Dams have a great deal of negative effects on the environment besides their benefit

of controlling stream regimes and consequently preventing floods.

Within recent decades the environmental impacts of dams have been debated. While
dams do perform important functions, their effects can be damaging to the
environment. People have begun to question whether the positive contributions of
some dams are outweighed by those negative effects.

Wherever the location of a dam is, its ecological results are the same. The
environmental impacts of dams can be classified according to different criterions as
long term and short term impacts, the impacts in the vicinity of the structure and
impact further downstream from the structure. The magnitudes of the effects are
usually directly related to the size of the dam.
Prior to dam construction, most natural watercourses have a flow rate that varies
widely throughout the year in response to varying seasonal conditions. Of course
once a dam is constructed, the flow rate of the watercourse below a dam is
restricted. The dam itself and the need to control water releases for the various
purposes of the particular dam result in a flow rate that has a smaller range of values
and peaks than what would normally occur. This may have a detrimental effect on the
ecosystems downstream of the dam as flow volume and duration, water chemistry,
water temperature and sediment load are all altered. In instances where the dam
results in no water flow downstream of the dam destruction of ecosystems is
inherent.

Because water is held behind the dam and often released from some depth, the
temperature of the water below the dam is usually lower than it would be prior to dam
emplacement. The temperature of the water flow is often constant, not reflecting the
natural seasonal variations that would have been the case in the free-flowing
watercourse. Similarly, the chemistry of the water may be altered. Water exiting the
reservoir may be higher in dissolved salts or have lower oxygen levels than would be
the case for a free-flowing watercourse.

The impoundment of water behind a dam causes the velocity of the water to drop.
Sediment carried by the river is dropped in the still water at the head of the reservoir.
Below the dam, the water flows from the clear water directly behind the dam.
Because the watercourse no longer carries any sediment, the erosive potential of the
river is increased. Erosion of the channel and banks of the river below the dam will
ensue. Even further downstream, sediment deprivation affects shoreline processes
and biological productivity of coastal regions.

Where the construction of a dam is proposed it is important to undertake a complete

environmental assessment that identifies likely environmental impacts both during
the construction phase and during the operational lifetime of the dam. In a formal
Environmental Impact Assessment (EIA) Process this is referred to as Scoping.

This document was prepared at the request of the Brown Hill Creek Working Party.
The objectives of this report are to:

highlight environmental impacts that have been identified in documents

previously submitted to Council I(Listed in Appendix A)

1
 highlight deficiencies in the environmental assessment that has been
undertaken to date and make recommendations as to further work required.

Brown Hill Creek Flood Control Dams

According to the documentation cited the current level of flood protection along the
length of Brown Hill Creeks is 1:10 ARI. In the event of a 1 in 100 ARI it is claimed
that 5000 properties will be flood inundated resulting in a likely damage cost of
$2000M. Minor flood damage is likely to occur in smaller events if no further action is
taken with an average annual damage cost of $12.7M over a 30 year period.

The construction of two flood control dams is likely to increase the level of protection
upstream of Cross Roads and downstream from Anzac Highway to 1:100 ARI. The
level of protection between Cross Road and Anzac Highway is likely to be increased
to a 1:20 ARI for a minority of properties and 1:50 ARI for the majority of properties
along this section of Brown Hill Creek.

Topography
Brown Hill Creek is a small intermittent stream on the western slopes of the Mount
Lofty Ranges. The stream flows six months of the year during periods of heavy
rainfall. Flooding of the creek occurs after periods of low intensity rainfall exceeding a
36 hour period.

The Brown Hill Creek catchment originates near Eagle on the Hill. The creek flows
north west in an unlined channel though the rural section before entering the urban
area near Old Belair Road. The channel remains unlined until it reaches Heywood
Avenue in Unley Park, after which point, the channel is concrete for the remainder of
its length. Major constrictions in the channel occur at Cross Roads, at the Glenelg-
Adelaide tramway and at Daly Street in Kurralta Park.

The catchment covers and area of 32km 2 (upstream of the airport) and flows through
the suburbs of Crafers West, Mitcham, Westbourne Park, Millswood, Ashford,
Kurralta Park and the Netley before discharging to the sea through the Patawalonga
Lake.

