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home -> conservation -> past submissions
CONSERVATION
Commerce in National Parks?
Save the Walsh River: another step in the right direction
Wenlock River needs your help!
Halt Sand Mining on North Stradbroke Island
Submissions...
Past Issues...

Detail of more recent submissions can be found here.

SUBMISSIONS MADE DURING 2008
Brisbane River North Bank development

Department of Infrastructure and Planning – September 2008

In its 3rd submission on subsequent North Bank proposals since 2005, WPSQ welcomed the idea of developing the area if the result enhanced the waterfront and improved access. This potential must however be balanced against environmental and hydrological values, and sustainable land use. WPSQ opposed any buildings or encroachment on the river, any impact on the historic vista, and any increased congestion in the CBD. WPSQ questioned the wisdom of incorporating a signature building, a public aquarium or a 'CBD playground'. Overall, the proposal was criticised for not providing enough detail for informed public comment WPSQ stated that building heights must be kept to a minimum and requested that the final outcome be one of balance not overdevelopment.

Far North Queensland Draft Regional Plan

Department of Infrastructure and Planning – August 2008

WPSQ welcomed the draft plan’s protection of the natural environment, and limitation on urban growth and urban sprawl, plus the plan’s support for non-car transport. However, the draft plan required more emphasis on the likely effects of climate change and other impacts on the valuable biodiversity of the region, including better protection for areas of highly ecological significance; and improved sustainable infrastructure provisions.

Beneficial Use of Waters Associated with Coal Seam Gas

Origin Energy ­ July 2008

WPSQ encouraged the beneficial use of the waters associated with coal seam gas (CSG), provided its use did not have an adverse impact on the environment. CSG sourced water might prove to be a viable alternative source of water other than large dams. Submitted in association with QCC

National Koala Conservation Strategy

Department of the Environment, Water, Heritage and the Arts - July 2008

WPSQ generally welcomed the draft conservation strategy but made several additional recommendations including specific protection strategies to support urban koala populations (eg restrictions on dogs); better protection and management of habitat; better integration of the strategy at all levels of government. The translocation of koalas was opposed.

Draft Environmental Assessment of the Suitability of the Import of the Savannah Cat (Domestic Cat x Serval Hybrid Specimens) into Australia

Department of Environment, Water, Heritage and the Arts - July 2008

WPSQ congratulated the federal government for the proposed amendment to the live import list to restrict the importation of the cross-bred cats, and the development of the draft assessment report. The savannah cat is a significant threat to wildlife and biodiversity and it should not be introduced into Australia.

Referral of the Nathan Dam and its pipelines to the EPBC Act

Department of the Environment, Water, Heritage and the Arts ­ July 2008

WPSQ strongly urged the Minister to exercise his powers and require SunWater to provide additional information about the dam’s direct and indirect climate change impacts, the cumulative environmental impacts of third party use of water supplied from the proposed action (specifically agricultural use) and impacts on Matters of National Environmental Significance as per legal decisions from the 2004 Nathan Dam court case. Submitted in association with QCC and EDO(Qld)

Fast tracking of Greenfield Sites

The Premier ­ July 2008

WPSQ wrote to the Premier opposing her call to increase land supply for housing through the early release and fast track development of Greenfield sites. Among other negative outcomes, this would put pressure on existing infrastructure and impact on SEQ koala populations. Appropriate planning processes should always be followed.

East Coast Inshore Fin Fish Fishery Regulatory Impact Statement

Department of Primary Industries and Fisheries – March 2008

WPSQ opposed the introduction of gill netting and the proposal for targeted killing of rays and sharks.

Moreton Bay Draft Rezoning Plan

Minister for Sustainability, Climate Change and Innovation – March 2008

WPSQ supported the expansion of go-slow zones, conservation zones and National Park zones in Moreton Bay but criticised the expansions as being too limited. National Park zones were only boosted to 15% of total whereas international standards consider 30% of total as a minimum. Among other issues, WPSQ was also concerned that too much fishing activity would be allowed in conservation zones and that enforcement would be inadequate in many limited activity areas.

