October 7, 2012






The draft Bahrs Scrub Local Development Area Plan Sept. 2012 has some unexplained offset and environmental land acquisition deliverables which are unresolved for the environmental values in the Plan which are to be protected. particularly those which have Development Applications or approvals over them.

The Bahrs Scrub Draft Planning Study Nov 2010 states on p64. To provide consolidated areas of developable land requires the loss of environmental values in some areas. The loss of environmental values is to be offset by establishing two core environmental management areas(EMAs) and a number of wildlife movement corridors:.. SMAs and... WMAs.:

The extent of koala habitat to be potentially cleared appears to be about 125 ha. but the State and LCC aggregation of offsets do not appear to be guaranteed to acquire EMA 1 and EMA2 in a rapidly changing era of deconstruction of the Planning and Environment Law and Administrative Arrangements.

However without early implementation of ; secure land acquisition, and better zoning instruments for perhaps EMA 1 and particularly EMA 2 and Wuraga Road, further field work will be needed for koalas and rainforest fauna protection. These baseline studies are needed for assessment, classification and management purposes and for funding leverage, negotiating and decision making tools.


A number of programs are needed to compensate for; the shortfalls in the Bahrs Scrub Local Plan and historically the lack of provision of state and local government reserves and Parks and some services in Greater Beenleigh area (GCCC). That for Bahrs Scrub "the extent of category 2 & 3 constraints would render most of the area unsuitable for urban development. The resulting area would be unsuitable for urban development." is a reflection of the poor urban designation (SEQ Regional Plan) consultation and investigation processes by OUM and DLGP in 2004 and 2010 respectively and GCCC in 2006.



Offsets are a last ditch response, where three levels of Govt have largely not delivered baseline flora and fauna surveys, bioregional corridors, reserve acquisition and land swaps and are largely without community support,(as Local authorities are restricted in Negotiating with developers for real Community Facilities and bushland). The delivery of offsets in Qld has been substandard, perverse (pers com.SEQ Catchments),unsustainable(DTMR), missing (DTMR),undelivered(Water grid)& or undocumented(CODE, & not in register) The LCC and state vegetation, koala habitat, and biodiversity Offsets do not appear to stack upg given the proposed urban vegetation and other exemptions applied for, on some of the 129 ha of northern Net Developable Area in Bahrs Scrub. The LCC Offsets are ambiguous, in ratios ranging from 1:1 to 1:2.8 and in the timing (Draft LCC Planning Scheme 2013). The effectiveness of implementation remain unknown because of the Stockland applications for Major Project status and koala habitat and vegetation exemptions, as well as the SEQ Regional Plan SPRP and SP Act rollback changes, Vegetation Management Act changes and Bilaterals. The premise that affordable housing can be provided here with these constraints resembles the fatal flaw of discounting at Greater Flagstone ULDA where no offsets or protections apply for another 5,000 ha of clear felling of koala habitat.

These areas of environmental loss are not specifically nominated by RE and regrowth (not offset) and other classification except Net Developable Area and Medium Value Koala Habitat, but mapped in 2012.


These offsets appear insufficient and not deliverable in time to secure/renegotiate the koala habitat in the 3 GCCC rezonings (about 140 lots) and secure much of the Environment Management Areas of about 120 ha, as state government processes, budgets(Koala Habitat fund cut 50%). and staff are disappearing.



The EMAs have largely stand-alone attributes, which should normally ensure their reservation by other state programs;Toward Q2, Greenspace Strategy, Inter urban breaks, Koala Habitat Fund, Green Infrastructure Program and Ecofund as State Government buyback


The planning certainty for EMA 2 is not guaranteed with ;the PLANEX Application (11 ha) east west severance of the Clarkes Hill to Wuraga Road conservation connexion and the adjoining two Jordan Brothers approvals on Wuraga Road. These 3 sites of about 35 hectares feature, in the majority, the geotechnical category 2 and 3 constraints and feature koala habitat and other environmental constraints which jeopardise EMA2 and its connectivity .


