prepared for the Engineering and Water Supply Department, South Australia.

[7] Walker, DJ. (2002) op. cit. Fig. 4.3 pp 7

[8] Webster, IT. (2005) op. cit. pp 7


[10] CFMI (1992) Mathematical Modelling of the Hydrodynamics and Salinity in the Coorong Lagoons, Report CNG-1-12-12/92 prepared for the Engineering and Water Supply Department, South Australia.

[11] CFMI (1992) ibid.

[12] Chappell, J. (1991) op. cit.

[13] Webster, IT. (2005) op. cit. pp 16-17

[14] Dredging reduced at Murray Mouth, Earth Mover Magazine, (11/2020)

[15] Campbell, T. Brown, R. Erdmann, B. (2008) Murray Mouth Sand Pumping: Keeping the Tided Flowing. Report by the Contract Manager, SA Water Corporation. pp 1

[16] Campbell, T. Brown, R. Erdmann, B. (2008) op. cit. pp 6

[17] Campbell, T. Brown, R. Erdmann, B. (2008) ibid. pp 6-7

[18] Campbell, T. Brown, R. Erdmann, B. (2008) ibid. pp 12

[19] The Southern Alexandrina Business Association. (2009) Submission to SA Water Security Minister on construction of Breakwaters.

Wednesday, June 23, 2010

Who killed free market oil salvage?

How to turn an industrial mishap into an ecological disaster. Just add bureaucrats.

We have all seen the unfolding disaster of the BP Deepwater Horizon oil spill as it spreads to the southern coast of the USA. The bill for damage appears likely to reach US$20 to $40 billion but a close look at the actual base numbers at play here makes it very clear that it is the collective failure of the American intellect that has turned an industrial mishap into an ecological and financial catastrophe that could punch a serious hole in the retirement savings of many Britons.

We are provided with potent images of a virulent discharge of oil and continually reminded of the estimated 30,000 - 60,000 barrels a day that is lost. See Like a car on an ice bound motorway, everyone from the media, the US EPA, to the politicians, all slide towards an apparently unavoidable collision with an ecological disaster with minimal avoidance effort. They are so transfixed by the assumed end result that even the most elementary mitigation options are left undone. And foremost amongst the institutional "stunned mullet" are the respective state and federal environmental protection authorities, the very same organisations that have held themselves out to the budget process as the agencies of first response.

The fatal flaw of these organisations is that their singular overriding perspective is pessimistic. Their sole focus is on the identification of environmental problems and the implementation of regulations to minimise any associated harm. Their collective myopia is so severe that they are incapable of even recognising an economic opportunity, let alone using open, functioning, minimally regulated markets to first solve the problem and eliminate harm.

Someone forgot to tell them that

"Where there's muck there's money".

But in fact, someone did. It has recently come to light that, back on the 4th of May, two Dutch companies had approached the authorities for approval to enter US waters with equipment capable of capturing a large portion of the oil as it first escaped to the surface next to the sunken platform. But no such approval was given. It seems authorities were concerned that the method left small droplets of oil when the cleaned water was returned to the sea. See and

and [courtesy Bill Pounder]

But lets take a close look at what we are actually dealing with here. A vast reservoir of crude oil worth billions of dollars, 65% owned BP, is leaking into the ocean. Each of these 30,000 barrels of oil is worth US$76.50 each so some $2,295,000 worth of valuable salvage is made available every day. Each barrel equates to a volume of 159 litres so there are 6.29 barrels in each cubic metre of oil. And the daily discharge amounts to 4,770 M3. Each cubic metre has a value of $480 and as there is 5 standard 200 litre, 44 Imp gallon or 55 US gallon, drums in each M3, then each drum full is worth $96.00 on the world crude market.

According to the RNW link above, the US authorities favoured a chemical treatment that broke down the oil, thereby extinguishing its salvage value. But Dutch research had already concluded that this method caused more harm to wetlands than the oil itself.

