TMBF response to the Coordinator-General’s Draft Terms of Reference (TOR) for an Environmental Impact Statement (EIS)

1. Apply a Strategic Lens to Impact Assessment

TMBF strongly recommends that the final TOR promote the use of Strategic Environmental Assessment (SEA) principles. This would allow for early integration of environmental, social, cultural, and economic objectives into project planning. It would facilitate transparent evaluation of alternative development scenarios, cumulative and long-term impacts, and enable better sustainability outcomes.

2. Embed Accountability Through a Robust Monitoring Framework

The EIS should include a Monitoring, Evaluation and Learning (MEL) framework that is:

• Transparent and adaptive.
• Co-designed with First Nations via a Cultural Heritage Management Plan (CHMP).
• Inclusive of cultural, social and environmental indicators to guide real-time management decisions.

3. Establish an Independent Environmental Information and Accountability Hub

TMBF recommends the TOR require the proponent to consider establishing a dedicated Hub for storing, analysing and communicating environmental and social data. This Hub would:

• Act as a trusted source of truth for stakeholders.
• Ensure open-access baseline and monitoring data are publicly available.
• Reinforce public trust and corporate social licence to operate.

4. Build Research Partnerships for Long-Term Impact

TMBF recommends the proponent be required to establish Memoranda of Understanding (MOUs) with regional universities and research institutions.

These agreements would:

• Enable access to data for students and researchers.
• Contribute to ongoing analysis and monitoring.
• Build community trust and scientific transparency.

5. Improve Scope and Depth of the EIS

For each assessment category in the EIS, the proponent should be required to:

• Provide a robust account of baseline conditions, acknowledging historical and seasonal variability.
• Include a full assessment of direct, indirect, cumulative and facilitated impacts.
• Acknowledge the cultural context, especially the project’s location along a major Aboriginal dreaming track, with processes co-designed with appropriate First Nations representatives.

TMBF recommends the TOR requires additional information in the Project Description, including:

• State and justify the climate scenarios used to guide engineering design of phases of the project over the multi-decadal timeline
• Expand 4.7 (b) (waterways and coastal wetlands) to ask that unmapped features such as ephemeral wetlands and minor habitat areas (for example as ecological habitats or nursery corridors) be described and assessed for significance and included in considerations of cumulative impacts.
• Expand 4.9 (design of facilities) to require the proponent to 
  • provide an assessment and explanation of any environmental and nature-based design features, such as: soft infrastructure (e.g. living shorelines) over hard structures, opportunities for habitat enhancement (e.g. shellfish reef creation, ecological bund design), low-impact lighting, stormwater capture or reuse and the use of nature-positive design alternatives to reduce the project footprint or provide net ecological benefit;
  • Explicitly map and justify proposed buffer distances between project operations and marine plants and key intertidal/subtidal habitats, cultural sites, public access or recreation areas and include a rationale for distance of setbacks chosen;
  • Include details on specific equipment, vessel types, and dredging techniques likely to be used (for example, particularly the use of trailer suction hopper dredges).
• Expand 4.10(d) (workforce) and 4.10(k) (management) to require a clear First Nations employment and procurement strategy, including:
  • Training, mentoring, cultural safety practices;
  • Identified roles across all phases (environmental monitoring, admin, construction, etc.);
  • Targets and tracking mechanisms for Indigenous participation.

TMBF recommends the TOR requires further information related to the Project Rationale and Alternatives, including:

• Provide a detailed scoping analysis of social, cultural, environmental, and economic aspects of the Port and its surroundings, detailed across relevant plans, policies, and programs (at local, state and national level) relevant to the port and its activities (including, for example, the impact of port activities on other Australian capital cities and their ports).

In considering alternatives, the ToR should require the proponent to describe future scenarios as follows:

• Scenario 1 – Project Undertaken: Describe the expected a) economic b) environmental and c) logistical impacts and outcomes of proceeding with the full-scale channel enhancement project, including implications for regional trade, port efficiency, vessel safety, and environmental mitigation measures.
• Scenario 2 – No Project Undertaken: Outline the potential economic, environmental, and logistical impacts and outcomes if the channel enhancement project does not proceed, considering limitations on vessel size, competitiveness of the Port of Brisbane, and potential future constraints on trade.
• Scenario 3 – Modified Development: Discuss potential alternative configurations or scaled-back versions of the project, including partial dredging, limited re-alignments, or phased approaches. Evaluate how this modified approach would balance port requirements with modified levels of economic, environmental and logistical outcomes.

For scenario 1 and 3 above, the ToR should require consideration of alternative possibilities as per draft TOR items 5.2 (a) and 5.2 (b) – both dredging and dredge dumping scenarios.

TMBF recommends the TOR requires additional information related to Legislative Requirements and Project Approvals, including details on alignments and non-alignments with relevant non-legislative plans, policies and frameworks. These should include (e.g.):

• A clear and detailed statement on alignment with the Marine Parks (Moreton Bay) Zoning Plan 2008, and whether the proposed activities (e.g. dredging, spoil disposal, reclamation) and potential impacts affect General Use, Habitat Protection, Conservation, or Marine National Park zones throughout the entire Marine Park.
• Any proposed exemptions, permissions or boundary changes that will be sought under the Zoning Plan; the justification for these, and any public consultation that will take place surrounding these proposals.
• Identification of any non-alignment or inconsistencies with Regional Plans including, but not limited to, the SEQ Regional Plan (ShapingSEQ); the State Planning Policy and Coastal Management Plan; the State Development Assessment Provisions (SDAP) and any relevant local government planning schemes or overlays.
• Identification of any non-alignment with The Blueprint (2025–2035) as the most comprehensive regional synthesis of values, threats, and priority actions for Moreton Bay. 
• A summary of how the project intersects with or addresses Biodiversity and Climate Frameworks such as the National Biodiversity Strategy and Action Plan 2030 and Queensland Biodiversity Offset Policy, Queensland Climate Adaptation Strategy and emissions reduction commitments, and the UN Sustainable Development Goals (e.g. SDG 13 Climate Action, SDG 14 Life Below Water).
• A disclosure of any anticipated use of coordinated project status or bilateral approval pathways under the EPBC Act or requests for fast-tracking, exemptions, or public notification waivers.
• A commitment to transparency, full scrutiny, and regulatory rigour that includes:
  • Public release of key compliance documents, including environmental management plans, offsets delivery plans, and dredge disposal strategies;
  • Independent audit or third-party review of compliance, ideally with stakeholder input or community oversight.

In addition, the proponent should advise if environmental restoration and or offsets will be required (or advisable) to replace marine plants, seagrass, mangroves, wetlands or fish habitat, and how offsets will be calculated, delivered and monitored:

Restoration Plans for Disturbed Areas 

• Provide a detailed plan for the restoration of habitats disturbed or impacted by dredging or other project activities. Include proposed techniques (e.g., seagrass replanting, coral translocation, mangrove planting, engineered/artificial shellfish reefs) and timelines for each stage of restoration, along with monitoring plans to ensure habitat re-establishment and success criteria for evaluating outcomes.
• Provide detailed and comprehensive plans, including permits and approvals, that will be necessary for restoration and how these will be obtained.

Compensatory Offsets for Habitat Loss 

• If restoration is not feasible or does not fully mitigate impacts, a clear offsets plan must be outlined. This should identify alternative sites or projects that compensate for habitat loss, contain clear, measurable objectives and timelines, and include consultation for cultural offsets with First Nations. 
• Describe consultatory process to determine co-design of necessary offsets with First Nations.
• Provide evidence that offsets meet regulatory standards and contribute meaningfully to biodiversity conservation.

Long-Term Monitoring and Maintenance 

• Outline a plan for ongoing monitoring and maintenance of restored habitats or offset sites.
• Specify responsible parties, monitoring frequency, and adaptive management strategies to address potential failures or declining ecosystem health.

TMBF recommends the TOR requires additional information on Owner and Stakeholder Consultation and Engagement, including:

Culturally appropriate engagement with First Nations

• Ensure all engagement processes are inclusive of First Nations groups including but not limited to Prescribed Body Corporates.
• Identify Indigenous groups with cultural, spiritual, or historical connections to the project area, provide information on existing partnerships or agreements, and outline steps for engaging in respectful, ongoing consultations to ensure their concerns, cultural heritage, and rights are fully integrated into the project’s planning and execution. Outline process consistent with the Aboriginal Cultural Heritage Act 2003 (Qld) and other legislative instruments, including provision of support for First Nations groups to participate effectively in consultation processes, such as providing technical or legal assistance, transportation to meetings, or compensation for time.
• Outline the strategy for integrating First Nations knowledge into project planning, particularly regarding environmental management, cultural heritage protection, and impact mitigation. 

Local Communities and businesses:

• Identify residential areas, community groups, recreational users, and local businesses that may be impacted by the project including those with specific concerns, and relevant interests (e.g., potential impacts on fishing, recreation, or tourism).

