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Bahrs Scrub another Traveston

A new community group meeting over the weekend has slammed the proposed Bahrs Scrub development, describing it as ‘another Traveston’ in terms of the money that will be wasted on preliminary studies and the likelihood that it may be stopped by the Federal Government on environmental grounds. Read the full article.


So many good reasons for preservation

The conservation values of the Bahrs Scrub Precinct may be so high that the area would warrant being turned into a National Park. Bahrs Scrub should be preserved and regenerated as a natural space to bring pride to our City, not turned into yet another housing subdivision, and here are some solid reasons why:


  • Bahrs Scrub locale is a well-known biodiversity hotspot with valuable flora and fauna, and should not be developed.
  • Bahrs Scrub is predominantly a very steep area, containing numerous, important waterways prone to flooding making construction restricted and expensive; 
  • Bahrs Scrub, being the only rainforest remnant in the Beenleigh area is very valuable for social amenity; 
  • Bahrs Scrub forest is serving as a carbon sink in the global fight to reverse anthropogenic climate change;
  • Bahrs Scrub has been the subject of numerous public submissions over several decades calling for its preservation which, in the interests of democracy; should have been heeded
  • Bahrs Scrub is a Greenfield area and in order to contain population growth, should not be developed.
  • No truly sustainable design exists that could preserve the values of Bahrs Scrub intact and accommodate 11,000 residents;
  • Bahrs Scrub and surrounds as a National Park or similarly conserved area has the potential to attract international and domestic tourism dollars to our area;
  • Bahrs Scrub and surrounds as a National Park or similarly conserved area, with its UNIQUE flora, and diverse regional ecosystems, will serve as a valuable educational resource for the youth of our area, and for primary, secondary and tertiary level students in its natural, undisturbed state;
  • Bahrs Scrub locale conservation values are so exceptional, and its climate systems importance is so significant, that any loss of key forest and wildlife cannot be mitigated;
  • Biodiversity hotspots do not qualify as greenfield under Qld urban planning definitions,
  • The long history of studies, including the latest environmental study supplied to Logan City Council, and which have informed and made possible the appalling State and Gold Coast City Council planning decisions have been seriously flawed;
  • All but the environmental studies in LCC's present round of studies contracted to Opus International Consultants have been funded by Stocklands, an interested party, thus clouding the objectivity of the studies, and raising future community costs. (see LCC document extract, pp 373-374 )
  •  The overriding State Govt South East Queensland Regional Plan requirement that Bahrs Scrub, a biodiversity hotspot, should be considered one of the forty-two greenfield sites to be supplied by Logan City Council to accommodate the state’s unconscionable population expansion is a bad decision that CAN be reversed (also see p15 of SEQ RP) through legal, democratic processes


It is imperative that the immediate community, and all conservation minded people demand that development of the Precinct be permanently ruled out and that Bahrs Scrub be preserved and regenerated as part of the local, state or even national reserve. (Letters page link here)

 For more detailed discussion, read on.

Biodiversity features:

The Bahrs Scrub locality is known to support unique, spectacular and threatened flora conservation values. These have been outlined in detail by local botanist, Glen Leiper (see Biodiversity), and will be drastically affected by development.

 Although not officially recognised as such, Bahrs Scrub is also home to koala and platypus, two species which are in grave decline statewide.

Hydrological features:

The Bahrs Scurb locality is interlaced with numerous waterways of varying capacities, which again have not been properly mapped. These waterways all contribute to support wildlife struggling for survival amidst neighbouring urbanisation, and contribute to water supply for the nearby Albert River. Development of the locality will inevitably alter or erase these waterways, particularly as the potential for flooding of created roads and residences will require the ‘taming’ of flows. Road infrastructure to address flooding will require large bridges and widening of roads, which will detroy vegetation and thus habitat. Ongoing human habitation of the locality will result in litter and runoff pollution of waterways, and human presence will either directly or indirectly affect the survival of dependent species, including platypus.

