Background

GIICA has lodged an EPBC Act referral with the federal government arguing that the proposed Brisbane Stadium, National Aquatic Centre and related precinct works at Victoria Park/Barrambin are not likely to have a significant impact on Matters of National Environmental Significance, and is therefore seeking a decision that the project is not a controlled action under federal environment law. Save Victoria Park believes this project should be declared a controlled action, which would mean it must undergo a full federal environmental assessment.

Under the EPBC process, the referral must be published for public comment, and the Minister for the Environment and Water, Murray Watt, must consider both the referral material and public submissions before making that decision. Supporter submissions matter because this is one of the few remaining formal opportunities for the public to put contrary evidence on the record, challenge GIICA’s claim that the impacts are minor, and show the Minister that there are serious unresolved concerns about the project’s ecological, hydrological and cultural impacts.

How to Make Your Submission

The comment period for this referral is open now. Submissions take around 5 minutes. Follow the steps below to have your say.

1. Go to the following link: https://epbcpublicportal.environment.gov.au/all-notices/project-decision/?id=98ff6052-2632-f111-88b4-7c1e5262e9e4

2. Scroll down the page to the blue Make Comment button and click it.

3. On the new page, complete your name, email address and title of your comment (you choose what to write here as the title of your feedback)

4. You will be asked: “Do you consider this is a controlled action?” A controlled action means that the project will be subject to a full environmental assessment before it can proceed. Select Yes if you agree that this project should be subject to full review.

5. Next you will be asked: “Provide reasons for why you believe this is/is not a controlled action.” Copy and paste one or more of the reason paragraphs from Part 2 of this document. Ideally adapt them into your own words — a personalised submission carries more weight.

6. You will be asked: “Is your response confidential?” Select Yes or No.

7. Confirm that you have read and understand the privacy notice. Select Yes or No.

8. Confirm that you have read and understand the declaration. Select Yes or No.

9. Optionally, attach a file if you wish to provide any additional supporting information.

Sample “Reasons”

Choose one or more of the paragraphs below. Each covers a different aspect of the referral’s deficiencies. They are written in first person and can be submitted as-is or adapted in your own words.

NOTE: A PERSONALISED SUBMISSION HOLDS MORE WEIGHT SO WE RECOMMEND ADAPTING THE FOLLOWING REASONS INTO YOUR OWN WORDS.

1.  Controlled action — the case for assessment

I am writing to request that EPBC referral 2026/10472, the proposed Brisbane Stadium, National Aquatic Centre and associated precinct works at Victoria Park/Barrambin, be determined a controlled action and assessed by Environmental Impact Statement. The applicant's own report confirms that the full 99.5 hectares of Victoria Park/Barrambin is conservatively assessed as the disturbance footprint — an area encompassing the entire park. This is a 300% increase on the figures cited by the Queensland Premier and the 100 Day Review, which promised that the stadium structure would occupy less than 10% of the park and that 68% would be retained as green space. That fundamental discrepancy alone demands full assessment before any determination is made.

2.  Impacts on nationally listed threatened species

Two nationally listed threatened species were confirmed present on the site: the Grey-headed Flying-fox (Vulnerable) and the White-throated Needletail (Vulnerable). The referral concedes that resource trees used by the Grey-headed Flying-fox will be removed, yet provides no detail on which trees will be retained or cleared — making it impossible to assess the actual impact. The applicant also acknowledges that summer surveys, as conducted, are unlikely to capture flying-fox usage during winter and spring, when the species is breeding. For the White-throated Needletail, both the 2023 and 2026 ecological reports note that roosting is known to occur within the site, yet no information has been provided on which hollow-bearing trees will be affected. Where the impact of a proposed action on a threatened species cannot be assessed due to inadequate information, the precautionary principle requires a controlled action determination.

3.  First Nations cultural heritage

Victoria Park/Barrambin is currently the subject of three pending applications for permanent protection under the Federal Aboriginal and Torres Strait Islander Heritage Protection Act. On 20 February 2026, Minister Watt affirmed that there was sufficient evidence to be satisfied that parts of the site are a significant Aboriginal area. Despite this, the applicant's Matters of National Environmental Significance report contains a single sentence acknowledging the site's First Nations history, with no mention of the pending applications, the Minister's recent decision, or the significance of York's Hollow as one of Brisbane's largest historical First Nations camps. The applicant has not met the requirements of the Department's own 2023 Interim Engagement with First Nations People and Communities guidance, which requires proponents to identify relevant Traditional Owners, engage them before referral, and document how their views were considered. No consultation has been undertaken with elders who have formally lodged S10 applications. This is a direct deficiency in the referral as filed.

4.  Inadequate description of the proposed action

The referral does not contain the basic information required to assess the environmental impact of this project. It includes no site plan showing the location of the Main Stadium, National Aquatic Centre, warm-up track or associated infrastructure; no detail of trees to be cleared by number, age or diameter; no cut-and-fill volumes despite enabling works involving an estimated 300,000 cubic metres of earthworks; and no information on truck movements, construction compounds, retaining wall heights or infrastructure upgrades. Due to the site's topography — with an average 30 to 35 metre fall across it — the scale of earthworks is comparable to a large quarry operation. The Department cannot make an informed determination on the basis of a referral that omits this information, and I urge it to request further information before proceeding.

5.  Inconsistencies in the ecological assessment

The same environmental consultancy, 28 South Environmental, prepared both the 2023 Targeted Ecological Assessment Report for Brisbane City Council and the 2026 Matters of National Environmental Significance Report for the applicant GIICA — for the same site. The two reports reach starkly different conclusions. The 2023 report described Victoria Park/Barrambin as an unusual inner-city biodiversity asset with mature habitat trees, 41 hollow-bearing trees, 34 ancient/veteran trees exceeding 1,200 mm diameter, and strong potential for rewilding. The 2026 report describes the same site as a highly disturbed, non-remnant landscape with limited ecological value. The 2026 report also altered the tree survey baseline, dropping the measurement threshold to inflate the total tree count from 2,426 to 4,536 by including juvenile plantings — statistically diluting the significance of the mature, hollow-bearing canopy. These inconsistencies undermine the reliability of the referral's ecological conclusions and warrant independent assessment.

6.  Community consultation was not meaningful

In 2023, the Brisbane City Council completed a four-year community consultation process involving more than 80,000 participants, resulting in an approved Master Plan for Victoria Park/Barrambin that prioritised rewilding, ecological restoration and celebration of First Nations heritage. That plan has now been set aside in favour of the proposed Olympic infrastructure, yet the community consultation submitted with this referral provided participants with no information on the scale of impact — no parkland footprint figures, no tree loss estimates, no earthworks volumes, and no comparison with the 2023 Master Plan. Sentiment research conducted in mid-2025 cannot be considered meaningful community consultation on a proposal whose full scope — 99.5 hectares of disturbance — was never disclosed to participants. I urge the Minister to require full public consultation on the actual scope of this proposal before any determination is made.

7. Inadequate Analysis of Hydrology and Hydrogeological Assessment

York's Hollow is fed by underground water (groundwater) flowing from aquifers beneath the park; it is not simply a stormwater pond. Barrambin Springs is the only functioning natural spring system left in Brisbane's CBD, and it has deep significance to First Nations people who relied on it for thousands of years. Building a stadium over the park's open land would prevent rainfall from soaking into the ground and recharging these underground water sources, permanently destroying the springs. An impact this irreversible should be assessed by an Environmental Impact Assessment.