Redlands2030 comments on the Toondah Harbour Draft EIS

More than 2,000 people demonstrated in Cleveland at the Walk for Toondah

The deadline for commenting on the Toondah Harbour Draft EIS is 6^th December 2022.

Here’s a few thoughts from Redlands2030 which may end up in a submission to Walker Group at engage@toondah.com.au

You can have your say at https://www.toondahharboureis.net/

Ramsar requirements and the Draft EIS

Walker Group is seeking Federal Government approval under the Environment Protection and Biodiversity Conservation Act for a project that will destroy part of a Marine Park and threaten biodiversity including shorebirds and koalas through increased human disturbance and loss of habitat.

Much of the area that Walker Group proposes to destroy through urban development is located in the Moreton Bay Ramsar site. As explained by Save Straddie, this proposal to build in Moreton Bay would breach Australia’s obligations under the Ramsar Convention, especially the specific obligation not to “delete or restrict” Ramsar site boundaries unless for “urgent national interests”. The EPBC Act requires that the Minister “must not act inconsistently with Australia’s Ramsar Convention obligations”.

Obviously, the definition of Australia’s urgent national interests can’t be stretched to include a private developer’s wish to make money from building 3,600 dwellings and 200 marina berths.

The Ramsar Convention commits member countries to promote the conservation of Ramsar wetlands and to plan for the wise use of all of the wetlands in their territories.

A Federal Government fact sheet says that ‘Wise use of wetlands is the maintenance of their ecological character, achieved through the implementation of ecosystem approaches, within the context of sustainable development’.

The Government goes on to explain that ‘sustainable development’ is “a pattern of resource use that aims to meet human needs while preserving the environment so that these needs can be met not only in the present, but also for generations to come”.

Does anyone seriously think that constructing what would become the most densely populated suburb in Queensland upon seagrass beds and mangroves in a Ramsar site could qualify as being “within the context of sustainable development”?

Counting the birds

As well as destroying feeding grounds used by migratory shorebirds such as the Eastern curlew (Critically Endangered) and the Bar-tailed godwit (Vulnerable), two important shorebird roosting sites close to Toondah Harbour  (Cassim Island and Oyster Point) would experience increased human disturbance as a consequence of 6,000 people with hundreds of dogs living in the 3,600 dwellings that Walker Group wishes to construct.

Comments in Walker Group’s Draft EIS that the risk of disturbance to roosting shorebirds would be mitigated through measures such as educational signage fail to recognize that many people will ignore such signage. Redland City Council’s track record of enforcing compliance with animal management laws is poor with dogs off leash regularly observed at locations such as Wellington Point Beach Reserve which is also part of the Moreton Bay Ramsar site.

It appears that the work done by Walker Group’s consultants to understand the number of migratory shorebirds using Toondah Harbour and nearby roosting sites is inadequate, particularly given the scale of environmental devastation that Walker Group wishes to undertake..

For example, the Draft EIS says that from 32 observations of the Oyster Point roost the maximum number of Eastern curlews sighted by Walker Group’s consultant was 45. Yet during the Draft EIS consultation period there have been recent reports by local bird watchers (supported with images) of several occasions when more than 100 Eastern curlews were at this location including one report showing 180 Eastern curlews.

Traffic and koalas

The Draft EIS assessment of vehicle traffic resulting from construction of 3,600 dwellings begs more questions than it answers, for example:

Toondah Harbour presents an opportunity to bring forward sustainable transport for the Redlands Coast including pedestrian and cycle infrastructure to fulfil strategic movements between Cleveland Point, Eddie Santagiuliana Way and Cleveland CBD via Middle Street. To achieve sustainable outcomes, the Project proposes to reduce private vehicle travel and promote public and active transport travel to the site. Use of an autonomous shuttle bus between Cleveland CBD, Cleveland Rail Station and the proposed ferry terminal will be explored (Executive Summary page ES-20).

Instead of such nonsense, the Draft EIS should have provided useful forecasts of vehicle traffic increases over time and should have included some predictions for traffic distribution on a time of day basis. This is particularly relevant for considering the potential impact of additional night time traffic on resident koalas. At present most of the traffic using Middle Street is day time traffic by people using the ferry terminal.