Engagement Objectives and Principles

• Define clear objectives for stakeholder engagement and align these objectives with key project stages, from planning and environmental assessment to construction and operation.
• Outline principles of engagement efforts (e.g. transparency, inclusivity, responsiveness, respect, and cultural sensitivity), and the practices to be followed (e.g.: providing access to project updates, and incorporating feedback into project decision-making.)

Consultation Methods

• Outline the methods for consultation with stakeholder groups, including accessible and diverse options for participation (e.g. community meetings, focus groups, virtual consultations, online engagement platforms, surveys, feedback forms etc)

Communication and Transparency

• Provide description of how First Nations and stakeholders will be provided with information (e.g. regular project updates through emails, newsletters, social media, local newspapers, project website)
• Provide a structured mechanism for collecting and responding to stakeholder feedback, including clear timelines for responding to inquiries and a documented process for incorporating feedback into project planning.

External Advisory Committee (EAC)

Provide detailed information on any EAC including:

• the composition of the EAC including First Nations and key stakeholder groups, including local community members, environmental NGOs, industry representatives, and government agency liaisons;
• the EAC’s roles, responsibilities, and decision-making powers (if any), including information on public reporting and accountability (ie: publish the EAC’s recommendations and any responses taken in response to these recommendations, meeting summaries and formal reports).

Ongoing Engagement and Feedback Loops

• Outline a formal process for logging, tracking, and addressing non-EAC stakeholder feedback and complaints, including the publication of summaries of feedback received and actions taken.

Full project engagement

• Define the engagement / feedback / response period over the full course of the project timeline (i.e. not only in the development phase). 
• Provide a plan for continued engagement to monitor impacts through the life of the project, and maintain open communication with affected stakeholders. This may include annual check-ins, surveys, or follow-up meetings with key stakeholders.
• Commit to reviewing the effectiveness of engagement efforts periodically and adjusting approaches as needed to address stakeholder needs.

TMBF recommends the TOR requires additional information on Tenure and Native Title, including the commitment to inclusive First Nations engagement:

The proponent must acknowledge that Prescribed Body Corporates with legal Native Title determination may not represent the full extent of cultural connection or custodianship in the region, and each cannot represent all First Nations in the region. The proponent should identify and engage with all First Nations groups with traditional, historical, or contemporary connections to Moreton Bay, including those without formal legal recognition, to assess the project’s impacts on cultural heritage and Sea Country. Engagement must be early, respectful, and ongoing, and reflect the diversity of cultural authority in the area. Cultural heritage assessments, mitigation measures and monitoring and / or management plans must incorporate the perspectives and knowledge of all relevant groups.

TMBF recommends the TOR requires further information on Land Use Planning, and require the proponent to address adjacent and affected marine and coastal protected areas, including:

• Describe all nearby protected areas, including the Moreton Bay Marine Park and Ramsar wetlands, and assess their proximity and sensitivity to the project. Include an overview of how these areas may be impacted by turbidity, noise, and other project-related activities throughout the full project lifetime and subsequently, as facilitated impacts.
• Recognise that these protected areas often contain both tangible and intangible cultural heritage that must also be identified, mapped, and assessed.
• Discuss and outline requirements for Moreton Bay Marine Park compliance throughout all potential zones impacted by the project, throughout the full project lifetime.
• Assess and discuss necessary and potential changes to zoning of Moreton Bay Marine Park both to facilitate, or as a result of, project activities and the changed use of shipping and dredging areas.
• Assess potential impacts on Moreton Bay Marine Park ecological, social and economic objectives and effectiveness, throughout the full project timeline, and subsequently, as facilitated impacts.

TMBF recommends the TOR requires further information on Dredging and dredge material placement areas (DMPA) to include comprehensive details on:

Sediment Plumes and Turbidity 

• Provide 3D hydrodynamic modelling of the dispersion of sediment plumes created by proposed dredging activities to assess impacts on water clarity, light penetration, and potential smothering of benthic organisms (impacts under Flora and Fauna). 
• Provide models under both typical and worst-case scenarios (for example spring tides, flooding events), AND for long-term and cumulative scenarios showing bathymetric changes due to altered sediment dynamics, scouring or infill from the project, and climate change effects such as increased storm intensity or sea level rise affecting plume dispersion or DMPA stability
• Assess impacts and potential impacts of sediment on: 
  • Pelagic processes including light-driven primary productivity
  • Benthic organisms, photosynthetic marine life, particularly seagrasses and algae, and reef-forming coral communities
  • Habitats influenced by tidal or current transport
  • Specify the dredging techniques that will be employed (e.g., cutter suction dredging, trailing suction hopper dredging) and justify their selection based on environmental considerations.

Characterisation of Dredged Material

The proponent should consider and Include:

• Detailed sediment analysis for all dredging areas and DMPAs, including:
  • Particle size distribution
  • Acid sulfate soils potential (PASS)
  • Contaminants of concern (e.g. heavy metals, hydrocarbons, PFAS)
  • Nutrient loading and organic matter
• Risk assessment of mobilised contaminants and nutrient fluxes post-disturbance.
• Evaluation of potential for anoxia, release of hydrogen sulphide, or other biogeochemical shifts.

DMPA Selection and Justification

The proponent should consider and Include:

• A multi-criteria analysis comparing all possible DMPA options (e.g. offshore, island-based, reclamation, land-based reuse)
• Justification for selected DMPA(s), including proximity to sensitive habitats; resuspension risk; amenity and navigational risks; cultural and community concerns; climate and emissions implications (e.g. transport distance)
• Evidence that beneficial reuse options (e.g. habitat creation, beach nourishment, saltmarsh remediation) have been considered and prioritised where feasible.

Sediment Control Techniques 

• Describe in detail the methods for controlling sediment dispersion during dredging, (e.g.: silt curtains, sediment traps, etc). Include information on placement, duration of use, maintenance schedules, and effectiveness under various tidal and weather conditions.
• Outline how dredging activities will be timed to minimise sediment disturbance, particularly during periods critical to sensitive species, such as breeding or migration seasons.

Monitoring and Response Plan

• Present a rigorously-designed sediment monitoring plan that:
  • Accounts for spatio-temporal variability in the variables being measured
  • Includes real-time data collection and reporting to track turbidity levels and suspended sediments during dredging
  • Describes transparency measures including public access to monitoring data.
  • Includes protocols for adaptive management, detailing thresholds and action triggers for management response, additional sediment control measures, or operational pauses if sediment levels exceed safe limits
  • Describes mechanisms for monitoring samples of dredged materials for artefacts associated with submerged cultural sites.

TMBF recommends the TOR requires additional information on Land – geology, geomorphology, topography and soils, including comprehensive details on:

Hydrodynamics and Currents

• Provide baseline data on current flow patterns, wave conditions, and sediment transport dynamics in Moreton Bay and the Brisbane River, focusing on areas within the proposed dredging and dumping sites.
• Explain how these processes contribute to sediment distribution and potential impacts on benthic habitats.

Erosion and Sedimentation

• Describe existing coastal erosion and sedimentation patterns, particularly around navigation channels, shorelines, and sensitive habitats.
• Identify any locations where these processes are already impacting habitat stability or water quality.
• Recognise that sediments along the Palaeo-Brisbane River channel could contain submerged archaeological evidence for Aboriginal occupation of the Moreton Plain during times of lower sea level during the Last Glacial Maximum (LGM).

Changed Coastal Hydrodynamics

• Evaluate potential alterations to local currents, sediment transport, and wave conditions due to the modified channel configuration. Assess impacts on coastal erosion, shoreline stability, and adjacent habitats, particularly mangroves and saltmarshes.
• Assess the impacts of changes to coastal erosion as a result of dredging that might affect coastal cultural heritage sites such as shell middens and artefact scatters.
• Assess the impacts of coastal erosion on ancient submerged artificial oyster banks, known from archaeological evidence to have been used by Aboriginal people of Moreton Bay for >1200 years 3.

Benthic environment (substrate)

• Describe the current benthic environment, including types of substrates (e.g., sand, silt, clay) and their role in the distribution of various habitat types, such as seagrass beds, corals,  mollusc communities and rocky reefs or outcrops (with reference to Flora and Fauna considerations).
• Describe the composition of sediments, and any contaminants present in the dredging areas with particular attention to any that may impact marine life (with reference to Flora and Fauna and Water Quality considerations.

Describe the chemistry of current sediment composition (dissolved oxygen levels, pH, etc) and how this chemistry is likely to change after dredging (both at site of dredging and at the site of the dumping), as anticipated changes in chemistry may impact contaminants (changes in pH can make heavy metals biologically available) 4.

