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Ecological Assessment Technical Memorandum

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Our Ref: 24-0565E
12/03/2026


ATTN: Peter McAvoy
McAvoy Management
Via email: [email protected]


Dear Peter,


RE:         Ecological Assessment Technical Memorandum to Accompany a
            Reconfiguration of Lot Application to Noosa Shire Council
            Sunshine Butterflies, 468-472 McKinnon Drive, Cooroibah



1. Introduction
1.1        Preamble
Therefor Group Pty Ltd was engaged by Peter McAvoy (hereafter referred to as ‘the
client’) to prepare an ecological technical memorandum addressing the potential
environmental constraints associated with the proposed development application for
reconfiguring a lot (1 into 2 and access easement) on land located at 468-472 McKinnon
Drive, Cooroibah formally described as Lot 1 and 2 on SP199340. Lot 1 on SP199340 is
included for the purpose of provided access and services via Easement C on SP199340
to the proposed lots. The subdivision solely relates to Lot 2 on SP199340 (hereafter
referred to as the ‘subject site’). The site is approximately 3.9 hectares (39,050 m2) in
area and is located within the Noosa Shire Council (NSC) Local Government Area (LGA).
                                                                                                                  Brisbane
This Assessment will provide:                                                                                     Turrbal and Yuggera Country
                                                                                                                  Longland Place, Level 2
            ▪     The current environmental regulatory constraints associated with the                            76 Skyring Terrace
                  subject site.                                                                                   Newstead QLD 4006
                                                                                                                  PO Box 436 New Farm QLD 4005
            ▪     The environmental values associated with the site.
                                                                                                                  Ph +61 7 3666 5200
            ▪     The relevant regulatory pathways to achieve compliance with relevant                            [email protected]
                  Commonwealth, State and Local regulatory requirements.
                                                                                                                  Sunshine Coast
            ▪     Recommendations in respect to further actions, studies, investigations,                         Gubbi Gubbi Country
                  permits or approvals that may be required in association with the future                        Building 1
                  development application.                                                                        30 Chancellor Village Blvd
                                                                                                                  Sippy Downs QLD 4556
A summary of the site details and relevant ecological development constraints within                              Ph +61 7 5294 0374
this response is outlined in Table A.i                                                                            [email protected]


ii
  Therefor Group has conducted this assessment based on the interpretation of government guidelines and           Gold Coast
Australian standards in assessing the anticipated risk associated with this development. The work was             Kombumerri Country
conducted, and report prepared with reliance on data and information available to Therefor Group and as
such Therefor Group holds no responsibility for inconsistencies and/or inaccuracies based upon this data.         Level 2
Whilst the author has utilised best practice and endeavours to ensure that the information contained herein is    14 Edgewater Court
valid and comprehensive, Therefor Group makes no representations or warranties about its accuracy,                Robina QLD 4226
reliability, completeness or suitability for any particular purpose and disclaims all responsibility and all      Ph +61 7 5636 9943
liability (including without limitation, liability in negligence) for all expenses, losses, damages (including
indirect or consequential damage) and costs which may be incurred as a result of the information being            [email protected]
inaccurate or incomplete in any way and for any reason. The report is tailored for the issue of interest and as
such the findings herein are not to be applied elsewhere. The document may only be used for the purposes for
which it was commissioned and in accordance with the Terms of Engagement for the commission.                      ABN 61 147 343 084
Unauthorised use of this document in any form whatsoever is prohibited                                            ACN 147 343 084



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Page 2

Table A - Site Summary Details
 Item                      Details

 Address                   468-472 McKinnon Drive, Cooroibah, QLD, 4565

 Plan Detail               Lot 2 onSP199340

 Total Area                39,050 m2

 Council Zoning            Rural Residential Zone
                           ▪    Essential Habitat

                           ▪    Regulated Vegetation – Category B

                           ▪    Waterway Barrier Works
 State Regulatory
 Matters                   ▪    Core Koala Habitat Area

                           ▪    Koala Priority Area

                           ▪    High Risk Protected Plants Trigger Area

 Local Regulatory
                           ▪    Area of Biodiversity Significance
 Matters
                           ▪    Waterway and Riparian Buffer Area


To inform this correspondence, the following study methodology was employed:
           ▪   Desktop interrogation of relevant Local environmental overlays, codes and data sources.

           ▪   Review of aerial imagery.

           ▪   Literature review of publicly available related materials, existing studies, and relevant information.

           ▪   Review of existing approvals related to the existing activity.

