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Walker Group Holdings Pty Limited/Commercial Development/Moreton Bay/Queensland/Toondah Harbour Project, Moreton Bay, Qld

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Walker Group Holdings Pty Limited/Commercial Development/Moreton Bay/Queensland/Toondah Harbour Project, Moreton Bay, Qld From: s47F To: EPBC Referrals Subject: EPBC ACT REFERRAL Date: Tuesday, 8 December 2015 4:32:55 PM Attachments: TOONDAH PROPOSED 2015 (B).pdf REFERENCE NUMBER 2015/7612 Walker Group Holdings Pty Limited/Commercial Development/Moreton Bay/Queensland/Toondah Harbour Project, Moreton Bay, Qld Dear Sir/Madam, I am concerned as to how a private investment group could possibly be attempting to acquire and develop, with Local Authority and State Government “assistance”, a substantial area of the Moreton Bay Marine Park, a RAMSAR site considered Critical Shore Bird Habitat, for the purposes of residential development. With the state government designating the site with PDA boundaries, the developers have now exceeded the original boundaries of the site they were allocated by approximately 97,500m2 (refer attached drawing TOONDAH PROPOSED 2015(B)), going further out into Moreton Bay and filling more of the marine wetlands. It is accepted procedure that any development must be contained within the site boundaries for public open space – apparently the Walker Group consider they do not have to meet boundary restrictions. They have filled the PDA site with buildings and then nominated nearly 10 hectare of Moreton Bay as public open space. Regards s47F From: s47F To: EPBC Referrals Subject: Toondah Harbour Priority Development Area Development Scheme- Reference No:2015/7612 Date: Sunday, 6 December 2015 4:53:07 PM Attachments: Environmental Impact Assessment Process 6 Dec 15.docx Dear Sir/ Madam , Please find attached a submission on the above proposal submitted to the Minister for the Environment. s47F s47F Referrals Gateway Environment Assessment Branch Department of Environment GPO Box 787 Canberra ACT 26001 6 December 2015 Toondah Harbour Priority Development Area Development Scheme Dear Sir/Madam, I understand that the above project has been submitted to the Minister for the Environment as the first step in initiating an environmental impact assessment. I should like to make the following comments on this Scheme. While I support the development of Toondah Harbour, the Scheme now proposed is a significant expansion on the development plan presented as a PDA and has a large negative impact on the environment and is inconsistent with the original vision of the PDA. Reclamation of a huge area of Moreton Bay National Park for the creation of a new medium/high density residential marina area creates a significant precedent, where the resulting loss of pristine natural bay and mangrove environment needs strong counter arguments in favour of housing development. I do not believe such arguments exist as Redlands is not short of suitable land for housing, and the development of the passenger/freight ferry terminal can be achieved without significant land reclamation or adverse transport and access issues. The proposed extended residential development which occupies the current tidal bay will require a significant elevation to provide storm protection consistent with the Redland City 100 year flood assessment. This footprint will require a huge increase in land fill sourced from reclaimed marine silt, indeed it may be impossible to source sufficient from the proposed marina without the addition of dredged fill from other parts of the National Park or from shore sourced land fill. Significant areas of acid sulphate soils are known to be in the area to be dredged for this landfill. There is little doubt marine flora and fauna will be seriously impacted by this resumption of Moreton Bay. Aside from the obvious loss of mangroves, sea grasses and their associated fish, turtles and dugongs, we have a loss of nesting and feeding tidal areas which are frequented by migratory sea birds. The magnitude of this loss of the Moreton Bay Marine Park seems inconsistent with the community’s expectations for future environmental management, particularly when so many other low impact options exist. Yours sincerely, s47F From: s47F To: EPBC Referrals Cc: s47F Subject: EPBC referral 2015/7612 Date: Sunday, 6 December 2015 5:55:33 PM Attachments: EPBC referral Toondah Harbour 6 Dec 15.doc Dear Sir/Madam Please find attached the submission from the Queensland Wader Study Group regarding the proposed Toondah Harbour development in Cleveland, Queensland. Yours sincerely s47F QWSG Committee member Queensland Wader Study Group (A special interest group of the Queensland Ornithological Society Inc) s47F s47F QWSG s47F www.waders.org.au 6 December 2015 [email protected] Dear Sir/Madam, Re: Toondah Harbour Development Project, Cleveland, Queensland by Economic Development Queensland and Redland City Council. Ref No. 2015/7612 The Queensland Wader Study Group (QWSG) is extremely concerned about the potential impact of the proposed Toondah Harbour development on the ecological character of the Moreton Bay Ramsar site and the Moreton Bay Marine Park. The proposed 167.5 ha