Since at least 2014, there has been a proposal to construct a 100 Megalitre dam near the summit of Mount Buller. The official title of the project is “Mt Buller Sustainable Water Security Project”. The project involves the destruction of about 5 hectares of treeless alpine native vegetation, and subtracts about 10 hectares from the existing downhill skifield on Mount Buller.

Federal legislation requires a period of time to allow interested people and organisations to comment. Submissions are due by 22 December 2017.

For background on the proposal please check here.

The following submission was prepared by Friends of the Earth and may assist you in preparing your comments.

Mt Buller Mt Stirling Resort Management

Alpine Central

Summit Road

Mt Buller, Victoria, 3723

Via email:

Mount Buller Sustainable Water Security

Thankyou for the opportunity to respond to this project. The report prepared by Biosis provides an indepth summary of the values of the area in question and hence the likely impacts of a 100 Megalitre dam.

While we understand the need to expand water supplies on the mountain we hold deep concerns about the planned storage facility in its current form.

1/ Impacts on vegetation and continued fragmentation of the mountain

According to the report prepared for Mt Buller, most of the area to be destroyed is ‘alpine grassy heathland’. Alpine and sub alpine ecosystems on Mt Buller have been destroyed, modified and fragmented for decades and with such a small area remaining of Alpine Grassy Heathland the destruction of more than 5 ha of this habitat cannot be justified.

Taken more broadly it would also further deepen the cumulative negative impacts of ski resort development on the mountain, which obviously includes significant weed infestation. It could be argued that Mt Buller is already the most heavily developed mountain in the state which has extensive alpine and sub-alpine ecosystems. This major new project would constitute another significant negative impact on an already fragmented mountain environment.

As noted in the report, the Project is within the Victorian Alps Bioregion. Field assessments indicated that three remnant vegetation Ecological Vegetation Classes (EVCs) are currently present within the ‘Project Construction Footprint’ (PCF):

Alpine Grassy Heathland (EVC 1004)

This is the most abundant EVC across the PCF, covering a total area of 5.832 ha.

This EVC is a high altitude open heathland dominated by tussock grasses and a range of forbs. It occupies a wide range of habitats generally on slopes above 1,400 m where exposure and frost are limiting to tree growth. Graminoids and forbs are abundant and vary in cover depending on shrub density.

Sub-alpine Wet Heathland (EVC 210)

Sub-alpine Wet Heathland is highly localised within the PCF, restricted to a small area north-east of the existing water storage tank, and covering an area of 0.082 ha.

Sub-alpine Woodland (EVC 43)

Sub-alpine Woodland is confined to a few localised patches (0.004 ha) within the PCF, where it occurs immediately downslope of Alpine Grassy Heathland, growing on skeletal clay loams with a rich humus topsoil layer. This EVC is a low, open woodland dominated by Snow Gum with a rich suite of grasses and herbs, or a dense layer of woody shrubs.

However, a larger area of 11.27 hectares in total exists within the Project Investigation Area (PIA) and may be impacted during construction. Decommissioning and re-alignment of other existing underground services including water supply and communications would also be required.

Alpine Sphagnum Bogs


We also note the potential for ‘off site’ impacts on Alpine Sphagnum Bogs. A very small area of the EPBC Act-listed ecological community Alpine Sphagnum Bogs and Associated Fens occurs within the PCF. This small area of the bog is part of a larger bog complex (in the headwaters of Boggy Creek) that is located outside the PCF

and PIA, downslope from the proposed water storage facility site, on the northern side of the mountain. Whilst this downslope bog community has been disturbed historically for the construction of an aqueduct and water collection system, it is of high ecological value and is listed as endangered under the EPBC Act.


The Alpine Sphagnum Bogs and Associated Fens ecological community is a groundwater dependent ecosystem (GDE) with a highly localised and restricted distribution at Mt Buller (total area of 1.995 ha across 12 individual bog areas) (Tolsma 2014 in GHD 2014a). Around 98% of the bog extent on the mountain is situated immediately downslope (0-150 m to the north) of the PCF.


Critical to the formation of Alpine Sphagnum Bogs and Associated Fens is a reliable supply of groundwater, and an impeded drainage system that maintains the water level at or near the surface (DEWHA 2009 in GHD 2014a). Changes to the water

runoff regime (both quantity and timing) have the potential to threaten the community as it can significantly alter the surrounding vegetation, leading to bogs and fens drying out.


Modelling of the effect of storage construction (rainfall interception) on surface water and groundwater, which supplies the alpine bogs immediately downslope and to the north of the PCF, suggests that five of the 12 bogs are likely to be impacted.


In summary, approximately 71% of the total alpine bog area at Mt Buller (as mapped by Tolsma 2014 – refer GHD 2014a) is likely to be indirectly impacted to some degree as the proposed storage dam is located within the catchment area for these

bogs. The three largest bogs likely to be impacted comprise 1.315 ha.

Furthermore, irrespective of the impacts associated with an upslope storage dam, the alpine bogs at Mt Buller are increasingly likely to be susceptible to climate change, particularly given their fragmented distribution in the Australian Alps and the fact that they are already at the edge of their environmental tolerance.


Further impacts on these ecosystems simply cannot be justified given the known threats of climate change and very small scale of the vegetation type at present.

2/ Impacts on fauna


There will be direct impact to habitat of three fauna species listed under one or more of the EPBC Act, FFG Act or Advisory List of Threatened Vertebrate Fauna in Victoria – 2013 which are known or likely to occur within the PCF;


  • Mountain Pygmy-possum (Burramys parvus)
  • Broad-toothed Rat (Mastacomys fuscus), and
  • Alpine Bog Skink (Pseudemoia cryodroma)


3/ The Mt Stirling offset

It is proposed that “compensation” be provided for the loss of 5 hectares of rare

alpine habitat on Mount Buller, by protecting 262 hectares around the summit area of Mount Stirling, in perpetuity.


Numerous studies have shown that losing biodiversity in one ecosystem, can rarely, if ever, be compensated by preservation of natural values in another location. There are significant differences in vegetation between the summits of Mt Stirling and Mt Buller.


All of Mount Stirling is already protected because it is zoned Public Park and Recreation Zone (PPRZ).


This situation is reflected in the Mt Stirling 2030 vision document, which explicitly rules out development of infrastructure like accommodation or ski tows.

The offset proposal seeks to protect something that is already protected.



We understand the need for extra water supplies on Mount Buller. However, the

ecological impacts of the 100ML open-air dam proposal are unacceptable.


Further water storage options such as above-ground or below-ground water storage

technologies should be considered. We do not support the project proceeding in its current form.