Redland City Council has referred the Birkdale Community Precinct and Redland Whitewater Centre to the Environmental Protection and Biodiversity Conservation (EPBC) Act – EPBC number: 2026/10471
Comments can be made through the EPBC Public Portal until Friday April 24, 2026
Make Comment
You are required to provide your full name and email address
Do you consider this is a controlled action? YES
Provide reasons for why you believe this is/is not a controlled action
Below are some points you can use in this section (using your own words where possible is best)
• The proposed construction of an industrial-scale whitewater venue within an area surrounded by Core Koala Habitat will have significant impacts on the endangered koala population.
• The action clearly meets the threshold for a ‘controlled action’ under the EPBC Act and must be subject to full and rigorous assessment.
o Koala experts have confirmed that at least 21 individual koalas have utilised the Birkdale site over a four-year period (2018–2022)
• The site functions as:
o Active habitat and movement corridor, not isolated or marginal land
• The proposal will:
o Directly and indirectly reduce habitat availability and connectivity
• Increase risk of population decline at a local and regional scale
• At least 126 non-juvenile koala habitat trees will be impacted:
o This figure is likely an underestimate, pending further arborist assessment and design changes
• Trees proposed for removal include:
o Critical “stepping stone” trees essential for safe koala movement
o Trees that play a key functional role in maintaining connectivity across the site
• Loss of these trees will fragment habitat and increase ground movement and associated mortality risks.
• The majority of the Birkdale site is mapped as:
o Core Koala Habitat
• The site also contains:
o Groundwater Dependent Ecosystems (GDEs) overlapping with koala bushland
• This combination represents:
o High-value, sensitive ecological habitat critical to species survival
Groundwater and Hydrological Risks
• The Whitewater Centre requires excavation depths of up to 7 metres:
o This will interfere with the underlying freshwater aquifer
• The impacts of this interference are:
o Unknown and inadequately assessed
• Risks include:
o Groundwater depletion or alteration
o Dieback of groundwater-dependent vegetation
o Long-term degradation of koala habitat
• Interference with this fragile system poses:
o A serious and potentially irreversible ecological risk
Increased Threats During Construction and Operation
• The proposal introduces additional threats to koalas, including:
o Increased traffic and associated vehicle strike risk
o Construction fencing and barriers over an extended period (~3 years), restricting movement
o Elevated stress and displacement
• These impacts:
o Compound existing threats and further reduce survival prospects
o The population already have high disease rate which is highly likely to be exasperated
Uncertain and Unenforceable Mitigation Measures
• The proposal relies on:
o Future mitigation actions linked to the broader Birkdale Community Precinct
• However:
o It is undetermined if or when this broader project will proceed
• As a result:
o There is no certainty that proposed mitigation measures will be implemented
• This creates:
o A significant accountability and enforceability gap
Incomplete and Inadequate Referral Information
• The application:
o Provides insufficient detail across key impact areas (subject to future specialist reporting)
o Fails to adequately assess:
Traffic impacts
Stormwater and wetland design
Groundwater impacts
Full extent of habitat loss
Functional ecological connectivity
• The lack of detail:
o Prevents proper assessment of impacts on MNES
o Reinforces the need for comprehensive assessment at a higher level
Failure of Strategic Conservation Frameworks
• A Conservation Agreement between Redland City Council and the Federal Government:
• Has not been finalised, this agreement is intended to:
o Protect and conserve biodiversity across the landscape
• Proceeding with this proposal in its absence:
o Undermines strategic conservation planning
o Risks further incremental loss of critical habitat
Conclusion and Recommendation
• The proposed action:
o Will have significant impacts on the endangered koala and its habitat
o Involves high ecological risk, scientific uncertainty, and inadequate assessment
• Therefore:
o The proposal must be declared a ‘controlled action’ under the EPBC Act
o It should be subject to rigorous, transparent, and independent environmental assessment (EIS level)