Comments on Walker Group’s revised plans for constructing 3,600 apartments on dredged Ramsar wetlands next to Toondah Harbour can be submitted to the Federal Government by Thursday 25 May.
Presented below are some preliminary comments from Redlands2030 which may assist others in making comments.
Details of the project referral
Reference Number: 2017/7939
Title of Referral: WALKER GROUP HOLDINGS PTY LIMITED/Residential Development/L58 on SP115554, L1 on RP145396, L33-35 on C618, L20 on SP153278, L79 on SL7088, L119 on SL9713/Queensland/Toondah Harbour Development.
Support for the project is overstated
In its referral Walker Group implies that its proposed project is widely supported by listing a number of Government plans and policies. These documents are cited in the context of a project promoted on the basis of an upgrade of the Toondah ferry and barge facilities. The rational for the project has shifted to a massive coastal residential development, of a type and scale unlikely to be considered in NSW, Victoria and Tasmania.
Where are the community benefits?
The State Government has claimed that the proposed development will result in 1,000 construction jobs and 500 permanent jobs but these figures have not been substantiated publicly. It seems to be usual practice for project developers and governments to overstate job numbers in an attempt to get public support for projects which are not acceptable to the community.
Even if the project were to result in creation of 500 permanent jobs, the effect of building 3,600 apartments on the Cleveland foreshore will be to increase the area’s population by 7,000 to 10,000 people requiring 3,000-5,000 new jobs which are most unlikely to be available locally. The net result will be to increase the number of people in south east Queensland who have to commute on overloaded transport infrastructure to obtain employment.
Attempts by the State Labor Government to pitch the construction of apartments on Ramsar wetlands near Cleveland as mitigation for closure of sand mining on North Stradbroke Island are dishonest. The employment impact of ending sand mining on North Stradbroke Island has been regularly overstated by the mining company and politicans.
Claims were made by Redland City Council in December 2015 that the project will deliver community infrastructure worth $116 million. The Council said that it would publish the agreement in early 2016, well over a year ago. The community is still waiting for this information to be released.
The revised plans submitted by Walker Group on 11 May 2017 show a significant reduction in new foreshore parks, raising further questions about the value of benefits to the community resulting from the privatisation of land and waters which are currently open space.
Community consultation about development at Toondah Harbour
This project has not been the subject of a proper community consultation process.
In 2014 a flawed community consultation process was undertaken by the Queensland Government and Redland City Council. The scale of development proposed at that time was much less than the work which Walker Group now proposes to undertake. In the 2014 consultation process the community was not properly informed about the costs and benefits of development in the Toondah Harbour Priority Development Area. Technical studies including environmental reports were withheld from the community until after the consultation period closed.
Given the rational for the project has shifted from the renovation of a barge and ferry terminal to a massive residential development the findings of the 2014 Consultation Report included in Walker Group’s referral should be totally disregarded.
Since it was selected as the preferred developer in 2014 Walker Group has shown itself to be inadequate at community consultation. The project website established in late 2015 has rarely been updated. Walker Group has not held any community consultation activities open to the public.
Since 2014 the community has come to realise that the scale of the development will have significant adverse impacts on their livability, with extra traffic being funnelled onto existing streets, existing infrastructure being overloaded, and promised new community assets being inadequate for the additional population. Promises of local jobs will not meet the needs of the additional residents.
As the community becomes increasingly aware of the proposed project’s environmental destruction, concerns are not being publicly addressed by the Walker Group.
Environmental impacts of the project are understated
The proposed project would adversely impact on an area which uniquely combines internationally significant wetlands, habitat for migratory shorebirds and a healthy koala population.
Proposed dredging activity would destroy many hectares of seagrass beds and probably harm corals establishing on Cassim Island and perhaps elsewhere in the Bay such as nearby Peel Island.
It is clear from Walker Group’s referral that the proposed project would destroy feeding grounds for migratory shorebirds including the critically endangered Eastern Curlew which is the subject of a single species recovery plan lead by the Federal Government.
Other species likely to be impacted include various turtle species and dugongs which feed on sea grass and have been observed in the Toondah area.
The scale of residential development proposed by Walker Group would have unacceptable impacts on the local koalas. The extra traffic from people living in the proposed 3,600 units added to streets regularly crossed by the Toondah koalas is likely to be the prime cause of fatalities.
Walker Group’s referral ignores the cumulative impacts from existing and proposed developments (including the massive 4,000 lots Shoreline project) and the known water quality problems in Moreton Bay. The methodology for assessing and managing water quality is unduly reliant on a “steady state” approach which lack an appreciation of existing problems and current trends. Given the fragile nature of the Bay and broader trends a more sophisticated framework for assessing impacts in the Bay is needed.
EPBC referral guidelines specify the need to “provide a detailed description of the proposed action including all proposed activities”, certain key elements of the construction appear to be either missing entirely from the description or lacking in detail. These include:
- construction materials for bunds, revetments, slope protection etc including; volumes, sourcing, transport and placement.
- the forms of building construction (including foundations), methods of construction and duration, in particular for locations close to sensitive areas.
- transport methods for major construction materials to site by land and/or water.
- the likely extent of vibration, noise, dust and pollutants produced in the construction processes.
- traffic and other significant activities generated by the development itself (land and waterborne).
Unlike the previous referral which contemplated a possible need to import fill, this time the construction proposals appear entirely reliant on the reuse of dredged (and excavated) material. While this approach may be considered consistent with good civil engineering practice, the geotechnical basis for achieving such a goal on this particular site may give rise to some doubt.
Suitability of Walker Group Holdings Pty Ltd
Any organisation undertaking work in such an environmentally sensitive area, impacting on matters of national environmental significance should have an excellent record of environmental management and a well-established environmental policy and planning framework.
Walker Group has failed in its referral to provide details of a corporate environmental policy and planning framework. This is unacceptable. They have had 17 months since their original Toondah Harbour referral to prepare and adopt an environmental policy and planning framework
Walker Group entities have on three occasions been found guilty of illegal land clearing. In one instance a NSW record fine was imposed and upheld on appeal to the NSW Court of Criminal Appeal. In another instance the Magistrate said “the offence reeked of incompetence”.
Walker Group has never done work as a controlled action under the EPBC Act.
Walker Group has failed to provide evidence that it has the experience and management capability to undertake an environmentally risky project in an area with high environmental values.
Responsibility for assessment
In its Referral, Walker Group says it wants the project assessment to be conducted by the Queensland Government under the Queensland environmental assessment bilateral agreement.
The Toondah Harbour Priority Development Area is established under the Economic Development Act 2012 which is not subject to the Bilateral Agreement.
If the Federal Government were to approve further investigation of this troubling project as an EPBC controlled action any assessment should be conducted by the Federal Government.
The Queensland Government has a conflict of interest in being a strong proponent of this development.
In proposing and supporting a massive disturbance in an area which is both Ramsar Wetlands and a habitat for critically endangered migratory shorebirds the Queensland Government has shown a lack of concern for matters of national environmental significance, regulated by the EPBC Act.
Government (and Opposition) in Queensland are regular recipient of financial donations from the Walker Group (and its related entities).
If the Federal Government were to allow the Queensland Government to manage the environmental assessment process, any findings may lack credibility and the process would have reduced community acceptance.
Submit your comments
Anyone can make a Submission to the Federal Government.
You can use the above Redlands2030 comments by cutting and pasting them into your submission, or you can add to or amend these comments, or write your own.
Guidelines for making a submission are available here.
When making your submission be sure to include your name and contact details.
The deadline for making submissions is Thursday 25 May 2017
Submissions can be emailed to: