Walker Group’s proposed Toondah Harbour development is clearly unacceptable and should be rejected said Birdlife Australia in its EPBC submission to the Federal Government.
Points raised by Birdlife Australia include:
- The project would encroach on 43 hectares of the Moreton Bay Ramsar site which is not permitted under the Ramsar Convention where the project is for commercial gain.
- Proposed development would significant impacts on Matters of National Environmental Significance protected under the EPBC Act (1999)
- The project would conflict with Australia’s international obligations to protect migratory shorebirds, especially the critically endangered Eastern Curlew
Birdlife Australia is a “science-based conservation group” with over 110,000 supporters.
Their submission calls on the Government to uphold its obligations under the Ramsar Convention and reject Walker Group’s development proposal.
Birdlife Australia’s submission about the proposed Toondah development’s assessment under the Environment Protection and Biodiversity Conservation (EPBC) Act is published below in full.
Hyperlinks for some documents referenced in and attached to the Birdlife Australia submission have been included by Redlands2030.
Birdlife Australia submission on Toondah Harbour Project
Department of the Environment and Energy
GPO Box 787
CANBERRA ACT 2601
Re: Reference Number: 2017/7939
Thank you for the opportunity to comment on the WALKER GROUP HOLDINGS PTY LIMITED/Residential Development/L58 on SP115554, L1 on RP145396, L33-35 on C618, L20 on SP 153278, L79 on SL7088, L119 on SL9713/Queensland Toondah Harbour Development proposal.
Birdlife Australia is an independent science-based conservation organisation with over 110,000 supporters throughout Australia. Birdlife Australia is recognised as a leading authority on the ecology and conservation of Australia’s shorebirds. Birdlife Australia’s Shorebirds 2020 Program and our Special Interest Group, the Australasian Wader Studies Group (AWSG), conduct and promote shorebird research and conservation throughout Australasia and the East Asian Australasian Flyway. This project should be declared Clearly Unacceptable as it is expected to have significant impacts on Matters of National Environmental Significance protected under the EPBC Act (1999).
The revised proposal by the Walker group submitted to the Department of Environment and Energy on the 11th May, 2017 fails to address Birdlife Australia’s previously expressed concerns. Therefore our objections to this development , which we raised with the Minister in August 2016, are unchanged.
Birdlife Australia believes the Project should be declared Clearly Unacceptable due to the proponent’s intention to encroach on approximately 43 hectares of the Moreton Bay Ramsar site.
Australia’s obligations under the Ramsar Convention make any plan developed within a Ramsar site for commercial gain unacceptable.
Further to this, we believe that the proposal should be rejected because:
- The Australian Government’s Wildlife Conservation Plan for Migratory Shorebirds (2016) identifies the need to protect migratory shorebird habitat across the flyway, including important habitat here in Australia. The Conservation Advice for the Eastern Curlew clearly identifies Australia’s obligation to maintain and improve protection of all feeding and roosting sites in Australia. Further, we are not aware of any evidence that feeding habitat can be successfully recreated for this species.Australia is also obligated under several international agreements to protect migratory shorebird habitat in Australia, including the Ramsar Convention, the International Single Species Action Plan for the Conservation of Far Eastern Curlew, the Convention on Migratory Species and CAMBA, ROKAMBA and JAMBA bilateral agreements.
- The referral documents acknowledge the significance of the area for shorebirds, including the Nandeebie Claypan and Cassim Island as roost sites. It is noted that the number of Eastern Curlew lost through reclamation exceeds the average number of Eastern Curlew found feeding within the Ramsar site.
- The referral implies that the mitigation actions proposed will limit the impact of the development. Further, it goes on to minimise the effect of these factors by alluding to the potential for birds to move to other roost sites and find alternate feeding grounds. It cites the decline in shorebird numbers in the Moreton bay Ramsar site as evidence of the capacity of the ecosystem to absorb these changes. We contest these findings. The mitigation actions proposed by the developer are inadequate. Part of the current roost site will be within 30 metres of the development. Given that human activity will be markedly increased, and given that the Eastern Curlew are extremely sensitive to disturbance, it is highly likely this increased disturbance will negatively impact on the birds’ capacity to reach the critical body mass to successfully migrate and breed.
- Whilst the number of marina berths has been reduced in the revised plan, the number of dwellings remains unchanged. The proponent has provided no additional information related to:
- a. plans to mitigate the impact of the build (during the dewatering phase and construction phase); or
- b. plans to demonstrate they are able to manage the impact from disturbance of acid sulphate soils – a factor acknowledged in its previous submission.
Given the known difficulties and costs associated with the management of Acid Sulphate (AS) soils, we believe this issue cannot be appropriately mitigated. The potential threat associated with acid water and AS leaching into the Marine Park/Ramsar site, and the impact this would have on the health of the entire ecosystem, far outweighs the perceived short-term benefits of the development. It calls into question the entire premise that the area has capacity to with stand and absorb the disturbances associated with this build.
Birdlife Australia is not against environmentally sensitive development of Toondah harbour. Over 12 months ago we provided an alternative plan to the Queensland Department of Environment and Heritage as well as the Federal Minister for Environment and Energy. This plan develops the ferry terminal to the level required to support tourism initiatives for North Stradbroke Island, and develops the foreshore without any encroachment into the Ramsar site. These plans are attached for your information.
In conclusion, the development as it currently stands will have a significant and unacceptable impact on the Ramsar site and Moreton Bay Marine Park, and destroy critically endangered species habitat. Any development that intends to reclaim part of a Ramsar site should be declared a clearly unacceptable action under the EPBC Act. We call on the Australian Government to uphold its obligations under the Ramsar Convention and reject this development proposal.
Thank you for the opportunity to comment on this matter.
If you have any further questions please contact Samantha Vine [contact details redacted by FOI decision]
Chief Executive Officer
25 May 2017
Other submissions about Walker Group’s EPBC referral
The Federal Government says that in response to Walker Group’s latest EPBC referral there were 1,419 submissions – 1,411 opposing and eight supporting the project.
Many of the submissions have been published by Redlands2030 – links are included below:
|Opposing submissions||Supporting submissions|
|1,411 submissions opposed the project referral||8 submissions supported the project referral|
|Toondah is clearly unacceptable says Birdlife|
|Ramsar Secretariat warns on Toondah impacts||Toondah project gets support from Grand View|
|Jobs impact of Toondah overstated, dishonest||Brisbane Marketing submission on Toondah|
|Walker Group’s Toondah plan is unacceptable||Property Council advocates for Toondah project|
|AMCS says Marine Park is too valuable to risk||Infrastructure Association supports Toondah|
|National Parks Association Toondah submission||Straddie Chamber supports Toondah project|
|Don’t take Toondah treasures from us||Sealink profit up but Straddie route challenging|