There is a need to secure conservation linkages between Bahrs Hill (& Lot 161 on W311592) and Clarkes Hill and Wuraga Road and to secure as reserves the three GCCC rezonings (about 35 ha) and subsequent approvals. These three sites have the majority of the urban lands classified as category 2 and 3 geotechnical constraints.

There are substantial grounds now to remove the EMAs from the Urban Footprint, in order to more adequately preserve them from other agency intrusion and spot re-zonings. The environmental values still remain unprotected. There is little to stop SEQ Water, Powerlink or Main Roads or other arms of Logan City Council installing infrastructure services and structures by severing/bulldozing core areas or corridors by Code or community infrastructureg approvals. The PLANEX Application virtually severs the northern EMA 2


Further field surveys of koala habitats are also warranted, in order to renegotiate GCCC rezonings on three sites in EMA 2. This would justify larger koala and vegetation offsets and acquisition of other parts of EMA 2. SEWPAC Compliance section should be notified of these koala habitats as controlled actions.


There are potentially 9 conservation corridors in and out of the precinct, most of which have no planning, budget or program commitment including the fauna bridge to Mt Warren Hill.

The futures of some of the nine corridors inside and outside of the precinct are largely not ecologically or statutorily recognised. These require remapping on fig 13 as Overlays GIS and included in the Strategic Planning description and as supporting information.


1.    Windaroo Creek is shown on fig 13 p.25 with Endangered Regional Ecosystem near Bahrs Scrub Road opposite the Rainforest Reserve, but it should have linkages to Windarooo Valley High School.

2.    The north south linkage between EMA and EMA 2 should be widened It is noted that the conservation corridor linking the two EMAs has been widened south west of the causeway on Bahrs Scrub Road but has been inappropriately included in SMA2 instead of EMA1. The unnamed north south road adjoining in this area warrants closure as a conservation reserve and included in EMA1. However, the new corridor design warrants mirror image widening to the north of Bahrs Scrub Road north west of the causeway for Riparian Zone and flanking Koala Habitat planting in the waterway corridor in part of lot 12 on RP 161279. The Addendum study by Chenoweth and Associates on fig 7A shows habitat link creek from Parkland balance of Lot 500 on SP207339 south to north on a un named tributary of Windaroo Creek east of Hillview Court and west of New Horizon Avenue to a bend in Windaroo Creek with some Of Concern vegetation.


3.   The linkage between Wuraga Road and Mt Warren Hill is shown on FIG 7A on the Addendum study as "corridor link B". This corridor is shown too far north of Wuraga Road, although there are 3 bushland parks there and some Council freehold with a Water Tower. The parcels on the North side of the road feature a tongue of bush land on the east of Lot 999 on SP175806, behind that to the north is Lot 902 on RP 891736 park 1.9ha, east is Lot 901 on RP 891736 park 1.1 ha, Water Reserve Lot 100 on SP 129422 Water Tower, Big Park Lot 101 on SP129422 4.2 ha, Lot 184 on CP901725 1.56ha powerline and lot 174 on SP127006 6.2 to Beenleigh Beaudesert Road. On the southside of Wuraga Road the corridor starts with, the balance of lot 143 on Wd3535, to balance of lot 178 on WD 2655, to a park SP 156828, a vacant bushland lot on the corner of Shae St. Lot 1 on SP 156828 0.4ha to the Lot 1 on WD 4254. Part of this site lot is a destination offset for the adjoining TMR road resumption and the proposed koala fauna overpass to Mt Warren Hill. The lot on the eastern side of Beenleigh Beaudesert Road, is Lot 997 on RP890527 with the Bridge site near a vertical steel pipe and old gold mine workings. The Dump site Transfer Station is Lot 1 on SP 127066 North of the Offset Site.


4.    The 200metre wide fauna corridor on Wuraga Road is strongly supported, and should be widened to 300metres and extended the full length and have subsequent study reporting. But wildlife movement solutions on the road or Menora Street and vegetation protection north of Wuraga Road do not feature as a Temporary Planning Instrument or similar document or intent.


