The opportunity to comment on how Walker Group should investigate environmental impacts of its proposed Toondah Harbour project closes on 6 March.
Proposed developments which impact on matters of national environmental significance need be approved by the Federal Environment Minister in accordance with Federal environment laws, including the Environmental Protection and Biodiversity Conservation (EPBC) Act.
The Federal Government decided on 23 July 2018 that Walker Group’s project triggered the need for Federal Government oversight. The Government also decided that if Walker Group wanted to proceed with its project, it would have to prepare an Environmental Impact Statement (EIS).
The guidelines for Walker Group to follow in preparing an EIS are determined by the Environment Minister. For this project the public has been consulted about the EIS guidelines before they are finalised.
It is important to understand that this EIS process deals primarily with matters of national environmental significance which in this case are:
- Wetlands of international importance (often called ‘Ramsar’ wetlands after the international treaty under which such wetlands are listed)
- Nationally threatened species and ecological communities.
- listed migratory species
Australia’s national environmental laws have been criticised robustly by a number of environmental organisations. Australia’s poor record of species extinction is currently the subject of a Senate inquiry which included a site visit to Toondah Harbour.
The Labor Party has committed to strengthening national environmental laws. but to date the Labor Party has not committed to applying stronger environmental laws to assessment of the Toondah project if it winds office at the next election.
Issues requiring State/Council approvals
Many other aspects of the project will need to be investigated and approved at State and/or Council level separately from the Federal Government’s environmental assessment e.g.:
- Construction issues including traffic, damage to roads, noise, dust, silt, odours, lighting, laydown areas, parking etc
- Native title and culture and heritage issues
- Impacts on the Moreton Bay Marine Park and any changes to the park’s boundaries
- Impacts of the proposed development of 3600 apartments and other facilities such as increased traffic, additional parking requirements, additional public infrastructure requirements (hospitals, schools, It is likely that much of sewage treatment), loss of scenic amenity, impact on local business.
- Environmental issues which are not of national significance but may be of state or local significance
Many of these issues are likely to be dealt with under the Economic Development Act.
Draft EIS guidelines for Walker Group’s Toondah proposal
Given that the Federal process deals with a narrow range of environmental issues, any comments on the draft Toondah EIS guidelines should focus on ensuring that these national environmental issues are investigated thoroughly and impartially.
Some preliminary thoughts about matters which should be considered in finalising the EIS guidelines are listed below;
- Impacts on corals of Moreton Bay are not mentioned in the guidelines
- Buffering the development footprint from the adjacent undeveloped areas of the Ramsar area is not addressed. A buffer should be inside the PDA (not the balance of the Ramsar area) and needs to provide for impacts that might overflow or escape from the development. A buffer for specific species will be needed in some places but a general buffer would be prudent for stormwater management, weed management, litter management and the control of public access.
- The overall health of Moreton Bay, cumulative impacts of development (in SEQ) on the health of the Bay or water quality trends for the Bay need to be considered. A healthy Bay has been subject of extensive research over the last 20 years but the research has been poorly integrated into planning processes. For example the SEQ Catchments Report Managing what matters: The cost of environmental decline in South East Queensland sets out minimal matters of concern in the management of the Bay
- The guidelines do not require the assessment to consider the prospect of Moreton Bay being listed as a World Heritage site, which if already done would raise another matter of national environmental significance. The prospect of Moreton Bay being World Heritage listed should be a factor to be addressed in any EIS.
- Suggested buffering of Cassim Island in Walker Group’s EPBC Referral documents seems arbitrary and inadequate especially given the buffer will comprise a recreation waterway which is likely to be very busy.
- Urbanisation of the Toondah PDA will introduce new threats to the ecological value and functioning of the land and waters proximate to the PDA development. These impacts need to need determined and impacts measured including, for example, the introduction of domestic animals, (especially) preying by cats, disturbance by dogs and diseases from caged birds should be fully examined.