Geological features

 The Bahrs Scrub locality is recognised as containing very steep areas. Development of Bahrs Scrub has the potential to result in accelerated erosion, landslide and slumping. Development will have to be contained to less sloped or flat areas, thus omitting a large proportion of the 800 hectares of the locality designated for acommodating 11,000 residents. Furthermore, the minimum density required by the State Govt of 15 dwellings per hectare means that Bahrs Scrub will be transformed from the tranquil, rural oasis it is now to a bare, overcrowded conglomerate of housing and its necessary support infrastructure, transforming LCC’s Draft Vision for Bahrs Scrub to illusion.

 The additional consequence of restricting undeveloped areas to very steep slopes is that any preserved natural heritage will be largely inaccessible for the community to enjoy.

 Preservation of natural environment within steep areas alone has further implications for biodiversity loss, since these habitats have their own characteristics which support particular flora and fauna. Biodiversity reliant on other types of habitat characteristics will thus not be preserved.

 Scenic/Social Amenity features:

 As alluded to above, Bahrs Scrub presently offers a rare remnant of the natural environment that once dominated the Albert and Pimpama valleys, now lost to the desertification of modern development. Bahrs Scrub reminds  residents or visitors to the area, that this entire region once supported forest, waterways and wildlife which rivalled better known and better preserved nearby areas such as the NSW Northern Rivers, Border Ranges or Gold Coast Hinterland for inherent loveliness.

 The psychological value of scenic amenity for human society is defined and acknowledged in the SEQ Regional Plan, which further states that ‘In 2004, 15 percent of SEQ had high scenic amenity.

 In total contradiction of this acknowledgement, the SEQ RP also mandates accommodation of eleven thousand resdents for the highly sensitive locality of Bahrs Scrub, thus ensuring the devastation of this last oasis of regional scenic amenity.  The necessary dwellings over such a relatively small area will mean overcrowding of the immediate area as well as overcrowding of facilities such as shops and schools, inevitably requiring construction of same, increased traffic, increased litter, increased crime and general social disorder.

 No matter how innovatively planned with attention to sustainability practices, the resultant development of Bahrs Scrub will still be an urbanised landscape. Development will totally alter the character of the area, drastically affecting present lifestyle and visual and social amenity.

Bahrs Scrub, as the last representation of the unique and beautiful landscape that once dominated the larger Beenleigh area, qualifies as an area to be conserved for ‘maintaining regionally and locally significant scenic amenity’. (SEQ RP)

 Rather than develop Bahrs Scrub, state and local authorities would be far better advised conserving and regenerating Bahrs Scrub as an important aesthetic feature the region can take pride in, and as a much needed sanctuary for local people and visitors.

Climate Change features:

Forest and non-forest vegetation serves as vital carbon sinks, storing tonnes of carbon in their structures and continuing to absorb CO2 from the atmosphere.

Destruction of vegetation, however, as in clearing for development, releases carbon into the atmosphere, either rapidly through burning or gradually if left to rot. Thus, destruction of vegetation adds to global greenhouse emissions, but preservation and regeneration of vegetation significantly reduces global greenhouse emissions.

In the light of this principle, no responsible nation should be allowing the further destruction of forest, and should in fact be taking every opportunity to reafforest.

Additionally, climate change will have unpredictable effects on ecological systems. Preserving and regenerating Bahrs Scrub will give the special ecosystems of the area the best chance of survival in the fast approaching era of climate instability.

Forest and non-forest vegetation is also pivotal in localised precipitation systems. Preserving and regenerating forest in the Bahrs Scrub Precinct will ensure the best opportunity for valuable local rainfall.

 Flawed official studies will inform the LCC planning decision:

 In order to create a Local Area Development Plan for the Bahrs Scub Precinct, the Logan City Council has contracted consultant company Opus International Consultants to undertake assessments of the area’s environmental, geological, hydrological and social values. However, most of these studies are funded by the interested stakeholder, Stocklands, raising issues of 

  • vested interest affecting objectivity of the studies,
  • costs to Council which will be passed on to ratepayers, and
  • costs to housing consumers.
  • lack of community access or input with expert and local knowledge 