TMBF recommends the TOR requires additional information on an assessment of First Nations Cultural Heritage including comprehensive details on:

Known Tangible and Intangible Cultural Heritage

• Provide details on the locations of both tangible heritage sites and intangible heritage places
• Outline known cultural heritage sites, including Indigenous and non-Indigenous cultural locations of significance within the project area. Identify and describe all physical cultural heritage sites, objects, and structures within the project area, including any listed Indigenous heritage sites, historical landmarks, or artefacts. 
• Describe any intangible cultural heritage elements, including Indigenous knowledge, traditions, languages, beliefs, and practices associated with the project area, especially those linked to Moreton Bay and surrounding landscapes.
• Recognising that submerged tangible heritage sites are highly likely to occur close to land and adjacent to the main channel, which was a river during the low sea level times of the Last Glacial Maximum, when occupation of the Bay has been documented.
• Recognise the need for a cultural landscape map of submerged landscapes associated with the paleo-Brisbane River and the submerged Moreton Plain which was occupied (based on archaeological evidence from North Stradbroke Island) at least 20,000 years ago 5. Mapping of the palaeo-cultural landscape is an important part of significance assessment and forward planning for cultural heritage management.
• Identify management of current and discovered significant areas and sites, including Dreaming tracks, ceremonial sites, traditional fishing grounds, and oyster farming areas.

Impacts on Tangible and Intangible Cultural Heritage

• Evaluate potential impacts on identified cultural heritage sites, including risks of physical disturbance to known archaeological or historical locations.
• Identify and describe potential for adverse affects where additional physical cultural heritage may occur – for example 1) submerged areas (artefacts may occur along the banks of the submerged Pleistocene river channel); 2) lands adjacent to the channel widening activities (e.g. Moreton and Bribie Islands) that may be affected; and 3)  sites where muddy sediment is planned to be dumped.
• Assess the potential for impacts to Aboriginal living heritage including the continuing practices of cultural fishing, oyster farming, and community gatherings as well as current intangible cultural practice.
• Assess impacts of project recognising Aboriginal Dreaming tracks and associated ceremonial performances affected by the project 
• Assess impacts of the project on yurees (totems), especially on yurees that are sea creatures, such as dugong, turtle, fish, sea birds, shellfish, etc.

Management, Mitigation And Monitoring

• Describe the completion of a formal cultural heritage management plan (CHMP) 6, undertaken at the earliest possible phases of project planning. 
• Describe a Monitoring Evaluation and Learning (MEL) 7 framework as designed by First Nations for use after the CHMP; to be used in determining whether submerged archaeological sites and artefacts occur on the floor of Moreton Bay, via monitoring of dredged sediments. Detail the recovery process for any artefacts found.
• Cultural Heritage Impact Assessment Metrics: Develop specific metrics for assessing cumulative impacts on cultural heritage, such as changes in access to cultural sites, disruptions to ceremonies, and effects on traditional resource use. Specify the frequency of monitoring, and ensure that results are reported back to First Nations groups for review and response.
• Define threshold values or trigger levels indicating significant environmental change, risk, or impact to tangible or intangible cultural heritage. These should be based on regulatory standards and scientific studies relevant to Moreton Bay and its unique ecosystems, and the Guidelines for Assessing and Managing Impacts to Underwater Cultural Heritage in Australian Waters (DCCEEW), in consideration with First Nations collaborators.

• Adaptive Management for Cultural Heritage Preservation Describe an adaptive management framework that actively considers cumulative impacts on cultural heritage, and includes regular consultations with First Nations to review and respond to emerging cultural heritage concerns. Include monitoring and reporting requirements to assess the effectiveness of cultural heritage protections over the long term, with adjustments as necessary to uphold cultural integrity. 

• As part of this adaptive management framework, the proponent should:
  • Propose adaptive management strategies if monitoring reveals significant impacts on cultural heritage. This mayinclude additional protection measures, revised access protocols, or increased support for maintaining traditional practices. 
  • Outline measures to protect and preserve tangible heritage elements (including submerged archaeological sites) during and after dredging and construction 
  • Outline strategies to preserve and promote intangible heritage aspects, such as involving First Nations collaborators in project decision-making, creating interpretive materials, or supporting cultural events and practices. 
  • Monitor samples of dredged material for the presence of artefacts from submerged sites including ancient campsites along the palaeo-Brisbane River.
  • Incorporate provisions for testing samples of dredged material for the presence of artefacts relating to past, now submerged, occupation of the Moreton Plain during the LGM.
  • Outline procedures for response protocols for any unexpected finds (e.g. immediate work stoppage,site buffering, protective enclosures or fencing, or relocation, if necessary), for assessment by qualified cultural heritage specialists. 
  • Outline consultation with First Nations people and relevant authorities to determine appropriate actions for preservation, documentation, or relocation. 
  • Detail the processes for consultation with First Nations and cultural representatives to ensure respectful and informed decision-making regarding tangible cultural assets and intangible elements 
  • Provide a plan for monitoring submerged heritage sites, Dreaming tracks, ceremonial sites, traditional fishing grounds, and oyster farming areas throughout project phases to detect any physical or cultural impacts. 
  • Monitor and document any impacts on living heritage practices, including cultural fishing, ceremonial performances, and the use of Dreaming tracks. Engage with First Nations people to establish protocols for documenting and responding to any disruptions in these practices. 
  • Conduct regular consultations with First Nations to gather input on the ongoing impacts of the project on cultural heritage. This feedback should be formally incorporated into monitoring reports, with summaries of First Nations collaborators’ observations and concerns.

In addition, require the proponent to commit to upholding Indigenous Data Sovereignty and Cultural Intellectual Property Rights, recognising that cultural heritage and knowledge shared by First Nations groups (including traditional ecological knowledge, oral histories, stories, artefacts, ceremonies, and environmental data related to Sea Country) constitute Indigenous data as defined by Halmai et al (2025) 8. In line with the principles of Free, Prior and Informed Consent (FPIC) and Indigenous Cultural and Intellectual Property (ICIP), all data collection, use, interpretation, and sharing involving First Nations knowledge must be governed by the relevant First Nations group(s), whether or not they are represented by a Prescribed Body Corporate.

The proponent must commit to:

• Seek formal consent before collecting or using any Indigenous data
• Provide First Nations people with full transparency over how data is stored, shared, and used
• Recognise traditional data stewardship practices (e.g. oral storytelling, ceremony, seasonal indicators) as legitimate 
• Embed data sovereignty protocols into the development of a Cultural Heritage Management Plan and all Environmental Management Plans under an integrated framework.

TMBF recommends the TOR requires additional information on Non-Indigenous Cultural Heritage including comprehensive details on:

Cultural Heritage Mapping and Data Sources:

• Identify and map all known cultural heritage sites, structures, and areas of significance using multiple sources, including (e.g.):
  • Queensland Heritage Register
  • Local government heritage overlays
  • Australian National Shipwreck Database
  • Maritime Safety Queensland and port authority records
  • Historical society and community archives
• Include land-based and underwater heritage features, such as:
  • Historic jetties, navigation aids, wharf structures
  • Shipwrecks, anchorages, historic channels
  • Remnants of historic fishing or aquaculture operations
  • Coastal defences or WWII-era structures

Landscape and Community Context

• Identify and describe:
  • Intangible heritage values, such as long-standing recreational, fishing, or transport use by local communities
  • Historical changes to coastal land use (e.g. port development, past dredging, land reclamation)
  • The project’s impact on sense of place, particularly for areas with strong community associations (for example Bribie Island, Amity Point, Redcliffe, Wynnum foreshore)

Impacts and management of Underwater Heritage impacts

• Provide a detailed protocol for:
  • Pre-dredging and pre-construction surveys using sonar or magnetometry, to identify submerged cultural heritage items (for example wrecks, artefacts, submerged sites)
  • Assessment by qualified maritime archaeologists, with transparent reporting
  • A step-by-step plan for responding to unexpected finds, including immediate stop-work requirements, notification timelines and responsible persons, engagement with heritage experts and regulators, conservation or in-situ protection options and training requirements for contractors and operators
• Describe approvals that may be required under the Queensland Heritage Act 1992 and Commonwealth Underwater Cultural Heritage Act 2018, and how any proposed disturbance of heritage places will be assessed and mitigated in accordance with the Burra Charter principles 9.

TMBF recommends the TOR requires additional information on Flora and Fauna to require comprehensive descriptions of:

Existing Conditions

Benthic Habitats 

• Describe historical and current distributions of various habitat types such as seagrass beds, corals,  mollusc communities and rocky reefs or outcrops. Describe changes in habitats over time and identify historical and contemporary trends in distributions and habitat loss and their drivers, throughout the project footprint and surrounding marine and coastal areas.
• Detail the species composition, density and biodiversity within these habitats, including any ecologically significant areas or known vulnerable habitats in the project area, overt and covert biodiversity (i.e. egg and seed banks), and their drivers. 
• Identify specific seascape connectivity (that is, ecosystems affecting each other through a conversation of geophysical, chemical and biological processes) within Moreton Bay and surrounds

Protected and At-Risk Species

• Identify key species that are protected under local, state or federal legislation, plans and policies, including any endangered, threatened, or vulnerable species at federal state or local level, recognising that many also have cultural significance. 
• Identify their pressures and threats and how these vary spatially and temporally across Moreton Bay

Migratory Pathways and Breeding Grounds

• Detail any migratory pathways for species such as turtles, dugongs, or migratory shorebirds, particularly within Moreton Bay’s Ramsar-listed wetland area, recognising that most of these species also have cultural significance to First Nations of the area.
• Describe the location of known breeding or nursery grounds that may be sensitive to increased turbidity, noise, or vessel traffic.
• Recognise that marine species nursery grounds are important for the living heritage of First Nations and Custodians who still use the bay for fishing activities that have been practised for thousands of years.