- Urbanisation of the PDA will introduce a high impact land use into a relatively stable and benign environment. It will dramatically increase the edge effects and the existing transition (which is largely from public park to wader bird to a transition to highly urbanized development to fragmented wader bird habitat)
- Disturbance of threatened species by new but also the pattern of lighting, noises, movements (people, vehicles, boats) and changes in the skyline (which could impact the navigation of threatened species and their ability to rest in an environment markedly changed from the natural (and historic) profile. Recent research on the dangers of blue lighting on native animals and people should be examined.
- Congestion and traffic movements to and through the PDA area are a clear danger to the existing koala colony in the Toondah precinct.
- G.J. Walter Park is the only significant parcel of public open space in the vicinity of the PDA residential development. The recreation setting of the park will likely change dramatically under plans discussed to date. The changed setting will alter and very likely increase the level of disturbance for koalas and other threatened species.
- A significant level of commuter traffic will be generated by the PDA development resulting in dramatic increases in peak hour traffic in the precinct. The concentrated movement of people at these peak times increase traffic congestion in streets that are not designed for these loads. This congestion will increase levels of disturbance on all species of concern in the precinct.
- Additional infrastructure needed to service the population of the PDA (new schools, extra hospitals, better roads, augmented emergency services) are not shown in the Referral documents. Without the “full” picture of the urban development it is impossible to draw conclusions about impacts on MNES. Glib responses to date by the proponent, the local Council and the State Government that such infrastructure will “follow” the development given no assurance that the full impacts of the development can be assessed in the EIS as derived from the Referral documents.
- Any discussion about proposed impacts of a proposed development should be based on thorough and comprehensive engineering studies which are incorporated into the EIS so that they can be scrutinised for adequacy. This would include geotechnical analysis, design of marine structures including breakwaters and revetment walls, hydrology, siltation, and crucially a detailed project construction schedule.
Here is a link to the draft EIS guidelines
Submissions referencing the project number EPBC 2018/8225 should be sent, no later than 11.59 PM on 6 March 2019 by email to: epbc.referrals@environment.gov.au
Redlands2030 – 28 February 2019
Please note: Offensive or off-topic comments will be deleted. If offended by any published comment please email thereporter@redlands2030.net
7 Comments
My apologies for not having time and space to make a thorough review of the EIS, we are just preparing for travel. The opening points about issues that have not been listed for assessment is concerning, especially given the scale of the PDA and its impacts on the immediate and surrounding environment.
Given the range of omission that have been noted and the lackadaisical and unprofessional manner in which ‘consultations’ were with residents and others maybe a different approach needs to be considered.
May I suggest that the local group and whatever supports are willing to assist go through the TOR for the EIS and, based on their own knowledge, experience and available studies, make responses to each of (or the most significant) points. You may be able to get assistance from Griffith Uni or QUT for this exercise, it would be a good one for their students to work on.
In parallel, may I also suggest you make a detailed list of the tasks you consider need to be performed and make cost and time estimates for each of there – i.e. an alternate work schedule and budget. Once complete (or well under way) this could be compared with the plans Walker, the Council or State have made, and the difference (lacks) highlighted. If you have an economist handy it might be interesting and revealing if the potential profits to be made by Walker could be compared to the cost of the PDA and the paltry amount they and government are willing to spend on the EIS and, importantly implementing recommendations. Further, it is important to see if an independent third party team assessor and monitor could be appointed – paid for by Walker but beyond their management or financial control – to ensure the rules and agreements are being honoured.
Given that a large part of the Bay is protected under the Ramsar Convention on wetlands of international significance, have you explored the possibility of getting them to make a judgement and/or that Australia will be in breach of its international obligations if it allows this kind of development to endanger the integrity of the designated area? This is an issue on which getting assistance from the Qld EDO would be very important. You may have to ‘kick start’ the Ramsar people, but I happen know that the current secretary general is concerned about what is happening in Moreton Bay.
Naturally all of this needs to posted on the internet/web as it proceeds. It occurs to me that you may find an ally in The New Daily (https://thenewdaily.com.au) who might be willing to consider running a daily or weekly update, complete with interviews and graphics, etc. on what is happening and the antecedents of the usual suspects ..?