We note the following assumptions and limitations:
           ▪   It is based on the most up-to-date information available at the time of writing.

           ▪   All measurements are reliant upon the accuracy of public, online aerial photography and are not survey
               accurate.


1.2        Subject Site
The subject site is located at 468-472 McKinnon Drive, Cooroibah, within the NSC. The site has a total area of
approximately 3.9 hectares and is situated 11km west from Noosa Headlands.
The site is irregular in shape with a private road network located in 468 Mckinnon Drive that directly connects to
McKinnon Drive. The Noosa Plan 2020 (NP2020), the local government instrument relevant to assessment of
development on the site, maps the site as Rural Residential Zone. Surrounding land uses include rural residential zoned
properties on acreage, with the Tewantin National Park located South of McKinnon Drive.
The site comprises a residential dwelling in the central extent of the site with associated ancillary structures including a
swimming pool and car shed. The site additionally holds horse stables in the central southern extent of the site. The
vegetation communities within the subject site comprise regrowth vegetation bordering the site with a regularly
maintained grassland and cultivated gardens surrounding the dwelling and driveway. A dam is located in the
northeastern extent of the site and connects to a mapped waterway traversing the site boundary in a northeasterly
direction.
Refer to Figure 1 for aerial imagery of the site.




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FIGURE 1 - AERIAL IMAGE OF STUDY
AREA

Sunshine Butterflies, 468-472
McKinnon Drive, Cooroibah

Noosa Shire Council

LEGEND

Subject Site ===}

 

Plan of Reconfiguration
Roads and Tracks <=>

Cadastral

CLIENT
Peter McAvoy
DRAWING NO. CRS PROJECTION
24-0565E/BF MGA2020
DATE DRAWN UTM ZONE
12.02.2026 Zone 56
0 15 30 45 60 75m

 

Page 4

2. Proposed Development Details
The Development Application seeks approval for a Reconfiguring a Lot (1 lot into 2 lots plus an access easement). The
application is to be over Lots 1 and 2 on SP199340. Lot 1 on SP199340 is included for the purpose of provided access and
services via Easement C on SP199340 to the proposed lots. The subdivision solely relates to Lot 2 on SP199340. For the
purposes of this report, it is hereafter referred to as the site.
The site contains an existing dwelling house and outbuildings, all which support the land use located at 468 Mckinnon
Drive, Cooroibah (the adjoining site). Located on the adjoining site is ‘Our Backyard,’ a community facility which provides
a range of programs, support services, and activities for those with disabilities. ‘Our Backyard’ supports 96 members each
week offering a range of daily recreational, educational and life skill programs all which create a sense of purpose and
belonging. Sunshine Butterflies own both sites.
There is a demand for disability support services within the Noosa Shire LGA. Sunshine Butterflies intend to expand their
facilities in response to the demand. Reconfiguring the site has been proposed to provide two lots which can facilitate
future development and allow Sunshine Butterflies to expand their facilities as they require.



3. Assessment Scope and Objectives.
This assessment has been prepared to address State and Local ecological constraints relevant to the proposed lot
reconfiguration, with the objective of identifying and evaluating any potential ecological impacts associated with the
establishment of new property boundaries should the application be approved.



4. Subject Site Ecology
Assessment of the subject site’s ecological features, processes and values was undertaken in accordance with the Noosa
Plan 2020 Schedule 6 Planning scheme policies SC6.4 PSP3 Ecological assessment guidelines. The assessment utilised
publicly available database records, mapping, aerial imagery and published literature, in addition to ground truthing and
field assessment (undertaken on 20th January 2026 by a Therefor Group Ecologist) to identify significant vegetation
communities, flora and fauna species, habitat features, connectivity and other areas of conservation value (refer to
Figure 2 Vegetation Community Extent).
Vegetation Community 1 (Non-regulated Vegetation) Refer Plate 1 - The predominate community within the subject site
contains a mown groundcover of exotic grasses (Digitaria didactyla) and various sealed and unsealed driveways/access
tracks in an informal network. The shrub layer consists of various exotic plantings dominated by Syagrus romanzoffiana
and Syzygium sp., typically confined to landscaped garden beds. The canopy layer is sporadic, with individual specimens
of Syagrus romanzoffiana and Eucalyptus microcorys present. The following images illustrate the vegetation community
observed during the field survey.
Vegetation Community 2 (Non-regulated Vegetation) Refer Plate 2 – The existing boundary of the subject site holds an
intact mature canopy layer comprising Melaleuca quinquenervia and various Eucalypt and Acacia species (Eucalyptus
propinqua, Eucalyptus tereticornis, Acacia spp.). A shrub layer consists of cultivated riparian species associated with
cultivated drainage systems and dam. The ground layer is minimal, consisting of sporadic native grass cover and mulch
consistent with cultivated gardens. The ends of the proposed boundary encroaches within this vegetation community.
The following images illustrate the vegetation community observed during the field survey on 20 January 2026.




