Re: Unsustainable Development in Noosa Biosphere – Powerlink’s 275kV Transmission Line and Substation Project 

Dear Minister,

The purpose of this letter is to bring to your attention the alternative proposal which P.A.G.E. has submitted to Parsons Brinkerhoff (PB) and Powerlink Qld. The P.A.G.E. proposal not only minimises the impact both environmentally and socially, but is significantly cheaper by $70.2m.

This ‘common sense’ approach is endorsed by the Noosa Biosphere Reserve governance board.  The Noosa Biosphere is Queensland’s first Man and Biosphere Reserve and is severely impacted by Powerlink’s proposal.  Noosa Biosphere joins PAGE in asking that you appoint an independent party to examine all alternatives as a matter of urgency. 

Background:

Powerlink currently has a $110m project to construct a new 275kV transmission line from Woolooga to Eerwah Vale, which is in the final stages of preparing to seek Ministerial designation for community infrastructure. Powerlink state that 90% of the line will use an existing easement, but the other 10% requires a new easement.

The purpose of this project is to reinforce the existing 132kV Energex double circuit power lines between  (i) Woolooga and Gympie, and (ii) between Gympie and Cooroy.

Powerlink claim this project will provide the additional power to beyond 2050 for the Gympie, Tin Can Bay and north Sunshine Coast areas without further upgrades and expenditure in that period.

The residents of Ridgewood and Eerwah Vale represented by the action group P.A.G.E. do not object in principle to upgrading or reinforcing electricity supply. However, the community (including the Sunshine Coast Regional Council) strongly oppose the route chosen by Powerlink as it violates and destroys a critical portion of Noosa Biosphere’s pristine wildlife habitat. The clearing of a 60m wide easement and significant additional 8m wide access tracks through steep inaccessible old growth forest will cause erosion and fragment wildlife corridors, especially for the healthy resident koala population.

P.A.G.E. has researched and developed lesser impact and lower cost alternatives utilising existing, common infrastructure corridors (ref. SEQIPP). P.A.G.E. has presented these alternatives to Powerlink and PB during the EIS and CID processes. PAGE has met with Powerlink Chief Executive Officer and requested community involvement in the alternatives assessment process – this has been ignored and it is P.A.G.E.’s opinion that Powerlink and PB have a clear conflict of interest in properly assessing the alternative proposals at this stage in the process. In short, Powerlink has their predetermined plan and do not intend to change it in spite of the P.A.G.E. alternatives meeting the requirements of security of supply at lower environmental, social and financial cost.

Solutions:  

The P.A.G.E. solution can be staged over different time frames. Initially, Powerlink need only spend approx. $1.5 million at this time which can delay the necessity of building new infrastructure in the short to medium term (to 2028), whilst overcoming the short term Energex 132kV network limitations. These limitations are prime drivers of Powerlink’s justification for their project.

This solution provides breathing space to give emerging low carbon technologies, strategies and government programs time to be developed and implemented (such as the Sunshine Coast Council’s Energy Transition Plan targeting 100MW of new capacity by 2020) thereby reducing the demand or need for additional major infrastructure such as Powerlink’s proposal. If by 2028 more powerlines are still required, P.A.G.E.’s solution utilises 97% existing infrastructure corridors, thereby minimising environmental damage. This option is $70.2m cheaper than the Powerlink proposal. This appraisal has been independently assessed using Performance Electrics Pty Ltd, Greystanes, NSW

Furthermore, the P.A.G.E. solutions avoid the irreparable damage to existing wildlife corridors, and in particular, to one of the last existing healthy colonies of koalas in the Noosa Biosphere. This is a direct impact on tourism’s ability to be sustainable and underpin economic survival of the eco-tourism market.  The governments own SEQ Catchment Report of 2010 identifies such damage as critical and immediate (>2020) with many billions in economic benefit stripped away due to the proliferation of utility corridors impacting local economies, agriculture, tourism and resultant social dysfunction.  Change to prevent this has to start somewhere.  We believe it is here where the line should be drawn.

Nevertheless, if it is the wish of government to spend money now on infrastructure, the community’s wish – this includes our local State representative and Council – is that this is not done at the expense of destroying this key environmental area in the Biosphere as there are lower impact and cheaper solutions, such as presented by P.A.G.E.