Sensitive Marine and Coastal Ecosystems

• Identify any areas within Moreton Bay and the Brisbane River that are vulnerable to ecological change likely to result from the development, such as seagrass meadows, coral reefs, benthic mollusc communities and mangrove ecosystems. 
• Recognise that all these natural landscapes are also cultural landscapes of significance to First Nations.
• Recognise the interdependence of marine systems, outline interdependencies of habitats within and at distance from project areas.
• Identify Traditional Owner cultural landscapes (including submerged cultural landscapes) and living heritage of these interconnected systems.

Direct And Indirect Impacts

• Use sediment dispersion models to show expected impacts from dredge activities on water clarity, light penetration, and potential smothering of benthic organisms. Discuss short-term and long-term impacts on photosynthetic marine life, particularly seagrasses and algae, and potential downstream effects.
• Assess the extent of estimated/potential habitat loss due to dredging activities, especially in seagrass meadows, coral habitats, and other sensitive or important benthic environments such as mollusc communities. Include estimates of the area to be directly affected and analysis of how habitat loss could impact local biodiversity and ecosystem functions.
• Evaluate the indirect impacts on marine species including adverse effects on tangible and intangible cultural and living heritage assets (including dugongs, turtles, fish, shellfish, and maritime cultural landscapes for Aboriginal subsistence and ceremonial economies and living heritage.)
• Assess the potential for dredging activities to disturb contaminated sediments and release pollutants, such as heavy metals, which could impact marine species directly or via bioaccumulation through food webs. Evaluate potential risks to the food web, including for species consumed by humans.
• Assess the extent and likelihood of direct impacts on marine mammals, migratory birds, fish, and benthic organisms from project activaties (including dredging) and increased shipping activity, through the project’s lifespan and after completion.
• Assess potential impacts of artificial lighting on fauna, particularly sensitive species such as marine turtles, shorebirds, and nocturnal marine or intertidal species
• Evaluate the indirect impacts on species dependent on affected habitats, including impacts on feeding, breeding, larval settlement and recruitment, and migratory behaviours of fish, invertebrates, and larger marine animals (e.g., dugongs, turtles)
• Identify threats to interconnected habitats and ecosystems and system processing even at distance from project area.
• Identify potential for disturbances to interconnected ecosystems to affect cultural landscapes and disrupt living heritage for First Nations of this area.

Mitigation And Monitoring

• • Identify mitigation measures including (but not limited to) measures that:
    • reduce fauna disorientation, behavioural disruption, and habitat avoidance caused by project activities
    • avoid and reduce sediment smothering of benthic habitats 
    • prevent bioaccumulation risks avoid disturbance to feeding and breeding behaviours of key fauna 
    • protect habitat connectivity and ecosystem processes
  • Impact Assessment Metrics: Define metrics to assess direct and indirect impacts on marine fauna. Specify the frequency of monitoring and reporting for each metric, the reference state measured against, and a grading approach to be used.
  • Vessel Traffic Management: Provide detailed measures for managing vessel traffic to avoid strikes on marine fauna. This should include designated shipping lanes, reduced speed zones, and operational timing restrictions in sensitive areas. Explain how these measures will be enforced and monitored, including any technological tools (e.g., radar, acoustic monitoring) to detect and track fauna presence.
  • Monitoring of Key Species: Identify priority marine species for monitoring, particularly those of cultural significance to First Nations, those at risk from vessel strikes, noise disturbance, or habitat disruption. Include specific observation protocols for species known to inhabit or migrate through Moreton Bay.
  • Detection and Tracking Technology: Detail the technology and methods to be used for real-time monitoring of marine fauna interactions (e.g. sonar, underwater cameras, acoustic detection, aerial surveillance). Specify procedures for using detection data to adjust vessel speeds or reroute activities in real-time to protect wildlife.
  • Training and Awareness Programs: Describe mandatory training programs for vessel operators and staff on marine fauna awareness and strike prevention. Include specific actions to take if animals are spotted in the project area and regular assessments of crew compliance with strike avoidance protocols.
  • Adaptive Management Measures: Propose adaptive measures to be implemented if monitoring reveals impacts on marine fauna. 

• Reporting Incidents: Describe a protocol for documenting and reporting any marine fauna interactions or strikes, including immediate actions, notification to relevant authorities, and corrective measures. Include incident investigation processes and a commitment to reviewing and improving vessel strike mitigation practices based on findings.

TMBF recommends the TOR requires additional information on Biosecurity to include comprehensive description of:

Existing risks

Identify and map current biosecurity risks in the project area, including:

• Presence and distribution of relevant marine and terrestrial pest species, such as Caulerpa taxifolia, Asian green mussel (Perna viridis), and Suminoe oyster (Magallana ariakensis)
• Vectors for pest introduction and spread, including shipping, dredging equipment, ballast water, and hull fouling.
• Existing biosecurity controls or surveillance programs in Moreton Bay (e.g. port inspections, local eradication programs).
• Sensitive or high-value ecological areas at risk of pest invasion (e.g. seagrass beds, coral habitats, aquaculture zones).

Impacts (including facilitated impacts)

• Assess risks of introduction or spread of invasive species, including (for example):
  • Mobilisation of dredging equipment from outside the region or internationally
  • Use of temporary infrastructure (e.g. floating plant, barges, temporary pontoons)
  • Disposal of dredged material or movement between locations within the bay and onto land
  • Increased vessel traffic during the project and after the project’s c ompletion
  • Changes to hydrodynamic conditions facilitating pest dispersal
• Evaluate potential impacts of pest establishment on:
  • Native biodiversity and ecosystem services
  • Commercial fisheries, aquaculture and recreation values
  • Cultural and community values, particularly where pest species may alter habitats important to First Nations of South East Queensland.
• Evaluate potential biosecurity hazards and likelihood of biosecurity breaches across Scenarios 1-3 (Project Rationale)

Monitoring, Mitigation and Management Measures

Comprehensively describe Monitoring, Mitigation and Management Measures that include:

• Prepare and include a comprehensive Biosecurity Risk Management Plan in line with national and Queensland biosecurity guidelines.
• Describe proactive measures to lower biosecurity risk, including (for example):
  • Vessel and equipment decontamination protocols before entry into the project area (especially for dredging and construction vessels)
  • Ballast water management and biofouling inspections for all vessels, in compliance with Australian Ballast Water Management Requirements
  • Ongoing surveys for early detection of marine pests in sensitive habitats.
  • A monitoring and rapid response framework for marine and terrestrial pest incursions during the life of the project, including sustainable funding for ongoing management, containment, or eradication works
  • Collaboration with existing biosecurity agencies (e.g. Biosecurity Queensland, neighbouring port authorities, First Nations ranger teams) to ensure alignment with regional management efforts.

In the above, ensure additional facilitated risks are considered and addressed.

TMBF recommends the TOR requires additional information on Water Quality, including the establishment and implementation of a water quality management plan, which should include: 

Baseline/Current

• Establish a detailed baseline of water quality in the project area and downstream receiving environments, including:
  • Key parameters such as turbidity, total suspended solids (TSS), nutrients (including nitrate, ammonium, organic and inorganic nitrogen), dissolved oxygen, pH, salinity, temperature, and chlorophyll-a
  • Dissolved and particulate contaminants and pollutants in the water column, including heavy metals, hydrocarbons, and PFAS, especially in dredging zones and spoil placement areas
  • Sediment quality, particularly in areas subject to disturbance, including analysis for contaminants and particle size distribution
  • Pelagic microbial communities, with particular attention to cyanobacteria and microbes of concern (e.g., infectious to humans, antibiotic-resistant strains)
  • Temporal and spatial variability (e.g. tides, rainfall events, seasonal changes)
  • Long-term water quality data from recent studies or ongoing monitoring in Moreton Bay and the Brisbane River (e.g. Healthy Land and Water monitoring, QLD DES datasets, and academic studies).
• Identify sensitive receptors for water quality impacts, including (for example):
  • Coral communities, seagrasses, shellfish reefs, mangroves, saltmarsh, and fauna (e.g. fish, turtles, dugongs)
  • Recreational swimming and diving areas, areas for shore and boat fishing 
  • Cultural sites with water-dependent values

Future Impacts

• Assess the potential impacts of construction and operational activities on water quality, particularly:
  • Dredging and spoil disposal (including overflow and turbidity plumes)
  • Resuspension of fine sediments and release of nutrients or contaminants
  • Alteration of hydrodynamic regimes (e.g. flow velocities, sediment transport) that affect flushing or sediment deposition
  • Risk of localised eutrophication or hypoxia due to nutrient input or organic loading
  • Redistribution of sediments and potential smothering of sensitive benthic habitats, including seagrass meadows and remnant coral reefs
  • Model spatial and temporal extent of impacts, including sediment plume modelling for typical and worst-case conditions (e.g. wet season events).
• Evaluate cumulative water quality impacts in the context of:
  • Ongoing sediment and nutrient loads from catchment runoff
  • Climate change stressors (e.g. temperature increases, sea-level rise)
  • Other dredging and / or development activities in Moreton Bay.

