The environmental assessment process for the Toondah Harbour dredging and construction project is expected to be decided by the Federal Government no later than 2 September.
This follows Walker Corporation’s referral of the project to the Government in November 2015 for consideration under the Environment Protection and Biodiversity Conservation (EPBC) Act.
The Government normally makes its decision on an EPBC referral within a few days. The timeframe for a decision on the Toondah referral has been extraordinarily prolonged with four extensions totaling more than eight months.
It appears that this long delay is due to a combination of major shortcomings in Walker Corporation’s plans and robust criticism in many submissions made back in December 2015.
Thirty seven submissions have become publicly available following a Freedom of Information (FOI) Request. Redlands2030 is now publishing these submissions.
Submission 1 – EPBC referral 2015/7612 Toondah Harbour
Referrals, Environment Assessment Branch
Department of the Environment
To whom it may concern,
I make the following submission to the EPBC Act referral, reference number 2015/7612 Walker Group Holdings Pty Ltd/Commercial Development/Moreton Bay/Queensland/Toondah Harbour Project, Moreton Bay, Qld.
- The bilateral agreement between the Commonwealth and the State of Queensland is not applicable in this matter. This application should be a controlled action assessed entirely by the Commonwealth Government.
- The development area impacts on the Moreton Bay Ramsar site. This site meets 6 of the 9 criteria for Ramsar listing. The Moreton Bay Ramsar listing description includes Aboriginal Cultural heritage.
- The flora and fauna surveys taken by the proponent are inadequate. The survey was only conducted over three days which is insufficient sample effort to ensure all species are sampled and distribution and abundance properly established. Seasonal, weather and tidal variation cannot be accounted for over such a short time. For example migratory birds are not generally present in winter when the sampling was done. Weather and tide conditions can affect activity of many species requiring sample effort to be spread over a greater period than 3 days.
- The site is likely to support a number of EPBC listed species eg dugong, green turtle, migratory birds and Illidge’s ant blue butterfly. The site contains endangered salt marsh communities
- The development will result in creased boat traffic, which has the potential to harm seagrass habitats used by green turtles, dugongs and migratory birds. Potential harm includes boat strike and\ or damage to habitat. The proposed development has the potential to change natural seawater movements.
- The application has not dealt appropriately with Indigenous Cultural heritage values and yet Indigenous culture is listed as a key feature of the Moreton Bay Ramsar site listing: Moreton Bay Ramsar site lies in the traditional estate of a number of Indigenous groups including the Kabi Kabi, Jagera and Turrbal, Quandamooka (Ngugi, Noonucle, Gorenpul), and Yugambeh and Ngarang-Wal/Kombumeri. Evidence from these excavations and other archaeological sites discovered in Moreton Bay indicates that fishing, the collection of shellfish and the gathering of local food plants were important activities for Indigenous peoples living in the region.
In conclusion, I submit that the applicant’s environmental and cultural studies are inadequate.
There is an unacceptable risk of harm to values of national environmental significance.
I submit the Commonwealth should reject this proposal.
This submission has been extracted from a pdf document provided to Redlands2030 by the Department of the Environment.
In many cases, the name and contact details of the person or organisation making a submission have not been made publicly available, indicated by “S47F”.
Submission number is by Redlands2030, reflecting the order of publication on our website.