In contrast, each 200 litre drum of oil is of equal value to half a days pre-tax pay for an American worker earning $24/hour. Tens of millions of Americans earn much less than this, especially the 10% of the workforce who are out of work altogether. There appears to be no valid reason why an average American could not collect two drums of oil in a normal working day. But the logistics of the exercise may complicate the equation somewhat. Add an open boat, fuel and storage capacity and the break even capacity gets greater, as does the minimum effective number of workers in each team. A 3 person team with boat etc would see the minimum daily collection target go out to about ten drums, or 2m3/day worth $960, from each team. And this, aside from the obvious ecological cost minimisation imperatives, means a bigger boat to cover a wider area and renders the economics of small patch oil collection marginal. This is the volume of oil one might find in a 400m2 patch of oil that is 5 mm thick. It would require at least 300 metres of floating barrier and a pump capable of processing the 40 tonnes of water in the top 10cm.

But this only applies to American wage rates. Lets not forget that this oil spill is in the Gulf of Mexico, and there are 109 million Mexicans who are closer to this problem than most Americans. The Mexican GDP per capita is $13,600 but this obscures the fact that 60% of the population share just 26% of the GDP. And that makes 65 million people with an average share of $6,000 a year each. That works out at $116/week, or just under $24/day or $3.00 an hour. At this rate, a crew of three on a small local craft might start to lose interest in the exercise if it took them a whole day to collect a single 200 litre drum of oil worth $96.00. This is the volume one would find in a 40m2 (5m x 8m) patch of oil that is 5 mm thick.

Most could collect a whole lot more using nothing but frying pans, especially if larger storages were maintained close to the collection area. Indeed, even if there were no larger industrial scale collection efforts in operation, the entire daily discharge volume could be collected by the number of Mexicans who try to cross the US border each week.

The leaking well is just 800km, or two days by slow boat, from the coast of Yucatan where the most disadvantaged Mexicans live. And the further the oil drifts eastward to the Alabama and Florida coasts the more dispersed and fragmented the oil patches become and the more imperative the use of free market, non-american labour, becomes. The exclusive use of American labour may have some traction when dividing the benefits of production but it has no traction, nor even logic, in minimising serious ecological harm.

The worlds poor, and the not so poor, have willingly scavenged for items of value from maritime disasters for millenia. Everything from shipwrecked cargo to drifting planks and sailcloth has been removed from the environment and returned to human use, both personal and through resale. Even beached whales were seen by early humans as a plentiful bounty, and a time of opportunity, for hundreds of millenia. But for some extraordinary reason we now have a collective intellect that is capable of compartmentalising our problems in a way that leaves us wringing our hands, transfixed by an approaching disaster when a normally functioning market place would instantly recognise an opportunity and proceed to exploit it to the point where the problem disappears altogether.

For some reason, apparently beyond the comprehension of reasonable men, this oil is deemed to be still in the possession of BP when it is clearly abandoned salvage on the high seas. Yes, BP has a legal obligation to clean up the mess but why is it being deemed to remain the exclusive property of BP?

If it were not so serious it would be high comedy. The US Coast Guard and the relevant Environmental Protection Agencies have diligently applied exclusion laws, that were designed to protect fish stocks, to an abnormal outbreak of oil stocks. With scant regard for the actual ecological outcomes, they carefully 'protected' their newly discovered mobile oil patches from rapacious foreign scavengers. Well done, fellas, (wave that flag, cue photo op).

BP has every right to argue that the bulk of the responsibility, and liability, for the harm that has befallen the southern coast of the USA rests squarely on the inactions of their own agencies. The means to collect the largest oil patches when it first came to the surface was available to them, at minimal net cost after sale of salvage proceeds, courtesy of the Dutch. But this offer was declined or not responded to in a timely manner.

The means to collect medium sized patches, again at minimal net cost after sale of salvage proceeds, by their own local fishing fleet, was also declined or not acted upon in a timely manner. And the means to collect even the smallest, dispersed oil patches was also available to them, at minimal net cost after sale of salvage proceeds, courtesy of the thousands of low income Mexican fishermen who lived within three days slow transit of the discharge zone.