Mitigation and Monitoring

• Develop and implement a Water Quality Management Plan, demonstrating alignment with
  • Environmental Protection (Water and Wetland Biodiversity) Policy 2019 (Moreton Bay including Stradbroke Islands, Moreton Island and other bay islands Environmental Values and Water Quality Objectives)
  • Water quality monitoring programs conducted by various agencies including the Qld Department of Environment Tourism Science and Innovation; Healthy Land and Water and Moreton Bay-adjacent councils

• Determine Water Quality Objectives for the project, including
  • Parameters and Sampling Locations: Specify the water quality parameters that will be monitored across multiple control locations for the duration of the project (20-25  years), and specific sampling locations throughout the project area, with particular focus on sensitive ecosystems (e.g., seagrass beds, coral reefs, Ramsar wetlands).
  • Sampling Frequency and Duration: Outline the frequency of sampling during each project phase (e.g., pre-construction, construction, post-construction). Include targeted and responsive monitoring particularly during high-risk activities such as dredging, with provision for long-term follow-up where delayed effects may occur.
  • Threshold Values: Provide baseline data for each parameter, describe the method used to detect a specific effect size, and the level of replication necessary to detect threshold values or trigger levels.
  • Contingency Actions: Define specific actions to be taken if thresholds are exceeded. Include procedures for notifying regulatory authorities of threshold exceedances and documenting response actions.

TMBF recommends the TOR requires additional information on Flooding and Regulated Structures including comprehensive details on:

Current/Baseline

• Historical and current data on storm surge, rainfall flooding and sea-level variability
• Hydrological and hydraulic modelling outputs for the Brisbane River and surrounding estuarine environments
• Existing regulated structures in the coastal zone, including navigational aids, revetments, groynes, seawalls, bunds, and jetties; flood mitigation infrastructure; dredge material placement areas and containment bunds
• Natural coastal defences (e.g. mangroves, saltmarsh, shellfish reefs) that currently play a role in buffering flood and storm surge impacts

Future Impacts

• A bidirectional assessment of potential impacts of the proposed works on flood behaviour, and the reverse. Include information on anticipated:
  • Alteration of flow paths and water surface elevations during tidal and flood events
  • Modelling of modified estuarine hydrodynamics that may increase local flood risk to coastal land or infrastructure
  • Placement or expansion of structures that could impede drainage, amplify stormwater ponding, or affect sediment dynamics
  • Evaluation of the integrity and performance of any regulated structures proposed as part of the development (e.g. revetments, bunds for dredge spoil)
  • Risk assessment for failure or overtopping during extreme weather
  • Evaluation of maintenance obligations and asset lifespan

• In addition, assess the exposure and vulnerability of the proposed project infrastructure, activities, and operations to existing and projected flood and coastal hazard risks. This should include:
  • Exposure mapping showing all project components within areas subject to riverine flooding, storm tide inundation, localised overland flow/flooding and coastal erosion hazard areas and permanent inundation zones under sea-level rise scenarios 
  • Risk assessment of operational impacts due to flood and storm tide events, including inundation of dredge material placement areas (DMPAs), reclamation sites, bunds, or plant locations; disruption to logistics, vessel access, or safety; containment failure and remobilisation of dredged or contaminated materials; damage to revetments, temporary works, or flood-sensitive infrastructure 
  • Assessment of compound and cascading events, for example:  storm surges coinciding with high tides or extreme rainfall 
  • Critical thresholds for key assets (e.g. overtopping, wave height, bund freeboard) under current and future climate conditions
  • Incorporation of sea level rise projections across the asset life span, with adaptive design thresholds at key intervals (e.g. 2050, 2070, 2100) 

• Emergency response planning for flood events during construction and operation, including:
  • Safe access and egress for personnel;
  • Contingency protocols for dredging or marine plant operations;
  • Flood-compatible storage and handling of hazardous materials.

Monitoring, Mitigation and Management Measures

• Prepare a Flood and Coastal Hazard Assessment Report that includes:
  • Updated flood modelling under current and future climate scenarios
  • Risk mitigation strategies for extreme rainfall or cyclonic events during construction
  • Description of permanent and temporary structure design to meet best-practice engineering and ecological criteria, including:
    • Incorporating nature-based solutions or hybrid infrastructure 
    • Ensuring structures do not reduce the capacity of floodways or increase offsite flood risk
    • Designing for long-term resilience to erosion, sea level rise and storm surge
  • A maintenance and decommissioning plan for any temporary structures or bunds used in spoil management
  • Description of research and consultation with local councils and First Nations to understand past flooding impacts, culturally significant floodplain areas, and opportunities for co-design of flood-resilient infrastructure.

TMBF recommends the TOR requires additional information on Visual Amenity, including comprehensive details on:

Existing conditions

• Describe existing visual character and landscape values of the bay and foreshore, including the open water horizon, island views, and existing built structures
• Describe ‘Viewsheds’ from public lookouts, recreational and residential , transport corridors (used by ferries, cruise ships etc). In particular, describe viewsheds in areas of high scenic quality or community sensitivity, including foreshore parks and walkways (e.g. Wellington Point, Wynnum Foreshore),  key tourism and recreation vantage points, and known First Nations and non-First Nations cultural heritage sites
• Include photographic viewpoints and simulations where practicable to support visual impact assessment

Impacts 

Assess potential visual impacts during both construction and operation, including:

• Dredging vessels, barges, stockpiles, and equipment lighting
• Temporary and permanent structures such as wharves, mooring dolphins, and disposal sites
• Light spill or glare from night-time operations affecting nearby communities, wildlife, or recreation users
• Changes to seascape openness, horizon lines, and the perception of a natural, low-development coastline (both realised and facilitated changes)
• Consider the duration, reversibility and cumulative nature of visual impacts, especially in the context of other major coastal infrastructure developments affecting the Bay.

Monitoring, Mitigation and Management Measures

• Prepare a visual impact management plan including (for example):
  • Minimisation of equipment and lighting intrusion during key viewing times (e.g. sunrise/sunset, weekend recreation hours or for the duration of special tourist seasons such as Christmas/summer periods and during the 2032 Olympics)
  • Restoration or enhancement of any disturbed areas to pre-construction visual condition where feasible
  • Process for consultation with local communities, First Nations and local councils to incorporate culturally and socially important landscape values 
• Use visualisation tools (e.g. photomontages, fly-throughs) as part of public consultation to improve transparency and community understanding.

Ensure that consideration of the additional facilitated changes the project is likely to create (e.g. increased size, number and frequency of container vessels through the Bay) is considered and addressed.

TMBF recommends the TOR requires additional information on Social aspects of the project, including comprehensive details on:

Current Social Use

• Describe current recreational users and use of Moreton Bay and the Brisbane River, including First Nations living heritage use
• Describe any community-valued landscapes or areas frequently used by communities for cultural or social activities
• Describe social objectives of the Marine Parks Act (2004) and social use of the Moreton Bay Marine Park and zones
• Socio-economic conditions, including dependence on marine and port industries, tourism, and ecosystem services
• Existing community health and wellbeing indicators relevant to coastal living and green and blue space access
• Community perceptions and concerns regarding port operations and development

Impacts:

• Assess impacts on recreational areas in Moreton Bay, including potential restrictions on boating, diving, and water-based sports. Include strategies to minimise disruptions to public access and maintain recreational opportunities during the project.
• Evaluate potential disruptions to current users of Moreton Bay, including First Nations, recreational and commercial boaters, fishers, and other water-based activities. 
• Consider cumulative social impacts, particularly where the project overlaps with other developments or policy changes (e.g. marine park rezoning, housing growth in SEQ). 
• In addition, consider cumulative impacts on recreational fishing grounds, including potential habitat degradation, stock depletion, and access limitations due to both current and anticipated future developments. Include an analysis of how prolonged habitat changes may affect fish populations and fishing yields.
• Assess how changes in water quality, increased vessel traffic, or impacts to marine habitats and marine life may impact other users and their ongoing use and enjoyment
• Assess potential impacts on Moreton Bay Marine Park social objectives and effectiveness