Boggomoss snail draft recovery plan

Department of the Environment and Water Resources – February 2008

WPSQ offered in-principle support to the plan, especially the expressed commitment to protect the snail’s habitat in collaboration with local landholders and indigenous people. However, the lack of reference to the likely impact of the proposed Nathan Dam on one of the snail population’s only two known sites lessened the value of the plan.

Draft horse riding code of conduct

Environmental Protection Agency – February 2008

WPSQ acknowledged that horse riding is a legitimate recreational pursuit but not in National Parks. This code implies that National Parks are for recreational horse riding and not their prime purpose of conserving our biodiversity. In addition, the draft code was considered to be inadequate in its detail and that EPA lacked the resources to police the provisions of the code.

Traveston EIS submission

Coordinator-General, Department of Infrastructure and Planning – January 2008

Wildlife Queensland made a submission in response to the Environmental Impact Statement (EIS) on the proposed Traveston Crossing Dam on the Mary River. The submission criticised both the content and the process of the EIS. The statement inadequately addressed how climate change will affect the dam’s impacts, the impact on species known to be endangered and other species, and failed to address alternatives to dams. Statements in the EIS were based on inadequate data, failed to address the terms of reference and did not deal with the Queensland Government’s obligations under federal protocols and agreements. Wildlife Queensland pointed out the implications of the impacts of the dam on the Great Sandy Strait environment and endangered species that live in the Mary River.

Read the full submission

PAST SUBMISSIONS UP TO 2007
Gamba grass

Minister for Sustainability, Climate Change and Innovation - December 2007

Wildlife Queensland, the Queensland Conservation Council (QCC), and the Wilderness Society (TWS) wrote to the Minister expressing concern about gamba grass, considered a major threat to Queensland’s biodiversity.

The three conservation groups asked that gamba grass be declared a Class 2 Weed under the Queensland Land Protection (Pest and Stock Route Management) Act 2002.

Queensland Government Environmental Offsets Discussion Paper 2007

Environmental Protection Agency - November 2007

Wildlife Queensland responded to the discussion paper with qualified support for the concept as a last resort if no other better outcome for the environment was possible. The use of offsets should not encourage inappropriate development and should provide a positive gain for the environment, ie. the offset should be close to the project; the offset should compensate at a rate of 200% for the damage it was offsetting;. We also noted that although vegetation offset was measurable, the damage to wildlife was hard to compensate for.

Draft Queensland Wildlife Trade Management Plan for Export – Commercially Harvested Macropods 2008–2012

Wildlife Trade Assessments, Federal Department of the Environment and Water Resources - October 2007

WPSQ made a submission stating that the Society was not opposed to the commercial harvest of certain species of kangaroos as long as a sound scientifically based management plan was in place; animal welfare issues were adequately addressed and an appropriate monitoring program ensured compliance with the plan and relevant legislation.

Wildlife survey of Protected Area Estate

SEQ Regional Nature Conservation Strategy Advisory Group - September 2007

Wildlife Queensland has urged the Queensland Government to systematically survey the fauna that live in the state-run national parks and reserves known collectively as the Protected Area Estate. It is Wildlife Queensland’s view that the government does not have an adequate knowledge of what wildlife lives on the estate it manages on behalf of the public and that current records are inadequate. This missing data is part of a knowledge gap in the state government that prevents the formation and implementation of adequate conservation management strategies. Wildlife Queensland will continue to raise this issue with the minister’s office.

More information on the need for wildlife surveys of the Protected Area Estate.

Hinchinbrook Resort Lease

Minister for the Environment and Multiculturalism - April 2007

Wildlife Queensland has written to the Queensland Minister for the Environment expressing concern that the developers of the environmentally controversial Oyster Point resort development on the Hinchinbrook Channel at Cardwell might be handed the lease for the Hinchinbrook Island Resort.

Read the Ministerial letter

Traveston Dam Senate Inquiry

Senate Inquiry into Additional Water Supplies for South - East Queensland April 2007

Wildlife Queensland made a written submission to the Senate Inquiry and subsequently appeared before the inquiry when it met in Brisbane to take verbal submissions and responses.Wildife Queensland stated it did not support the Traveston Dam as part of the solution to south-east Queensland's water supply issues. Wildlife Queensland urged the federal government to examine its powers to block the project.

Read the Full submission to the inquiry; the Address to the inquiry.

