Australia has been reminded of its obligations to protect internationally significant wetlands and protected species by the organisation which manages the Ramsar Convention.
The Ramsar Secretariat, based in Switzerland, made one of the 1,411 submissions opposing residential development in the Moreton Bay Ramsar Site next to Toondah Harbour.
Key points in the Ramsar Secretariat’s submission include:
- The proposed project will have an adverse impact on the ecological character of the Moreton Bay Ramsar Site
- Impacts from increased pollution and disturbance have not been evaluated
- Loss of wetland habitat for development will set a precedent for other developments in Ramsar sites in Australia and elsewhere in the world
The Federal Government is reminded that it has an international obligation to promote the conservation of the Moreton Bay Ramsar Site and the migratory shorebirds which use this area, and in accordance with article 2.5.5. of the Ramsar Convention:
If the proposed development is approved and involves reclamation or development into the boundary of the Ramsar Site such that the boundary has to be restricted, then the Government is required to show that this need was due to ‘urgent national interest’ and to inform the Ramsar Secretariat as soon as possible.
It seems the importance of protecting the Moreton Bay Ramsar site has not been well understood by the Redland City Council and the Queensland Government who have been pushing for a residential development which clearly has nothing to do with “urgent national interest”.
Here is the Ramsar Secretariat’s submission (FOI 170702 Document 33)
Hyperlinks to referenced documents have been inserted by Redlands2030, for convenience.
Ramsar Secretariat Submission Ref. Number: 2017/7939
I am writing concerning the public referral exercise for the proposed Toondah Harbour development adjacent to the Moreton Bay Ramsar Site (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).
The Ramsar Secretariat has reviewed the project document available on the http://epbcnotices.environment.gov.au/ website [each document is here] relating to the proposed development and have a number of general comments.
- The impacts from increased disturbance to the area from greater boat traffic due to the proposed harbour, marina and development has not been evaluated;
- The impacts from increased pollution from the operation of the proposed harbour, marina and developments have not been mentioned;
- The proposed development extends into the Moreton Bay Ramsar Site but the documents does not indicate the area (or percentage) of the Ramsar Site that will be affected (Referral document page 2, para. 5, line 1);
- Loss of wetland habitat for development will set a precedent for other developments in future;
- The proposed development will include 40 hectares of reclamation. If this is of tidalflat habitat within the Ramsar Site, then apart from the adverse impacts this will have on the ecological character of the Site, it will also set a precedent for developments around other Ramsar Sites in Australia and also elsewhere in the world.
Our specific comments are included in Appendix 1 (attached). Overall, these indicate that the proposed project will have an adverse impact on the ecological character of the Moreton Bay Ramsar Site and the criteria under which the wetland was designated. This would be due to the direct loss of wetland habitatswithin the site through reclamation and the knock-on impacts that this will have on the species dependent on the site (Appendix 1). In fact, the referral document itself states that the proposed development will likely impact on the ecological character of the Ramsar Site (Section 2.3) and that this impact will be significant (Section 2.3.2).
If areas of the Ramsar Site were to be lost to the proposed development, e.g. through reclamation, then the areas lost would have to be excised from the boundary of the Ramsar Site which would have to be redrawn.
With reference to the Articles of the Ramsar Convention on Wetlands which are relevant to this case, it states that:
- Contracting Parties shall “…formulate and implement their planning so as to promote the conservation…” of their Ramsar Sites (Article 3.1);
- “Each Contracting Party shall consider its international responsibilities for the conservation, management and wise use of migratory stocks of waterfowl…” (Article 2.6);
- “Each Contracting Party shall arrange to inform the Ramsar Secretariat “…at the earliest possible time if the ecological character of any wetland in its territory and included in the List has changed, is changing or is likely to change as the result of technological developments, pollution or other human interference.” (Article 3.2);
- Contracting Parties have the right to restrict the boundary of their Ramsar Site because of “…urgent national interests…” and to inform the Ramsar Secretariat “…at the earliest time…” if this were to happen (Article 2.5);
- “Where a Contracting Party in its urgent national interest, deletes or restricts the boundaries of a wetland included in the List, it should as far as possible compensate for any loss of wetland resources, and in particular it should create additional nature reserves for waterfowl and for the protection, either in the same area or elsewhere, of an adequate portion of the original habitat.” (Article 4.2
- “If Contracting Parties make alterations to their list of Ramsar Sites or changes in the character of the Ramsar Sites, then the Secretariat will “…arrange for these matters to be discussed at the next Conference.” (Article 8.2d).