For this reason, the last 10% of the Powerlink project should utilise other existing, common infrastructure corridors such as the current Bruce Highway upgrade and railway easements, as has been done in numerous other projects across Queensland and Australia.

The P.A.G.E. network solution (injecting supply to the north of Cooroy) offers superior design for future network development and is based on using existing infrastructure corridors on 97% of the route minimising environmental impact. This alternative also costs significantly less, with projected savings of some $20m on a like-for-like basis. These savings are significant in the current financial climate and Powerlink has the obligation of providing power at the cheapest cost to the consumer.

How much support could be provided via the Premier’s flood relief fund via these savings, how many houses and businesses could benefit from such support?

Detailed documentation is available as and when required.

Yours sincerely,

POWERLINE Action Group Eumundi’s proposal to route a proposed new Powerlink line down an easement on the Bruce Highway would be thoroughly investigated, Member for Nicklin Peter Wellington said.

Mr Wellington met representatives from the independent Energy Sector Monitoring Unit and the State Government’s Department of Energy last week regarding the proposed Woolooga to West Cooroy line.

He presented a submission outlining PAGE’s proposal and said he came away satisfied its call for an alternative route to that proposed by Powerlink would be given full consideration.

Mr Wellington said he had been shown examples of other challenges to Powerlink proposals that had been reviewed by the unit.

Eerwah Vale residents are concerned at the potential damage to koala and Richmond Birdwing butterfly habitat and to the loss of amenity for land owners if the route goes ahead.

Mr Wellington said he had been given an “iron clad guarantee” that the PAGE submission would be given equal attention.

MEMBER for Nicklin Peter Wellington is headed for a showdown in Parliament next week over Powerlink’s proposed high voltage powerlines through Eerwah Vale, Belli Park and Ridgewood.

 Mr Wellington has requested a meeting in Parliament with the general manager of the energy group appointed to assess Powerlink’s proposal, who will then make a recommendation to Minister for Energy and Water Utilities Stephen Robertson.

 Powerlink proposes to run power lines through picturesque property in areas such as Eerwah Vale.

Lobby group People Advocating Green Energy (PAGE) says the powerlines should run along the Cooroy to Curra highway corridor.

 Last week, Mr Wellington called for an independent review to be funded after he received conflicting information from PAGE.

Mr Wellington told The Journal he had received advice that the Cooroy to Curra route was not wide enough for the proposed powerlines.

However, a meeting between PAGE and a senior staff member working on the highway upgrade indicated the highway in fact was wide enough.

‘‘I have now received a commitment (from the general manager of the energy assessment group) that they will investigate the issue of the road corridor being able to accommodate the powerlines,’’ he said.

‘‘I want to see evidence where previous applications from Powerlink have not simply been rubber stamped.’’

PAGE president Jack Connolly said the group still wants an independent review.

‘‘Our option is 7km shorter, it’s cheaper and it meets all the objectives of Powerlink,’’ he said.

Jack Connolly with Peter Wellington and locals at proposed powerline site.

Source: www.questnews.com.au

The project outlines the transformation of a 50-hectare Valdora site into a state-of-the-art solar park sporting approximately 50,000 solar panels feeding power directly into the local grid for approximately 2500 Sunshine Coast homes.

EPA director Jason Hague believes the project will not only generate local employment opportunities and significant economic benefits for the Coast, but will elevate the region as a leader in the development of green power solutions.

“The Sunshine Coast has a real opportunity to become a leading hub for the production and use of clean-tech products and services,” says Jason, who is also a town planner. “If we want to change the way we operate and live up to the vision of being Australia’s most sustainable region, we need to embrace the technology and innovation available and do so on a scale that has real impact. There’s pressure on every level to deploy green-energy options that can cater for the ever-increasing energy needs of 21st century communities in Australia – politically, socially and environmentally. This solution can be rolled out on strategically located sites across the Coast and beyond to deliver solutions to high-demand locations.”

The solar panels will span across 20 hectares of the cane land site with the surrounding 30 hectares being rehabilitated as green space to minimise the impact on the local landscape.

The EPA model is based on identifying appropriate sites and building several centralised energy parks across the Sunshine Coast that provide large-scale photovoltaic (PV) deployments close to infrastructure and end-user demand.