5.    The WMA Corridor on the western side of the precinct is supported, but the area is of a drier nature, similar to the Buccan Reserve which has different R.E.s and should not be burnt. From the Lot 31 on RP216567 on the WMA connecting to the Buccan Reserve this corridor should cross Randall Road to another Council Reserve at Wolffdene West Lot 203 on WD 4310.


6.    From the top of Bahr- Hill the corridor proceeds west following the rainforest and ridgelines and then south to across lot298 on W 312266 and lot 342 on SP101421 to Wolffdene.


7.    The creek rises in lot 297 on W3148 through Rosemont Farm Lot D on SP206342 including reserves Lot 997 on RP 842213, Lot 998 on RP 842211and Lot 500 on RP 813846 to cross the Beenleigh - Beaudesert Road to reserve Lot 91 on WD5965. This is shown on fig 7A of the Addendum Report as Corridor D. These need imported pasture removal and endemic species Revegetation.


8.    The ephemeral broad washes travel east through lot 2 on RP 8173 from Lot 297 and Belivah Road. The 1 in 100 flood coverage appears to be about ten percent of the lot. The site needs inspection for water meadows, application of new green fauna infrastructure, leading to statutory protection. See Worley Parsons flood map.


9.    Linkages from the WMA north across Wuraga Road to Lot 999 on RP 175806 have been omitted. These are shown as Corridor Link A on Fig 7A


The Koala Habitat and Subtropical Lowland Rainforest (& 5 plant species) with EPBC Act listing are of priority interest and leverage. By overlaying the Logan City Council maps or inspecting in the field, one can see the areas of high ecological interest on fig 29, listed in previous reports, but not adequately disclosed in or provided for; in a land use budget table (especially 3 GCCC Approvals unresolved and the applicable vegetation and koala offsets apparently exempt) and not detailed in the reporting of the current planning document.

Locality descriptions and linked supporting documents, once a feature of Albert Shire, Brisbane City and Logan City planning documents are missing. The strategic Intents by description are also missing. Many of the SEQ Regional Plan components of Green Wedges Inter Urban Breaks and Green Space are missing. The reservations, programs and policy roll out are not evident or indicated.


The environmental studies of Glen Leiper and the recent Chenoweth Study and addendum at Bahrs Scrub have not yet been translated into

         environmental planning instruments and


         reserve acquisition or conservation management

         Green fauna infrastructure initiatives.

         Designation of Environmental losses in Net Developable Area Plan

         Applicable offsets in terms of land swap areas or fiscal offset contribution & benchmarks

         Further koala surveys and rainforest fauna surveys(one recommended by Chenoweth & Associates)


Some of these planning instruments relate to intrinsic values or to the residents or groups protecting; the environment, the creeks, the dry rainforest and much of the undocumented and protected fauna. (Much of LCC‘s environmental, biodiversity and road data (ONE NETWORK PLAN) cannot be released).


Successful Green Fauna Infrastructure is featured at Compton Road Karawatha to Kuraby.

The successful devices include an overpass with glider poles, dry cell fauna underpasses, possum bridges and fauna proof fences (See Prof. Darryl Jones Griffith University Nathan)


The Koala Habitat mapped by DERM appears to be poorly and inadequately protected by that agency as evidenced in the Bahrs Scrub Net Developable Area Plan- Submission Analysis & Response Report. Appendix 2 October 2011. DERM haveg rolled over on their previous statutory and other recommendations on Corridors, SMAs and various Essential and koala habitats 2010. This is another poor precedent for future Bilaterals under the EPBC Act. Much of the 30% of the site mapped as Koala Habitat on site (fig 8) is destined for:


1.    Lowland residential smaller lot development of say 300-450 square metres lots and as such to be cleared and traded as LCC or EHP koala offsets, or EHP vegetation or biodiversity Offsets if not exempt.