This proper functioning of a salvage market would have been quite capable of capturing the overwhelming majority of the discharge for as long as it takes to relieve the pressure on the discharge site with additional drill holes. And BP itself would have been the logical buyer for all that salvaged oil which it could then on-sell to its existing customers at little more than the cost of consolidating volumes. Instead, one of the best run companies on the planet now has a huge financial exposure thanks to the collective intellectual lard of the US environmental protection industry who simply cannot understand that there is always a place for free market ecology to turn entrenched notions on their head and convert imaginary problems into real opportunities.

More sinister is the revelation in the last paragraph of the Dutch article above. "In 1989, a Dutch team and equipment had already been flown in to tackle the Exxon Valdez oil tanker disaster off the coast of Alaska. But in the end the US authorities sent them home." This technology has been around for more than 21 years but it is standard operating procedure for the US environmental protection authorities to reject proven harm minimisation options. One can only conclude that they seek some sort of perverted publicity gain from an unrestrained ecological disaster.

The BP legal defence team needs to take a good hard look at the option of laying formal charges of gross negligence on US authorities.


Monday, March 22, 2010

Half Truths in Retirement Saving

Be careful now, they are after even more of your money.

The entire funds management industry has been guilty of gross misrepresentation of fact in relation to the future retirement funding of Australians. They assume that retirements will only be funded through formal savings plans, less their own commissions, of course.

But they, and their self appointed champion, Paul Keating, forget that most Australians have parents, who own a house. And by the time each of us approaches retirement age our parents will be passing on and leaving the overwhelming majority of us a share of, at least, the median house price. This is currently in the order of $400,000 depending on where they live. And the further into the future we go the larger that average share will become because the average family size is declining.

So people born in 1950 are likely to inherit a quarter of the median house price. Those born in the 1970s will inherit a third and those born in the 1990s will inherit half of whatever the median house price is when they retire in the 2050s. Add those funds to a 9% superannuation scheme and very few Australians will be anywhere near underfunded in retirement.

So forget about the market spivs and all their scams for using the equity in your own house to fund a long retirement. The equity in your parent's house will arrive at about the same time as you will need it.

It is so painfully obvious that it is downright shocking to note that we currently have a retirement savings policy that is completely devoid of all consideration of inheritance and intergenerational transfers. It is doubly shocking because inheritance remains the key element of capital formation in most families, on the whole planet. It is almost like someone forgot to input this basic element of wealth accumulation into the cyber based mindset. Along with the absence of a site from which to download common sense, the role of inheritence in retirement funding has also slipped below the cyber radar.

One must ask, which planet has Keating been on all these years? And what, exactly, has been his purpose in building his own wealth, if not to ensure the future wellbeing of himself, his children and his grandchildren?

Or is it simply the case that the sons and daughters of no-hopers that now make up a large part of the Australian Labor Party had no idea of the concept of family wealth creation in the first place? And have shaped policy for the rest of us, entirely on the basis of their own ignorance?

First posted at:

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Monday, January 18, 2010

More on IPCC Himalayan Glacier blunder

The story has just broken on the complete absence of scientific evidence for the IPCCs claim that the Himalayan glaciers will have all melted by 2035. But there is much more to the story than has been covered in the mainstream media.

In, "United Nations' blunder on glaciers exposed", Chris Hastings and Jonathan Leake from The Australian (January 18, 2010 12:00AM) said;