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 Plate 1 – Vegetation Community 1




 Plate 2 – Vegetation Community 2




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Page 6

 

 

 

FIGURE 2 - VEGETATION
COMMUNITIES

Sunshine Butterflies, 468-472
McKinnon Drive, Cooroibah

Noosa Shire Council

LEGEND

Subject Site ==]

 

Plan of Reconfiguration
Roads and Tracks <=>

Cadastral

Vegetation Communities
Vegetation Community 1 [~~]
Vegetation Community2 (8

CLIENT
Peter McAvoy
DRAWING NO. CRS PROJECTION
24-0565E/BF MGA2020
DATE DRAWN UTM ZONE
12.02.2026 Zone 56
0 15 30 45 60 75m

 

therefor

GROUP

Page 7

5. Subject Site Constraints
5.1       Regulatory Environment – State-Level Constraints
Regulated Vegetation
The Vegetation Management Act 1999 (VMA) regulates vegetation clearing in Queensland. Under the VMA, regulated
vegetation management mapping developed for the subject site (Figure 3) indicates that vegetation located within the
northwestern extent of the land parcel (272m2) is mapped as Category B Remnant vegetation.
Concurrent to the regulated vegetation polygon, an area mapped as Essential Habitat for threatened (endangered or
vulnerable) wildlife is nominated. Specifically, the Essential habitat nomination is provided to recognize the presence of
appropriate habitat for Phascolarctos cinereus (Koala).
The new boundary line traversing the central extent of the subject site is not located in close proximity to regulated
vegetation and is not anticipated to impact existing mapped areas.
Regional Ecosystem Mapping
Regional Ecosystems (RE) mapping describes the vegetation communities within a bioregion, defined by unique geology,
landform, and soil characteristics. Technical descriptions of individual ecosystems provide more detailed information
regarding communities’ structure and floristic composition.
The RE mapping sourced from the Queensland Herbarium indicates the site contains one (1) regional ecosystem (Figure
4). A total of approximately 272m2 of remnant vegetation along the northwestern boundary is mapped as endangered
Regional Ecosystem (RE) 12.5.2 which is described as Corymbia intermedia, Eucalyptus tereticornis open forest on
remnant Tertiary surfaces, usually near coast and on deep red soils. The remaining 25,800m2 of site is mapped as non-
remnant Category X vegetation under the VMA. As aforementioned, the new boundary line traversing the central extent of
the subject site is not located in close proximity to regional ecosystems and is not anticipated to impact existing mapped
areas.
Koala Habitat Area Mapping
Koala habitat and priority areas are incorporated into Queensland’s land-use planning framework, the Planning
Regulation 2017, which restricts vegetation clearing within Koala Priority Areas and regulates development in Koala
Habitat Areas. Overlays relating to the protection of koalas and koala habitat, which may constrain development, include:
      •        Koala priority areas;
      •        Core koala habitat areas;
      •        Locally refined koala habitat areas; and
      •        Koala broad hectare areas.
As demonstrated in Figure 5 the subject site is mapped as containing approximately 272m2 of Core Koala Habitat Area
(KHA) along the northwestern boundary associated with intact remnant vegetation within north of the subject site. It is
acknowledged that the site is mapped entirely as Koala Priority Area (KPA).
Whilst the polygon representing KHA is located on a pre-development site boundary and no matter associated with the
development application is proposed to interfere with the mapped habitat area, (thus avoiding the prohibited
development condition provided within Schedule 10, Part 10, Division 2 of the PR 2017) Schedule 11 Part 2 Section 3 of
the Planning Regulation 2017 states that Part 2 Section 4 (Assessment Benchmarks) is applicable for an application for
RoL located within a PKA that is not interfering with KHA. As such the Section 4 Assessment Benchmarks must be
addressed for the application.