Mitigation And Monitoring

• Describe meaningful and equitable stakeholder and community engagement from the earliest stages of the project development, and throughout the project, including transparency measures
• Prepare and describe a Social Impact Management Plan that includes:
  • strategies to maintain or improve public access to foreshore and recreation areas
  • strategies to minimise disruptions, such as providing alternative access points, establishing exclusion zones
  • programs to offset any reduction in visual or recreational amenity (e.g. community infrastructure improvements)
  • measures to monitor community sentiment, health, and wellbeing during construction and operation
  • local employment and procurement initiatives to share project benefits equitably
  • communication strategies to ensure communities are kept informed of project timelines and affected areas
  • commitment to ongoing social license to operate, including community liaison groups and complaint resolution mechanisms

TMBF recommends the TOR requires additional information on Economics including comprehensive details on:

Impacts on Local Economy: 

• Assess potential disruptions to local industries (e.g. commercial and recreational fishing, tourism, and non-fishing recreational use). 
• Evaluate potential disruptions to fishing areas in Moreton Bay, including commercial, recreational and First Nations  fishing sectors. 
• Discuss potential compensation or mitigation measures, such as alternative fishing locations or temporary fishing restrictions.
• Assess cumulative impacts on commercial fishing grounds, including potential habitat degradation, stock depletion, and access limitations due to both current and anticipated future developments. Include an analysis of how prolonged habitat changes may affect fish populations and fishing yields.
• Evaluate potential impacts to recreation and tourism in Moreton Bay, including to existing operations and to projected opportunity for the tourism sector

Local Employment and Supply Chain Impacts:

• Assess the potential positive and negative effects of the project on local employment, small businesses, and regional supply chains. This should include workforce displacement, potential job creation (temporary or permanent), and impacts on employment sectors directly or indirectly reliant on the Bay’s natural assets and cultural values, including marine tourism, hospitality, and local First Nations enterprises.

Economic Valuation of Ecosystem Services:

• Quantify the economic value of ecosystem services that may be affected by the proposed works (e.g. water filtration by seagrass beds, shoreline protection by mangroves, cultural and recreational values). This assessment should include scenarios of long-term degradation, and the implications for the Bay’s natural capital and broader economic sustainability.

TMBF recommends the TOR requires additional information on Hazards Health and Safety, including comprehensive details on:

Spill and Leak Risks 

• Assess the risks of spills or leaks from dredging vessels, including potential impacts on marine and coastal environments. 
• Outline response protocols for spill containment and mitigation measures to prevent contamination.

Vessel Collision and Grounding Risks 

• Evaluate risks of increased vessel traffic in the modified channels, particularly the risk of vessel collisions, groundings, or interactions with marine wildlife. 
• Outline strategies to enhance vessel navigation safety, such as designated lanes, navigational aids, and speed restrictions.

Safety Risks to Workers and the Public

• Assess potential health and safety risks associated with dredging activities, including safety protocols for project workers and strategies to prevent accidents that could impact the local community.

Public Health and Water Quality Risks

• Assess potential impacts of dredging and sediment resuspension on water quality and associated public health risks, particularly for recreational users (e.g. swimmers, fishers, divers) and vulnerable populations. Consider microbiological and turbidity thresholds, and the cumulative risk of exposure to contaminants through seafood consumption or water contact.

Cultural Risk And First Nations Health, Safety And Wellbeing

• Address the potential health and safety impacts of the project on First Nations communities, including impacts to customary fishing or sea country access, and implications for cultural and spiritual wellbeing. Consultation should be undertaken to determine culturally appropriate risk management measures, respecting First Nations knowledge of safe use of sea country
• Assess the project in light of the channel widening occurring along the length of a major Aboriginal dreaming track 
• Recognise that damage to significant spiritual places can cause cultural and spiritual risks.

Climate-Exacerbated Hazards and Emergency Preparedness

• Evaluate how climate change may exacerbate existing hazards (e.g. extreme weather events, sea level rise, coastal inundation) during the construction and operation phases. Outline how emergency response and risk management plans will account for these interacting risks, especially in low-lying or flood-prone areas adjacent to the port and Bay communities.

TMBF recommends the TOR requires additional information on Air Quality, including comprehensive details on:

Existing Air Quality

• Describe prevailing meteorological conditions over marine and coastal areas of the project footprint, including wind speed/direction, temperature inversions, and sea breeze influence, as these affect dispersion of emissions from marine vessels.
• Identify current ambient air quality in ecologically significant marine areas, including marine national parks, intertidal zones, and habitats supporting threatened species.

Assess Air Quality Impacts and Potential Impacts

• Assess cumulative air quality impacts from increased vessel emissions within Moreton Bay, including emissions from support vessels, dredgers, and anchorage zones. Include facilitated impacts enabled by the project’s completion.
• Evaluate deposition of airborne pollutants (e.g. nitrogen compounds, particulates) on marine surface waters, intertidal habitats, and seagrass beds, including potential effects on water quality and ecosystem function.
• Quantify emissions from dredging activities and associated vessel traffic, including particulate matter (PM10, PM2.5), nitrogen oxides (NOx), and sulfur oxides (SOx). 
• Assess air quality impacts on nearby communities and sensitive receptors, particularly in residential or ecologically sensitive areas.
• Assess any potential odour impacts related to dredging and dumping activities, particularly where organic or anaerobic sediments are involved, and detail measures to mitigate odour for nearby residential areas and recreational spaces.

Mitigation and management

• Identify mitigation measures specific to marine operations, such as use of low-emission marine fuels, shore power or hybrid technologies where feasible, and limits on idling time at sea.
• Propose real-time air quality monitoring from project-related sources, especially near sensitive marine habitats and coastal communities, with publicly available results and adaptive management triggers.

TMBF recommends the TOR requires additional information on Noise and Vibration, including comprehensive details on:

Current Ambient Noise Levels

• Describe existing noise levels in and around the project area, including daytime, nighttime, and seasonal variations, with a focus on underwater noise from existing port operations, commercial and recreational vessel movements, and other industrial activities
• Identify proximity to human receptors and ecological receptors (on water, underwater, and on shore)
• Underwater acoustic environment should be characterised using hydrophones to measure sound pressure levels, frequency, and duration, particularly in key habitats used by dugongs, dolphins, turtles, and migratory fish

Impacts

• Model underwater noise levels from dredging and shipping activities, assessing current and projected impacts on marine species sensitive to noise, such as whales, dolphins, and fish. Evaluate potential behavioural changes, such as avoidance of key habitats or disruption to migratory paths and resting environments

• Analyse the physical impacts of vibration effects that could affect animals, benthic organisms or structures. Include consideration of cumulative impacts from existing port operations and dredging activities.
• Assess potential airborne noise impacts on nearby coastal, riverside and Island communities, including increased levels from dredging equipment and vessel traffic. 

Mitigation And Monitoring

• Discuss mitigation measures to avoid or minimise harmful noise levels throughout all project phases and across all affected locations
• Outline how dredging and vessel operations will be managed to reduce noise impacts, including time-of-day restrictions, speed limitations, and soft-start procedures. Describe specific technologies or modifications to equipment to reduce underwater noise impacts (e.g., quieter engines, bubble curtains). 

• Provide a detailed plan for underwater noise & vibration monitoring, including monitoring locations and equipment to measure noise levels during dredging and other activities. Specify the frequencies and decibel levels to be monitored, as well as threshold values that align with marine fauna tolerance levels at which noise reduction actions will be triggered.
• Describe measures to protect nearby communities from airborne noise, such as installing noise barriers, using low-noise machinery, and scheduling high-noise activities during daylight hours.
• Provide data on expected noise levels with these modifications and how they compare to existing baseline levels and known thresholds for sensitive species.
• Describe how real-time airborne noise monitoring will be conducted, with specific steps to reduce noise levels if thresholds are approached or exceeded. Include actions such as slowing equipment, pausing high-noise activities, or adjusting work schedules. Include provisions for regular noise monitoring at community-sensitive locations and steps for engaging residents about potential disruptions and mitigation strategies.

Reporting on Noise Impact: 

• Define specific metrics and reporting requirements to assess the effectiveness of noise reduction measures, including any recorded exceedances and corrective actions taken.

TMBF recommends the TOR requires additional information on Traffic and Transport, including comprehensive details on:

Existing conditions

• Describe existing vessel traffic volumes, types and routes within the Port of Brisbane and adjacent Moreton Bay Marine Park, including commercial shipping, recreational boating, fishing vessels, and ferry operations.
• Identify current navigation aids, vessel control systems, and known maritime safety issues or conflict zones (e.g. between commercial and recreational use).
• Map sensitive marine habitats and species migration routes (e.g. dugongs, turtles, humpback whales) in relation to baseline vessel traffic patterns.
• Include existing land-side port access and freight routes that may affect catchment runoff and waterway health.

Short and Long-term Impacts 

• Assess impacts from dredging and construction vessel movements, including increased collision risk with marine fauna, underwater noise, and water quality disturbance from propeller wash and sediment resuspension.
• Consider and address expected facilitated impacts from the long-term increase in shipping volumes enabled by the wider and deeper channel, including:
  • Increased risk of ship strikes on marine megafauna (especially turtles, dugongs, dolphins and whales).
  • Higher likelihood of anchor damage and prop wash affecting seagrass beds and benthic habitats.
  • Potential for greater disturbance of recreational and tourism uses of the Bay, with socio-economic implications.
  • Increased emissions and wake energy in shallow areas leading to shoreline erosion and habitat degradation.
• Evaluate indirect land-based transport impacts from increased freight activity as a result of the increased shipping load, including increased sediment-laden runoff from port-linked infrastructure expansion, and road traffic into catchments.