THE peak UN body on climate change has been dealt another humiliating blow to its credibility after it was revealed a central claim of one of its benchmark reports - that most of the Himalayan glaciers would melt by 2035 because of global warming - was based on a "speculative" claim by an obscure Indian scientist.
The 2007 report by the Intergovernmental Panel on Climate Change, which claimed to incorporate the latest and most detailed research into the impact of global warming, appears to have simply adopted the untested opinions of the Indian glaciologist from a magazine article published in 1999.
The IPCC report claimed that the world's glaciers were melting so fast that those in the Himalayas could vanish inside 30 years. But the scientists behind the warning have now admitted it was based on a news story in the New Scientist, a popular science journal, published eight years before the IPCC's report.
It has also emerged that the New Scientist report was based on a short telephone interview with Syed Hasnain, a little-known Indian scientist then based at Jawaharlal Nehru University in Delhi.
Mr Hasnain, who was then the chairman of the International Commission on Snow and Ice's working group on Himalayan glaciology, has since admitted that the claim was "speculation" and was not supported by any formal research.
The revelation represents another embarrassing blow to the credibility of the IPCC, less than two months after the emergence of leaked emails from the University of East Anglia's Climatic Research Unit, which raised questions about the legitimacy of data published by the IPCC about global warming.
One email written by a scientist referred to ways of ensuring information that doubted the veracity of man-made climate change science did not appear in IPCC reports.
Murari Lal, who oversaw the chapter on Himalayan glaciers in the 2007 IPCC report, said on the weekend he was considering recommending that the claim about glaciers be dropped.
"If Hasnain says officially that he never asserted this, or that it is a wrong presumption, then I will recommend that the assertion about Himalayan glaciers be removed from future IPCC assessments," Professor Lal said.
The IPCC's reliance on Mr Hasnain's 1999 interview has been highlighted by Fred Pearce, the journalist who carried out the original interview for New Scientist. Pearce said he rang Mr Hasnain in India in 1999 after spotting his claims in an Indian magazine.
"Hasnain told me then that he was bringing a report containing those numbers to Britain," Pearce said. "The report had not been peer reviewed or formally published in a scientific journal and it had no formal status so I reported his work on that basis.
"Since then I have obtained a copy and it does not say what Hasnain said. In other words, it does not mention 2035 as a date by which any Himalayan glaciers will melt. However, he did make clear that his comments related only to part of the Himalayan glaciers, not the whole massif."
The New Scientist report was apparently forgotten until 2005 when environmental group WWF cited it in a report called An Overview of Glaciers, Glacier Retreat, and Subsequent Impacts in Nepal, India and China. The report credited Hasnain's 1999 interview with New Scientist. But it was a campaigning report rather than an academic paper.
Despite this it rapidly became a key source for the IPCC when Professor Lal and his colleagues came to write the section on the Himalayas.When published, the IPCC report gave its source as the WWF study but went further, suggesting the melting of the glaciers was "very likely". The IPCC defines "very likely" as having a probability of greater than 90 per cent.
Glaciologists find such figures inherently ludicrous, pointing out that most Himalayan glaciers are hundreds of metres thick and could not melt fast enough to vanish by 2035 unless there was a huge global temperature rise.
Julian Dowdeswell, director of the Scott Polar Research Institute at Cambridge University, said: "A small glacier such as the Dokriani glacier is up to 120m thick. A big one would be several hundred metres thick and tens of kilometres long. The average is 300m thick so to melt one at 5m a year would take 60 years."
Some scientists have questioned how the IPCC could have allowed such a mistake into print. Professor Lal admits he knows little about glaciers."

What the reports don't mention is the fact that most of these glaciers, like the largest, Siachen, go from altitude 6000m to 7000m. And most junior high school geography students will know that temperature declines by 1 degree C for each 100 metre increase in altitude. And that means the top of these glaciers are a full 10C colder than the bottom. It also means that temperatures would need to rise by a massive 10C for the glaciers to melt completely.

One must ask, what body of science is currently claiming that CO2 emissions will be so high as to produce the kind of CO2 levels (2000ppm or more) that would produce a 10C increase in global temperature? Answer: None. IPCC head, Pachauri, has obtained funding for his own consulting business on the basis of a completely preposterous claim.