Protected Plants Flora Survey Trigger Mapping
The flora survey trigger map identifies high-risk areas where endangered, vulnerable, or near-threatened (EVNT) native
plants are present or are likely to be present. Within the subject site, vegetation adjoining the northern boundary
including that congruent with the regulated vegetation polygon detailed above, is mapped as a High-Risk Area under the
Nature Conservation Act 1992.
As the proposed development footprint (i.e. the proposed new boundary delineating Proposed Lot 1 and 2) is limited to
the central section of the predevelopment land parcel and no interference with the trigger area will be resultant from
development approval. However, due consideration to the potential impact buffer (i.e. 100m) from the development




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Page 8

footprint is warranted where indirect impacts of the development may affect the persistence of EVNT species in the
vicinity of the development footprint.


Waterway Barrier Works
The Fisheries Act 1994, regulated by the Department of Agriculture, Fisheries and Forestry (DAFF), establishes the
framework for regulating and protecting areas of importance for fish habitat and marine plants. Waterways for Waterway
Barrier Works (WWBW) mapping identifies waterways providing for fish passage (and habitat), which are considered
MSES under the Environmental Offsets Act 2014. Operational works involving constructing or raising waterway barriers in
fish habitats are likely to trigger referrals to the State Assessment and Referral Agency (SARA) for assessment against State
Code 18. As demonstrated in Figure 6, one (1) low order fish passage is located in the northeast boundary of the site. The
stream traverses from the northeast and terminates just within the subject site, feeding into the existing dam. No
interference with the waterway is proposed under the development application and no assessment against either
acceptable development definitions for waterway barrier works pursuant to the planning regulation nor the State
Development Assessment Provisions is required.



5.2       Regulatory Environment – Local-Level Constraints
Pursuant to the NP2020, the site is mapped as containing several subcategories of the Environmental Significance
Overlay. The purpose of the Environmental Significance Overlay, as detailed within the City Plan, is to identify and protect
matters of environmental significance and ensure development is consistent with, and contributes to, the achievement of
the objectives of the Our Natural City Strategy. The following Environmental Significance subcategory overlays and
relevant performance outcomes have been identified within the subject site:
Biodiversity, Waterways and Wetlands Overlay – Area of Biodiversity Significance
Vegetation located along the boundary of the subject site is mapped as Areas of Biodiversity Significance under the
NP2020 Biodiversity, Waterways and Wetlands Overlay.
Biodiversity, Waterways and Wetlands Overlay – MSES Environmental Values
The subject site is mapped under the MSES Environmental Values subcategory of the NP2020 Biodiversity, Waterways and
Wetlands Overlay. Environmental Significance – Vegetation Management Overlay. This mapping is in association with
state mapped Category B regulated vegetation within the northwestern extent of the site. This vegetation is mapped as
the endangered regional ecosystem (RE) 12.5.2, described as Eucalypt open forest on remnant Tertiary surfaces, usually
near coast and on deep red soils.
Biodiversity, Waterways and Wetlands Overlay – Waterway and Riparian Buffer Area
Pursuant to the Biodiversity, Waterways and Wetlands Overlay, a MLES mapped waterway and Riparian Buffer Area is
located in the northeastern boundary and traverses northeast of the subject site. The stream terminates at the dam
located in the northeastern extent of the site. Refer to Figure 7.




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Page 9

 

 

 

FIGURE 3 - REGULATED VEGETATION
& ESSENTIAL HABITAT MAPPING

Sunshine Butterflies, 468-472
McKinnon Drive, Cooroibah

Noosa Shire Council

LEGEND

150m Buffer Area. ===
Subject Site ==
Plan of Reconfiguration ———
Roads and Tracks <>

Cadastral

Essential Habitat

 

Regulated Vegetation
Category8 (NN
Category [7

CLIENT
Peter McAvoy
DRAWING NO. CRS PROJECTION
24-0565E/BF MGA2020
DATE DRAWN UTM ZONE
12.02.2026 Zone 56
0 15 30 45 60 75m

 

A therefor

GROUP

Page 10

FIGURE 4 - REGIONAL ECOSYSTEM
MAPPING

Sunshine Butterflies, 468-472
McKinnon Drive, Cooroibah

Noosa Shire Council

LEGEND

150m Buffer Area ==]
Subject Site ==
Plan of Reconfiguration. ———

Roads and Tracks =>

Cadastral

Regional Ecosystems
Remnant (Endangered) [i

Regrowth (Endangered) [|

CLIENT
Peter McAvoy
DRAWING NO. CRS PROJECTION
24-0565E/BF MGA2020
DATE DRAWN UTM ZONE
12.02.2026 Zone 56
| O
0 15 30 45 60 75m