 LCC originally allocated $150,000 as their share of the funding for Opus assessments, but subsequently allocated an additional $100,000 to this project, $80,000 of which directly funded the environmental studies under sub-contractor, Chenoweth Environmental Planning, and the remaining $20,000 to cover inevitable blow-out of costs for Opus. The Chenoweth environmental studies were conducted over a mere week by a limited number of staff, access was not gained to all properties within the Precinct, and even the properties studied, were not fully accessed. SBS Alliance therefore considers the results of the environmental studies as seriously flawed due to

  • inadequate survey personnel numbers
  • inadequate survey hours
  • inadequate survey coverage
  • no taking into account of fauna population factors such as times of day or seasonal patterns
  • no recognition of flora and fauna studies or advice supplied by SBS Alliance

 The SBS Alliance, based on information from past EPA officials’ records, observations by expert naturalists, and testimonies of local residents, asserts that development of Bahrs Scrub is planned regardless of numerous, large and unquestionably valid environmental, geological, hydrological and social constraints. SBS asserts that Bahrs Scrub is host to unique, rare flora species, several listed under the EPBC Act, and a range of valuable fauna species, including troubled species such as the koala, platypus, or grey goshawk.

SBS urgently requires funding in order to commission formal, independent environmental studies which can be officially recognised to inform State and Council planning decisions, and trigger environmental protection under Queensland and Australian law.   (Donate here)

Population pressure features: 

The State Government and Logan City Council cite Queensland’s rapid and high population growth and the nation’s projected population numbers as the driving factor for the development of Bahrs Scrub.

 While the argument that ‘people have to live somewhere’ is morally undeniable, the argument is also being employed as a shield behind which poor or even mischievous planning decisions hide.

 The primary premise of this argument ignores the fact that federal government policy over the past decades of both the Howard and Rudd Governments has been to actively encourage population growth.

 Actively engendered population growth for Australia is reprehensible in an era when the planet’s advanced nations are heeding the findings of associated woes of over-large human numbers, including the drastic impacts on and of anthropogenic climate change – all of which, according to widely held theory, is driven by large numbers of people directly or indirectly using fossil fuels. Australian Treasury modelling shows that any achievement in emissions reductions gained by legislation such as an ETS or Carbon Tax, will be nullified by Australia’s population growth over the coming decades. Yet state and local authorities do little to nothing about opposing such policy, either through voicing of concern or through legislative measures .

 Proponents of an inreased Australian population also cite the vastness of the Australian continent for accommodating signifciant growth. However, such an argument discounts and dangerously devalues the fact that the Australian continent is mostly very dry, and its ancient soils deficient in nutrients. Factors of water supply and agriculture will further be affected by the unpredictable ravages of climate change. Population must therefore be restricted to the relatively thin strip of mostly the East Coast of Australia.

Many conservationists warn that the coastal strip has already reached carrying capacity. Water suppy alone is proving extremely difficult in most heavily populated coastal shires, and as rural shires and rural sections of urbanised shires become increasingly encroached upon by development, loss of lifestyle is also a predominant concern. Importantly, further urbanisation or industrialisation of the coastal strip will seriously decimate what remains of the unique, precious, and highly fragile regional ecosystems which exist to support our diverse flora and fauna. Evidence that Australia's biodiversity is already in decline is now being presented by the Australian Government, having been forewarned by international agencies such as the Red List of the IUCN, as well as local conservation organsiations and individuals.

Australia’s valuable democratic ideals rightly prevent local authorities from turning away internal migration within any given regions; however Queensland’s response has been to do all in its power to accommodate and encourage the influx. Population growth discouragement strategies, such as capping development and/or population numbers within shires, or restricting the release of further land for development are not being given adequate consideration at state or council level, despite the claims of the South East Queensland Regional Plan to be a planning instrument for responsibly controlling growth.

 Allowing Greenfield is a population growth incentive philosophy, as giving over natural environments to urban expansion implies supplying residents with personal land space, rather than offering only multiple level dwellings. Single dwellings are an attractive prospect for internal migrants, which encourages population growth.

