2208-30467 SRA - Information request

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            Action:
            Provide a response to State code 25 (SDAP version 3.0) in its entirety, identifying how the
            proposed development meets each performance outcome (PO).

            The latest version of State code 25 is available at:
            https://planning.statedevelopment.qld.gov.au/planning-framework/state-assessment-and-
            referral-agency/state-development-assessment-provisions-sdap


PO1, PO2 and PO4 of State code 25 – Connectivity, fragmentation and safe koala movement
3.          Issue:
            The application does not demonstrate how the proposed development supports connectivity
            between highly connected patches of mapped KHA. Specifically, the application proposes
            to retain trees throughout the impact area; however, insufficient information has been
            provided to demonstrate that koalas will be able to move through the site around / under the
            proposed cabins and walkways.

            The application material includes proposed planting of native understorey vegetation to
            improve connectivity and fauna refuge opportunities; however, the Bushfire Hazard
            Assessment and Mitigation Plan requires understorey and groundcover vegetation to be
            managed on an ongoing basis, with groundcover kept to a maximum of 100mm.

            The application does not demonstrate how fragmentation of patches of mapped KHA will be
            prevented. Specifically, from the proposed location of the built infrastructure on site, it
            appears the development will fragment retained patches of KHA from one another and will
            fragment KHA north of the site from KHA south of the site.

            Although the application proposes to elevate buildings and walkways, insufficient
            information has been provided to demonstrate that safe koala movement will be supported
            (e.g., is there evidence in the literature that koalas can and will safely and easily move
            under elevated structures such as those proposed?).

            The application does not demonstrate that the proposed development will not compromise
            koala safety through impediments that restrict movements between highly connected
            patches of mapped KHA.

            Although the application proposes to retain individual trees throughout the site, the
            development footprint extends nearly the entire length and width of the site, with built
            infrastructure scattered throughout the area, significantly reducing the permeability of the
            landscape to koalas and interrupting connectivity between existing KHA north and south of
            the site.

            Action:
                 Provide a plan in digital format that identifies the location of all impacts on
                    connectivity between highly connected patches of mapped KHA; and the locations
                    of all measures proposed to support connectivity (e.g., koala friendly fencing, fauna
                    crossing measures, etc.).
                 Provide clarification regarding how planting of native understorey species will be of
                    benefit, considering the bushfire management report requires the understorey and
                    groundcover to be maintained on an ongoing basis.
                 Provide further information, prepared by a suitably qualified ecologist, which


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                      demonstrates how the proposed elevation of the cabins and boardwalks will be
                      sufficient for maintaining connectivity and safe koala movement through the site
                      (e.g., results of a literature review).
                     Provide further information, prepared by a suitably qualified ecologist, which
                      demonstrates how the impediments to safe movement proposed by the
                      development will not restrict safe koala movement between highly connected
                      patches of mapped KHA.


PO3 of State code 25 – Koala safety from clearing and construction activities
4.          Issue:
            The application does not include a Koala Management Plan, or sufficient information to
            demonstrate that PO3 has been met.

            Action:
            Provide a Koala Management Plan which includes the following (as a minimum):
                 all potential risks to koalas from clearing and construction activities proposed on
                    site, including vegetation clearing, earthworks, plumbing and drainage works and
                    building works
                 all potential risks to koalas from the proposed future use of the site
                 all management measures that will be implemented to address the risks
                 the process and measures to address accidental injury or death of koalas
                 stop work procedures in the event a koala is identified as sick, injured, killed or
                    orphaned on the site
                 procedures for pre-start machinery checks
                 the process for implementing the management plan including:
                         o identifying the person responsible for implementing the plan (e.g., site
                              supervisor, foreman)
                         o the process for training all contractors working on the site to comply with
                              the plan.


PO5 of State code 25 – Avoidance, minimisation and mitigation of impacts on MSES
5.          Issue:
            The application has not demonstrated avoidance of impacts to matters of State
            environmental significance (MSES), as the majority of the site is intended to be developed.

            The application seeks to minimise and mitigate impacts to MSES through the retention of
            individual trees throughout the development impact area, constructing cabins and walkways
            elevated off the ground to allow minimal disturbance to tree roots during construction, and
            through proposed weed control and rehabilitation of the entire site. However, the
            application does not include a weed management plan or rehabilitation plan; nor has
            sufficient information been provided to demonstrate that the elevation of the buildings will
            appropriately minimise the impacts on MSES.

            Furthermore, although the application proposes to retain 276 trees throughout the impact
            area, information included in the Bushfire Hazard Assessment and Mitigation Plan provides
            that the entire impact area would be subject to significant ongoing disturbance of ground
            and understorey vegetation layers through limitations on shrub layer height, mowing and
            removal of leaf litter and woody debris. It is known that structural complexity is important for
            supporting ecological functionality and there is evidence that koalas prefer structurally


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             complex vegetation. SARA considers that although the proposal seeks to retain mature
             trees, ongoing management of the site will reduce the habitat value and ecological function
             of the site.

             The application material has provided a tree retention and removal plan; however, has not
             quantified the number of non-juvenile koala habitat trees (NJKHTs) proposed to be removed
             and retained.

             The application material proposes to retain 276 trees throughout the impact area; however,
             SARA notes that vegetation clearing exemptions relating to bushfire management and
             protection of infrastructure may apply to the site if the proposal was approved. This could
             potentially result in almost the entire site being cleared of vegetation. This has not been
             addressed in the application material.

             Action:
                  Provide an amended tree retention and removal plan which clearly identifies the
                     number of NJKHTs proposed to be retained and removed.
                  Provide further information regarding how retained vegetation is intended to be
                     protected from future development, including exempted development relating to
                     bushfire management and asset protection (e.g., through a legal protection
                     mechanism such as a covenant).
                  Provide a rehabilitation and weed management plan.
                  Calculate the significant residual impact that would occur as a result of the
                     proposed development.



How to respond
You have three months to respond to this request and the due date to SARA is 29 November 2022.

You may respond by providing either: (a) all of the information requested; (b) part of the information
requested; or (c) a notice that none of the information will be provided. Further guidance on responding to
an information request is provided in section 13 of the Development Assessment Rules (DA Rules).

It is recommended that you provide all the information requested above. If you decide not to provide all
the information requested, your application will be assessed and decided based on the information
provided to date.

You are requested to upload your response and complete the relevant tasks in MyDAS2.

As SARA is a referral agency for this application, a copy of this information request will be provided to the
assessment manager in accordance with section 12.4 of the DA Rules.




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If you require further information or have any questions about the above, please contact Danika Cowie,
Principal Planning Officer, on (07) 5352 9776 or via email [email protected] who will
be pleased to assist.

Yours sincerely




Caroline Plank
Principal Planning Officer

cc        Noosa Shire Council, [email protected]

 Development details

 Description:                Development permit                  Material change of use for short-term accommodation (16 Eco-Cabins)
                                                                 and new lagoon pool

 SARA role:                 Referral agency

 SARA trigger:              Schedule10, Part 10, Division 3, Subdivision 3, Table 1 (Planning Regulation 2017)
                            Development interfering with koala habitat in SEQ

 SARA reference:            2208-30467 SRA

 Assessment criteria:       SDAP Version 3.0
                            State code 25: Development in South East Queensland koala habitat areas




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