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Wednesday, November 11, 2009

Young Ghosts by an old country Cenotaph

It is November 11 again. My eldest son is just 9 weeks shy of his 19th birthday. He is the only one in the family line to carry the name of his Great Grandfather who went off to the western front at the same age. So please forgive me. When I think about the dreadful sacrifices made by almost every farming family I can only ask if we are still worthy of the rights and liberties that were protected at such a cost.
I think about the rights that have already been taken without so much as a single bloody nose, or even a hurled egg or tomato. I wonder if those boys are still watching us now. I wonder what they would think about the people who claim to represent us but who give up so meekly and then pose for the camera, doing all they can to provide our persecutors with the veneer of good governance their voters still expect of them.
I wonder why it is that those who have had so little of life can give so much. And why those of us who have had so much of life will pay so little to hang on to what has already been paid for in full.
I still can't get over what an incredible bond of trust and belief in the inherent worth of their own community there must have been for parents to let their kids go into something like that. If Rudd & Wong, Bligh & Beattie, Carr and all the rest are the litmus paper of the nation we have become then, I'm sorry to say it, but these people are not worth the death of one good man, let alone 65,000, and just as many in continuous care some 3 decades later.
I was the last Cadet Officer of my school Cadet Unit before Whitlam shut it down in 1973, so I missed the draft by 2 years. But there was never any doubt as to where my duty lay. This was no mistake on my part, nor any moral fall from grace, as the left would have history record. You see, I was the son of a farmer who also rented land to other, poorer, farmers. And there were these people who knew nothing about farming who had consistently chosen to shoot folks like me and my family, without trial, every time they had the chance. And it was solidarity with people just like us that reinforced the need to fight murderers at their own place, not our's. Just as we now fight murderers in their own place today.
When I got to Uni I found that there were people with academic tenure who were quite capable of justifying my arbitrary dispossession and execution on the grounds of some illdefined "greater good". The students who were taught by those academics have reinvented themselves and now run our state and federal governments. And it is with the profoundest regret that it has come to the point where I could break both my son's legs before I would let them risk their lives for these leaders and the nation that elected them.
We all need to examine our consciences and ask if we have done enough to look those young ghosts in the eye as we pass them by at all those little country Cenotaphs. It is no good remembering them on just 2 days of the year while squandering their inheritance for the rest of it.

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Tuesday, September 15, 2009

Livestock in Riparian Zones - Reality vs Greenspin

How a picture can tell a thousand lies.

A green blogger recently provided a link to a NSW Catchment Management Authority web site as “evidence” of the degraded condition of “our” environment due to grazing of stock in riparian zones. But in reality, the site provides a very good example of how a few pictures and sloppy captioning can tell a thousand lies. See;
The introductory text said;
“Inappropriate livestock grazing is one of the most significant causes of degradation to the land-water interface in Australia. Livestock have long been part of the Australian landscape. Cattle, sheep, horses, goats and pigs arrived with the first settlers in the 1780s and moved with them across NSW into the Central West. Settlements sprang up along river systems supported by clean water and fertile floodplain soils. Since that time, livestock have caused damage to the most sensitive part of the landscape – our riparian lands.”

This picture was captioned;
"The access of livestock to waterways has many detrimental impacts on riverbank stability and water quality. (NSW DPI)"

True, we see cattle by a creek and some exposed soil which would lead most urban punters to conclude that this picture is representative of the entire length of the creek on that farm and representative of all grazed creek banks on all farms.

But we can be quite certain, given the proven MO of CMA’s and their staff, that the picture shows worse than average impacts. A random inspection of the first, second and third order farm streams that account for most of the riparian interface in the landscape is unlikely to provide a single example of conditions like those shown. It is also highly improbable that anything like those conditions would be replicated over the entire length of that particular stream. Indeed, there may be only one or two such examples on the entire property.

It is also quite certain that the conditions produced in the photo represent the sum of all cattle damage over a period of more than 100 years. Once the landform modification has been made by the stock to match their normal level of traffic, the rate of change (called degradation) will reduce to a minimum. Most of the modification shown in the photo would have been done in the first decade after settlement.

Stock can produce physical modifications to a small portion of a riparian zone when they are first introduced to a landscape or when a major increase in animal traffic at a particular point takes place. If the stocking rate has essentially remained the same and the number of access points is not reduced in a way that increases traffic on the remaining access points then there is minimal on-going impact. But the CMA text merely indicates that this “significant” damage has taken place “since that time” (ie implying it is on a continuous basis, in the past and in future). It converts an historical event as evidence of a future threat.

