Draft submission

Draft submission


The deadline for submission is 25 May, 2017

The draft submission is in response to the Federal Environment Department’s Invitation to comment on the latest referral of the Toondah Harbour proposal to dredge and “reclaim” over 40 hectares/100 acres of Moreton Bay’s Ramsar protected wetlands at Cleveland – where the ferries depart for North Stradbroke Island – to construct a high-rise “development” including 3,600 apartments. Submissions must be sent by 25 May.

You will find all the relevant information relating to the latest referral of the proposal by the Walker Group to the Federal Environment Department linked to this post from Redlands 2030 –

The proposal cannot proceed unless the Federal Government approves it under federal environment laws.

Please feel free to copy and paste this draft and re-word as you like and add your own personal touch. A personally worded submission carries a lot more weight than one copied and pasted word for word. But take notice of the Federal Environment Department’s advice on making a submission – scroll down this link to ‘Invitations for public comments’ –


As requested in the Invitation for public comments, please email your submission to the following email address and make sure you include the Re: section as this information is essential.

(Cc email to yourself for your records. You could also send a copy to the Federal Environment Minister, Josh Frydenberg)

Re: Walker Group Holdings – proposed Toondah Harbour development – Reference Number: 2017/7939

I submit that approval of this proposal should be rejected because it is likely to have a significant impact on matters of national environmental significance protected by the EPBC Act. More specifically, I urge rejection of the proposal for the following reasons:-

  1. It is very similar to the previous proposal referred under the EPBC Act by the Walker Group in November, 2015 (EPBC referral Ref: 2015/7612), but withdrawn by Walker on 4 May, 2017. The withdrawal followed an unprecedented six suspensions of decision making by the Federal Government. It is obvious the Federal Government had very serious concerns about the proposal’s impact on matters protected by the EPBC Act and there is little reason for this view to change.
  2. The latest proposal still involves dredging and reclamation of over 40 hectares of the protected Moreton Bay Ramsar site. This by itself should be sufficient to refuse approval, but there are many other reasons which also call for refusal.
  3. Developers, including those who donate to political parties such as the Walker group of companies, should not be able to profit from real estate developments constructed on publicly owned areas protected under the Federal Environment Protection and Biodiversity Conservation (EPBC) Act.
  4. There are a number of migratory bird species which inhabit the area in and/or around the proposed reclamation area, most of which is Ramsar protected. They feed and/or roost in these areas. These birds are protected under the EPBC Act. They include the critically endangered Eastern Curlew and the critically endangered Great Knot, whose numbers have declined substantially in recent years. Australia is also a party to other international agreements designed to protect migratory birds.
  5. A significant koala population inhabits the foreshore area included in the proposal. This has been documented by koala groups and is well known. How could the koalas survive the proposed construction, the increase in traffic during and after construction, the likely increase in the number of dogs in the area and other related threats?
  6. The referral documents (eg the map included in the summary of the report by frc environmental) also reveal that more than half of the Ramsar protected wetlands area to be reclaimed under the proposal is covered by seagrass, which is part ofmigratory bird feeding grounds and is also important to other species inhabiting the area, such as dugongs and turtles, and for fish and prawn breeding. The importance of seagrass is even recognised by the Queensland Government – eg see –
  7. Other areas of Moreton Bay are at risk of being affected by dredge spoil and other current carried pollution, not to mention construction noise over 15 to 20 years, plus on-going noise from up to 10,000 people who would inhabit the proposed 3,600 dwellings to be constructed, including over the top of currently protected wetlands. The Redland City Bulletin reported in May, 2017 that Walker’s proposal still involved 3,600 dwellings – the report can be read here.
  8. The proposed action is not for critical infrastructure which in some circumstances might be considered to justify destruction of Ramsar wetlands, although in these circumstances, where critically endangered migratory birds would be impacted, it should not.
  9. The North Stradbroke Island ferry departure point has been misused by the proponent and some of its supporters in an attempt to justify the destruction of Ramsar wetlands for the massive real estate development proposed. The ferry/ water taxi terminal is not in need of anything other than a modest upgrade which could be undertaken by the ferry company, Sealink, which made a record profit last year and record interim profits this year – and
  10. The proposed ferry/water taxi terminal shown in the proponent’s plans is significantly smaller than the current area occupied by the ferry and water taxi departure points. Also, the traffic problems created by the proposed construction and large scale residential and retail area are likely to inconvenience users of the ferry terminal.
  11. We do not have a shortage of dry land which could be purchased in the usual way by a real estate development company wishing to profit from the construction of a residential development in South East Queensland.
  12. The last time the Walker Group wanted to dredge and reclaim important (but not Ramsar protected) wetlands, which was near Hobart, the Federal Government refused approval even though the nearest Ramsar wetlands were 12 kilometres from the proposed development site ( EPBC Ref: 2006/3193 – Walker Group – re: Lauderdale, Tasmania). For more information and for a link to the Federal Government’s Refusal Notice, click here.
  13. At Toondah Harbour, the proposal is to destroy a section of the Moreton Bay Ramsar wetlands. Also, the indirect threats from current carried dredge spoil and other pollution relate to Ramsar wetlands which surround the proposed development site and extend to a distance of 12 kilometres from the proposed development site.
  14. Applying the same logic as was used by the Federal Government to reject Walker’s Tasmanian proposal, it is likely that large sections if not all of the Moreton Bay Ramsar site would be at risk of damage from current carried dredge spoil and other pollution from the proposed development site.
  15. The reasons for rejecting approval are over-whelming. In particular, as it involves the destruction of a section of the protected Moreton Bay Ramsar wetlands site, I urge you to reject it as being clearly unacceptable.


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