 

therefor

GROUP

 

 

Page 11

FIGURE 5 - KOALA HABITAT MAPPING

Sunshine Butterflies, 468-472
McKinnon Drive, Cooroibah

Noosa Shire Council

LEGEND

Buffer Area P=]
Subje eal
‘onfiguration. ———
ls and Tracks <=>
Cadastral
re Koala Habitat Areas
Regrowth
Remnant (0)
jority Area (ZZ)
CLIENT
Peter McAvoy
‘| DRAWING NO. CRS PROJECTION
4  24-0565E/BF MGA2020
DATE DRAWN UTM ZONE
4 12.02.2026 Zone 56

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Page 12

FIGURE 6 - WATERWAY BARRIER
WORKS

Sunshine Butterflies, 468-472
McKinnon Drive, Cooroibah

Noosa Shire Council

LEGEND

Subject Site ===]

Plan of Reconfiguration

 

Roads and Tracks C2

Cadastral

Waterway Barrier Works

low ———

CLIENT
Peter McAvoy
DRAWING NO. CRS PROJECTION
24-0565E/BF MGA2020
DATE DRAWN UTM ZONE
12.02.2026 Zone 56
| O
0 15 30 45 60 75m

 

therefor

GROUP

 

 

Page 13

FIGURE 7 - NP2020 BIODIVERSITY,
WATERWAYS AND WETLANDS OVERLAY

Sunshine Butterflies, 468-472
McKinnon Drive, Cooroibah

Noosa Shire Council

LEGEND

Subject Site ===]
Plan of Reconfiguration
Roads and Tracks
Cadastral
NP2020 Area of Biodiversity Significance
NP2020 Ripiarian Area Buffer

NP2020 Waterways

CLIENT

Peter McAvoy

DRAWING NO. CRS PROJECTION
24-0565E/BF MGA2020

DATE DRAWN UTM ZONE
12.02.2026 Zone 56

O

 

Page 14

6. Discussion
6.1           Matters of State Ecological Significance
As aforementioned, the northwestern extent of the subject site is mapped as under the Regulated Vegetation, Regional
Ecosystem and Koala Habitat Mapping. The proposed reconfiguration has been configured to be located wholly outside
areas of mapped MSES on site, thus retaining mapped biodiversity value and existing ecological services on the site.
Notwithstanding, the complete avoidance of impacts associated with State regulatory constraints (including those
associated with potential consequential clearing outcomes) some consideration to the buffer areas to these constrained
areas is valid for assessment. Further discussion to these matters is provided below noting that no further assessment is
required for matters associated with:
               ▪   Regulated vegetation pursuant to the VMA 1999; and

               ▪   Waterway Barrier Works pursuant to the Fisheries Act 1994.



Planning Regulation 2017 – Koala Habitat in SEQ Region
As identified previously, the subject site is mapped entirely within a Koala Priority Area (KPA) and contains Koala Habitat
Areas (KHA). Whilst the proposed development has adopted a principle of impact avoidance and no direct or indirect
impacts associated with the new boundary configuration will result (including those known to cause consequential
clearing), Schedule 11 Part 2 of the PR 2017 is applicable where development is to occur on a premises in koala priority
areas that is not interfering with koala habitat areas including for development associated with a RoL application.
Given the condition applies to the proposed development, Table B below provides our response to the Part 2 section 3
Assessment Benchmarks demonstrating compliance.
Table B - Compliance with PR2017 Schedule 11 Part 2 Assessment Benchmarks
 PR Clause         Assessment Benchmark                                 Response
                   The following matters are assessment                 Complies
                   benchmarks for the development— (a) the
                   development provides, on the premises, the safe      No Koala Habitat on the premises will be impacted by the
 4(1)(a)(i)
                   koala movement measures necessary to                 proposed reconfiguration nor will consequential clearing
                   maximise the safe movement of koalas— (i)            impacts result from the proposed reconfiguration. As such,
                   within a koala habitat area on the premises;         connectivity is maintained within the koala habitat area.
                                                                        Not Relevant