And it begs the question, do we regard a road culvert as evidence of land degradation? Or do we regard it as a piece of infrastructure that is a normal and necessary part of the prevailing use of the land as a road? Clearly, we view it as the latter. So why do we regard customary tracks (roads) made by cattle for their own continuing use as anything different to our own road culverts?

Both involve an initial excavation that exposes soil and both then involve only minimal soil disturbance for many decades after. And just like our road system, the more traffic cattle tracks have, the greater the visual impact. Do we begrudge Elephants or Caribou their right to shape creek crossings? No, only domestic stock.

To its credit, the site does include some helpful tools for minimising on-going soil movement. And just as for our own road culverts, this involves paving the most prone parts of the road with rock and concrete. The irony is that this simple, logical solution can only be carried out with the approval of DPI and the additional cost and effort that involves. And it is also fairly obvious that any approval for such works would only come with very significant and expensive conditions like fencing off the entire riparian zone and installing unnecessary watering points and piping.

Don’t get me wrong, additional watering points away from streams and dams make very good sense as they spread the grazing intensity more evenly over the entire area. But when faced with baseless, ideologically driven demands to render existing in-stream watering points redundant as a condition of approval for your voluntary good works, most farmers, justifiably, opt to let the authorities continue abusing themselves.

This photo was captioned;
"Sheep are said to have a greater impact than cattle in the riparian zone. (NSW DPI)"

It shows a fairly normal steep bank of a deep riverine cross section. Yes, there are sheep in the picture but one is left to wonder what, exactly, is the impact of those, or the past century of previous sheep, on the steepness of the river bank? Sure, they graze on the grass and may also graze on any tree seedlings that might germinate there. But the chances of such stems surviving the first flood event are quite low as they are more rigid than grass and much more likely to get tangled with passing debris.

Are we to seriously believe that without the sheep this river bank would be steeper? No.
Is there any evidence that the bank is not maintaining its form? No.
Would the bank structure be any different if there were trees atop the bank? No
In fact, if trees were present we would probably observe exposed roots as evidence that additional erosion had taken place. The area of exposed soil would be greater because the grasses would be competing for moisture with the trees and this would present a more erodible face to flood waters with greater potential for snags.

The third photo is just as misleading. We are told; “This creek was severely polluted with sediment and animal waste laden run-off. The rapid increase in nutrient levels caused a massive toxic blue-green algae bloom, rendering the creek water unusable for stock or domestic consumption.”
But what they do not tell us is that this is a temporary condition that starts at the beginning of a dry season and will only last until the pool dries up later in the season. More importantly, they do not mention that most high faecal E. coli counts and algal blooms are the result of self reproduction in the warm stagnant water. As was found to be the case with Canberra’s Lake Burley Griffin, most algae in a bloom is of a secondary or “regrowth” nature.

The severity of an algal bloom or the ultimate concentration of faecal E . coli, is not a function of the initial volume of coli being supplied to the pools in runoff. Rather, the longer the dry season, the warmer the temperature, the shallower the pools and the less frequent the intermittent runoff events take place, the greater the exponential rate of bacterial and algal growth becomes.
Algae reproduce faster and more often in favourable conditions, get used to it, folks.

The official CMA summary is in black type, below. It does not present a true and fair view so we have added a few comments in green to get closer to the truth about the impacts of grazing on riparian zones;

The real impacts of riparian grazing

isolated, once-off loss of vegetation cover in the first few years exposure to grazing
once-off soil compaction at a few specific points and initial erosion
once-off bank instability followed by long term stability of the modified landforms
isolated instances of reduced water quality
no evidence of reduced property values from the presence of stock modifications
enhanced germination of native tree species in hoof depressions etc

localised instances of poor water quality (increased turbidity, nutrients and salinity)
very localised loss of in-stream habitat
isolated, once-off changes to river channel shape of minor consequence
minor silting of rivers and creeks compared to that produced by unsealed roads
enhanced natural regeneration of native trees along previously cleared creek banks

Clearly, a picture can, indeed, tell a thousand lies. And government and green pictures seem to tell the most lies of all.

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