“This solution goes a long way to meet council’s Energy Transition Plan endorsed in December 2010, which aspires for the Sunshine Coast to be a low-carbon economy,” says Jason. “The Valdora Energy Park will be a $40 million-plus venture and if successful in our application, we aim to develop local partnerships to deploy the technology on the site, thereby further delivering economic benefits for the region.”

EPA extensively researched the viability of the project and the range of benefits for the Coast, including ongoing discussions with the council.

“Energy Parks Australia has had several meetings with various departments within the council to discuss the project and to ensure its submission is of a high-quality, comprehensive in scope and addresses the wide range of issues required to be considered during the DA process,” says Michael Bismire, manager of Planning Assessment at the council.

Source: http://editorial.mypropertypreview.com.au/my-feature/coast-leads-the-solar-charge.html

Eerwah Vale residents James & Janet Luttrell and Jack & Margaret Connolly.

A NOOSA hinterland lobby group fighting high voltage transmissions lines through their area have helped engineer a power play that could go all the way to Premier Anna Bligh.

The Powerlines Action Group Eumundi has brought alleged contradictory advice about the suitability of the Bruce Highway along the Cooroy to Curra route to carry the electricity pylons to the notice the Member for Nicklin Peter Wellington.

He is now demanding that Energy Minister Stephen Robertson implement an independent assessment of PAGE’s Cooroy to Curra route by today or he will take his concerns to Ms Bligh.

Mr Wellington told ABC Coast FM on Wednesday morning that Mr Robertson had been told last year by the Minister for Main Roads Craig Wallace that the highway corridor was not suitable for the pylons.

“Since then there was a meeting held with the (PAGE) action committee and one of the senior department officers working on that (highway) project,” Mr Wellington said.

“The senior department officer confirmed in email to me, through his secretary, that effectively those minutes said there was sufficient capacity in the national highway corridor for the location of the transmission towers.”

Mr Wellington wants an independent review carried out before Mr Robertson makes a final decision on Powerlink’s proposed $100 million project that would cut a swathe through Ridgewood and Eerwah Vale.

He said that was expected by the middle of the year.

“I do not have confidence in the advice that the consultants are providing to Powerlink and I do not have confidence in the advice that Powerlink is providing to the minister.”

Mr Wellington said national highways were the appropriate and best location for powerlines

“I’d like the minister to find a way a way where his department is able to start an authorised assessment – if he is not able to do that well then I’ve made it clear I will take it to the Premier.”

PAGE spokesman Mike Tsilfidis told the ABC that such a review was “exactly the outcome that we’re looking for”.

“That’s great news.

“We were never against the security of supply in the area.”

PAGE believes the shorter highway route could save the taxpayers tens of millions of dollars.

A spokesman for Mr Robertson told the ABC that Powerlink was continuing to assess submissions and further comment wouldn’t be appropriate until he received a relevant report.

 Source: http://www.noosanews.com.au/story/2011/02/25/group-urges-minister-to-get-facts-noosa-powerlines/

POWERLINK will “thoroughly assess” a submission for an alternative route for powerlines through Eerwah Vale west of Cooroy.

Residents group Powerline Action Group Eumundi (PAGE) met with Powerlink representatives yesterday to present its case for the lines partly to follow the new infrastructure which will carry the proposed Cooroy-to-Curra section of the Bruce Highway.

Group spokesman Jack Connolly said he did not want to comment on the meeting until Powerlink responded.

Member for Nicklin Peter Wellington attended the meeting and said he was surprised to find Powerlink’s plans were to take the transmission lines all the way south to Caboolture.

He said PAGE’s proposal was “a better and cheaper option” than Powerlink’s proposed $110 million Woolooga-to-Eumundi powerline plan.

Cooroy councillor Vivien Griffin, who also attended, emphasised the council’s concern about the impact of the powerlines on residents.

Ms Griffin requested that Resources Minister Stephen Robertson provide a full cost-benefit analysis of the proposal in the light of renewable energy and the State Government’s own Q2 energy efficiency goals.

Powerlink CEO Gordon Jardine said the group’s submission would be properly scrutinised.

“This alternative route will be thoroughly assessed for its technical viability, environmental and social impacts, and the requirement under the regulatory framework for Powerlink’s network development to be undertaken with the least overall cost over the long run,” Mr Jardine said.

He said about 90% of the new line had been planned to be built within existing easements, “next to an existing transmission line”.

