Toondah Project a dangerous precedent

Green turtles frequent the seagrass in the proposed Toondah Harbour development area

Green turtle grazing on seagrass Stock photo by P. Lindgren Wikimedia Commons

Urban development in a Ramsar site would set a dangerous precedent said the Wildlife Preservation Society of Queensland Bayside Branch in its submission about Walker Corporation’s Toondah project.

The Redlands based conservation group said the Federal Government should reject the proposal because:

There are a wide and diverse range of State and National Matters of National Significance that will be destroyed and or put under threat by the proposed development.

The submission criticised the flora and fauna studies submitted by Walker Corporation as being “minimalist” and understating the value of ecosystems and species present in the area proposed for development.

Walker Corporation’s suitability for doing a project of this type is questioned in the submission which notes:

The referral documentation indicates the proponent was found guilty of clearing native vegetation without consent on a number of occasions.

The submission argues that the Queensland Government is unsuitable to be engaged in the assessment of this proposed development, saying:

 the Queensland Government has shown nothing but contempt for protecting Matters of National Significance.

Federal Government assessment of the Toondah Harbour Project

In late 2015 Walker Corporation referred its proposed Toondah Harbour project to the Federal Government for assessment of matters of national environmental significance.

Normally, the Federal Government makes its decision on a project referral within ten business days after the closing date for lodgement of submissions.

Extraordinarily, the Government’s decision on Walker Corporation’s proposal has been delayed five times, by almost a year.

The Federal Government invited comments on Walker Corporation’s referral and received many submissions. Redlands2030 has already published four of the submissions which have been made publicly available:

Here is the submission by Wildlife Preservation Society of Queensland Bayside Branch.

Submission 5 – EPBC referral 2015/7612 Toondah Harbour

Referrals
Environment Assessment Branch
Department of the Environment
GPO Box 787
Canberra ACT 2601
Friday, 4 December 2015

Dear Sir or Madam
We make the following submission to the EPBC Act Referral – 2015/7612; Walker Group Holdings Pty Limited/Commercial Development/Moreton Bay/Queensland/Toondah Harbour Project, Moreton Bay, Qld.

Bilateral agreement is not applicable

1. The bilateral agreement between the Commonwealth and the State of Queensland is not applicable in this matter.

The assessment of the project to date has been undertaken under the direction and provisions of the Economic Development Act 2012. Refer to item 8.1 References in the proponents ‘Referral of proposed Action.” The Economic Development Act 2012 is not a legal planning instrument recognised by the bilateral agreement. The Economic Development Act 2012 gives the Minister broad powers to the extent that any decision made is not bound to adhere to requirements in relevant planning instruments, such as those mentioned in the Bilateral Agreement.

Economic Development Act 2012, which the Queensland Government initiated indicates the objective of the Queensland Government is about development and not about the protection of the environment as required by Section 5(a) of the bilateral agreement. All key environmental studies and considerations to date undertaken by the proponent and State Government have been undertaken under the provisions and guidance of the Economic Development Act 2012. Any studies and findings produced by the proponent in support of the referral are tainted by the pro-development focus of the Economic Development Act 2012 and should accordingly be discounted.

As the Economic Development Act 2012 is not recognised by the Bilateral Agreement, any material produced by the proponent under this legislation should not be considered and therefore the Referral should be rejected.

The Queensland Government has shown impotence and disregard for the protection of State and National matters of Environmental Significance. This is clearly reflected in the DRAFT local planning scheme for the Redlands, the local authority area in which the subject site is located. The State Government authorised the release of this draft legal planning instrument for public comment clearly understanding that it removed protection for koala habitat and encouraged intensive commercial development adjacent to the Moreton Bay RAMSAR site and Marine National Park (MN24). Both the koala and RAMSAR site are matters of National Environmental Significance. To date the Queensland Government has shown nothing but contempt for protecting Matters of National Significance.

Accordingly the Queensland Government is unsuitable to be engaged in the assessment of this proposed development.

We strongly recommend that this is a controlled action that should be subject solely to the scrutiny of the Commonwealth Government.

