Coastwatchers congratulates the relevant council staff and the consultants on the study and plan. It is a very useful document. The plan, when implemented, should go a long way towards protecting the Tomaga estuary.

Our comments are listed in the order the sections appear in the study and plan -

1.3 (p 2) Description - Is the estuarine waterway area really only 1.6 sq km when the length of the estuary is 11 km?

1.5 (p 6) Issues introduction - 2nd last dot point - replace "depredation" with "degradation"

1.5.4 (p 7) Ecological concerns - 2nd dot point - It is mainly the saltmarsh between George Bass Drive and the Tomakin Caravan Park that is being degraded.

2.6.2 (p 32) Irrigation - While irrigation may not be taking much water from the tributaries there are many dams in the catchment affecting inflows to the river. It would be good if the Plan registered these dams. The number of dams and their cumulative impact is likely to increase considerably in future, especially if properties are further subdivided.

3.2.8 (p 43) Appropriate and Inappropriate Areas for Grazing - This section implies that it is all right to graze cattle up to within 10m of the estuary but does not make it clear if the edge is the top of the bank or the MWL mark. Even so 10m is not an adequate width for protection of the riparian zone
Fisheries recommend "foreshore buffer zones at least 50m wide should be established and maintained with their naturual features and vegetation preserved."(p 54, 3rd dot point under Aquatic Habitat Management…). The Draft Habitat Rehabilitaion Plan Section 3.3 (p 4) says 30m has the greatest influence on ecosystem health of the stream; 100m is described as necessary for a wildlife corridor; and 300 to 600m each side of the stream is required to provide wildlife habitat.
Grazing cattle intermittently within a corridor or wildlife habitat may be acceptable to control some weeds but should not happen often.

Table 6.3 (p 68 & 69) Options and strategies…erosion and sediment - The reason "No loss of sand and mudflats which are feeding grounds for fish and birds." should be deleted from the sections of table dealing with Beach nourishment (by dredging), Rock revetment wall, and Gabion mattress wall. All of these actions would have the effect of altering sand/mud flats in the river either directly or indirectly. This is recognised in the Plan - see Table 6.7 (p 80) Protect fish habitats "Dredging or rock walling…will threaten (sand banks and mud flats near the mouth)".

Table 6.5 (p 75) Options and strategies… water quality - Mogo Zoo - Council should also be working with the Zoo to reduce run-off from paddocks. The ones used by buffalo are heavily grazed, accumulate large amounts of dung (especially in winter) and have drains that direct run-off straight into the river.

Table 6.6 (p 77) typing error in Declining fish catches - "stopped"

Table 6.7 (p 78) Options and strategies .. ecological - There is a large reservoir of bitou on higher ground 'islands' in the wetland opposite the spit. This should be targetted by helicopter or with backpack sprays landed from boats.

Table 6.7 (p 80) Options and strategies .. ecological - Encourage catch and release programs - the reason should read "Allows people to enjoy fishing while reducing the damage to fish populations" fish are still harmed and many do not recover.

(p 82) The last two points at the bottom of the page are the same.

6.5.3 (p 83) Waterway usage - Recommended strategies - Voluntary restriction on boat sizes is not practical. If the size limit is made enforceable then who will police it? If there is to be a restriction then 6m seems too large for some types of boats in the river.

7.4.2 (p 100) Option 2: Bank Protection near George Bass Bridge - The project impacts should include the damage that will be done to the riparian vegetation by the machinery placing the rocks etc.

7.5.3 (p 103) Option 3: Controlling stock access to foreshores and wetlands - Compensation for land surrender does not seem fair if the neighbouring land owner has been using adjoining Crown and Council land without paying to lease it.
It is very important that Crown land in the riparian zone is not sold. The land is essential for riparian protection, wildlife corridors and public access.

7.5.5 (p 105) Monitoring wetlands - The report says elsewhere that the saltmarsh near Tomakin Van Park is already being badly degraded. It will require more than monitoring the wetlands to prevent further degradation.

7.6.3 (p 108) - Encourage landholders to implement best acceptable practices for grazing - Approximate Costs - Information evenings alone are not likely to reach the majority of landholders. A field officer may need to be contracted to visit all the properties and talk to the owners/occupiers.

7.9.2 (p 116) Option 2: Maintain discussion between Council, Waterways and boat users - Relying on existing Estuary Management Committee meetings to reach most boat users is not likely to be successful.

8.1 Recommendations
Coastwatchers supports nearly all the recommendations so we have mainly confined comments on this section to areas where we disagree.

8.1.1 (p 134) Objective 1: Manage the Spit….. - We agree that the breakthrough should be allowed but question whether it will be more effective, cheaper and less damaging to maintain an entrance in the middle of the spit if this is the main one for a while. As the report says elsewhere, an entrance through the Spit will be more dangerous for boat users; a breakthrough will eventually migrate back to the current entrance site; and in the meantime it will probably be necessary to dredge a channel from the Mossy Pt boat ramp to the breakthrough entrance probably damaging important seagrass beds en route.

8.1.4 (p 135) Objective 4: Protect Foreshore Habitat - We support all the recommendations except the last. Monitoring will not be sufficient to protect some saltmarshes, especially the one near the Tomakin Caravan Park.

8.1.8 (p 136) Objective 8: Resolve Conflicts Between Users - The reference to a Voluntary Code of conduct for PWC users should be deleted. Perhaps this should be replaced with "Enforce the regulations on waterway usage". This applies to everyone, not just PWC users, and gives flexibility to cover any future changes in the rules.

8.1.9 (p 136) Objective 9: Manage Invasive Species - We would like to see the first recommendation reworded to say "Progressively remove Bitou Bush and Prickly Pear from the spit and wetland opposite…"

8.1.14 (p 137) Objective 14: Maintain the Unspoilt Nature of the Tomaga Estuary - Our members are particularly supportive of this objective and the options to achieve it.

8.2 (p 137) Implementation table - typing error "whether" not "wether"

Table 8.1 (p 138) Implementation Table - This is not easy to interpret and would be better spelt out in more detail (even if it takes a couple of pages) with words briefly summarising what the objectives and options are, eg
Objective 1 The Spit Option 1 No action, dredge lagoon. Conflict

Appendix C Waterway User Management Plan - update area to include the ocean landward of Longnose Pt to Broulee Is, and delete references to voluntary code of conduct for PWC users in sections 4.4 and 6(4).

Appendix D Foreshore Rehabilitation Plan - 4.4 Bank erosion at Tomaga Caravan Park - The recommendation to grade back the bank is inappropriate given that it will destroy trees shrubs and possibly aboriginal heritage sites.
Typing error in 2nd dot point "toe" not "tow"