South-East Queensland Regional Outdoor Recreation Strategy

Department of Local Government, Planning, Sport and Recreation - March 2007

Wildlife Queensland recognised the recreational needs of Queensland’s growing population but expressed concern that the strategy contained no commitment to protect the limited remaining natural areas and their important biodiversity.

  • We urged the government to provide funding for the acquisition and management of recreational estate distinct from the protected area estate.
  • We commented that the discussion paper didn’t provide much detailed information or guiding principles.
  • We suggested...
    • a user pays system in places in conjunction with a permit system could be appropriate;
    • user education about weeds and disease risks; adequate budget to protect areas of biodiversity;
    • partnerships of all levels of government, community and user groups to be charged with the care and maintenance.
Brisbane River North Bank development

Submission to Department of Infrastructure - March 2007

We criticised the selected developer (Multiplex)’s proposed design concept for these reasons:

  • Varies a great deal from the State Government’s Preferred Strategic Plan for North Bank released in November 2004 (on which WPSQ made comment, see archive) including ignoring guidelines on building height.
  • Ecological destruction of the Brisbane River and destabilisation of the riverbank by encroaching on the river, which damages a major asset of Brisbane.
  • Proposed increased car access and parking to service multistorey commercial buildings will increase traffic congestion, detract from the city’s liveability, add to pollution and increase pressures on infrastructure.
  • Destruction of the amenity of existing public space in the city.
  • Impacts too heavily on the context and surroundings of Brisbane’s last vestige of historic and cultural heritage in the William Street/Queens Wharf Road precinct.

We supported the provision of pedestrian and bikeways.

Review of the Integrated Planning Act 1997

Submission to the IPA Review, Queensland Department of Local Government and Planning

Wildlife Queensland urged the State Government to amend the Integrated Planning Act 1997 (IPA) to mitigate the impacts of climate change in Queensland. Predicted rapid global climate change will raise temperatures in Queensland too fast for animals or plants to migrate or evolve to deal with the changing conditions. The results will be widespread species death and extinctions before 2070. Wildlife Queensland's proposal recommends strategically amending the IPA to preserve Queensland bushland vegetation so that animal and plant species are more likely to survive.

Read a 1-page summary; the executive summary (8pp); the entire submission (62pp); the recommendations (16pp).

More information about Wildlife Queensland's Protecting our Bushland campaign.

Federal responsibility for National Parks

Submission to Senate Inquiry on National Parks, Other Conservation Reserves and Marine Parks - March 2006

Wildlife Queensland put in a submission to the federal inquiry that raised these issues:

  • exploitation of National Parks for commercial gain
  • lack of development in the marine park system
  • failure to achieve target acquisitions under Australia's obligations to the National Reserve System and the deficiency of the current model related to funding cuts, among other topics
  • the possibility of a levy to fund the development and acquisition of land for parks and reserves in Australia.
  • threats to National Parks and other parks that could be addressed by better government management at all levels.

Read the full submission

Selection of submissions during 2006
Banning monofilament netting

Submission to the Federal Minister for the Environment February 2006

Wildlife Queensland asked the minister to support a ban on the import and/or sale of monofilament nylon netting because its use on backyard fruit trees is killing and maiming flying foxes.

Selection of submissions during 2005
Cannon Hill Community Links (previously known as Minnippi Community Links)

Submission to Brisbane City Council - October 2005

Wildlife Queensland strongly opposed this proposal and expressed grave concern about the potential loss of green space from the city's environs and the threat to wildlife in general, and the local squirrel glider community in particular. The potential damage will include loss of vegetation and fauna habitat, damage to and pollution of wetlands and waterways, and waste management problems. Wildlife Queensland also noted that there are remnants of Of Concern Regional Ecosystem vegetation in the affected area.

Brush-tailed rock wallabies at Perseverance Dam

Submission the Queensland Minister for the Environment and Local Government - October 2005

Wildlife Queensland asked the Minister to protect the colony of brush-tailed rock wallabies that live on the dam wall at Perseverance Dam, Crows Nest. The small but significant colony of this species, listed as vulnerable in Queensland, is shrinking because the wallabies are being killed by traffic when they cross the road that runs past the dam. WPSQ asked the Minister to get her two departments to work together to produce the necessary Traffic calming measures and wildlife-friendly road structures.