If you have a friendly lawyer in the EDO’s office – what chance is there of getting a court order to delay any decision being made until after the feral election – when to the current mob go into ‘caretaker’ mode and be disbarred from making decisions? The new feral environment minister is clearly not competent or qualified for making informed judgements on cases like this …
Btw, have the links between Walker and politicians at all levels been thoroughly researched and the results publicised? An old adage: follow the money …
Btw, I’m a scientist and international environmental consultant with 30+ years of experience with EIA/EIS …
Good luck!
Sean Foley BSc (Hons) PhD FRGS
IMOATT: How proactive have our council and members of Parliament been in consulting and providing information on this issue, as appropriate, and accessible for all those residents likely to be impacted by such an invasive 20 year period of prolonged development and local and ecological disruption?
Why has there been no definition of a projected impact area to responsibly keep those impacted directly informed and reliably advised? If that had happened, as is alleged, there wouldn’t be a persistent ignorance amongst a large sector of the stakeholder population. As recently as Sunday 3 March 2019, Grand View Hotel Patrons were learning about this development, its size and probable impact for the first time. Wouldn’t and shouldn’t we expect the patrons of this cultural and historic landmark icon, located as it is on the precipice of this proposed development, be expected to know the goings on in and around their local “watering hole”?
This startling revelation should provide pause to anyone daring to espouse this as an integrity development application or bonifide community consultation process, well after the PDA process was launched years ago. It is a significant failure, to responsibly inform stakeholders and ensure those same stakeholders are reliably informed and made aware of how their public assets are being administered with their rate and tax payer monies, especially when the individual impacts on private assets and quality-of-life for local residents are exposed! Desperately random pop up consultations simply don’t cut it!
Why do we continue to find out about alleged public consultation late in the day, and via the community bush telegraph – the hearsay of passionate and committed community members who struggle to obtain the information and are allowed insufficient time to conduct their independent research and apply integrity checks, let alone formulate an appropriate response? Why are these stalwarts (allegedly) the victims of attempts to discredit them, despite the growing protest and majority and international evidence perpetually on show (Reference submissions for and against, where the majority is predictably against, representing people of all origins and socio-economic backgrounds)?
Where are the formal announcements, reference in councillor postal delivered fliers, public notices, signage, public forums, reminder notices? Why is the community absorbing this cost when the council is already resourced to do so…….and independently elects to with hold this service, effectively delegating responsibility to an ill-informed community to conduct its own….a difficult activity when you remain in ignorance and/or are offered platitudes and superficial promises without substance, (allegedly) most of the time.
Why are councillors with integrity from across a variety of councils, complaining of alleged “Gag Orders”, as reported in community press and social media platforms? Isn’t this a direct contradiction with founding Local government principles of transparency and accountability? How does this censorship align with the alarming evidence of council corruptions (93 charges laid to date and the majority of councils yet to be similarly investigated). Is there a relationship here with rate payer financed legal insurance, allegedly allowing council sources to exhaust the resources of public and legitimate resident litigants, regardless of the integrity and righteousness of those claims? Did you know that council sources do not have to remunerate the council for the resources depleted to provide these legal defences, unless found guilty of an adverse result? Would it not make sense to drag a case out with every available means to avoid any adverse result?
In NSW. one council is already at risk of bankruptcy, due to legal costs, as reported in the press. Is this what council rate collections were intended for? What assurance do we have that the same may not eventuate here? We have none. and no means or access to information to assess and scrutinize the real risk!
How do you defend the argument that this provision is open to actual or potential abuse to protect and cement alleged council voting blocks with vested interests of their own? (Case to watch where this is alleged to be the case – Cassowary Coast Council Vs Toogood. Do equivalent cases exist locally? How the hell would most people know, if there is no public register to refer to and hold such actions accountable and open to resident scrutiny? Where are the public schedules, provided by councils engaged in partaking of this latest rate-payer benefit awarded exclusively to council sources but not the people financing the arrangement, to allow the public an appropriate audience to witness thisHow are these costs accounted for in annual and audit reports?). Where is the equal opportunity and consideration in this provision? How is this considered justice?
