KAG Notice – Submissions on Toondah Harbour due on Wednesday 20 June 2018.

By June 12, 2018 June 18th, 2018 News

Dear members and friends,

A revised plan has been proposed by Walker Group with a reduced size of the reclaimed land in Moreton Bay Marine Park.  The proposed plan still includes a 200 berth marina and up to 3600 dwellings in the form of high rise units to be predominantly built on the reclaimed land.  The entire development area takes in 17.5 hectares on land and 49.5 hectares over marine and tidal environments. 

 From the beginning much of this whole project has been shrouded in deception and secrecy, evidenced by the term ‘Tourism and Recreation’ under Project Industry Type, and restriction of detail from the Queensland Government and RCC.  This is clearly a massive housing development in a very confined space with very limited vehicular access (one road and one street, both terminating at the waterline).   The calculated population density in this site will effectively add a new city electoral division to this small area.  It would be difficult to find an existing housing area so densified that isn’t beset by social impacts.

The environmental impacts on the RAMSAR listed Moreton Bay Marine Park will still be significant, as will the negative impacts on the Toondah and Cleveland koala population which will struggle to survive the substantial increase in traffic expected during the construction phase and the traffic movement of a future population of up to 10,000 additional people.

The Federal government is again asking for submissions and the period for community consultation this time is (disturbingly) very short, closing on Wednesday 20 June 2018.

 To assist with submission writing, below is some information from KAG and Redlands 2030 that can be used for your own submission by cutting and pasting.  Feel free to copy the following information,  make any amendments and add your own comments if you wish.

Email submissions to:  epbc.referrals@environment.gov.au



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 and my grounds for this 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.

Moreton Bay is a Ramsar wetland and thus is an important habitat for thousands of migratory shorebirds. The proposed development would destroy feeding grounds used by various shorebird species including the vulnerable Bar-tailed Godwit and the critically endangered Eastern Curlew. Australia has signed agreements with China, Japan and Korea to protect many species of migratory shorebirds and their habitats.

The Moreton Bay Ramsar site has been protected since 1993 because of its biodiversity including many vulnerable species.  The bay’s seagrass beds support a significant dugong population and many species of turtles including Green, Hawksbill and Loggerhead.

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.

NOTE: In a recent decision about the Redland Bay ‘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.


A radio tracking study conducted by the Koala Action Group shows that the area around Toondah Harbour contains a healthy breeding koala population. The Toondah Harbour precinct and surrounding areas contains some of the most valuable koala habitat.  One of the most nutritious species of eucalyptus in the region, Eucalyptus Tereticornis is predominant in the Toondah precinct and are heavily utilised by the koalas living in and around the area.

Numerous old growth eucalyptus trees are located on the footpaths of Shore St East and will potentially be removed for future widening of this narrow street, being one of only two access roads into the proposed development area.

The tracking study has proven that the numbers of koalas in the area are much greater than the two koalas stated in the developers report and the data collected has highlighted the vast movement patterns of this population of koalas who regularly cross roads in the area.  These vital movement corridors will be severely impacted by the substantial increase in traffic created by the proposal both during construction phase and with the future population growth of up to 10,000 people.

Heritage values

The construction of a marina, high rise buildings and associated development will significantly undermine the heritage values of GJ Walter Park and historical house ‘Ferneigh’. It was one of the first houses to be built in Cleveland and encompasses a slab-built construction originally used as the first school house in Cleveland.  Its views, currently looking out to the bay would be replaced by an aspect looking on to high rise buildings and would seriously diminish its heritage values.

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.

Community consultation process flawed

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 an alternative

If Walker Group’s Toondah plan is not approved, the process of upgrading the Stradbroke Island 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 the recently completed redevelopment of the bus/ferry terminal at Weinam Creek in Redland Bay.


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