Redlands2030 has prepared a draft submission for people wanting to oppose development in Ramsa wetlands next to Toondah Harbour

Redlands2030 has prepared a draft submission for people to oppose development in wetlands next to Toondah Harbour

People concerned about Walker Group’s plans for constructing 3,600 dwellings on dredged wetlands next to Toondah Harbour can use a Redlands2030 template for submissions to the Federal Government.

Walker Group’s latest Toondah Harbour development plans have been released for public consultation under the Environment Protection and Biodiversity Conservation (EPBC) Act which is intended to protect matters of national environmental significance.

Links to documents provided by the developer are provided below for those who wish to review the available information in detail.

Some examples of submissions made in response to earlier versions of Walker Group’s Toondah plans are also provided below.

Increased traffic congestion, inadequate infrastructure, destruction of protected Ramsar wetlands, reduction of the Marine Park and loss of the local koalas are some of the project’s likely impacts if a mega residential development in Moreton Bay is approved.

A short period of community consultation closes on Monday 18 June.

If you wish to lodge a submission you can cut and past the text below into an email, make amendments or additional comments if you wish to, and email it to:

epbc.referrals@environment.gov.au


Referrals

Environment Assessment Branch

Department of the Environment

GPO Box 787

Canberra ACT 2601 I am writing to express my concern in regards to the following referral:

Reference Number: 2018/8225

EPBC Case Title: WALKER GROUP HOLDINGS PTY LIMITED/Tourism and Recreation/Numerous lots/Queensland/Toondah Harbour Development, Moreton Bay, Qld

I urge the Department of Environment and Energy to declare this referral as a ‘clearly unacceptable action’ under the EPBC Act.  My concerns are highlighted below:

Ramsar wetlands, migratory species and threatened species

This development proposal will have negative impacts on three Matters of National Environmental Significance protected under the EPBC Act: a wetland of international importance, listed threatened species and migratory species.

Further, as a contracting party to the Ramsar Convention, Australia has an international obligation to protect Ramsar-listed wetlands.  Reduction of a Ramsar site’s area can only take place if the change is urgent and in the national interest. A private sector real estate development meets neither criteria.

Any development that intends to reclaim part of a Ramsar site should be declared a ‘clearly unacceptable action’ under the EPBC Act.

The proposed development would destroy feeding grounds used by various shorebird species including the vulnerable Bar-tailed godwit and the critically endangered Eastern curlew.

In a recent decision about the Shoreline project (2016/7776), the Federal Government imposed strict conditions to prevent any impacts on the Eastern curlew’s foraging area. This level of protection would preclude any dredging and development in shorebird feeding areas in the Toondah Harbour Priority Development area.

Koalas

A tracking program managed by the Koala Action Group shows that the area around Toondah Harbour contains an active and healthy koala population.

These koalas are likely to be wiped out if the proposed project is approved due to construction disturbance, and ongoing impacts of traffic and human activity (including an increase in the area’s dog population)  resulting from up to 3,600 new dwellings.

Construction impacts

EPBC referral guidelines specify the need to “provide a detailed description of the proposed action including all proposed activities”. Certain key elements of the construction appear to be either missing entirely from the description or lacking in detail. These include:

  • Location and heights of proposed multi-storey buildings
  • Details of proposed dredging and reclamation work including risks of acid sulphate soils and impact of released silt on corals in Moreton Bay
  • Method of constructing the new land forms including foundations, bunds, revetment walls, and transport of material to and from site over a 20 year construction period.
  • Assessment of risk from increased sea levels and storm surges due to global warming.

 Project benefits are not justified

Attempts to justify this project on the basis that it would provide community benefits are inadequately detailed and in some cases misleading. Many important details have been withheld from the community due to secretive arrangements between the project proponent, local council and the State Government.

Claims that this project will offset loss of jobs when sand mining finishes on North Stradbroke Island in 2019 are not credible. In recent years this industry has employed very few people and North Stradbroke Island is already transitioning to a future based on eco-tourism.

The value of community infrastructure and benefit proposed by the developer is not made clear in the referral nor is there any certainty that such infrastructure and benefits will actually be provided as described in the referral.

Developer’s track record

The Walker Group has no publicly available environmental policy and has never done any project subject to a controlled action under the EPBC Act. Multiple breaches of environmental laws (illegal tree clearing) are disclosed in Walker Group’s current EPBC referral.