2.    Three midland to upland urban developments approved by Gold Coast City Council or to be reassessed by LCC. As these are designated as a state bioregional corridor under BPA 3.5 December 2007 and levels 3 and 4 (highest environmental value ) on figure 29 p.41 of the Draft Bahrs Scrub Local Development Plan Area. These should not be given extensions relaxations or further approvals, Operational works or veg clearing permits under GCCC or LCC Planning Schemes or VMAct.


3.    Some Wildlife Movement Areas (Corridors) and Environmental Management Areas. Other Offsets in SMAs etc .The proposed trading and clearing in koala and other offsets with offsets ratios listed as 1:1 + and 1: 2.8 does not compare well with the higher ratios of State and Commonwealth Offsets of 1:5 and is severely criticised.


4.    Exemption from SPP2/10. (See Stocklands D.A. table p. )The larger Net Developable Area of 270 ha has about 89 ha of Medium Value Koala Habitat and about 37ha of remnant vegetation.


5.      Exemption from the Vegetation Management Act under Urban Exemption (See Stocklands D.A.). So about 125 ha of medium value koala habitat could disappear under development without any real time amelioration to the site or even on site offsets. Connectivity into other areas is being cut off i.e. North of Tallagandra (developed) only between Tallagandra to Wuraga Roads left, to Mt Warren Hill (Main Roads and development) only leaving stepping stone parks and proposed green fauna Infrastructure to Mt Warren Hill, East to the Albert River (developed) and to bushland in Belivah/Buccan /Wolffdene.


There is little analysis of how the Koala survives inside the study area,

1. on Wuraga Road /parks/to Mt Warren Hill or

2. To other adjoining areas inside and in WMAs EMAs

3. Separately outside the Precinct from WMAs, SMAs and EMAs and waterway corridors and buffers

4. Inside around the Net Developable Area in SMAs/EMAsin this Plan or in the Planning Scheme.


This is critical in linkages into Buccan, Randall Road, Mt Warren Hill and Wolffdene, as well as the immediate problems of future Extractive Industry type Residential on Clarkes Hill, Wuraga Road and Windaroo St/ Janine Court, totalling about 140 lots.



The highest value ecological areas on the maps at Bahrs Hill (lot 161 on W311592) etc and an area from the Bahrs Scrub Road Reserve over Clarkes Hill toward Wuraga Road are largely not in Government, Council or Land Trust Control (See fig 29).


These should be acquired as National Park (not govt policy) Conservation Park or by the National Reserve System (NRS), similar to the recent Cornubia Reserves, or by Land Trusts similar to two at Nichols Scrub in the Currumbin Valley (held by BHFund, Currumbin Bird Sanctuary and National Park), and undertaken in parallel to the perverse and unsustainable Offset System, and beyond parts of this Local Area Plan. This should ensure better management plan and other protection from threats; other agency resumption, water grid, community infrastructure, fire, feral animals and weeds. These sites include koala habitat and dry rainforest which require field fauna surveys.


These areas of High Nature Conservation Values (HNCV) have some Commonwealth Values of Koala Habitat, Protected and Threatened Plant Species and arguably Sub Tropical Lowland Rainforest.


Some of these HNCV areas have the conflict of some old Gold Coast City Council Approvals which allow Extractive Industry type Residential Development on scenic hillsides already seen in the precinct at northern Belivah and Windaroo Street west. It is hoped this will not happen here again or on Mt Warren Hill.



The road designs are disturbing, given the number of four-lane roads on the secretg LCC One Network Plan and the Mt Lindesay North Beaudesert Corridor Investigations, the current modelling undertaken and the onsite and offsite impacts on lifestyle and the environment on some difficult and potentially black spot roads. Tallagandra Road has been modelled outside the Plan but the necessary commitment to join it up is not apparent. The new set of lights by Main Roads near Mt Warren Hill is a strategic indicator. A Tallagandra through road of 4 lanes is a necessity. A rectangular road grid is shown on the Stocklands part of the Plan and it should be used to enter and exit via Prangley, Tallagandra and Teys Roads.


