FoE Australia submission

Friends of the Earth Australia have put in this submission to the Coordinator General's Office in Brisbane about KUR-World, a mega resort and satellite suburb proposed for the ecologically fragile Myola valley in Far North Queensland. Please send in your own submission. The deadline is Monday 14 January 5pm 2019.

Foe Australia Submission:


Friends of the Earth (FoE) Australia opposes the proposed KUR-World development of a mega resort and satellite suburb in the Myola Valley. The KUR-World proposal would have negative environmental, cultural, economic and social impacts.


We support truly sustainable planning that


  1. protects and enhances the rich biodiversity of the Kuranda region and the Wet Tropics World Heritage Area and its river systems

  2. has broad community support

  3. preserves cultural values

  4. is carbon neutral or offsets its carbon footprint

  5. is economically sustainable and works towards prosperity for everyone in the region


We believe the KUR-World Integrated Eco Resort fails to meet any of the above criteria.


We have the following concerns about the negative impact of this proposed development on the environmental values of the area especially:


  1. the endangered Southern cassowary habitat, connectivity and recovery plan for the species

  1. the critically endangered and endemic Kuranda tree frog and its recovery and recently released action plan

  2. the endemic Myola palm


Please see detailed submissions on the KUR-World Environmental Impact Statement regarding these issues below.


We also wish to support Friends of the Earth Far North Queensland’s submissions which will address the

  • impact on water quality

  • inadequate infrastructure ( roads, medical and emergency services, hospitals, water supply, electricity and telecommunications)

  • the negative social and economic impacts of this project.


1. Negative effect on Southern cassowary habitat, connectivity and its recovery plan

Terms of Reference Section -11.17,13.22,13.32,13.54


Negative effect of proposed KUR-World project on Southern cassowary habitat, connectivity and recovery plan for the species. (The overall objective of this recovery plan is to protect cassowaries, habitats and corridors from threats through better planning, monitoring and community involvement.) 1


The Southern cassowary is a keystone species for the rainforest. If we were to lose this species, we would lose rainforest trees which rely on digestion in the Cassowary’s gut to germinate and which need the Southern cassowary for distribution. These trees tend to be the larger, longer lived species that form the backbone of the rainforest and protect it from damage from cyclones.


The draft EIS recognises that 'the project area occurs in a broad section of landscape where north- south connectivity for certain rainforest fauna is relatively limited2 ' . This north- south connectivity is vital for the Southern Cassowary gene pool to be diverse and to provide a range of habitat and altitude for the species- which is vital for the cassowaries to survive climate change.3

However KUR-World would bring many threats to the Southern cassowary including:

A. Loss of connectivity and habitat due to

1. clearing of remnant vegetation, which is essential cassowary habitat, for buildings and roads especially

a. the proposed access road to the Kennedy highway ,

b. the access road from the helipad in the south to the rainforest education centre

c. the access road from the rainforest education centre to the glamping

d. the access road from the helipad to the main KUR-World precinct in the north. Helicopters would be landing in the southern forested area ( remnant vegetation) in the Concept Master Layout map and traffic travelling through this essential cassowary habitat to reach the main KUR-World precinct.

As Miriam Goosem writes 4 'When planning for new roads and powerlines, resource managers should strive to avoid critical habitats for rare and threatened species as well as areas of high biological diversity and abundance.'

2. the physical barrier of roads and buildings leading to avoidance of these areas by cassowaries

3. Light & noise pollution – e.g. the noise of frequent helicopter flights- up to 20 movements a day would stress cassowaries and cause avoidance of affected areas and so loss of habitat.

4. increased vegetation loss in cyclones due to clearings in the forest making it more vulnerable to damaging winds

5. erosion especially during construction and in the Wet

6. introduced weeds both from ornamental plants on the property (which apparently are already being bought) and from seeds brought in on footwear of construction workers, tourists and residents

7. introduced feral animals and pests such as yellow crazy ants. In the EIS Chapter 8 fauna and flora, it is recognised that the introduction of yellow crazy ants would be disastrous.