 With regard to koalas, the proposed mitigants of constructing an underpass in Middle Street and planting 1000 trees in GJ. Walter were clearly meant to sound good when said by a politician. But the Redlands based Koala Action Group considers these proposed measures to be implausible action for protecting koala well-being.

Plans for a north-south road bisecting the historic G.J. Walter Park, where koalas are often sighted, were put forward by Redland City Council and the State Government in 2014 in their Draft Development Scheme for the Toondah Harbour Priority Development Area (PDA).

In response to community concerns expressed during public consultation about the draft development scheme, the Government said: the development scheme has been amended to strengthen the protection of the recreational function of GJ Walter Park and the proposed north south link has been removed.

Walker Group is proposing to have a north-south road through G.J. Walter Park which will reduce the Park area, and diminish its recreational function significantly. This shows blatant disregard for the approved Toondah Harbour PDA Development Scheme.

Why haven’t the State Government and Redland City Council compelled Walker Group to comply with the approved Development Scheme?

Climate change and the Draft EIS

Plans to build 3,600 dwellings, mostly on wetlands between the Grand View Hotel and the Toondah Harbour ferry terminal, are particularly unwise given their exposure to risks associated with sea level rise and storm surges. Given the world’s global warming trajectory, inundation of the proposed development is a matter of when, not if.

The Draft EIS claims that: “The Project itself will not generate significant amounts of carbon and will not contribute to drivers of future climate change”.

The building and construction sector is a major contributor to greenhouse gas emissions. The proposed Toondah project would be an excessive emitter due to activities such as dredging, transport of rock and lime by diesel burning trucks, and treatment of acid sulphates.

A full lifecycle assessment of project contributions to greenhouse gases (including remediation after inundation by sea level rise and storm surges) would be required, if a final EIS is to be prepared. Such assessment should include consideration of replacing all diesel engine construction equipment with electric equipment (powered with renewable energy), as is happening in countries such as Norway.

Local residents face 20 years of noise

If the unthinkable were to happen, and this project proceeded, the Cleveland community would be exposed to twenty years of horrendous disturbance from construction activity including noise, vibration and odour associated with dredging, reclamation and building construction.

The Draft EIS does not clearly explain the full impacts that would be experienced by nearby residents from dredging and reclamation. The document fails altogether to provide information about the noise that will result from construction of buildings up to ten storeys. Noise impacts from hundreds of trucks carting rock and lime through Redlands’ suburban streets are not explained.

Ferry channel fairy tales

The project appears to be justified by the proponent on the grounds that there is a need to widen, deepen and straighten the Fison Channel used by ferries, and that the only possible way to dispose of 530,000 m³ of dredge spoil is ‘beneficial’ reuse to create new landforms for residential and commercial development.

The Draft EIS fails to provide any convincing arguments that a bigger ferry channel is required. The two ferry companies using Toondah Harbour have made no public statements calling for a bigger ferry channel. Maritime Safety Queensland affirmed as recently as 2020 that the Fison Channel in its current configuration is fit for purpose.

Suggestions that SeaLink may need a bigger channel to deploy longer vehicular ferries are speculative without evidential justification. Further, the Draft EIS fails to consider possible use of double ended vehicular ferries which would avoid the requirement for vessels to perform a 180 degree turn at Toondah Harbour.

In fact, the only people who would benefit from a bigger ferry channel are the owners of 200 motor yachts that would spend most of their lives in the marina that Walker Group is proposing to develop.  

Blue lagoons to cost ratepayers

In a desperate attempt to garner local support for the Toondah project, Walker Group has been promoting the possible inclusion in the project footprint of a blue lagoon within a 3.5 hectare foreshore park.

The Draft EIS states that this park and the blue lagoon will be given to Redland City Council who will henceforth be responsible for the costs of owning, managing and maintaining these contributed assets. These costs would be considerable given the need to employ lifesavers when people may go swimming.