The Brown Hill Creek catchment consists mainly of rural land in the Hills Face Zone
and as such it mainly vegetated. The upper reaches of the catchment have medium
grades and defined riverine channels which retard flow and limit the spread of flood
waters out of the channel. The middle and lower reaches have defined channels, but
flatter grades hence flood waters are more likely to spread out of the channels in
major storm events.

Proposed Sites for Flood Control Dams

The Master Plan suggests that two upstream flood control dams in the rural area of
the Brown Hill Creek catchment will minimise flooding issues.

2
Topography
Dam 1
The proposed site of Dam 1 (referred to as Basin 2 in the Master Plan) is located
several hundreds of metres upstream of the junction of Brown Hill Creek Road and
Tilleys Hill Road.

The area around the proposed site of Dam 1 has a long history of vegetation
clearance and landscape degradation. The site was historically used as market
garden irrigated from Brown Hill Creek. Historical irrigation practices have resulted in
significant alteration and disturbance of the stream bed. The majority of indigenous
riparian vegetation has been cleared however some significant tress are located in
close proximity to the site of the proposed Dam.

Currently vegetation at the site consists of woodland of mature Manna Gum trees
(Eucalyptus vimimalis) and scattered River Red gums (Eucalyptus camaldulensis)
over an understorey dominated with introduced species. Trees on the north western
slopes of the creek are suffering from die back most likely due to deforestation by
introduced Koala (Phascolarctus cinereus)

Dam 2
The proposed site of Dam 2 (referred to a Basin 4 in the Master Plan) is on the
southern arm of Brown Hill Creek towards the upper boundary Mitcham and Adelaide
Hills Councils. This site is located within a steep valley that has been cleared
previously for crop cultivation. Natural regeneration of both native vegetation and
exotic weed species has since occurred. The site is relatively inaccessible to both
pedestrian and vehicle access.

Currently vegetation at the site consists of woodland of mature trees of Manna Gum
(Eucalyptus viminalis) with some River Red Gums (Eucalyptus camaldulensis). There
is an extensive understorey of woody and herbaceous introduced species including
invasive pest olives and blackberry.

Currently Known Environmental Impacts

After reading through the reports and information listed in Appendix A, it is apparent
that limited investigations of the environmental impacts of the proposed construction
have been undertaken. The following provides a brief summary of the environmental
impacts known and makes recommendations for further investigations.

It must be noted that the outcome of environmental investigations may have

implications on the development assessment process undertaken should the
development proceed. These implications are also discussed in this paper.

3
Aboriginal and European Heritage
The proposed Brown Hill Creek Flood Control Dams are in close proximity to both
Aboriginal and European heritage places. The significance of these sites is high and
the archaeological sensitivity to disturbance is high.

A desk top study of the locality of the proposed two flood control dams has revealed
that there are three (3) sites of aboriginal significance and 14 listed European
heritage places.

The three known Aboriginal heritage sites include an engraving site and two scar
trees.

Further to this, given that that locality of the proposed flood control dams is within the
claimed traditional lands of the Kaurna people and the hills face zone would have
provided significance shelter and resources for Aboriginal people there is a medium
to high potential for currently unknown buried and/or unrecorded Aboriginal sites to
be in the vicinity of the proposed development

Any Aboriginal sites, whether recorded or not recorded, within the Brown Hill Creek
Flood Control Dams area are protected under State and Commonwealth legislation
from activities that may damage or disturb the sites.

Section 23 of the Aboriginal Heritage Act 1988 prohibits damage, disturbance or

interference of Aboriginal objects and Aboriginal sites, and disturbance, interference
or removal of Aboriginal remains without the authority of the Minister.

The fifteen European Heritage sites are listed on local government, State and
Commonwealth heritage lists. These sites include the former EW&S water tank and
water infrastructure (includes tank, brick well, stone valve well, dam wall, settling
pond, water fountain and associated pipework), Springfield House, Carrick Hill
Museum, Former Wheat Grainger Mines, Manure Pits, Birralee House, Former Holy
Innocents Church, St Johns School. Belair Railway Station and Signal Box, Sheoak
Riding School, Railway Cottages, and three un-named dwellings.