Minimalist approach of fauna and flora studies

2. A minimalist approach was adopted to the fauna and flora surveys.

Figure 1: location of reef communities in subject area. Source: Moreton Bay Dredge Material Placement Study, Stage 2.

Figure 1: location of reef communities in subject area. Source: Moreton Bay Dredge Material Placement Study, Stage 2.

This is highlighted by an omission of a number of factors that impact upon matters of National Environmental Significance. The studies supporting this referral were completed over a 3 day period showing a failure to consider seasonal and climatic trends, which impact upon the presence of species and the health of species. The studies were undertaken between the 5 – 8th July, 2013. July is a period when migratory wader birds are chiefly absent from Moreton Bay and Australia and seagrass is at its lowest density due to cooler conditions and reduced daylight hours.

The subject site supports dugongs, noted by the Citizen Science projects involving seagrass and mangrove monitoring. https://wildlifebayside.wordpress.com/ Dugong feeding trails have been noted through adjacent seagrass meadows to the North of the proposed development and dugongs sited feeding 25 metres directly to the East of the Mangrove community found within the Southern section of the subject area. Green Turtles are commonly noted feeding on seagrass within the subject area.

The subject area is noted for supporting seagrass and mangrove habitat, both habitats are critical to a number of species listed as matters of National Environmental Significance, which includes Dugongs, Green Turtle and migratory wader birds. There is a reef (including coral communities) immediately adjacent to the North as highlighted by Map 9C, 2.8.3 ‘Areas of Coastal Biodiversity Significance’, SEQ Regional Coastal Plan, Oct 2005. (See Fig. 2).

Figure 2: State Significant Coastal values. Seagrass, shorebird habitat and Reefs. Source: SEQ Coastal Management Plan. Areas of state significance (Natural Resources), August 2003.

Figure 2: State Significant Coastal values. Seagrass, shorebird habitat and Reefs.
Source: SEQ Coastal Management Plan. Areas of state significance (Natural Resources),
August 2003.

The Moreton Bay Dredge Material Placement Study, Stage 2 Report likewise highlights the sparse coral communities in Figure 7.4 ‘Coral and Rocky Reef Communities’, 28th June 2006 (See Fig. 1). The subject area is also noted as supporting critical shorebird habitat as highlighted by Map 9B, 2.8.3 ‘Areas of Coastal Biodiversity Significance’, SEQ Regional Coastal Plan, Oct 2005. A critical migratory roost site is directly adjacent to the subject site to the South of the subject site. The mangrove communities located in the Southern section of the proposed development currently provide a buffer to human disturbance emanating from Toondah Harbour. Any development in this area is likely to have a negative impact upon these Significant Environmental values.

The subject site likely supports a population of Illidge’s ant blue butterfly, Acrodipsas illidgei, listed as Vulnerable under the Queensland Nature Conservation Act. Refer to QLD Govt. https://environment.ehp.qld.gov.au/species-search/details/?id=27# Hagan (1980) – Recent records of Acrodipsas illidgei (Waterhouse and Lyell) (Lepidoptera: Lycaenidae) from the Brisbane area, Queensland, Aust. Ent Mag. 7(3), November , 1980. Beale & Zalucki (1995), Status and distribution of Acrodipsas illidgei (Waterhouse and Lyell) (Lepidoptera: Lycaenidae) at Redland Bay, southeastern Queensland, and a new plant-association record. Journal of the Australian Entomological Society 34: 163-168. These studies show that the subject site and adjacent areas have high potential to support further populations of this rare species. Hill & Michaelis (1988) identified urbanisation as a threat. Dunn et al. (1994) identified clearing, marina construction and land reclamation as threats. Damage and disturbance to mangrove habitats has affected A. illidgei, especially removal of old growth Avicennia marina (> ca 12 cm B.D.) and other vegetation (e.g eucalypts and casuarinas) growing near, or at the edge of, mangroves.