Eastern parts of Wuraga Road and Bahrs Scrub Road Collector Roads have designated and implicit wildlife Corridors, and crossing points but no Wildlife Movement Solutions policy or Green Fauna Infrastructure design with mitigating road speeds or that fauna devices and signage have been committed to.



The specific widening of Bahrs Scrub Road in the east, west of Windaroo Street is not acceptable because of the valuable vegetation in and outside the road alignment, the valuable vegetation on the very steep creek banks of Windaroo Creek and the listed rainforest (BREC, Parks Dept) in the adjoining reserves and freehold parcels on both sides of the Road and Rainforest Species in the road verges. The fauna crossing area in this vicinity has been designated and has planning support from the studies, Consultants and SBSA.


The development Industry does not want to use/upgrade this road because of the narrow constraints and the discussion about lifting the two crossings/bridging of Windaroo Creek above the 1:100 floodline or higher. As the bridging is not described, there are questions of type and cost of structure, as well as green fauna infrastructure and traffic calming.


Severe caution is needed in placing another 3 metre wide bikeway /pathway within this narrow and environmentally sensitive alignment. Any widening will result in loss of rainforest, canopy cover and degrees of fauna connectivity. (There are Camphor laurels to be removed amongst other valuable endemic rainforest trees). Parts of the reserve and disturbance to the steep banks of Windaroo Creek are noted for erosion on the Windaroo Creek Catchment Study 2006.


The proximity of Windaroo Valley High School is another reason to drop road speeds .The traffic projections for this road warrant active road network redesign and alternative solutions. Such alternative Solutions are; Extended Domain Design, Traffic calming, lower road speeds, street furniture, speed bumps, signage, green fauna infrastructure and disincentives. The collector road designation is vigorously opposed


There is a need to look at better ways of getting to Beenleigh, Beaudesert, Waterford and Yarabilba both inside and outside the precinct, and with the unpredictability of the GCCC Approvals, particularly to and from Beenleigh-Beaudesert Road.

         There is a need to examine the future of Windaroo Street as a buffer /green space

         There is a need to examine the road Windaroo Street North as part of a GCCC rezoning and other developments entrance /exit from PLANEX Development and as a potential linkage and exit to Janine Street/Beenleigh Beaudesert Road

         There is an unconstructed part of Bahrs Scrub Road and other roads to be closed as reserve

         There are measurable and unsustainable road impacts to wildlife, lifestyles and pedestrians inside and outside the site with this unfortunate road network.



The upgrading of Menora/Hein Road link to Buccan, Logan village and Yarrabilba severs potential bushland linkages through freehold between the two Buccan Reserves. This is another externality which needs attention and use of Extended Design Domain (Ricky Cox TMR) and green fauna infrastructure as a part of roads budget, planning and design.



The intention for a singular storm water impoundment may constitute an undue impact on the landscape and decided land use option. A series of smaller impoundments is preferred. See the Catchment Study



The integration Workshop and Parsons Brinkerhoff records are not public Information. Fieldwork on geotechnical aspects including Colluvium which may supply constraints in SMA areas has not been undertaken. Further work on Koalas is needed for the EPBC Act.

Baseline information is still missing on rain forest flora and fauna, and catchment/streams.




There is little explanation yet of the 2000 square metre lots in several high level SMAs in terms of access, soil parameters and variabilities, building envelopes, infrastructure provision, vegetation retention and rehabilitation on steeper slopes and onsite and offsite runoff impacts. The DERM recommendations to revoke SMAs 2, 4 and 5 on page 47 of the Planning Study 2010 have been ignored


Some of the higher altitude SMAs should be revoked on grounds of; previous classifications, steep slopes, potential runoff, erodible soils, lack of infrastructure provision or difficulty particularly water supply and the need for native vegetation retention.



The lack of about 5 environmental planning instruments, incentives and programs for residents to stay and to retain and replant rainforest on Windaroo Creek and on the scrub slopes is a definite gap and disincentive which should be rectified.