 Those who wish to profit from population growth should not be able to do so at the expense of the amenity of surrounding residents, the natural environment, or indeed, the future survival of the planet’s present life forms. If population growth is to be allowed to direct urban expansion, the many and crucial constraints of the present era including biodiversity decline, climate change and greenhouse gas abatement demand that such expansion should only be infill and the concept of Greenfield development be relegated to the driving misconceptions of the past.  (LETTER protesting Greenfield/LCC & SG)

 Planning decisions

 The very high conservation values of the Bahrs Scrub locality have been known by locals and officials from at least twenty-five years ago, yet by 2006, Bahrs Scrub had been declared a Major Development Area, and by 2009, is fast tracked as a Local Development Area.

Conservation organisations and individuals with local and/or expert knowledge have a multiple decade history of submitting assessments to local authorities, which outline the very high conservation values of the Bahrs Scrub area and recommending that the area be at least preserved from development if not regenerated to better secure the area’s values.

Bahrs Scrub values have been documented in the Border Ranges Rainforest Biodiversity Conservation Management Plan May 2009 compiled by NSW CERRA, QLD EPA, and Australian Govt DEWHA, as well as in the CERRA East Australian Rainforest Draft Management Plan

 Bahrs Scrub values have been documented in the book, Mangroves to Mountains (Leiper, Glazebrook, Cox & Rathie, 2008).

 EPA agents traversed the area approximately twenty-five years ago and noted key species in the field. Records of these findings were never made official and EPA moves to acquire Bahrs Scrub land for conservation were obstructed by political ambitions.

 Much of Bahrs Scrub’s conservation value has been recorded in the Gold Coast City Council 1998 Nature Conservation Strategy.

 The Gold Coast City Council undertook a Major Investigation Study of Bahrs Scrub some years ago, which should have identified the true values of the Bahrs Scrub area and informed planning decisions. This study has reportedly been misplaced in the transfer of authority from GCCC to LCC, leaving Bahrs Scrub vulnerable to state planning dictates based on apparent ignorance of the area’s conservation values.

 Local residents have reported frequent sightings of a wide range of fauna including koala, now at risk of extinction in SEQ.

 Despite these submissions, studies, reports and entreaties, the Qld EPA has still not officially recorded the presence of very high value flora and fauna in the area, the Gold Coast City Council declared Bahrs Scrub a Major Development Area in 2006, the State Government expanded the area’s zoning as a Future Growth Area within the SEQ Regional Plan Urban Footprint and now requires that the area be fast-tracked as a Local Development Area. Logan City Council has recently gone to the expense of funding  an environmental study through Chenoweth Environental Planning, but the validity of these studies (see above) has been seriously compromised by unrealistic time and staffing constraints.

 Lack of democratic process in planning decisions

 The fact that irresponsible Bahrs Scrub planning decisions have been made in the face of copious, highly informed and documented opposition points to an apparent total disregard for democratic process within this state, and a lack of sincerity in the legislative environmental protection process.

 Division Four Cr Sean Black informed the October 8, 2009 community meeting that, “Council determined that [development planning would occur] sooner rather than later in consultation with landowners”. The LCC Bahrs Scrub Newsletter (p8, 2009) illustrates the chain of process embarked on by Council as LDA -> Planning Scheme Amendment -> Development Assessment -> Construction. From these and other comments made by speakers from Logan City Council on October 8, 2009, it is apparent that planning amendment to allow development of Bahrs Scrub is a foregone conclusion in the minds of the LCC, ostensibly rendering the entire process of community consultation and community input meaningless.

 It would appear to those residents of Bahrs Scrub and neighbouring areas, and to those who genuinely value Australia’s natural heritage, that to the ears of those in authority at state and local level, not one of the many, irrefutable and salient arguments against development of Bahrs Scrub, including matters as specific as the presence in the area of threatened, unique, newly discovered species, or as global as greenhouse gas abatement, has validity over the desire of a few landowners to profit from the sale of their large blocks, and the desire of large development corporations to make subsequent profit.

 The entire history of the zoning and development of Bahrs Scrub is an illustration of very poor execution of democratic principle, and is worthy of official, high level enquiry.