Where are the authority references to substantiate all the ridiculous claims made (e.g. alleging a job benefit when the development substantially aggravates the existing job deficit????)
Why are stakeholders being denied the opportunity to fact check for themselves………in alignment with all the espousals of transparency and accountability?
What a singularly poor show! Toondah as it exists now should be a no-go!
The Walker so-called consultation drop in event at Cleveland was an absolute farce! Many concerned residents packed the room, trying to find a consultant, but without any names, or identifying tags on the “consultants”, that wasn’t easy. When I finally eased into a group around one “consultant”, he didn’t ever write down questions or suggestions from any of the 5 people asking questions and certainly didn’t write down his totally unsatisfactory replies. It was apparent that we, the residents, had far more in-depth knowledge of the environmental concerns than him. Not one question was answered satisfactorily about a huge range of concerns. Some that I heard ranged from “It’s Ramsar, why isn’t that sufficient to negate this development?” What about the JAMSA, CAMSA, ROCAMSA Agreements Australia signed promising to protect migratory shorebirds, roosts and feeding grounds? How can you possibly prevent dredge spoil in acid-sulphate soils from polluting Moreton Bay (Remember Ramsar) Cassim Island corals, sea grass meadows, commercial fisheries and oysters farms? How can you protect the Toondah koalas trees and ranges? ( Consultant had never heard of them!) How can Walkers protect the turtles and dugong who feed on the sea grass meadows to be dredged? How can Walkers possibly remove 1 1/2 kilometres of protected mangroves, when residents are prosecuted if they even prune a branch? No questions or “answers” recorded, so how can the residents’ feedback be included? This was a travesty of consultation and feedback, which achieved one thing only. The entire room voted against the Toondah/Walker project, bar one confused lady, who rapidly changed her vote and one local activist for the developers. No doubt Walkers will say, tick that off – we’ve had the consultations! What a farce!
This development will adversely effect our precious coral, the dredging will negatively impact Moreton Bay for decades and effect the flora and fauna that life in this environment.
Urbanisation of the Toondah PDA will introduce new threats to the ecological value and functioning of the land and waters proximate to the PDA development. These impacts need to need determined and impacts measured including, for example, the introduction of domestic animals, (especially) preying by cats, disturbance by dogs and diseases from caged birds should be fully examined.
Impacts on corals of Moreton Bay are not mentioned in the guidelines
Buffering the development footprint from the adjacent undeveloped areas of the Ramsar area is not addressed. A buffer should be inside the PDA (not the balance of the Ramsar area) and needs to provide for impacts that might overflow or escape from the development. A buffer for specific species will be needed in some places but a general buffer would be prudent for stormwater management, weed management, litter management and the control of public access.
The overall health of Moreton Bay, cumulative impacts of development (in SEQ) on the health of the Bay or water quality trends for the Bay need to be considered. A healthy Bay has been subject of extensive research over the last 20 years but the research has been poorly integrated into planning processes. For example the SEQ Catchments Report Managing what matters: The cost of environmental decline in South East Queensland sets out minimal matters of concern in the management of the Bay
The guidelines do not require the assessment to consider the prospect of Moreton Bay being listed as a World Heritage site, which if already done would raise another matter of national environmental significance. The prospect of Moreton Bay being World Heritage listed should be a factor to be addressed in any EIS.
Suggested buffering of Cassim Island in Walker Group’s EPBC Referral documents seems arbitrary and inadequate especially given the buffer will comprise a recreation waterway which is likely to be very busy.
Urbanisation of the Toondah PDA will introduce new threats to the ecological value and functioning of the land and waters proximate to the PDA development. These impacts need to need determined and impacts measured including, for example, the introduction of domestic animals, (especially) preying by cats, disturbance by dogs and diseases from caged birds should be fully examined.
Urbanisation of the PDA will introduce a high impact land use into a relatively stable and benign environment. It will dramatically increase the edge effects and the existing transition (which is largely from public park to wader bird to a transition to highly urbanized development to fragmented wader bird habitat)
Disturbance of threatened species by new but also the pattern of lighting, noises, movements (people, vehicles, boats) and changes in the skyline (which could impact the navigation of threatened species and their ability to rest in an environment markedly changed from the natural (and historic) profile. Recent research on the dangers of blue lighting on native animals and people should be examined.