Other negative effects of KUR-World would be:


B. Dog attacks

These would be likely to increase with KUR-World with the introduction of residential lots on the property. The EIS suggests limiting pet ownership to small dogs. However the success of similar covenants has been low in the Kuranda region and , we believe, unenforceable where land tenure is freehold, which appears to be the intent of this development .


If fencing is allowed, connectivity would be affected. Also roaming small dogs are also capable of eating cassowary chicks and other small wildlife- and stressing adult cassowaries.


C. Disease

Southern Cassowaries are also threatened by diseases, such as avian tuberculosis, which is caused by the bacterium mycobacterium avium. It causes chronic wasting in infected birds and there is no known treatment. Pressures such as food shortages, habitat loss and the presence of predators such as roaming domestic dogs, are likely to stress cassowaries, making them more susceptible to disease .5

D. Roads

Roads are a major cause of direct cassowary mortality due to vehicle strikes. Vehicle strikes are the leading mortality cause in the Mission Beach

According to data from The Queensland Department of Environment and Heritage Protection Threatened Species Unit and Garners Beach Cassowary Rehabilitation Centre, there were 104 deaths from vehicle strikes between 1992 and January 2014.

Increased traffic in the Kuranda region due to the rapid increase in population which KUR-World would produce, would have the risk of producing the same tragic effect on roads on the project site and in the region especially the Kuranda Range Road.

Other current threats:

Natural Catastrophic Events

We are in the middle of a drought in the Kuranda region at the time of writing. This is almost certainly impacting on the small population of cassowaries. Much erosion has taken place along creeks and river beds due to a large flooding event in March of this year which caused the loss of large areas of vegetation.


More extreme weather conditions- both drought and then severe cyclones- are predicted with climate change. Cyclones are the main natural threat to habitat and consequential cassowary food tree loss. Not only are cassowaries in danger from falling trees and rising waters during storms – they must travel further to find food, increasing their exposure to risks such as road crossings.


If we are serious about ensuring that cassowaries survive as a species on into the next century, despite climate change and natural catastrophic events, we need to ensure the cassowary population is more resilient by protecting and enhancing their habitat and its connectivity.


It would be irresponsible to approve this project that significantly threatens this already endangered species.


Mitigation Measures

Several mitigation measures are proposed in the draft EIS:


  1. Wild dog control programmes- A wild dog control programme has been suggested as a mitigation measure against the above impacts: 'There is opportunity to offset this impact by implementing a wild dog control programme, though the degree to which this may offset project-related threats is uncertain6'.

As noted in the draft EIS, the use of poison would be problematic due to its effect on other native animals such as the northern quoll7.


Also it is more likely that the problem would be of roaming domestic dogs not wild ones- made worse by the residential component of KUR-World as noted above in B. Dog attacks.


Baiting dogs in residential areas is also prohibited- and baiting roaming domestic dogs requires a special permit.


  1. Road design Management Measure 30 : 'Roads through forest areas, notably the proposed access roads, should be designed to minimise the barrier effects to fauna movements and to reduce the likelihood of fauna being hit by vehicles. A suitably qualified and experienced ecologist should be involved with the designs. '

The aim of reducing the likelihood of cassowaries being hit ( most effective strategy being to encourage cassowaries to avoid the roads) is not consistent with the aim of minimising the barrier effect so this is a challenging task for the most experienced ecologist.


50 km/gr for the access road, even if complied with, is fast enough to be unable to stop if a speedy cassowary jumps out in front and could result in serious injury of both cassowaries and humans.


Indeed it states in the EIS 'The residual impact is of concern for the Southern Cassowary because the local population is apparently small, and therefore sensitive to additional threats.'

  1. Revegetation of banks- This would involve the use of a large amount of either labour or chemicals (which may be detrimental to wildlife) to be successful and even if successful, would take some time to establish.

  2. Management Measure 44: Prepare a Species Management Plan for …. Southern Cassowary

It is impossible to critique this as it does not appear to have been prepared.


The EIS acknowledges: 'Non-definitive evidence of the EPBC Act Endangered Southern Cassowary was recorded on the project area. There is historical evidence of the species on the project area and the area contains potential habitat. Existing threatening processes are possibly inhibiting the establishment of a permanent and appreciable population on and directly adjacent to the project area.''8

A significant degree of clearing has taken place on the property since it was bought in 20149.