 LCC representatives have made a case for development of Bahrs Scrub based on the premise that the development was mandated by the State Government. However, notwithstanding such legislation being voted on by both sides of the House, this submission calls attention to the democratic right of the community to express dissent with legislative decisions and to call for the overturning of same. Legislation is not, as Cr Black made out (Oct 8/09), either immutable or set in stone, and is only as valid as the result of a subsequent election when laws and decisions may be reversed.

 Sustainability issues: Natural laws cannot be ‘balanced’ or ‘managed’

 Human laws, however, are wholly unlike the laws that govern the natural world, and although we are in a culture of denying and ignoring nature, we are also now in the era when we are forced to acknowledge that the rigours of the planet cannot be denied or thwarted.

 While the term ‘balance’ has been upheld by development advocates for years in the face of continuing environmental degradation, it is worth pointing out that the concept has always been inherently flawed. Urban management may be able at best to marginally slow the advance of natural destruction, but while population continues to be actively increased for short term political and economic gain, and urban expansion is facilitated by planning instruments, common sense, let alone the wealth of empirical evidence that now exists, decrees that the environment will always be the loser.

 There is a general philosophy among planning authorities that a ‘balance’ can be achieved between urban expansion and environmental needs. That this philosophy is flawed is starkly demonstrated by the recent spate of evidence that human systems are failing, with cataclysmic consequences for all life on Earth. Global acknowledgement of anthropogenic climate change, national acknowledgement that Australian biodiversity is in ‘serious and rapid decline’, and the state acknowledgement that the SEQ Koala is in grave danger of extinction are among the hierarchy of observable consequences of human failure to ‘manage’ natural systems or achieve balance between the needs of the Earth and desires of modern lifestyle.

 In the case of Bahrs Scrub, it is doubtful in the extreme that “Balancing vegetation management and building a vibrant community’, as stated by a Town Planner on October 8, can be achieved when nowhere on the planet has it been achieved yet.

 The LCC Bahrs Scrub Planning Study Newsletter indicates the inclusion of a ‘mixture of housing types’, ‘social infrastructure’, public transport and other services, ‘catering for a population of some 11,000 residents during the next 15 to 20 years’. The Draft Vision is of a ‘new and modern community in a sustainable setting’, with the LDA designed in an ‘innovative and sustainable way’.

 Such language is indicative of the philosophy referred to above that human management of the natural environment is achievable. However, the concept is initially flawed, as any intrusion of human infrastructure upon an undeveloped site immediately results in net loss of natural environment. Furthermore, while considerable advances have been made in design to lessen the impact of human habitation on the natural systems, these gains are minimal and relate primarily to issues of greenhouse gas abatement and water conservation. Construction design has not negated the physical impact upon natural spaces of buildings, roads and other infrastructure, no matter how energy or water efficient. Nor has design negated the ongoing impacts of human infrastructure such as contamination from chemical use and litter or weed infestation.

 Nonetheless, Council makes statements both verbally and in print claiming that development of Bahrs Scrub will involve, ‘complementing nearby employment and other activity and contributing to their growth”, ‘7-11000 residents over the next 15-20 years, creating a modern, diverse lifestyle’, while previously stating, ‘values will have to be protected as we go forward’, “Bushfire threat exists but will go if we cut down trees”.

 Council’s linguistic contradictions are strong indicators that planning intended for Bahrs Scrub will be no more capable of achieving a ‘balance’ between urban expansion and natural conservation than this or any other authority has managed in the past.

 Mitigation and offsetting:

Mitigation and offsetting have also been touted as the answer to ongoing biodiversity loss. Given the provisions of state and federal environment laws and the prioritising of development and financial gain over preserving the natural world, mitigation and offsetting will undoubtedly be employed to address the irrefutable claims of those who oppose development of Bahrs Scrub on conservation grounds.

 Yet again however, the mitigation and offset concept, flawed from its initial premise, is proving to be a failure, as national and state acknowledgement is made of rapid biodiversity decline. The mitigation and offset mentality fails because it does not factor in the simple truth: habitat is finite, thus habitat loss cannot be mitigated.

 In the case of Bahrs Scrub, the above concerns about human impacts upon natural systems are even more significant as the locality is known to support extremely sensitive ecosystems. Development of Bahrs Scrub, no matter how innovatively designed and carefully planned will result in net loss, and very possibly total loss of high value species.

