In March 2019, TMBF provided a submission to the State Government Department of Environment concerning the Draft Guidelines for the Environmental Impact Statement on the Toondah Harbour (Cleveland, Queensland). Key points that TMBF raised in that submission include:

the impact of sea-level rise and related impacts on the extinction of habitats cause by the hardening of aquatic and terrestrial habitats;

the impacts on wetlands (as per the Ramsar agreement);

the importance of ongoing consultation with the Traditional Custodians of the land and seascape;

the importance of assessing changes in access, opportunities and catch (including impacts on prawns, crabs and finfish) for commercial, recreational and indigenous fishers;

considering additions to the list of species listed as Vulnerable; and

consideration of the remedies and provisions available should the developer fail in their obligations to adopt mechanisms to ameliorate environmental impacts.