To take baseline studies of the wildlife- including the cassowary- after this extensive clearing does not give a clear picture of the importance of the habitat to species such as the Southern cassowary.


A female cassowary can have a range of 5 to 10 square kilometres in degraded habitat and she can mate with around 4 males in this area. Interrupting her range with clearing can impact on mating behaviour and her ability to navigate in her territory.10




  1. A cassowary recovery plan for the property needs to be undertaken- and this plan needs to be critiqued and approved. This needs to occur before the EIS can be considered completed and itself approved. This plan should include revegetation of cleared areas that were previously regenerating regrowth.

EIS recognises that '.The conservation value of forested regrowth is high in some instances'

It is no longer high in conservation value, sadly, when it is cleared- and even less when it is built on. Revegetation and water quality along creeks need to be monitored by wildlife experts in these areas.

  1. The current helicopter flights should not be allowed to prevent stressing the cassowary with the noise of up to 20 movements over essential habitat.

  2. An eco resort suitable in size could be approved- such as Cedar Park11 in Koah, Kuranda region that has 5 rooms, no televisions, skylights to minimise energy use and blends into the landscape. But putting thousands of visitors and residents in this sensitive area is ecological vandalism, for purely economic gain.

Conclusion: There are no solution that can be seen for a project of this size and nature. Therefore the proposed project must be rejected. It is too big and in the wrong place.

2. Impact on Kuranda Tree frog (Litoria myola) and Lacelid frog (L.dayii)

Terms of Reference Section -13.54


Negative impact of KUR-World on the critically endangered and endemic Kuranda tree frog (Litoria myola)

The Kuranda Tree frog is endemic to the Myola Valley and Jum Rum creek catchments, some 14 creeks and associated seasonal creeks. There is an estimated population of less than 750 individuals over an area less than 3.5 km squared.

The proposed KUR-World project would affect 3 of these creek systems – Cain, Owen/ Haren and Warril creeks which contain approx. 40% of the known population of these frogs12 (Hoskin 2016)


A large dam constructed on the property in 201513 is already likely to have destroyed habitat of the Kuranda tree frog:

Dr Conrad Hoskin reported:

'A fourth creek on the property, the small creek downstream of the dam by the homestead, would almost certainly have had Litoria myola until recently (marked in red shading on Figure 3)14.


However, sediment from dam construction and the eroding dam wall has filled this creek for hundreds of meters downstream of the dam and the habitat is no longer suitable for Litoria myola breeding.


'The reasons I can be fairly sure this creek had Litoria myola are:

  1. It is within the typical distance Litoria myola occurs upstream from the Barron River;

  2. The creeks on either side have Litoria myola up to at least this point; and

  1. Assessment of the size and structure of the creek, and associated vegetation, enables me to make an educated estimate of how far upstream they would have bred on the creek.


'In the adjacent unnamed creek, L. myola extends to within 300 metres of the head of the creek. Using this as a benchmark, I have estimated an upstream extent of the former occurrence of L. myola on the creek below the dam (see Figure 3). Remedial works have begun regarding the sediment issue in this creek, and these are ongoing'15


Construction of the access road through old regrowth forest will cut directly across the rest of the entire catchment for Warril creek (that has not already directly affected by KW site development) and there will ongoing pollutant loads in the creek as a result of road storm water run-off.


Proposed construction and intended operation of the KUR- World development will affect the aquatic habitat of the 10% of the L.myola population present on the KUR- World property and the remaining 30% in downstream populations of endangered frogs (L.myola ) plus L.dayii) along the length of Owen, Warril and even Cain creek.


Primarily the damage will be done through altering the flows of water on the site with secondary effects during construction and operation from soil and sediment erosion.


The Kuranda tree frog is already at risk of an exotic frog fungus called Chrytridiomycosis which invades the surface layers of the frog's skin.


Just last week the Kuranda Tree Frog Community Action plan was launched. This is the result of more than a year's work and conservation efforts so far have included tree planting for habitat restoration and riparian corridor linkage of breeding area, Kuranda tree frog monitoring and frog call training for the community.


A recent report in the Mareeba Express16 quoted Kuranda EnviroCare's Cathy Retter saying,

' We'll be working towards …..entire habitat restoration for the frog, with fully connected 100m riparian corridors along all creeks..'