Therefore, the Government of the Commonwealth of Australia has an obligation to promote the conservation of the Moreton Bay Ramsar Site and to consider its international responsibilities for the conservation, management and wise use of the migratory shorebirds at the site. As the ecological character of the Site is now likely to change due to the proposed development, the Site will be placed under Article 3.2 notification. If the proposed development is approved and involves reclamation or development into the boundary of the Ramsar Site such that the boundary has to be restricted, then the Government is required to show that this need was due to ‘urgent national interest’ and to inform the Ramsar Secretariat as soon as possible. The Government should then, as far as possible, compensate for any loss of wetland resources, and in particular create additional nature reserves for waterfowl and for the protection, either in the same area or elsewhere, of an adequate portion of the original habitat. At the same time, the Ramsar Secretariat would then make arrangements for this matter to be discussed at the next Conference of Parties to the Convention.
I would be grateful if you can keep the Ramsar Secretariat updated about the decision of the Government concerning the proposed development.
Yours sincerely,
Lew Young
Senior Regional Advisor for Asia-Oceania
May 2017
Appendix 1: Impact of the proposed development on the criteria for which Moreton Bay was designated as a Ramsar Site
Ramsar designation criteria | Impact |
1b. Moreton Bay is one of the largest esturine bays in Australia which are enclosed by a barrier island of sand dunes. |
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1c. Moreton Bay plays a substantial role in the natural functioning of a major coastal system through its protection from oceanic swells providing habitat for wetland development, receiving and channelling the flow of all rivers and creeks east of the Great Dividing Range from the McPherson Range in the south to the north of the D’Auguilar Range. | |
2a. Moreton Bay supports appreciable numbers of the {* the status of some of these species have changed since when the present Ramsar Information Sheet was drafted in 1999) |
2017-7939 Referral document.pdf Section 2.3.1:
Section 2.4.1:
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2b. Moreton Bay supports over 355 species of marine invertibrates, at least 43 species of shorebirds, 55 species of algae associated with mangroves, seven species of mangrove and seven species of seagrass. | The documents provided shows that there will be loss of wetland habitat from the Ramsar Site with subsequent impacts on the biodiversity. |
2c. It is a significant feeding ground for [endangered] green turtles and is a feeding and breeding ground for [vulnerable] dugongs. The Bay also has the most significant concentration of young and mature [vulnerable] loggerhead turtles in Australia. | (see above following the criteria 2a) |
3a. Moreton Bay supports more than 50,000 wintering and staging shorebirds during the non-breeding season. | 2017-7939 Referral document.pdf
2017‐7939 Referral‐Attached‐8444_att_3_‐toondah_harbour_ramsar_wetland_assessment
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3b. At least 43 species of shorebirds use intertidal habitats in the Bay, including 30 migratory species listed by JAMBA and CAMBA. | (see above following the criteria 3a) |
3c. The Bay is particularly significant for the population of wintering [endangered] Eastern curlews (3,000 to 5,000) and the Grey-tailed tattler (more than 10,000), both substantially more than 1% of the known Flyway population. |
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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 |
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 – 27 September 2017
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2 Comments
The significance of the Ramsar agreement barely rated a mention in the plan put forward for community consultation by Redland City Council and the State Government in 2014. The attempt to ignore Ramsar implications was surely an insult to Australia’s international agreements (i.e. treaties).
In fact the poor quality “planning” which is the basis of the Walker Group’s interest in the site skated over many constraints and has no social licence.
It is a dog of a project.
Redland City Council initiated the residential and marina development in 2014.
Karen’s Vision.
http://www.redlandcitybulletin.com.au/story/2017300/marina-plan-for-cleveland-revamp/