development footprint that plans to excise and fill 43.5 ha of intertidal and sub-tidal marine habitats will have a major environmental impact on the local and regional migratory shorebird populations. The BAAM (2014) migratory shorebird assessment found that there were up to 180 of the nationally Critically-Endangered Eastern Curlew Numenius magagascariensis that forage within the development or roost nearby. These tidal flats form part of a network of foraging habitats used by a large number of shorebirds that occur in Moreton Bay during their non-breeding season. Eastern Curlew have recently been listed as Critically-Endangered under the EPBC Act due to the incremental loss of habitat that has occurred on their non-breeding grounds in Australia (Wilson et al., 2011) and their migratory stop-over sites in Eastern Asia (Yang et al., 2011). This proposed development will remove another 50.5 ha of migratory shorebird foraging habitat and will incrementally contribute to the on-going declines in the numbers of migratory shorebirds feeding in Moreton Bay. Wilson et al. (2011) found that migratory shorebird populations had declined by 62% in Moreton Bay during the previous 15 years. Nearby high tide roosts will receive increased disturbance from the increased human activity by the people living within the development. These birds are highly likely to abandon these roosts due to this increased disturbance as has been found elsewhere in Queensland (Milton and Harding 2011). 2 The nearby Nandeebie Park and Cassim Island high tide roosts can be used by over 2,000 migratory shorebirds (QWSG records in BAAM 2014). These large numbers of migratory shorebirds demonstrate that the intertidal areas within the development area are a critical part of the foraging habitat of these birds. Besides the loss of key feeding habitats within a nationally-protected Ramsar site and state marine park, the increased human activity will have a demonstrated effect on the use of the remaining intertidal areas and high tide roosts adjacent to the site from increased human disturbance. Similar effects have been shown for a shorebird high tide roost in Mackay (Milton and Harding 2011). The proposed close proximity of the outer wall of the development at the western edge of the Cassim Island mangroves will also degrade these mangroves as a result of the stormwater runoff, increased urban refuse and altered tidal flow patterns. We urge the Environment Department to refuse this development application on the clear unacceptable impacts on matters of national environmental significance and should not proceed to be assessed under the EPBC Act. References BAAM (2014). Migratory shorebird assessment for the Toondah Harbour and Weinam Creek Priority Development Areas. Report prepared for frc environmental on behalf of Walker Corporation. 17 pp. Milton, D.A. and Harding, S.B. (2011). Death by a thousand cuts: the incremental loss of coastal high tide roosts for shorebirds in Australia: Sandfly Creek environmental reserve central Queensland. Stilt 60: 22-33. Yang, H.Y., Chen, B., Barter, M., Piersma, T., Zhou, C.F., Li, F.S., and Zhang, Z.W. (2011). Impacts of tidal land reclamation in Bohai Bay, China: on-going losses of critical Yellow Sea waterbird staging and wintering sites. Bird Conserv. Int. 21: 241-259. Wilson, H.B., Kendall, B.E., Fuller, R.A., Milton, D.A. and Possingham, H.P. (2011). Analysing variability and the rate of decline of migratory shorebirds in Moreton Bay, Australia. Conserv. Biol. 25: 758-766. Yours sincerely, s47F Queensland Wader Study Group From: s47F To: EPBC Referrals Subject: submission for Toondah Harbour Project 2015/7612 Date: Tuesday, 8 December 2015 4:26:24 PM s47F From TO; Referrals Gateway Environment Assessment Branch Department of the Environment REGARDING THE TOONDAH HARBOUR PROJECT REFERRAL, 2015/7612 - please consider my written comments below. Under 1.9 and 2.2 “Alternatives to proposed action” the response given by the Proponent is totally unsatisfactory. This project in its latest version proposes to reclaim publicly owned marine park for suburban real estate. Presumably this is justified as being highly profitable and therefore able to drive other non- profitable aspects of the project, but i believe such a rationale is a fault of the design overall, and should not be part of the EPBC Act assessment for environmental loss. - The precedent set for revoking of the marine park for suburban land creation is something that cannot be given as a simple ‘no other alternative’ claim by developers i.e. the words of 2.2 “the proposed action is consistent with the government parties’ proposal for the Toondah Harbour PDA”. On the contrary, the previous plan for the PDA did not have reclamation for suburbia, so that was obviously an alternative then. Further to 2.2 and also 2.3 - The sound alternative to this proposal is to downsize to a marine facility-oriented land development, in keeping with the long term State Govt planning for south east Queensland and the Moreton Bay marine park, with the only high rise being less than 3 stories and that largely offsetting costs for a large three story carpark that caters to the parking.
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