Support for the project is overstated

Walker Group implies that its project is widely supported by listing a number of Government plans and cites previous consultation. These documents were prepared in the context of an upgrade of the Toondah ferry and barge facilities, not the proposed mega residential project which has not been subject to normal town planning. Issues such as infrastructure requirements (especially traffic and transport) have not been properly addressed.

Walker Group’s referral includes a State Government report on consultation undertaken in 2014. This consultation process was flawed. Various technical and environmental studies were withheld from the community and the community was not made aware of environmental impacts of developing in the priority development area. The scope of development put forward in 2014 was vastly less than the project being proposed by Walker Group. Apart from the EPBC process there has been no genuine community consultation about the various Toondah development plans put forward by Walker Group since 2015.

There is another alternative

If Walker Group’s Toondah plan is not approved, the process of upgrading ferry terminal and associated facilities could be funded and executed by the State Government in the same way that other transport infrastructure is improved in Queensland, such as recently completed redevelopment of the bus/ferry terminal at Weinam Creek.

Other matters

  • ……………………………………………………………………………………………………………………

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Signed:…………………………………………………………………Date:……………………………….

 

Name (printed):………………………………………………………………………………………………………….

 

Address:…………………………………………………………………………………………………….(House # / Street)

 

……………………………………………………………………………………………………..(Suburb/ Postcode)


Walker Group’s latest Toondah proposal

The EPBC referral number for Walker Group’s latest Toondah plan is 2018/8225.

The following documents referred to the Government by Walker Group have been made available via the EPBC Public Notices webpage.

Referral

Project Description

Attachment 2: EPBC Act Protected Matters Report

Attachment 3: Assessment of Potential Impacts on the Ecological Character of the Moreton Bay Ramsar Wetland from the Toondah Harbour Project

Attachment 4: Assessment of Potential Impacts on EPBC Act Threatened and Migratory Species

Attachment 5: Marine Ecology EPBC Referral

Attachment 6: Terrestrial Ecology Assessment

Attachment 7: Water quality report

Figures (maps)

Submissions Report (from 2014 consultation about the Priority Development Area development scheme)

Walker Group has also provided some project information on its website.

How to make an EPBC submission

Advice on making a submission to an EPBC referral is available from:

Federal Government

EPBC Referral Notices Facebook page (a community page)

Submissions or comments can be sent to:

Email: epbc.referrals@environment.gov.au
Fax: 02 6274 1620

Or post your submission to:

Referrals Gateway
Environment Assessment Branch
Department of the Environment
GPO Box 787
Canberra ACT 2601

Submissions about Walker Group’s previous plan

Many submissions about Walker Group’s previous plan were obtained by Redlands2030 through a Freedom of Information request. A number of these submissions were published by Redlands2030. Links are included below:

Opposing submissions Supporting submissions
1,411 submissions opposed the project 8 submissions supported the project
 Toondah is clearly unacceptable says Birdlife

Mayor Williams’ Toondah claims need testing

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

Since the new plan is not much altered, many submissions about the Walker Group’s previous Toondah plan will contain points relevant to the new plan.

Submissions made in response to Walker Group’s previous development plans will not necessarily be re-considered by the Federal Government so anyone who made a submission last time should submit their views again.

Questions about making a submission

Questions about making a submission can be addressed to Redlands2030 at thereporter@redlands2030.net

 

Redlands2030 – 9 June 2018

Walker Group’s latest plans for development at Toondah Harbour

2 Comments

Jason B, Jun 21, 2018

Well done Redlands2030 and thanks. I dont think many of us could do justice to the submission process. Why is made so hard? Why can’t the EPBC process include a simple survey (not the Laming fiasco) that deals with the fundamentals and leaves the nuanced stuff to others?

And I hope you take up the timeframes..utterly ridiculous 10 days isn’t enough time to read the documents never mind do decent research…especially when the proponent has skimped on proper investigations.

Ann Richardson, Jun 18, 2018

I am vehemently against all proposals for the development of Toondah Harbour.
Currently the area is already over populated the roads increasingly congested parking atrocious and to dump 3,600 dwellings into an already congested and compromised environment is entirely unthinkable.
The natural environment is struggling to survive and the construction disturbance, and ongoing impacts of traffic and human activity will forever change this area to the detriment not only of the human population but also to the naturally occurring native creatures. Our wetlands are so vulnerable and once destroyed will never return. My family and I love the Redlands and do not wish to have the face and infrastructure of it changed any more than it already has been in particular over the last 6years. High Rise units on this part of the coastline is completely unacceptable. Once destroyed or damaged can not be repaired.
I implore you not to destroy the lifestyle and living conditions in this part of the iconic and beautiful Redlands Coast.

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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