The ability of offsets to deliver; the tiered sets of recreation reserves, and the existing koala habitat and regional and state significant conservation parks in the Environmental Management Areas and renegotiation of 3 GCCC Bushland Rezonings does not stack up. The later timing of examination of constraints items, the inequity of the offset ratios and unknown delivery of offsets, the awkward road network and old approvals jeopardise the sustainability and amenity of the Plan.

Temporary Local Planning Instrument Vegetation should be applied to the north eastern sector of the precinct to stop exploratory or pre emptive clearing.


The Preliminary Approval Development Application by Stocklands over 129 ha has pending major project status. The same D.A. has applied for Urban Exemption status for vegetation clearing. The same D.A. has applied for exemption from Koala Offsets under the Koala SPP 2/10.



A very approximate land use and vegetation allocation has been put together



Designated Area

Approximate Area Hectares (ha)


Medium Value Koala Habitat in precinct



Urban land Development Area (North)



Jordan Brothers 2 rezonings/RoLs



Planex rezoning



Urban land development area (South)



Stocklands D.A


Half of NDA north

Medium Value Koala Habitat (NDA North)



Remnant vegetation



Medium Value Koala Habitat Stocklands



Remnant Vegetation - Stocklands



Creek Compartment and Veg


Very Large Buffers

LCC Offsets equivalent - Stocklands



Council Park


Pask‘s +Small wild areas

Essential Koala Habitat



EMA 1 North



EMA 2 South




800 approx



The likelihood of potential total koala habitat losses appear to be 89ha plus 36 ha., say 125 ha without surety of offsets in spite of outcomes Achieving a net gain in bushland habitat through the use of environmental offsets p.17 p.41& p74 as about 4 different processes individual decisions have not yet been made. These relate to a sequence of inter related items:

1.   Urban exemption vegetation application under the VMAct

2.   Exemption application from Koala Offsets under SPP2/10 and SPRP SEQ PLAN provisions. Whether LCC s Offset Provisions can be used in lieu or additional to, or without State provisions is dependent on 1.New Planning Scheme (1: 2.8) 2. Other instruments 3 Major Project designation.

3.   Option for Stocklands to provide dollar contributions, or provide bushland within or outside the estate or find a broker to arguably render down the outcomes.

4.   Major Projects Designation decision pending for Stocklands


With the proposed exemptions indicated in the Stocklands Preliminary Approval Development Application, the Offsets of Logan City Council policy documents are not visible, at p.41. P.74 in tangible benchmarks. There is a priority need for advancing negotiations for acquisition before core areas and koala corridors are severed or cleared.



There are components of these which can overlap in purpose and function. Others exist under umbrellas of larger planning instruments interstate. With the likely downgrading changes to the SPA, SEQ Regional Plan, Institutional Arrangements and the VMA these warrant investigation as stand-alone and Likely Instruments. These are needed to encourage existing residents conserving HNCV riparian areas and rainforest scrub.


Differential Rating (BCC)

Environmental Easements

Conservation Precincts

Closure of vegetated unconstructed roads as reserves (Lands Act, Land Titles Act)

Upgraded VCAs

Riparian Landholders programs and Initiatives

Residential Conservation Zoning (Carbrook /Cornubia)

There is no written commitment to advance this policy or program. This situation is not best practice. There is need for a temporary local planning instrument (Vegetation)




As there are arguably, omissions of adequate resourcing comparisons of Social Services of greater Beenleigh to Bahrs Scrub, lack of planning certainty for some residents, and the lack of delivery of reserves, then other actions are needed. As questions of; planning need for the urban extents and higher density, and questions of outcomes from inadequacies of previous studies and previous planning steps, then the commitment to some environmental and social planning initiatives should be under taken outside the Bahrs Scrub Local Area Plan process.

Green Fauna Infrastructure Planning and Policy documents are unacceptably not committed to, as policy, budget or Infrastructure Charging.