Mr Jardine said proposed lines through to Caboolture would only invest in what was already in place on double-width easement acquired more than 30 years ago in anticipation of future growth.

Source: http://www.sunshinecoastdaily.com.au/story/2010/07/13/powerlink-to-assess-new-route-powerlines/

Stuart Topp — Project Manager
Woolooga to Eerwah Vale Project
Powerlink Queensland
PO Box 1193
VIRGINIA QLD 4014

Delivered via Email: stopp@powerlink.com.au                                                                                    09 June 2010

CID – Woolooga to Cooroy Transmission Line and Eerwah Vale Substation Project

Powerlines Action Group Eumundi (PAGE) is a community group formed to ensure that the wider community interests are served when considering how to provide energy for sustainable development on the Sunshine Coast.

With this in mind, PAGE wish to work constructively with the Queensland Government and its agencies to deal with the issues facing the Sunshine Coast with respect to provision of energy. With this mind PAGE have commissioned an independent electrical engineering consultant to review the proposal and make an assessment of the Powerlink proposal and any feasible alternatives that meet the network requirements – the full report is attached with this submission.

This submission comprises documents (noted in the list of attachments below) which we have produced in response to your letter of 7 May 2010. In this covering letter we raise our general concerns with the proposed Powerlink project. These general concerns are drawn from our list of specific issues raised with the project to date and the supporting attachments. We expect you to respond to the matters raised in this covering letter and the specific issues in the attachments.

This document also addresses fundamental deficiencies in the Environmental Impact Statement (EIS) process and the substandard final EIS produced. Core issues are addressed in an executive summary, with more detail and comments provided in the ensuing table, referenced for ease of use. We trust you will act on our comments and demonstrate that genuine community input into this proposal is possible at this late stage. We look forward to receiving the response to the CID submission in due course.

Yours faithfully,

Jack Connolly,
President,
Powerlines Action Group Eumundi Inc.

Executive summary

The Environmental Impact Statement (EIS) is a complex and lengthy document. In order to deliver a meaningful, community-centred reflection of impacted residents’ concerns, a substantial amount of time and effort was required, but not provided.

The main requirement of the EIS was to provide an assessment of the environmental (economic, social, cultural and physical) impacts from the construction, operation, maintenance and decommissioning of the proposed transmission line (TL) and substation, and to duly consider alternatives to the proposal carried forward. Ultimately this document is to be used to form the basis of a Ministerial designation of land for community infrastructure.

PAGE concludes that the proposal:

• Fails to assess the lowest cost and lowest impact solution
• Fails the Australian Energy Regulators (AER) lowest cost solution requirement
• Fails in its requirement to have adequately consulted with the community
• Fails to comprehensively address the issues raised by the community
• Fails the threatened iconic Koala
• Is not required in light of the alternatives proposed

The EIS cannot therefore form the basis of a credible assessment of the environmental impact of the proposal, which is intended to responsibly meet the future energy requirements of the northern Sunshine Coast and Gympie regions. The Woolooga – Eerwah Vale project is not required. It is incomprehensible from a system strategic assessment as to why the proposed 275kV injection with 800MW capacity would be fed into a 132kV bottle neck which is the 132kV system between Woolooga to Palmwoods given that the 132kV system limits the flows out of the 132kV system to the wider Sunshine Coast area to 200MW in its present and proposed configuration, while the wider Sunshine Coast area is seen to be the area which requires the new additional supply capacity.

There are several key issues that PAGE has identified within the EIS and project assessment process that lead us to this conclusion. These issues are outlined below and explored in greater detail in the attachments to this submission.

Fails to assess all viable options

Three alternatives have not been adequately considered by Powerlink and are documented in more detail in attachment A of this submission. The proposals have not previously been adequately assessed by PL or Parsons Brinckerhoff.  PAGE puts forward three cheaper and significantly lower impact solutions:

1. A single Bus Section Circuit breaker at Gympie (Cost estimated at $1.5M) deferring any augmentation requirement until at least 2027.
2. A Staged augmentation north of Cooroy (NPV estimated at $96.2m – savings of $14.4m )
3. Network augmentation Woolooga to Palmwoods at 275kV using the existing PL easement (NPV estimated at less than $60.5m – a saving of over $50m)

Options 2 and 3 were put forward in submissions to the draft EIS in May 2009. The solutions developed by PL from this information were incorrect and bore no relation to the actual solution being proposed. PL did not attempt to clarify or validate their understanding of the alternative solutions that they assessed and dismissed in the EIS. Options 1 and 3 have been put forward by an independent electrical engineering consultant, who has reviewed option 2 and concluded that this is also a feasible alternative to the Powerlink proposal.

