Birdlife says reject Walker Group’s Toondah plan

In its EPBC submission Birdlife Australia supported this alternative proposal for upgrading Toondah Harbour

Birdlife Australia proposes a Toondah Harbour upgrade which does not impact on the Moreton Bay Ramsar site.

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

Eastern Curlew at Toondah Harbour

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

Referrals Gateway
Department of the Environment and Energy
GPO Box 787

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:

  1. 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.
  2. 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.
  3. 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.
  4. 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]

Paul Sullivan
Chief Executive Officer
Birdlife Australia

25 May 2017

Other submissions about Walker Group’s EPBC referral

Submissions about Walker Group’s proposed Toondah Harbour project were obtained by Redlands2030 through a crowd funded Freedom of Information (FOI) request.

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

Mayor Williams’ Toondah claims need testing

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


Redlands2030 – 6 October 2017

Please note: Offensive or off-topic comments will be deleted. If offended by any published comment please email

4 thoughts on “Birdlife says reject Walker Group’s Toondah plan

  1. I read with interest the letter below by Jan, who travelled through a number of countries and noted the emphasis they place on their natural treasures and on their wildlife. I have only just returned from an African Wildlife Adventure to the Serengeti and likewise the Government of Tanzania has learnt that it is in their own best interests to conserve their unique wildlife. Australia also has unique wildlife which is endemic to our country and yet I see greed for the dollar jeopardising the very habitat these animals need for survival. If our Federal Environment Minister is swayed by the greed factor I will have no choice other than to vote for another Party and this also goes for state government.

  2. After travelling thru 5 countries and 20,000klms looking at how other communities, some quite poor and underdeveloped, are coping with preserving and showcasing their country with an eye to catching the world’s tourist dollar, it is amazing to see the one feature that shines through when speaking with other travellers about what raised their curiosity about spending large amounts of money on flights, accommodation and local guides at their destinations. It is the unique natural environment and the biology, geology, history that go into making up the individual story. The excitement in their eyes describing an incident of driving back to their hotel at night and their coach having to slow down and turn off the lights as a shadow shifted from the side of the road, and a jaguar lazily stretched up from where it had been resting on a warm road, licked itself over a few times, then slowly moved off alongside the length of the coach. Nobody inside moved! Then next morning, whilst walking alongside a waterfall, cheeky coatamundis prancing around to see if some crumbs cound fall their way. A few days later, walking up some ancient stone staircases, with a lot of other tourists, lazily circling condors high in the sky were still a feature. The some days later, to watch every footstep as baby fur seals or marine iguanas or lava lizards are around your feet nd you have to keep away from them, not the other way around. And each evening or morning, listening to conversations from fellow travellers from UK, USA, Northern Europe all were of the opinion that is was the natural environment that was the draw! We had been to all of the capital cities and also to the main centres and it was bedlam – all wanted out. It was to the natural environment that these people spent their dollars on camera equipment, diving equipment, money on specific guides for some optional side tours, and we were also impressed by the national parks and young guides working to protect what these countries know is precious. They do have their dollar driven developer problems and govt corruption – these are countries that still have missing thousands of children from military juntas etc. But they are trying hard and doing a lot that we could learn from. They have extremely strict guidelines for visiting the UNESCO site at Macho Pichu and also even stricter visitor guidelines for visiting the Galapagos. But it is because they recognise what treasures they have and are prepared to fight to protect them! Our govts, by allowing big business, to take over any of the Toondah RAMSAR would be an unforgiveable slight to Australia’s reputation in any new negotiations we would undertake in regards to protections of the environment. If we can’t keep our promise that we made in the 1970’s to NOT just protect that particular part of Toondah but to EXPAND the wetland, why should anyone want to undertake aanother agreement with us???????

  3. There can be no sensitive development to protect, for example, migratory shorebirds that lists under the RAMSAR Convention the critically endangered Eastern Curlew where, as we have become aware, Walker Corp proposed massive project is strictly for commercial gain. There’s a saying ‘give an inch and they take a yard’…what would be left of environmental value to, we the people of Redlands, once this massive development got underway?
    Minister for Infrastructure Jackie Trad was quick to approve Walker Corp’s plans for Toondah Harbour’s 3600 units, etc to be built on the surrounds in high-rise apartment buildings. Noted following comments I would like to share with you all, in Friday’s CM, Oct6/2017:
    “Qld Labor pocketed $300,000 from a mass cash-for-access event in August that all Palaszczuk Govt ministers were required to attend. Property, mining & gambling businesses were among 27 firms that stumped up for the $5500-a-ticket event, according to an analysis of donation disclosures and ministerial diaries.
    Deputy Premier Jackie Trad, was one of the most popular ministers among the deep-pocketed participants, holding 35 of 99 meetings. Jackie Trad met with the WALKER GROUP whose head Lang Walker boasted of being able to buy politicians”.
    And…as for banning political donations, Greg Hallam of Local Govt Assoc of Qld boss says ‘the problem will only be pushed underground.
    It will be interesting to see what changes will come about from Mr MacSporran’s Report on Crime and Corruption as regards councils in SEQ…

  4. As a senior marine biologist who has carried out a PhD on the zooplankton of Moreton Bay and described 14 new species of marine crustaceans I cannot understand how certain sectors of the Redlands that purport to uphold the responsible and sustainable development of this region of south east Queensland, are in effect supporting the destruction of wildlife for commercial gain. This proposal should be rejected outright by the Australian Federal Environment Minister and those supporting it should be noted because they are not acting in the best interests of the residents or the environment, which is what attracts us to the Redlands.

Comments are closed.