European heritage sites do not have the same blanket protection as Aboriginal
heritage sites however there are provisions under both the Heritage Places Act 1993
and the Development Act 1993 for European heritage sites listed on State and Local
heritage lists.

Recommendation
It is recommended that additional investigation and research into the presence
of both Aboriginal and European heritage sites be undertaken.

Environmental Implication
Flora
Preliminary surveys and database searched have indicated that the Pink-lipped
Spider-Orchid (Caladenia behri) and the Stiff White Spider-Orchid (Caldenia rigida)

4
are likely to grow in the area. Both these species of orchid are listed as endangered
pursuant to the Environment Protection Biodiversity Conservation Act 1999

An area of vegetation will need to be cleared for the construction of flood control
dams and to provide access to the site for construction equipment and vehicles.

An ecological assessment will be required to determine what impacts construction of

the two flood control dams will have on these species and the mechanisms that can
be put in place to mitigate any adverse impacts.

Recommendation
It is recommended that both a detailed flora survey and ecological assessment
be undertaken in the location of the proposed flood control dams

Fauna
Preliminary surveys and database searched have indicated that the Chest-nut
Rumped Heath wren (Calamanthus pyrrhopygius parken) and the Southern Brown
Bandicoot (Isoden obesulus obesulus) may also habitate the area. Both these
species are listed as endangered pursuant to the Environment Protection Biodiversity
Conservation Act 1999.

An ecological assessment will be required to determine what impacts construction of

the two flood control dams will have on these species and the mechanisms that can
be put in place to mitigate any adverse impacts.

Recommendation
It is recommended that both a detailed fauna survey and ecological
assessment be undertaken in the location of the proposed flood control dams

Water Quality
The existing waster quality with the Brown Hill Creek is of a good standard based on
historical data sourced from the Adelaide and Mount Lofty Ranges Natural Resource
Management (NRM) Board.

The construction of the flood control dams may possibly have an impact on water
quality by way of:

Degradation of water quality in the Brown Hill Creek downstream of the flood
control dams due to flow restrictions
Degradation of water quality in Brown Hill Creek upstream and downstream of
the flood control dams in the vicinity of road relocation works

Recommendation
It is recommended that a suitable erosion and sediment control management
plan be devised and implemented to minimise the risk to water quality during
and post construction of the flood control dams.

5
Additional Investigations
The documents currently in the possession of Council are concept designs only.
Limited construction details are provided in the reports. A formal development
application should provide the following details at a minimum:

A site plan drawn to scale, showing the proposed dams on the site, including;

the capacity of the dams (in m3);

the location of the entire dam including spillways (measured in metres) and
the distance of the dam to adjacent lot boundaries and buildings,

the crossover and internal driveways/movement routes which vehicles will

use during the filling of the land,

any storage area of materials including earth associated with the dam
construction,

the temporary or permanent change to any drainage areas of the site

including flood plains, creeklines, river, dam, and wetlands,

the location and height (in AHD) of the dam walls;

7. Cross section/s of the site drawn to scale, including:

the depth of the dams ( measured from the existing ground level before the
construction and the ground level after the construction);

8. Provide written documentation to justify and/or explain:

the location and size of the dam;

the amount of landfill material proposed on the site (amount in m3/tons)

the reason for the landfill. Is the completed landfill area intended to be used
for a particular purpose?

the staging (if any) of the landfill, including the commencement, duration
and completion of each stage.

the composition (eg. sand, clay, building rubble) and the source of the
landfill material/s;

the removal of any vegetation, rural/cultivation areas, landscaping onsite

and the description of any signification flora on site;

the description of methods to control noise and dust, erosion, siltration of

water courses, visual screening of the site;

6
 the hours of operation of the landfill activities;

the machinery and vehicles used in the landfill;

the public roads (the route) which vehicles will use to access the landfill
area/property;

the method of compaction of the land fill, - the machinery uses, hours of
operation, staging;

the method or type of revegetation of the landfill area. Detail staging, plant
species, growth rates, irrigation of vegetation;

the effect on the site and on adjoining sites of any changes to surface
drainage and changes to any water features on site.

maintenance of existing runoff or stream flows to ensure adequate

protection of the natural environment and not greatly impact on down
stream users.