The Eerwah Vale 275kV tee off line and substation is not required for the Energex 132kV Woolooga to Palmwoods system and the PL preferred solution is not the cheapest or lowest impact solution.

Consultation

PAGE considers the consultation process to be flawed and have consistently pointed this out to both Powerlink (PL) and Parsons Brinckerhoff (PB) Australia during the past 18 months. The EIS displays lots of statistics about the volume of consultation, but no information regarding the quality or timeliness of the consultation. From a community perspective, the quality of consultation has been completely inadequate on a number of levels. They include:

• Refusal to provide relevant and timely information when requested
• Refusal to attend community organised public meetings
• Issuing misleading information and attempting to portray PAGE as deceitful and dishonest
• Treating this community with contempt, with no willingness to conduct an open and transparent consultation process
• Inadequate time provided to formulate a comprehensive response to a 1900-page document that it has taken PL/PB 19 months to compile
• The EIS either does not address satisfactorily or ignores the majority of issues raised in the PAGE submission on the draft terms of reference

The combination of these factors leads PAGE and its members to have little or no faith in consultation process undertaken to inform the EIS process or as a basis for the Minister to make an assessment regarding community infrastructure designation.

Financial assessment

The proposal is not the lowest cost alternative and the augmentation is not required urgently as stated by Powerlink. The table below highlights the alternatives, their cost and the timing:

Alternatives    NPV    Timing
Powerlink Woolooga – Eerwah Vale Project    $110.6m    2014 / 22
PAGE – Option 1 – Bus Switch (Gympie)    $1.5m    2014
PAGE – Option 2 – A Staged augmentation north of Cooroy    $96.2m    2014 / 27
PAGE – Option 3 – Woolooga to Palmwoods    $60.5m    2027
PAGE Preferred Option – Combine Option 1 and 3    $62.0m    2014 / 27

The PAGE preferred option is not only the cheapest, but provides a staged solution, requires investment when it is demonstrated that demand requires it and provides the best long term security of supply for the whole of the Sunshine Coast Region.

Impact on Koala and other species

Powerlink’s proposed route is planned to go through pristine koala habitat, which is home to a healthy population of Koalas. The koala habitat mapping commissioned in 2009 by the Queensland Government, the very mapping relied upon by Parsons Brinckerhoff, as the basis for their assessment of the Woolooga to Eerwah Vale area, has been found to be flawed and has drawn scathing criticism from a wide circle of stakeholders – including conservation groups, local government authorities and landowners throughout South East Queensland. Chief among their criticisms has been the methodology employed in this mapping project – which relied on the remote digital analysis of aerial image pixels (pertaining to tree colour). The consultants responsible for the delivery of the mapping to DERM (GHD), recommended comprehensive ground truthing (field verification of koala habitation), and that this was not conducted to the extent required.

Other key species including the northern most colony of the Richmond Birdwing Butterfly will be adversely impacted by Powerlink’s proposal with the easement planned to go directly through the habitat of the butterfly. Generally survey methods undertaken were not considered adequate, despite the community putting forward detailed proposals at the ToR stage of the project that would have ensured that detailed and best practice flora and fauna surveys were conducted. These proposals were ignored through the EIS process. Consequently the community has little faith in the veracity or accuracy of the conclusions relating to environmental impacts based upon the actual studies undertaken.

Conclusion

The dismissive approach taken to the alternative technologies and sustainable strategies aimed at meeting the energy needs of the region is extremely disappointing, particularly as it counters major policy reforms of the Bligh Government, namely Towards Q2.

Not only does it counter the Towards Q2 target of protecting more land for conservation as it rips through hectares dedicated as Land for Wildlife, it also highlights that Powerlink, a Queensland Government agency, is not serious about introducing its own policies and measures to cut carbon omissions. The government’s Towards Q2 – Tomorrow’s Queensland green vision is made to appear as nothing more than that; a vision.