Outline Transport Management Measures

• Propose measures to minimise vessel-related impacts during and after construction, such as:
  • Speed restrictions and exclusion zones near sensitive marine fauna habitats.
  • Routing adjustments to avoid ecologically sensitive areas.
  • Vessel scheduling to reduce peak congestion and conflict with recreational users.
  • Design of channel and navigation aids to maximise navigational safety and minimise oversteer or wash in shallow zones.
• Describe long-term port development scenarios including cumulative effects, and describe include offset or mitigation strategies
• Describe strategies to avoid increases in land-based sediment and pollutant runoff linked to induced freight growth, particularly into creeks and rivers that discharge into Moreton Bay.

TMBF recommends the TOR requires additional information on Waste, including comprehensive details on:

• All waste types generated during construction and dredging, such as
  • dredge material (classified by contamination level and sediment type);
  • fuel and oil residues, bilge water, and vessel maintenance waste;
  • domestic and operational waste from construction vessels (plastics, food, packaging, sewage);
  • waste generated during site mobilisation and decommissioning.
• Locations of onshore and offshore waste storage, treatment, or disposal, including but not limited to dredge material placement areas (DMPAs), and any reuse applications.
• Detailed protocols for classifying, tracking, and reporting dredged materials and associated contaminants.

Impacts 

• Potential impacts of waste handling and disposal on marine water quality and ecological health (e.g. smothering of benthic communities from poorly managed spoil placement or sediment drift); public health and amenity (including odour or contamination affecting local residents or recreational users); and marine species (particularly ingestion or entanglement hazards from plastic and packaging waste).
• An evaluation of accidental discharge of hazardous waste or contaminants during storm events or mechanical failure.
• Discussion of cumulative and facilitated impacts, including increased long-term waste generation from:
  • Greater shipping traffic (e.g. vessel waste discharge, hull cleaning residues, maintenance waste);
  • Expanded port activities and freight handling infrastructure (e.g. landfill, microplastics, industrial runoff);
  • Ongoing dredging or channel maintenance linked to the widened infrastructure footprint.

Management and Mitigation

• Provide a detailed Waste Management Plan, including:
  • Measures to minimise waste generation at source
  • Best-practice containment, transport, and treatment of dredge spoil, aligned with National Assessment Guidelines for Dredging (2009)
  • No discharge of untreated waste into the marine environment, with all domestic and industrial waste to be returned to shore for appropriate disposal
  • Monitoring for legacy contamination or leakage from placement areas and bunds.
• Propose real-time leak detection and water quality monitoring around DMPAs and waste storage zones, with public reporting and adaptive triggers.
• Require future-proofing of port waste infrastructure to handle projected long-term increases in vessel waste and freight-associated industrial waste

TMBF recommends the TOR requires additional information on Climate Change, including comprehensive details on:

Local Climate Data

• Summarise historical climate data, including temperature ranges, precipitation, and seasonal patterns.
• Describe any extreme weather events, such as cyclones or major flooding, that may affect the project area.

Climate Change Projections

• Outline any relevant climate change projections for the region, including anticipated sea-level rise, increased frequency of extreme weather events, and potential effects on local ecosystems and project infrastructure over time.
• Assess how climate change projections, including sea-level rise and increased frequency of extreme weather events, could affect the project and its viability. 
• Assess how these changes might impact the stability of dredged areas, channel depth, and maintenance requirements over time, and beyond the period of the project’s completion

Climate change scenario modelling

• Model and evaluate the project under a range of future climate scenarios or Representative Concentration Pathways (RCPs) (e.g. RCP4.5, RCP8.5). Modelling should assess how climate change may influence Shared Socioeconomic Pathways (SSPs) describing the magnitude, frequency, and distribution of environmental, cultural, social, and economic impacts across all aspects of the project. The modelling should:
  • Be applied consistently across all thematic areas of the EIS (e.g. water quality, flora and fauna, cultural heritage, coastal processes, and economic viability).
  • Identify risks that may be exacerbated under certain futures and assess the cumulative interaction of project impacts with climate-driven environmental changes.
  • Be supported by transparent assumptions, data sources, and timeframes, and include a sensitivity analysis to highlight thresholds or tipping points for project viability and ecosystem health.
  • Inform the development of long-term adaptation, monitoring, and risk management strategies, including mitigation of residual risks under high-impact scenarios.

Adaptation and Resilience Measures

• Outline adaptive measures in project design to address future climate impacts, including resilience strategies for project infrastructure and response plans for extreme weather events.

TMBF recommends the TOR requires additional information on Greenhouse Gas, including comprehensive details on an assessment of the short and long-term implications for the region’s greenhouse gas emissions and any contributions to climate change:

• Estimate the carbon footprint of the project, including direct emissions from machinery and vessels through the lifetime of the project phases
• Estimate both direct and indirect emissions associated with outcomes from the project, including the facilitated impacts of increased port operations, shipping, and land-based freight. 

TMBF recommends the TOR requires additional information on Cumulative Impacts, including comprehensive details on short and long-term cumulative and multiplying impacts on:

Biodiversity and Habitat 

• Assess cumulative impacts of the project on marine biodiversity and habitats, considering other ongoing and future projects in Moreton Bay and the Brisbane River. This should include long-term and multiplying effects on sensitive habitats, such as seagrass meadows, coral reefs, mangroves, mollusc communities and other critical ecosystems, with a focus on resilience and recovery capacity. 
• Recognise the cultural significance of these biodiverse habitats.

Water Quality and Sedimentation 

• Evaluate cumulative impacts on water quality from prolonged dredging activities, vessel traffic, and potential future development in the bay. Assess changes in sedimentation patterns, turbidity, and potential impacts on water quality that may compound over time.

Climate Change

• Include consideration of how climate change may exacerbate cumulative impacts, such as increased stress on marine ecosystems due to warming temperatures, sea-level rise, and extreme weather events. Discuss how these factors may interact with the project’s environmental footprint over time.

Cultural Heritage

• Impact on Living Heritage and Cultural Practices: Assess how the project’s long-term impacts, combined with other developments in Moreton Bay, could affect Aboriginal living heritage and the continuity of cultural practices. This should include an evaluation of the cumulative effects on traditional fishing, oyster farming, and the maintenance of Dreaming tracks and ceremonial sites over time.
• Cultural Landscapes and Sacred sites and Places of Significance: Evaluate how changes to ecosystems, such as seagrass beds, coral reefs, and mangroves, may have cumulative effects on cultural landscapes that hold spiritual and historical significance for First Nations. Consider how alterations to these interconnected ecosystems may affect the integrity of sacred sites and places of significance including Dreaming tracks, and areas used for ceremonial performances.
• Loss of Access and Cultural Knowledge Transfer: Assess the cumulative impact of potential access restrictions and ecosystem degradation on the ability of Indigenous communities to engage in cultural practices, transfer traditional knowledge, and maintain a connection with their heritage landscapes. Propose mitigation strategies to ensure continued access to culturally significant areas, and outline adaptive measures that allow for cultural activities despite potential long-term environmental changes.

Cumulative Impacts on commercial fishing and other economic uses

• Assess the long-term cumulative effects on commercial fishing, including potential habitat degradation, stock depletion, and increased/larger vessel traffic. This should include mitigation strategies to minimise impacts, such as suspended sediment control, compensatory measures, and collaboration with management agencies to support the local livelihoods.

Spatially explicit, GIS-based modelling framework

• This should integrate multiple concurrent and interacting stressors – such as sedimentation, vessel traffic, noise, dredging, and ecological fragmentation – across spatial and temporal scales. The results should inform the establishment of baseline conditions and thresholds for change, to underpin a strategic, adaptive MEL framework and enable public, ongoing evaluation of environmental condition and change.

In all cases, consideration should be shown to the cumulative impacts throughout the life of the project and to the facilitated effects of the changed future state, and changed future use of the area, as a result of the proposed development.

In addition, cumulative impacts of the project should be assessed with consideration of other impacts in the region – e.g. landside (non-dredging) sources of sedimentation to Moreton Bay – an existing and preeminent threat.

TMBF recommends the TOR requires additional information on Environmental Management and require the proponent to prepare and provide:

• A Cultural Heritage Management Plan (CHMP)
  • The Cultural Heritage Management Plan (CHMP) be developed prior to construction and final design, and not deferred.
  • It must be developed in genuine partnership with First Nations and include identification of cultural values, proposed protection mechanisms, and shared decision-making roles.
  • The CHMP should be embedded within the overall environmental management framework and not treated as a separate or secondary plan.