9. A hydrological report may be required that demonstrates that the proposed dams
do not impede natural stream flow, nor the recharge of groundwater.

Planning Implications
The subject land is located in the Hills Face Zone within the City of Mitcham.

In accordance with Principle of Development Control 28 of the City of Mitcham

Development Plan the following kinds of development are non-complying in the Hills
Face Zone.

Excavation where the depth of excavation of land exceeds 2 metres below

natural ground level, except for the portion of a building that is fully
underground, underground homes, pools, underground tanks, cellars,
pipelines and waste disposal and treatment systems

Filling where the height of filling of land exceeds 1 metre above natural ground
level except for underground homes, underground tanks, and cellars.

It is envisaged that the proposed flood control dams would involve excavation and/or
filling of land in excess of the specifications detailed above.

The application will require Category 3 public notification

At this point is time there are three possible avenues that development assessment
may be undertaken.

7
DAC as the Planning Authority
Development Assessment Commission (DAC) is the relevant planing assessment
authority in relation to some development in the Hills face Zone, including:

Excavation and/or filing of land, other than-

o In association with the construction, conversion or alteration of, or
addition to, a building; or
o For the purpose of a Stormwater Detention Basin used, or to be used,
for the purpose of primary production, or
o For the purpose of carrying out earthworks that are ancillary and
subordinate to residential or rural development within the ambit of the
relevant application or previously approved under the Act.

The Development Regulations will require that the DAC provide the City of Mitcham
with an opportunity to provide written comment on the proposal. A six week period is
specified for comments to be provided by the Council to the Commission.

Crown Development Planning Assessment

The Development Act 1993 (Section 49) provides a separate planning assessment
process for State Agency Development.

State Agency means-

The Crown or a Minister of the Crown
An agency or instrumentality of the Crown (including a Department or
administrative unit of the State)
Any other prescribed person or prescribed body acting under the express
authority of the Crown

Pursuant to Section 49, the State Agency would lodge the application with the DAC
for planning assessment if

A State agency proposes to undertake development (other than in partnership

or joint ventures with a person or body that is not a State agency), or
A State agency proposed to undertake development for the purpose of the
provisions of public infrastructure (whether or not in partnership or joint
venture with a person or body that is not a State agency), or
A person proposes to undertake development initiated or supported by a State
Agency for the purpose of the provision of public infrastructure and specifically
endorsed by the State agency for the purpose of this section

Public Infrastructure means-

The infrastructure, equipment, structures, works and other facilities used in or
in connection with the supply of water or electricity, gas or other forms of
energy, or the drainage or treatment of waste water or sewage.
Roads and their supporting structures ad works
Ports, wharfs, jetties, railways, tramways and busways
Schools, hospitals and prisons

8
 Other facilities that have traditionally been provided by the State (but not
necessarily only by the State) as community or public facilities

The City of Mitcham would be provided with the opportunity to provide a report to the
DAC regarding the proposal. The City of Mitcham has up to two months to submit the
report to the DAC.

It is unclear at this stage as to whether or not a State Agency will be undertaking the
development.

Major Development Planning Assessment Process

The Brown Hill Creek Flood Control development may potentially have impacts on
matters of National Environmental Significance (NES) given that there are four
endangered species and both Aboriginal and European heritage sites in the vicinity of
the proposed development.
-
On the basis of the analysis undertaken it would appear that endangered species
listed under the Environment Protection Biodiversity Conservation Act 1999 may be
impacted from the proposed project. Four species listed as endangered as previously
described.

Pursuant to Section 46 of the Development Act 1993 the Minster may declare the
proposed development to be a project of major environmental, social or economic
importance by virtue of the likely presence and potential impact on endangered
species.