Therefore, based on the innumerable flaws in the EIS, many highlighted in this document, this Project and the proposed alignment cannot be recommended to the Minister for designation and should be stopped now. This EIS fails to fulfil the ToR and lacks critical detail, providing the Minister with inferior and insufficient information on which to base a decision regarding the designation of land for community purposes.

This Project also cannot be recommended with integrity, based on the inappropriate EIS process deployed, including poor community consultation and engagement practices. The process for Ministerial designation regarding this Project is therefore flawed to a potentially devastating extent, based upon the current analysis completed.

Recommendation

Based on the above considerations, the PL preferred option cannot be endorsed and Community Infrastructure Designation (CID) should not be granted. The EIS has failed to address all of the relevant and cheaper options. The PL preferred option is clearly not the cheapest option and will not pass the regulatory test as required by the Australian Energy Regulator. The CID should be refused and PAGE asks that an independent and transparent assessment be made of the options proposed in this document and that the lowest impact and cheapest option be selected that meets the network requirements.

PAGE further recommends that should an alternative option be considered a more appropriate alternative that the Community Infrastructure Designation process be abandoned for the Powerlink proposal and the cheaper options outlined in this submission be assessed with a view to eventual designation when actually required in 2027 at the earliest.

Full Submission Document Link

The full submission can be downloaded from this link (967kB):

PAGE CID Submission – Alternative Proposal

An alternative powerline upgrade proposed by Noosa hinterland residents would save taxpayers at least $8.2 million compared to the proposed Powerlink route.

Powerlines Action Group Eumundi has made a submission to Michael Choi, parliamentary secretary of Energy Minister Stephen Robertson which it hopes will halt high voltage pylons cutting through Ridgewood and Eerwah Vale.

PAGE president Jack Connolly said on Friday it looked as though their counter proposal may see the minister consider his options.

He was told officially that Mr Robertson’s community infrastructure designation – the green light to start buying land for the route – was to have been made last week.

This was after the post-Easter week deadline was extended.

Mr Connolly, in a letter to Mr Choi, who recently inspected the proposed areas, said PAGE’s proposal makes use of existing infrastructure corridors and “avoids additional environmental impacts”.

The lobby group maintains there would be no new fragmentation of koala habitat, and had better access for construction and maintenance.

Part of the PAGE route follows the existing Bruce Highway

“Since the inception of the Powerlink project, the growth patterns in population have changed,” Mr Connolly wrote.

“Noosa area is now projected to grow at a lower rate than anticipated and the Gympie region is projected to grow at a higher rate.

“PAGE contend that the PL (Powerlink) solution, contrary to the EIS, will not meet the power requirements for the Gympie region in the long term and additional augmentation will be required making the PL solution more costly than disclosed.”

PAGE claimed any excess energy requirements that may be required on the northern Sunshine Coast could be delivered via the new Energex Pacific Paradise project “which reinforces the Noosa area”.

Powerlink said upcoming consultation, as part of the designation process, will provide a formal opportunity for all interested stakeholders to make further comment.

Powerlink chief operating officer Simon Bartlett said that the formal process for the Woolooga to Eerwah Vale Transmission Line and Eerwah Vale Substation project under the Sustainable Planning Act 2009 was still under way.

“Specialist environment consultant Parsons Brinckerhoff (PB) assessed 12 different routes for the new powerline in the Final Environmental Impact Statement (EIS) for the project,” Mr Bartlett said.

“This assessment included all alternative route submissions that had been provided to Powerlink by the Powerlines Action Group Eumundi (PAGE) and/or community members at that point in time.

Some of the 12 routes included alignments alongside the Bruce Highway for part of the way.

“It is understood that since the conclusion of the Final EIS, PAGE has developed another highway option.”

Mr Bartlett said the designation consultation process would commence in early May Powerlink wrote to all stakeholders, including landowners whose properties were expected to be directly affected by the project, advising of its intention to seek ministerial designation of the land required for the project. Advertisements will also appear in local newspapers.

“Landowners, stakeholders and other interested parties will be invited to comment on Powerlink’s proposal to seek ministerial designation.

“All submissions will be addressed,” Mr Bartlett said.

Source: http://www.sunshinecoastdaily.com.au/story/2010/05/04/pages-cost-effective-option/

Read the article below by Isobel Coleman that appeared in the Noosa Journal on 31 December 2009.