Congestion and traffic movements to and through the PDA area are a clear danger to the existing koala colony in the Toondah precinct.
G.J. Walter Park is the only significant parcel of public open space in the vicinity of the PDA residential development. The recreation setting of the park will likely change dramatically under plans discussed to date. The changed setting will alter and very likely increase the level of disturbance for koalas and other threatened species.
A significant level of commuter traffic will be generated by the PDA development resulting in dramatic increases in peak hour traffic in the precinct. The concentrated movement of people at these peak times increase traffic congestion in streets that are not designed for these loads. This congestion will increase levels of disturbance on all species of concern in the precinct.
Additional infrastructure needed to service the population of the PDA (new schools, extra hospitals, better roads, augmented emergency services) are not shown in the Referral documents. Without the “full” picture of the urban development it is impossible to draw conclusions about impacts on MNES. Glib responses to date by the proponent, the local Council and the State Government that such infrastructure will “follow” the development given no assurance that the full impacts of the development can be assessed in the EIS as derived from the Referral documents.
Any discussion about proposed impacts of a proposed development should be based on thorough and comprehensive engineering studies which are incorporated into the EIS so that they can be scrutinised for adequacy. This would include geotechnical analysis, design of marine structures including breakwaters and revetment walls, hydrology, siltation, and crucially a detailed project construction schedule.
Recall when Raby Bay was approved for development, engineers advised RSC against building on mangroves. Their advice fell on deaf ears and today, since pylons did not go down deep enough, cracks in walls, houses, soon appeared and repairs are continuous. Is Redland City Council, State Government pollies, taking note of potential damage to the entire eco-system at Toondah Harbour and surrounds if the Walker Corporation project goes ahead? Any thought given to traffic generated by building 3,600 apartments plus other buildings?
Being resident of Capalaba adjacent to 4-way intersection Finucane/Moreton Bay/Old Cleveland Rds. I’ve seen horrific road crashes on roads not built for the kind of traffic we see today…even a semi-trailer…that killed a young female at the intersection. There have been already too many deaths where politicians appear to turn a blind eye to congestion that increases along with traffic due to continuous building of housing estates in Redlands. Promises are made of easing congestion, Mayor had sign on Cleveland-Redland Bay Rd Thornlands prior to last local govt election that read “Williams Will fix this road”. I would not like to drive along there rush hour as late afternoon with moderate traffic, drove towards Cleveland on road suddenly disappeared and merged into one I consider ‘unsafe’. Finucane Rd after death of 26 yr old male crashed into at Willard and Finucane Rd at a black spot, now fixed, is declared by State Govt as being an ‘unsafe’ road. It’s well known overseas where new roads have been built to ease congestion on existing congested ones, soon fill up, and is not the answer. Serious consideration has to be given and acted on at all levels of government in promoting fast affordable public transport, road and rail, to encourage commuters to leave their cars at home. Diesel fumes are carcinogenic and I see around me most vehicles are powered by diesel, knowing builders do not have to leave pollution barriers, people living alongside busy roads, are subjected to inhaling particulates from auto exhausts causing respiratory and other health destroying conditions. In the end, the only wealth any of us have, is our health, without which we cannot have a productive workforce, or community wellbeing. My view.
There is sufficient expert knowledge of the significance mangroves play in this fragile ecosystem, which brings life and food sources for so many animal species.
This is suppose to be protected Ramsar wetlands.
It needs to be protected, a buffer area put in place for any development or improvements of the car park situation at Toondah.
Upgraded car park is all that is needed, that’s all, no need to go multi level concrete destruction here.
Keep the mangroves alive, keep the ecosystem alive, keep our animals alive.
We do not need what the Walker group is proposing, there is no need for that, that is just greed, with no thought to the future of our fragile ecosystem.
Go on, kill off a bit more of this precious world help tip the balance, be another fool amongst the fools……