This would appear to be incompatible with the KUR-World development



  1. Successful revegetation of a 100m buffer along all streams would need to be one condition for approval. It would take several years for revegetation to be fully established and proven successful. Revegetating without any chemicals to avoid damage to these frogs would make this even more challenging- and possibly take longer.

  2. Preventing sedimentation of streams and pollution during construction would also be a necessary condition. However for such a large project this would seem impractical


We can see no solutions. The project is too big and in the wrong place, in a highly sensitive and unique ecological area.


3. Impact on Myola Palm (Archontophoenix myolensis)

Terms of Reference Section 13.54

The endangered Myola Palm is endemic to the Myola valley . The most significant

stand of the Myola Palm occurs on Warril Ck, with scattered records in nearby areas along

the Barron River. Both the Kuranda Tree Frog and the Myola Palm are listed as Endangered

at the Queensland (NCA, 2014a; NCA, 2014b) and Federal (EPBC, 2016a; EPBC, 2016b)

levels( ref:footnote 13)


The EIS states 'To address this, the project has defined buffers to each side of sections of Owen, Haren and Cain Creeks, which have been identified as breeding or foraging habitat for the Kuranda Tree Frog. Additionally, these buffers will protect habitat of other important species such as the Myola Palm and the Southern cassowary, while helping to maintain water quality and quantity'.17


It also states ' Forested streams are of highest conservation value as these areas are known to support breeding populations of EPBC Act Threatened frogs and are potentially core habitat for EPBC Act Threatened Myola Palm and micro-bats. '


However the ES recognises the risk of both 'inappropriate excavation or earthworks practices, during construction and/or operation, resulting in erosion and vegetation loss. ' and

'inappropriate vegetation clearing practices, during construction and/or operation, resulting in the inadvertent loss of vegetation (directly or indirectly due to erosion).'


It is worth noting that the proponent has already cleared to within a 10 metre buffer along both Haren and Owen creeks. This makes the issue of monitoring to ensure that existing buffers are maintained- and revegetated to 100m -very problematic in the future without a strict and independent monitoring programme -and the imposition of fines as needed.


Biosecurity risks such as the introduction of invasive weeds are increased with the movement of thousands of people and machinery on and off the property.



  1. a comprehensive and independent monitoring programme paid for by the proponent is necessary to ensure best practice in

  • checking for biosecurity risks- washing down machinery and footwear of construction workers, tourists and residents to remove seeds whenever they move on and off the property

  • revegetation of creeks- as noted above, this revegetation project would need to be established and proven to be successful before approval for KUR-World was given

  • construction and clearing of land in the project site so that streams with the Myola Palm are not contaminated

The above measures, while necessary, seem impractical. Therefore this project should be refused as it is too big and in the wrong place.



2Ref: Chapter 8 Fauna & Flora Landscape context and connectivity.

3See attachment Ecological Corridors

4 Ref:Goosem, Miriam (1997) Internal fragmentation: the effects of roads, highways and powerline clearings on movements and mortality of rainforest vertebrates. In: Laurance, William F., and Bierregaard, Richard O., (eds.) Tropical Forest Remnants: ecology, management, and conservation of fragmented communities. University of Chicago Press, Chicago, IL, USA, pp. 241-255.


6Ref: Chapter 8 Fauna & Flora Potential Residual Impacts to Fauna

7Ref: Chapter 19 Matters of National Environmental Significance Management measure 33 p.89

8Ref: Chapter 8 fauna & Flora Matters of National Environmental Significance

9See attached image Conrad Hoskin report and land clearing by Jo Martin

10. Ref: Ingrid Marker of Cassowary Keystone Conservation


12Ref: Dr. Conrad Hoskin Surveys for endangered frogs and other wildlife on Barnwell Road Holdings

13See attached illustration Conrad Hoskin Report and land clearing by Jo Martin

14 See attached Litoria Myola records

15 Ref: Dr. Conrad Hoskin Surveys for endangered frogs and other wildlife on

Barnwell Road Holdings

16Mareeba Express Wed 21 Nov p. 6

17 Ref: EIS executive summary p.12


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