The Roads such as the Tallagandra Extended Road warrant pursuit through Committees

Little analysis of how koala survives in the Net Developable Area, the study area and environs has been undertaken in the face of Controlled Actions and International scrutiny. The consultation on a Koala Strategy and Recovery Plan is not evident. Cross Agency/NGO investment in Koala programs is warranted (See Sunshine Coast Koala Summit 2012)

Corridor Programs and acquisition warrant community involvement with Catchment Group and a Scrub Group implementation

These steps include; new information, social program provision, catchment management, and high nature conservation value (HNCV) land acquisitions, grant securement ,rezoning renegotiations and management, which are to be raised with different levels of government.


The brochure on Bahrs Scrub plants edited by Glen Leiper and SBSA and produced by Logan City Council indicates the attractiveness and values of the Rainforest Plants here. The opportunities for Rainforest Reserves, for Fauna and Flora protection and as part of our Heritage, with a recreation trail and interpretive trails has been denied to the greater Beenleigh residents, schools and Logan area for many years. Further flora surveys and fauna studies in the rainforest are warranted. The securing of some of the Rainforest parcels (lot 161 on W311592 Bayer) with other partnerships National Reserve System and Land Trusts is at a critical moment.



The potential outcome of Offsets from the LCC Offsets Policy appear limited and subject to longer timeline of unpredictable trickle down decisions on 125 ha of Koala Habitat to be potentially cleared. The program needs for: Koala survey, koala and fauna protection, ferals eradication, fauna fencing and fauna infrastructure provisions, koala habitat join up and reinstatement, are immediate as the koala population in SEQ is largely on the decline.



The opportunities for a land use budget featuring environmental losses in the NDAP and Wuraga Road and Offsets Budget provides more certainty. Benchmarks for Offsets should be featured. Environmental Planning Instruments and Incentives should also be advanced .The Wildlife Corridors warrant better overlays, policy documents and land acquisition.

The Green Fauna Infrastructure and Wildlife Movement Solutions (BCC) are missing from the EMAs, Park and Corridor Programs, and Roads budgets.

The zoning and tenure changes for Lot 161, HNCV areas in SMAs, and EMA1 and EMA 2 are timely opportunities.



The Road grid should exit via Prangley, Teys and Tallagandra Roads with Wuraga Road having speed restrictions. Bahrs Scrub Road should not be a collector road.

A Series of smaller water impoundments should be used.

Higher level SMAs above 55 m AHD should be revoked on grounds of scenic amenity unwanted water towers and potential ridgeline mansions.



With very few State offsets on the register, and with very few case studies sustainably delivered as like for like and as adjacent land acquisitions, and with three offset exemptions decisions pending for Stocklands, the LCC and state koala, vegetation and biodiversity offsets do not stack up. The LCC Offsets at 1: 2.8 are lower than 1:5 ratios at state and EPBC Act levels and may not be guaranteed in time.


Consequently there are major actions which Logan City Council should undertake outside the Bahrs Scrub Local Plan process, also mentioned above.

The resolution of the 3 GCCC rezonings with sustainable outcomes for the State Bioregional Corridor and EMA 2 particularly for Koala Habitat is warranted, for the credibility of the Plan.

The National Reserve System funding should be sought with other partners and LCC for Rainforest purchase on Lot 161, Rainforest further south and in some Koala hotspots.The Ecofund and Koala Habitat Fund (program halved) should be approached with good proposals for the EMAs. A rainforest fauna study should be undertaken.


The initiatives within the Bahrs Scrub plan which should be included firstly feature a koala survey and tracking as Logan City does not have a Koala Strategy and Recovery Plan which has been undertaken in Redland City Council 2008-2012. The redesign of the road network, corridor network and storm water provisions has large impacts on future liveability and sustainability for the Precinct. The Planning Tools have a range of new and old instruments which should be consolidated to retain Endangered Vegetation on Windaroo Creek and in the Dry Rainforest Scrub in SMAs. A TEMPORARY LOCAL PLANNING INSTRUMENT (TLPI) Vegetation should be used, particularly in the northern part of the precinct to stop pre emptive clearing.


Edward Fensom GDURP

Coordinator, Brisbane Region Environment Council

For More Information

Ted Fensom 
Brisbane07 3801 1208
Region Environment Centre

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