• An Integrated Environmental Management Framework using an Adaptive Management Approach
  • Include a summary table of proposed Environmental Management Plans (EMPs), showing which phase they apply to, their regulatory triggers, and how they interrelate (e.g. sediment and erosion control plans feeding into water quality management).
  • Provide a clear structure and timeline for preparation, approval, and implementation of all EMPs across project phases (pre-construction, construction, operation, decommissioning).
  • All EMPs must be underpinned by a clearly described adaptive management approach, incorporating thresholds and triggers for key environmental indicators (e.g. turbidity, seagrass health, species presence), real-time monitoring, reporting, and feedback loops, and pre-defined corrective actions if thresholds are exceeded. 
  • In addition the frameworks should describe transparent, public documentation of response actions and effectiveness reviews.
  • The framework should include a commitment to periodic review and update of EMPs based on monitoring data, stakeholder feedback, and new science or cumulative impact understanding.

• A Description of Governance, Roles and Responsibilities
  • Provide details of a defined project governance structure for environmental management, including lines of accountability from contractors to senior management.
  • Describe roles of Independent Environmental Monitors, auditors, and/or First Nations rangers in compliance oversight.
  • Provide information on regulatory reporting, including how reports will be coordinated and made available to the public.

Stakeholder and First Nations Involvement

All EMPs must outline how First Nations and local stakeholders will participate in design, monitoring, and review of management plans, and include cultural protocols and engagement procedures for environmental incidents affecting culturally significant areas or species.

Contents and Standards

The proponent should be required to:

• Describe EMP consistency with appropriate relevant standards (as for example) ISO 14001 Environmental Management Systems; ANZECC/ARMCANZ Water Quality Guidelines; and Queensland’s Environmental Protection Act and State Development Assessment Provisions (SDAP).
• Include consistent standard inclusions including: 
  • Objectives and performance outcomes
  • Mitigation and management measures
  • Monitoring program (indicators, frequency, methods)
  • Trigger levels and response actions
  • Reporting and review procedures.

MONITORING, EVALUATION AND REPORTING FRAMEWORK

TMBF recommends the TOR requires additional information on a Monitoring, Evaluation and Reporting Framework. All Management Plans must be consistent with a robust framework that ensures compliance with relevant regulations, transparency in evaluations and reporting, and adaptive management to respond to emerging issues. Consistent with the recommendations in the preceding sections, the proponent should address:

A Monitoring, Evaluation and Learning (MEL) framework that extends beyond technical reporting requirements to support adaptive governance and public accountability. The framework should:

• establish clearly defined, science-informed thresholds to guide action
• integrate periodic reassessment of climate-related risks
• include nature-based solutions (e.g. seagrass and mangrove restoration) as proactive management options
• provide publicly accessible, real-time or regularly updated data platforms
• be designed after a full Cultural Heritage Management Plan (CHMP) is co-designed with First Nations to reflect actions that are culturally appropriate and meaningful inclusion of First Nations knowledge systems and priorities
• be co-designed with stakeholders to ensure it is a living tool that enables the Port of Brisbane, regulators and the public to track performance against stated environmental, cultural and social commitments.

Reporting Frequency and Submission

• Regular Reporting: Specify the frequency of regular monitoring reports (e.g., monthly, quarterly) and require submission to relevant regulatory agencies and other stakeholders. Each report should summarise monitoring data, any exceedances, actions taken, and progress towards environmental objectives.
• Annual Comprehensive Reports: Commit to comprehensive annual reports that consolidate data collected throughout the year, assess trends, and evaluate the overall effectiveness of mitigation measures. The report should also include recommendations for improvements and adaptions for the following year.
• Incident and Threshold Exceedance Reports: Mandate immediate reporting to regulatory authorities for any incidents or threshold exceedances, including a detailed incident description, root cause analysis, and corrective actions taken. Define timelines for these reports and specify contact information for relevant agency notifications.

Report Formats and Accessibility:

• Standardised Format: Describe reporting via standardised format (to include clear data tables, graphs, and explanations of findings, and executive summary for a quick overview of key results)
• Public Accessibility: Describe public access to reports, including the formats that will be provided. (e.g., PDF, accessible web pages). Commit to ensuring accessibility of maps, charts, and other visual aids to illustrate spatial and temporal patterns in water quality, fauna interactions, and noise levels, allowing stakeholders to explore data in greater detail.

Independent Auditing and Verification:

• Third-Party Audits: Conduct periodic independent audits of monitoring data, methods, and reporting processes to verify compliance with regulatory standards and accuracy of data. Specify audit frequency (e.g., annually or biennially) and provide documentation of audit findings.
• Verification of Monitoring Equipment and Data: Include protocols for calibrating and verifying monitoring equipment to ensure accuracy. Regularly review monitoring methods and data collection procedures to maintain data integrity and confidence in reporting.
• Stakeholder Review Opportunities: Establish opportunities for stakeholder and regulatory agency review of monitoring reports and audit findings, with a clear process for addressing any concerns or feedback provided.

Continuous Improvement and Adaptive Management:

• • Review and Adjustment of Monitoring Program: Commit to an annual review of the monitoring program to assess effectiveness, update threshold values based on emerging data, and incorporate stakeholder feedback. Include mechanisms for adapting the monitoring approach to address new or unforeseen environmental and social impacts.

• Adaptive Management Triggers: Define specific triggers based on monitoring results that would prompt adaptive management responses. 

• Documentation of Adaptive Measures: For each adaptive management action taken, document the rationale, implementation steps, and results. Include this information in regular reports to regulatory agencies and stakeholders to demonstrate a commitment to proactive impact management.

TMBF recommends the TOR requires additional information in the Appendices to additionally require the proponent to prepare and provide (in addition to draft TOR items (a) to (d):

(e) First Nations Engagement Summary

This should be a standalone appendix detailing all engagement with First Nations groups, including:

• Traditional Owner groups consulted
• Dates and nature of consultation activities
• Key issues raised by First Nations representatives
• How these issues have been addressed or responded to in the EIS

(f) Spatial Data Register

A register of all spatial datasets used in mapping, modelling, and assessments, including:

• Data custodian and source
• Date and resolution of data
• Licensing or use restrictions
• Links to open-access or publicly available datasets, where possible

(g) Cumulative Impact Summary Table

A summary of all known or foreseeable projects within the Moreton Bay region that have been considered in cumulative impact assessments, including:

• Project name and proponent and / or sector of originating project (for example: coastal development; private sector)
• Relevant impact pathways (e.g. dredging, runoff, marine traffic)
• Assessment timeframe and any modelling assumptions
• Key interactions or compounding effects

(h) Facilitated Impacts Assessment Summary

This appendix should include a table identifying and summarising the facilitated or induced impacts (e.g. future increased shipping, development, or maintenance dredging) expected as a result of the channel enhancement project, including:

• Anticipated change in volume or type of activities
• Environmental and cultural risks
• Proposed monitoring or management responses

(i) Stakeholder Engagement Log

This appendix should include a summary and a table listing:

• All stakeholders engaged (including government, community, NGO, industry, and research organisations)
• Topics discussed or submissions received
• How feedback was incorporated (or reasons for non-inclusion)

TMBF recommends the TOR requires additional information on Matters of National Environmental Significance (MNES), requiring proponents to include in this chapter:

Explicit consideration of cumulative and multiplying impacts in Moreton Bay

The Blueprint for a sustainable Moreton Bay for people and nature (2025-2035) and other reports, plans and research outcomes consistently identify cumulative/multiplying threats such as sedimentation, coastal development, and boating activity as major pressures on MNES values such as seagrass meadows, turtle and shorebird habitat. The MNES chapter should:

• Require spatial and temporal assessment of cumulative pressures from existing and proposed developments.
• Include GIS-based cumulative impact mapping where feasible.

Commitment to engage with and incorporate First Nations knowledge and management priorities.

First Nations leadership in sea country management is well documented. The MNES chapter should:

• demonstrate how it incorporates First Nations Knowledge in assessing impacts to MNES.
• describe consultation and collaboration processes undertaken with First Nations of Moreton Bay, including consideration of any management or research plans and priorities, monitoring activities, and community initiatives.
• include a statement on Free, Prior and Informed Consent for any use of Traditional Knowledge.

Assessment of ecosystem services at risk from MNES impacts

The Blueprint and other reports, plans and research outcomes emphasise the importance of ecosystem services (e.g. shoreline protection, carbon storage, tourism and cultural value) provided by habitats like seagrass, mangroves, and shellfish reefs. The MNES chapter should 

• Include an ecosystem services impact assessment, detailing services supported by each relevant MNES.
• This assessment should include potential socio-economic and cultural losses from MNES degradation.

Provide clear guidance on the use of sedimentation modelling and climate change scenarios

Many MNES values (e.g. coral, seagrass, shorebirds) are vulnerable to sediment loads and climate-driven changes. The MNES chapter should:

• Include modelling of sediment impacts on MNES habitats under current and future climate and development scenarios.
• Justify model selection and clearly describe uncertainties and assumptions.