National Parks Association Toondah submission

National Parks Association of queensland made a submission opposing Walker Group's proposed Toondah Harbour project

Hundreds of cormorants and a few pelicans in the Moreton Bay Ramsar site near the entrance to Toondah Harbour

The National Parks Association of Queensland wants the Federal Government to honour its commitment to protect Ramsar wetlands through rejecting the Toondah Harbour proposal.

The Association has been around since 1930 promoting the preservation, expansion, good management and presentation of national parks and other protected areas in Queensland.

You can find more information about the National Parks Association of Queensland on its website.

Recently, the Association has campaigned against a developer’s plan to revoke 31 hectares of national park on Lindeman Island in the Whitsundays.

In its submission about the Walker Group’s proposed Toondah Harbour project, the Association lists a number of environmental concerns and says any environmental assessment of the project should not be managed by the Queensland Government due to its potential conflict of interest.

Here is the full text of the submission made by the National Parks Association of Queensland.

National Parks Association of Queensland Submission

Thank you for the opportunity to comment on the Toondah Harbour Project EPBC Referral (2017/7939) and supporting documents.

The National Parks Association of Queensland (NPAQ) is dedicated to promoting the preservation, expansion, good management and presentation of national parks and other protected areas in Queensland.

Established in 1930, NPAQ is an independent, not-for-profit, membership-based organisation. The association has played a pivotal role in the establishment of many national parks in Queensland. NPAQ’s purpose is achieved through advocating for the protection, expansion and good management of the protected area estate in Queensland; fostering the appreciation and enjoyment of nature through a bushwalking and outdoor activities program; undertaking on-ground conservation and monitoring work; educating the community about national parks and their benefits; and supporting the development and application of scientific and professional knowledge in advancing national parks and nature conservation.


NPAQ supports an upgrade to the Stradbroke Island ferry terminal to provide the public with improved access to Naree Budjong Djara National Park (North Stradbroke Island). However, the scale and extent of the Toondah Harbour Project is inappropriate for the sensitivity and significance of the project area given as its location is within and adjacent to the Moreton Bay Ramsar wetland, an internationally recognised protected area.

NPAQ is concerned with the direct and indirect impacts of the proposed development on the Moreton Bay Ramsar wetland, migratory birds, terrestrial and marine threatened species and seagrasses. NPAQ priority concerns include:

  • Significant direct impacts on over 40 hectares of the Moreton Bay Ramsar wetland thereby undermining the environmental values of the internationally important protected wetland.
  • Significant impacts on several EPBC Act listed migratory bird species including the critically endangered Eastern Curlew and the critically endangered Great Knot associated with loss of habitat.
  • Significant impacts on the local koala population associated with vegetation clearing, traffic during and after construction, and other threats relating to the high proposed residential population.
  • Significant loss of seagrass, which is part of migratory bird feeding grounds and is also important to for dugongs and turtles, and for fish and prawn breeding.
  • Significant indirect impacts on the Ramsar wetland and the abovementioned matters of national environmental significance associated with sedimentation from dredging, litter and runoff from several thousand people residing in thousands of proposed dwellings, etc.

Declaration of international protected areas is only made following a rigorous assessment process and is made for the benefit of existing and future generations. The proposed action, which is of largely commercial interest with little public gain, provides no valid justification for significantly undermining the environmental values of the protected Moreton Bay Ramsar wetlands and other mattes of national environmental significance.

Australia’s commitment to protect Ramsar wetlands should be honoured through rejecting the Toondah Harbour Proposal, thereby providing continued protection of the area for existing and future generations. Also, the project, as a joint initiative of the Queensland government and Redland City Council, should never be considered for assessment under the Queensland environmental assessment bilateral agreement due to the potential conflict of interest.

Yours sincerely

Laura Hahn
Conservation Officer
National Parks Association of Queensland

25 May 2017

Other submissions about Walker Group’s EPBC referral

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

The 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.

Other submissions about Walker Group’s proposed Toondah project are discussed in these Redlands2030 stories:


Redlands2030 – 13 September 2017

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One thought on “National Parks Association Toondah submission

  1. I think that the National Park Association makes many good points in its submission. the one that stand out for me is that the type and scale of development is inappropriate for the area. Yes we need the harbour facilities to be upgraded, there is no argument about that at least from me. However, to build 3 600 apartments, plus the commercial area is overkill. the scale of development will have significant adverse effects on the RAMSAR site.

    Let me ut this into context, we residents of Redlands still not have been told what exactly what development is proposed; our elected representatives cannot tell us because they are bound by commerical confidentiality. What we have been told is proposed for TH is too large for the area. It would need to be significantly reduced to decrease its environmental impact. Why is this immportant? We know that the Walker Corporation will not be held responsible for the environmental damage that the development causes. The bill for that will be picked up by the rate payers of Redlands. That is how the costs are alloccated in our economic system. Environmental damage is treated as an externality and therefore not included as a cost for the developer.

    That is why in an earlier post I want to know what is it going to cost Redland ratepayers upfront for the TH development to go ahead. The council should be able to provide an estimate of this cost, if it cannot, then in my opinion the council has not made an informed decision. How much are the sweetners that council is giving the Walker Corporation to develop TH costing ratepayers? That should be a straightforward accounting exercise for the council to calculate. The more difficult one is calculating the cost of mitigating the environmental damage to the adjacent areas. What are the social costs of loss of amenities for the existing residents of area impacted directly by noise and traffic congestion arising from the development? What will be the impact on the health snd well-being of those residents and the impacts on their productivity?

    All these costs will affect the budget of the Redands City Council in at least two ways: 1. the sources of income; 2. items of expenditure. the developer will not be required to cover the costs of loss of amenity, nor the other social problems that are created, but council will. To cover the extra expenditure, the rates will need to be increased. In that case, the rate payers will be asked to cover the extra expenditure incurred because of the nature of the TH devlopment.

    In conclusion, there is a significant cost that accrues to the ratepayers of Redlands City from developments such as TH. Council has not told us upfront what those costs will be. We know what the Walker Corporation is contributing, but we have no idea what Council is contributing and its impact on our household expenditure though increased rates.

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