The studies provided in support of the referral understate the value of ecosystems and species present. The proponent’s studies (Pg. 13 Ecology study) seems to suggest that the loss of salt marsh communities is offset because similar habitat is nearby. This is an endangered ecological community subject to potential widespread loss due to sea level rise. Many studies and media articles highlight the varied important ecological services that salt marsh provide Laegdsgaard (2006) is a point in case. The proponent’s studies fail to highlight this point. The proponent’s studies did highlight the high value seagrass in the Northern section of the subject area, a seagrass community utilised by dugongs based on sightings and feeding trails. Likewise the mangrove community in Southern section of the subject area was identified as having high value. Whilst these high values were identified as such on Page 13 the same study goes on further on Page 22 to suggest the seagrass is of marginal value. The schizophrenic tone of the subject studies is typical of EIS studies undertaken in Queensland as they wrestle with reporting ecological values and meeting customer expectations.

Studies understate the value of ecosystems and species

3. The studies provided in support of the referral understate the value of ecosystems and species present.

The proponent’s studies (Pg. 13 Ecology study) seems to suggest that the loss of salt marsh communities is offset because similar habitat is nearby. This is an endangered ecological community subject to potential widespread loss due to sea level rise. Many studies and media articles highlight the varied important ecological services that salt marsh provide Laegdsgaard (2006) is a point in case. The proponent’s studies fail to highlight this point.

The proponent’s studies did highlight the high value seagrass in the Northern section of the subject area, a seagrass community utilised by dugongs based on sightings and feeding trails. Likewise the mangrove community in Southern section of the subject area was identified as having high value. Whilst these high values were identified as such on Page 13 the same study goes on further on Page 22 to suggest the seagrass is of marginal value. The schizophrenic tone of the subject studies is typical of EIS studies undertaken in Queensland as they wrestle with reporting ecological values and meeting customer expectations.

WPSQ seagrass monitoring program, which has been in progress since 2001 shows the area supports a healthy but dynamic seagrass community. Figure 3 shows our Cleveland seagrass monitoring sites, CL 1 and CL2. CL2 is closer to the subject site and is representative of the seagrass communities in that area. Dugong trails have been noted South of CL2. The fluctuations in seagrass density are not a factor that the proponent’s study would identify in their 3 day study.

Seagrass summary data for Cleveland site 2. Cleveland, QLD seagrass monitoring sites. Habitat loss and fragmentation are recognised by Queensland Shorebird Management Strategy Moreton Bay as threats to migratory species. Fragmentation of habitat forces migratory species to forage further
and disrupt foraging habits. Further, fidelity of long-distance migratory birds to sites in their non-breeding grounds can have a major influence on their foraging and roosting success and survival (Coleman & Milton, 2012). The subject areas supports Critical Shore Bird Habitat as shown in Map 9B, 2.8.3 ‘Areas of Coastal Biodiversity Significance’, South-east Queensland Regional Coastal Plan. These impacts and issues are poorly defined in the proponent’s studies.

Habitat loss and fragmentation are recognised by Queensland Shorebird Management Strategy Moreton Bay as threats to migratory species. Fragmentation of habitat forces migratory species to forage further and disrupt foraging habits. Further, fidelity of longdistance migratory birds to sites in their non-breeding grounds can have a major influence on their foraging and roosting success and survival (Coleman & Milton, 2012). The subject
areas supports Critical Shore Bird Habitat as shown in Map 9B, 2.8.3 ‘Areas of Coastal Biodiversity Significance’, South-east Queensland Regional Coastal Plan.

These impacts and issues are poorly defined in the proponent’s studies. The proposed development will result in increased boat traffic representing a significant threat to turtles and dugongs. Moreton Bay is recognised by the Queensland Government as having the highest number of turtle fatalities due to boat strikes.

Despite our disappointment with the proponent’s studies it does form the basis of a strong case as to why the Commonwealth should reject this proposal. There are a wide and diverse range of State and National Matters of National Significance that will be destroyed and or put under threat by the proposed development.

We believe the proponent’s studies, inadequate as they are, and the material we have supplied provide a clear case to reject this proposal. The development has been clearly shown to have an unacceptable, significant and long term detrimental impact upon Matters of National Environmental Significance.