 VERY EXPENSIVE:The economic imperative and the ethical imperative

It is clear from LCC representatives’ statements on October 8, and council publications, that the attraction for Bahrs Scrub as a development site is wholly financial. Bahrs Scrub’s ‘location, size and potential for provision of urban infrastructure’ are all elements that make for cost-effective development measures for Council and the attendant development corporations.

Furthermore, the recent planning amendments will somewhat financially benefit landowners who sell their blocks for development, considerably benefit development corporations, and consistently benefit Council income from increased rates.

The apparent cost-savings of the location however, disguise the reality that the preliminary studies and infrastructure required to contend with the steepness, flood susceptibility, high biodiversity values of the Bahrs Scrub Precinct will be extremely costly; these high costs will ultimately be passed on to the consumer and the LCC ratepayer. Great profit for a few will be at the expense of the larger community, hardly an ethical consequence. 

Such short term gain for a relatively small proportion of the community wil furtherl result in immediate environmental and social amenity losses, which will have diverse, intricate and ongoing consequences, many unforeseeable.

Besides the observable, quantifiable and practical arguments for preserving Bahrs Scrub in the face of the underlying economic imperative that is driving its development, must be the ethical/moral imperative.

 Each generation and its elected representatives are endowed with the responsibility to preserve life on this planet. Wanton destruction of species and landscapes anywhere on Earth, the only known manifestation of the phenomenon of life, is reprehensible and foolish. To prioritise commerce over natural heritage is deeply unethical.

Bahrs Scrub conservation advantages:

Keeping Bahrs Scrub vegetation communities intact has a practical function in greenhouse gas abatement issues, which directly impact upon human survival. The carbon storage qualities of the Bahrs Scrub locality also represent economic pragmatism against future carbon trading or carbon tax schemes inevitable within the next five years.

 Preserving Bahrs Scrub vegetation and wildlife communities also represents political pragmatism since the community largely expects biodiversity protection, particularly of iconic species such as the koala or platypus, both of which are present in the locality. Furthermore, the psychological value of scenic amenity, acknowledged in State Government publications such as the SEQ Regional Plan, and the effects of overcrowding on crime and other social stress factors prioritise preservation of natural spaces for the maintenance of social harmony.

 Bahrs Scrub’s unique conservation values, its significance as a remnant of Albert and Pimpama Valley habitat, and its newly discovered species qualify the area for preservation and regeneration as a national heritage asset. Such a feature has the potential to bring considerable economic gain to the region from tourism interests alone.


 Given the constraints and values summarised above, Bahrs Scrub should not be zoned a Local Development Area, but preserved and regenerated as a conservation area, part of the nation or region’s natural heritage assets. Rigorous mapping of the area’s flora and fauna, waterways and geomorphology is urgently required to engender official recognition of the great significance of the Bahrs Scrub locality. However, larger, deeper, philosophical perspectives driving priorities must also undergo rapid change in order to address the grave and urgent demands of the present era, pivotal to the Bahrs Scrub case. Planning authorities have traditionally focused on economic gain, population increase support, and a belief in being able to artificially manage and balance environmental and human needs. Such focus prevents authorities from aligning with the new and necessary philosophies, perspectives and priorities of the present era of anthropogenic climate change, biodiversity decline, the recognition of human psychological dependence on natural environments, and the recognition of non-human species’ intrinsic right to existence. Through such enlightenment to modern realities, authorities will finally waken to the greater need to leave Bahrs Scrub naturally intact, and will be responsible for the preservation of precious flora and fauna.


  • Rigorous flora, fauna, and geomorphological mapping of the locality is required; community input should further inform the mapping.
  • The SEQ Regional Plan requirement that Logan City Council provide 42 Greenfield sites should be rescinded. 
  • Bahrs Scrub – a biodiversity hotspot - should be considered inappropriate as a Greenfield site.
  •  The Bahrs Scrub locality should be preserved and regenerated as a conservation asset, and as a regional greenhouse gas abatement measure.