The Major Development Assessment Process is likely to be the most favourable and
appropriate assessment process for the following reason:

It would enable a proper and thorough assessment of the cumulative impacts

of the development with extensive consultation with other public agencies.

It provides greater opportunity for public input and comment. However it must
be noted that it does not provide members from the public with an appeal right
against any approved decision.

It must be noted that only the Minister can declare a development to be a Major
Project.

Declaration as a 'Major Development' means the Minister (assisted by the

Department of Planning and Local Government) will comprehensively assess the
proposal and its impact using the following process

The application will be referred to the DAC for setting of assessment level and
guidelines and the DAC will consider the application and identify the key social,
environmental and economic issues relevant to the assessment of the proposed
development. The DAC may consult with relevant State agencies as part of this
process.

The three possible levels of detailed assessment may be required by the DAC are:

9
 An Environmental Impact Statement (EIS) - required for the most
complex proposals, where there is a wide range of issues to be
investigated in depth;
A Public Environmental Report (PER) - sometimes referred to as a
'targeted EIS', required where the issues surrounding the proposal
need investigation in depth but are narrower in scope and relatively
well known;
A Development Report (DR) - the least complex level of assessment,
which relies principally on existing information.

The DAC will publicly issue a Guidelines document to the proponent as to what level
of assessment is required and what issues that assessment should address.

The Guidelines will be published on both the DAC website (www.dac.sa.gov.au) and
the Department of Planning and Local Government website www.planning.sa.gov.au)
and also be made available in hard copy and on CD-Rom.

The proponent will prepare an EIS, PER or DR, as directed by the Development
Assessment Commission. The length of time it takes a proponent to prepare the
assessment document is not set, and depends upon the level of assessment, the
complexity of the proposal and the sensitivity of the site. A DR generally takes the
shortest time, while an EIS takes the longest.

Once it is complete, the EIS, PER or DR is released for public and agency comment
for either three (DR) or six weeks (EIS, PER) and made available at the relevant local
council and on the Department of Planning and Local Government website. A
mandatory public meeting is held early in the exhibition period for an EIS or PER.

In Summary
There are a number of environmental and heritage issues that require further
investigations. The following recommendations are put forward to address these
issues.

Recommendation 1
It is highly recommended that additional investigation and research into the
presence of both Aboriginal and European heritage sites be undertaken.

Recommendation 2
It is recommended that both a flora survey and an ecological assessment be
undertaken undertaken in the location of the proposed flood control dams

Recommendation 3
It is recommended that both a detailed fauna survey and ecological
assessment be undertaken in the location of the proposed flood control dams.

Recommendation

10
It is recommended that a suitable erosion and sediment control management
plan be devised and implemented to minimise the risk to water quality during
and post construction of the flood control dams.

The proposed development may potentially have impacts on matters of National

Environmental Significance (NES) given that there are four endangered species and
both Aboriginal and European heritage sites in the vicinity of the proposed
development the Minster may declare the project to be a Major Project thereby
requiring environment impact assessment.

11
Appendix A
Brown Hill Creek Stormwater Project. - Preliminary Assessment of Flood Detention
Basins on Brown Hill Creek. Report on Stage 1 GHD October 2008

Brown Hill and Keswick Creeks Flood Mitigation study. Flood Management Plan.
Hydro- Electric Corporation15th December 2006

Flood Mitigation Study for Brown Hill and Keswick Creeks. Hydro Electric
Corporation. 5th August 2005

Urban Flood Risk Reduction and Stormwater Harvest. Technical Group. Brown Hill
Creek Stormwater Project. 14 October 2008

A Water Supply System in Colonial South Australia. (Abstract) Australian

Archaeological Association Inc

Stormwater at Adelaide Airport. Adelaide Airport Limited. September 2008

Brown Hill Creek and Keswick Creeks Flood Mitigation. A Review of the Justification
for the Construction of two Large Detention Dams in the Upper Reaches of Brown
Hill Creek. Peter Collins, John Wilson. July 2009.

Reducing the Flood Risk in the Brown Hill and Keswick Creek Catchments. Technical
Summary Report (Undated)

Brownhill Creek Recreation park Management Plan. Government of South Australia

June 2003.

12