The referral documentation indicates the proponent was found guilty of clearing native vegetation without consent on a number of occasions. We raise concerns about their attention to protecting ecological values and the State Government’s enthusiastic support.

We strongly recommend that the Commonwealth reject the urbanisation of a RAMSAR site, despite the fact it is inconsistent with the ‘Wise Use’ principles of RAMSAR it sets a very dangerous precedent.

Yours sincerely

Wildlife Preservation Society of Queensland Bayside Branch (QLD) Inc.

References:

Coleman, JT and Milton, David A. Feeding and roost site fidelity of two migratory shorebirds in Moreton Bay, South-Eastern Queensland, Australia. Sunbird: Journal of the Queensland Ornithological Society, Vol. 42, No. 2, Dec 2012: 41-51.

Dunn, K.L., Kitching, R.L. and Dexter, E.M. 1994. The National Conservation Status of Australian butterflies. A report to Australian National Parks and Wildlife Service, Canberra ACT.

Hill, L. and Michaelis, F.B. 1988. Conservation of insects and related wildlife. Australian National Parks and Wildlife Service Occasional Paper No. 13.

Laegdsgaard, P. (2006). “Ecology, disturbance and restoration of coastal saltmarsh in Australia: a review.” Wetlands Ecology and Management 14(5): 379-399

Publication details

This submission, by the Wildlife Preservation Society of Queensland Bayside Branch (QLD) Inc., was extracted from a pdf document containing information provided to Redlands2030 by Australia’s Department of the Environment.

This information became publicly available via the Department’s Disclosure Log following a Freedom of Information request which Redlands2030 understands to have been submitted by Walker Corporation.

All of the submissions made publicly available by the Government can now be accessed from the Redlands2030 website via these two links:

Published by Redlands2030 – 2 September 2016

Please note: Offensive or off-topic comments will be deleted. If offended by any published comment please email thereporter@redlands2030.net

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3 thoughts on “Toondah Project a dangerous precedent

  1. If the Walker project is so wholesome for Qld and Redlands for the future, how come an eerily similar proposal by Walkers involving dredging to produce a marina with associated “world class” facilities for tourism and housing – NEAR a Ramsar site in Hobart Tas was refused by the Federal govt. Toondah involves actual land within the RAMSAR treaty confines, an international treaty signed by Australia in the 1970’s, even with such a pro-development environment federal minister as currently in power.

  2. I agree totally with the comment made by Me Too.
    Yes, go away Mr. Walker! We need someone who knows and appreciates Moreton Bay to design and build what is needed to access Minjerribah from Toondah Harbour.
    It would be criminal to allow Mr Walker and his team to wreck this precious part of Moreton Bay. How can it be that Walker and his team still don’t seem to understand that Moreton Bay is covered by the Ramsar Convention? The migratory birds fly from other parts of the world to rest on this precious area eating and getting strong to take off on their next journey. The seagrass is needed for turtles as shown above and the dugongs that inhabit Moreton Bay and the design that the Walker team is planning will wreck so much of this area.
    I feel so helpless as I know so many do that this group is being allowed to extend another time to work out their problems.
    I repeat Go away Mr Walker. Find some other place to destroy, please leave Toondah Harbour alone.

  3. Just watched national TV interview with Cameron Costello and plans for Minjerribah (Straddie) to grow eco-friendly world-wide tourism.
    This came just after I’d just read your reminder above from what very knowledgeable people have already written about the proposed Toondah venture.
    There is no way the desecration of the Ramsar site by urban development in the Walker proposal for Toondah would make us anything other than a laughing stock so far as eco-tourism goes.
    The submissions to Canberra show the richness and importance of what exists here.
    Every councillor, every state politician, local federal member, heads of government departments, all need to have read and understood what has been said in the R2030 post. A local college has just been reported as having students take part in a planning exercise for Toondah. We don’t know if it was a sterile paper exercise or whether students were encouraged to look closely at the surroundings and context. But I’m sure students were thinking of the dugong and dolphins they would have seen from Cleveland Point, have never minded the Governor’s mud, or missed a dawn shot of birds from far away places.
    Go away Mr Walker.
    Someone come up with a better solution to access Minjerribah.