Cruise terminal in the Broadwater, Gold Coast

Submission to the Premier - April 2005

Wildlife Queensland opposed this proposal because it will reduce public space and destroy the beauty of the area. We believe the ecology of the region will change and there will be more pollution and increased turbidity that will damage seagrass beds. Biosecurity will also be a problem.

Codes for better control of broadscale clearing

Submission to the Department of Natural Resources and Mines - March/April 2005

Wildlife Queensland supported the improved codes because they protect fauna habitat but we are concerned about the exemptions given to mining and State projects. We asked for:

  • fodder harvesting to be restricted to mulga lands and other parts of western Queensland where harvesting happens already
  • better guidelines for issuing weed control permits
  • the codes to include a process for declaring areas of high conservation value.
Draft Nature Conservation (Koala) Conservation Plan and Management Program 2005

Submission to the Environmental Protection Agency (EPA) - March 2005

Wildlife Queensland thanked the Government for the plan but said it doesn't do enough. Our criticisms included:

  • The plan is based on codes that are not available.
  • The mapping of the management areas and zones seems inaccurate.
  • Research and monitoring is restricted to South-East Queensland.
  • The Queensland Government keeps allowing development on land that includes koala habitat.

We asked for:

  • compulsory covenants to protect koala habitat
  • enough resources to put the conservation plan into practice and make sure it is carried out
  • a decision by the Queensland Government on how many people can sustainably live in South-East Queensland
  • the Queensland Government to take account of how many eucalyptus trees are likely die because of global warming.
Declaration of Great Sandy Strait Marine Park (Northern Section)

Letter to Environmental Protection Agency - February 2005

Wildlife Queensland thanked the Queensland Government for declaring the Marine Park as promised. However, we are disappointed that only 4 per cent of the total area is protected. We said that:

  • commercial fishing has too much access to the area
  • the proposed zonings don't protect the area enough.
South-East Queensland Regional Plan

Submission to Regional Planning Minister - February 2005

Wildlife Queensland congratulated the Queensland Government on the proposed plan. However, we think it is too limited to deliver ecologically sustainable development. Our criticisms included:

  • The planning principles are not best practice.
  • The urban footprint is too large and affects areas of high conservation value.
  • Population needs to be limited to be sustainable.

We asked for:

  • better protection for high conservation areas, wildlife corridors, waterways and wetlands
  • more accountability by the people responsible for putting the plan into practice.
Brisbane River North Bank development

Submission to the Department of Public Works - February 2005

We asked for the development to be changed to cause less damage to the area's environmental and historic values. We also asked for more vegetation and parkland and better public transport/bicycle facilities.

Changing Nature Conservation Act 1992 regulations

Submission to the EPA - February 2005

Wildlife Queensland supported the redraft of the regulations, including increased penalties for serious wildlife offences and better control of commercial ventures in protected areas. We opposed fishing in protected areas or allowing people to own electric grids to control flying foxes.

Selection of submissions during 2004
Protecting mineral and mining resources

Submission to the Department of Natural Resources and Mines - December 2004

We criticised how the draft State Planning Policy (SPP) conflicts with existing approved planning uses, significant regional ecosystems, wildlife corridors, agricultural land, Ramsar areas, World Heritage Areas and other parts of the SPP. We also criticised how the Queensland Government manages resource demand and the impacts of extraction.

Managing macropods

Submission to the Queensland Parks and Wildlife Service (QPWS), EPA - October 2004

Wildlife Queensland supported the plan's continued licensed commercial harvest of kangaroo species as long as the practice is humane and sustainable. Wildlife Queensland opposes the harvest of whiptail wallabies and recreational hunting of any kind. Wildlife Queensland supported the decision for each of the regions to have its own quota, rather than one quota for the whole state. However, we also asked for at least two more regions to be created. Wildlife Queensland is not opposed to EPA staff issuing Damage Mitigation Permits but we asked for the total number of animals killed under permit to be part of the total kill quota.

Conservation in Carnarvon National Park

Submission to QPWS, EPA - August 2004

Wildlife Queensland supported the draft conservation plan for the national park, but we opposed low-level joyflights being introduced.