Data for similar free to use facilities in Queensland at Yeppoon and Ipswich indicates that the blue lagoon and foreshore park at Toondah Harbour would cost Redlands ratepayers at least $2 million per year. While this may be a reasonable impost considered in isolation, the fact is that Redland City Council is already planning to deliver a swimming lagoon in its Birkdale Community Precinct which the Council is developing at an estimated capital cost of $300 million and a water play area in the $200 million Heinemann Road sports precinct.

But wait, there’s more. Just prior to the 2020 local government elections Redland City mayor Karen Williams said she had asked Lendlease to incorporate a South Bank-style water park into its Shoreline Project in southern Redlands. So, if a blue lagoon were to appear at Toondah Harbour, Redlands ratepayers would be in the unenviable position of having to fund at least $6 million per year to operate three blue lagoons plus a water play area in Mount Cotton.

The Draft EIS says that 340 car parks will be provided near the Foreshore Park but these car parks can’t be found in any of the various plans or drawings included in the Draft EIS. Why not?

Abysmal community engagement

Community engagement by Walker Group and its joint venture partners (Redland City Council and the Queensland Government) has been abysmal since Walker Group was picked as the preferred developer. By the way, Walker Group was announced as preferred developer in September 2014, not September 2015 as is stated incorrectly in the Draft EIS. Perhaps the date error was because the Draft EIS author didn’t think that the Council’s expression of interest process for the Toondah Harbour Priority Development Area could possibly have yielded a winner within just a few weeks. This EIO process followed community consultation for 800 apartments mainly on land. The project morphed into 3600 apartments without further public disclosures, a stunning rebuttal of community interests and community values. How this happened remains unknown under Council’s shabby “commercial-in confidence” agreement with the proponent.

If ensuring widespread community awareness of the proposed project were an objective, then one might have expected large signs to have been erected many years ago near the G.J. Walter Park foreshore and in the Toondah Harbour Ferry terminal. One of these signs could have been placed near the public boat ramp explaining that Walker Group plans to decommission this facility and extend the ferry terminal south resulting in the destruction of 0.7 hectares of mangroves south of the boat trailer car parking area.

A community petition calling for a public notice board at G.J. Walter Park was submitted to Redland City some years ago, but the Council said no. We have learned since through documents obtained via RTI that the Council’s secret joint venture agreement with Walker Group and the State Government requires the Council to always act in the best interests of the joint venture. So presumably the public interest comes second.

Due to the lack of signage about the proposed Walker Group project, a considerable proportion of people using the current ferry terminal and G.J. Walter Park are unaware of the environmental destruction being proposed through this largely clandestine privatisation deal.

Reading the Draft EIS

Turning back to the Draft EIS we note that Walker Group failed to comply with the Draft EIS Guidelines which stated that:

 Information provided in the EIS should be objective, clear, succinct and be supported by maps, plans, diagrams or other descriptive detail that is easily understood by the general reader.

Only three hard copies of the Draft EIS were made available in Redland City, one copy at each of the Cleveland, Victoria Point and Capalaba Libraries.

Walker Group’s presentation of the Draft EIS online was totally inadequate. It was as if the intent was to make the document’s contents as hard to find as possible.

Redlands2030, acting in the public interest, provided a publicly available way of viewing the document online in a logical easy to use way that many people found helpful, via a blog post Unboxing the Draft EIS.

To assist in reviewing the draft EIS through use of key word searches, Redlands2030 also prepared a consolidated single pdf version of the Draft EIS which we made publicly available.

Doing word searches of the consolidated Draft EIS shows that the document makes much use of weasel words presumably intended to lull readers into a state of ‘don’t you worry about that’. So, a document heralded as “The Science” by some local politicians contains a lot of hesitant, qualified ambiguity through liberal use of words and phrases such as: approximately, minimal, minor, nominal, ‘not expected’, only, slightly, and unlikely. Also troubling are gaps in the Draft EIS which makes reading it like a game of “Where’s Wally”.

In conclusion, the Draft EIS is an inadequate piece of work and does not form a basis for considering the proposed destruction of Ramsar wetlands and negative impacts on migratory shorebirds and other wildlife.

What the document does do, is give local residents some understanding of some of the horrors that would be visited upon them if this project were to be approved.

Redlands2030 – 30 November 2022