                                                                        The configuration of Koala Habitat areas on and around the
                                                                        subject site can be generally described as one large contiguous
                                                                        habitat area directly adjoining the northern site boundary
                                                                        (inclusive of the circa 200m2 area traversing the site boundary)
                                                                        and another large contiguous area located to the south of
                                                                        McKinnon Drive. The two areas are currently connected by an
                   The following matters are assessment                 intact corridor of significant width (circa 280m) located at its
                   benchmarks for the development— (a) the              nearest point approximately 75m from the sites eastern most
                   development provides, on the premises, the safe      boundary.
                   koala movement measures necessary to                 Interpretation of the clause requires a development to provide
 4(1)(a)(ii)
                   maximise the safe movement of koalas— (ii)           connection to Koala Habitat Areas where any existing area of
                   between a koala habitat area on the premises         koala habitat (on the premises) is within 200m of a second intact
                   (the first area) and a koala habitat area or         koala habitat area. The existing configuration of KHA provide
                   ecological corridor within 200m of the first area;   only a single complying scenario where the clause could be
                                                                        interpreted to be relevant and is related to the intact corridor
                                                                        approximately 75m from the sites easternmost boundary.
                                                                        However, it is noted that the distance between the Koala habitat
                                                                        on the premises and this corridor exceeds 200m and as such can
                                                                        be eliminated from compliance requirements relating to
                                                                        provision of connectivity.
                                                                        The southern area of koala habitat identified is separated from
                                                                        the Koala habitat on the premises by a distance of approximately




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                                                                      270m and as such compliance with the assessment benchmark
                                                                      is not considered as necessary or relevant to the development
                                                                      application.
                                                                      Complies

                                                                      The proposed reconfiguration provides for only one new
                                                                      boundary to be established. The new boundary to be created is
                (1) The following matters are assessment
                                                                      located a distance greater than 50m at its nearest point to any
                benchmarks for the development— (b) either— (i)
                                                                      retained Kola Habitat Area. As such the development
 4(1)(b)(i)     each building, structure or works associated with
                                                                      application is considered as compliant to the clause. Further
                the development is at least 50m from a koala
                                                                      extension and consideration to indirect impacts of the
                habitat area;
                                                                      application where a structure is created as a result of the
                                                                      application also conforms with the assessment. Any structure
                                                                      created will be located within proposed Lot 2 that in its entirety
                                                                      is greater than 50m from an intact Koala Habitat Area.
                                                                      Complies
                (1) The following matters are assessment
                benchmarks for the development— (b) either— (ii)      The development complies with the assessment benchmark of
 4(1)(b)(ii)
                the development complies with each of the             4(1)(b)(i) and as such 4(1)(b)(ii) is not applicable and further,
                criteria stated in subsection (2)                     compliance with assessment benchmarks associated with
                                                                      subsection 2 are not required.
                (2) For subsection (1)(b)(ii), the criteria are as    Not Relevant
                follows— (a) any change to the condition of soil as
 4(2)(a)
                a result of the development does not adversely        Not applicable. Compliance with Subsection (1)(a) and
                affect a koala habitat area;                          Subsection 1(b)(i) is achieved.
                (2) For subsection (1)(b)(ii), the criteria are as    Not Relevant
                follows— (b) any alteration of hydrological flows
 4(2)(b)
                as a result of the development does not adversely     Not applicable. Compliance with Subsection (1)(a) and
                affect a koala habitat area;                          Subsection 1(b)(i) is achieved.
                (2) For subsection (1)(b)(ii), the criteria are as
                                                                      Not Relevant
                follows— (c) any landscaping associated with the
 4(2)(c)        development that involves planting non-native
                                                                      Not applicable. Compliance with Subsection (1)(a) and
                vegetation does not adversely affect a koala
                                                                      Subsection 1(b)(i) is achieved.
                habitat area;
                (2) For subsection (1)(b)(ii), the criteria are as
                                                                      Not Relevant
                follows— (d) the development does not adversely
 4(2)(d)        affect a koala habitat area by resulting in the
                                                                      Not applicable. Compliance with Subsection (1)(a) and
                increased growth or spread of weeds in the koala
                                                                      Subsection 1(b)(i) is achieved.
                habitat area;
                (2) For subsection (1)(b)(ii), the criteria are as
                                                                      Not Relevant
                follows— (e) a building, structure or works
 4(2)(e)        associated with the development is located to
                                                                      Not applicable. Compliance with Subsection (1)(a) and
                minimise the amount of vegetation required to be
                                                                      Subsection 1(b)(i) is achieved.
                cleared for safety purposes



Nature Conservation Act 1992
The subject site is partially mapped as a High-Risk Area under the Protected Plants Flora Survey Trigger Map, with
approximately 200m2 located in the northwestern portion of the site (congruent with KHA and Regulated Vegetation
polygons. Desktop and field surveys were conducted within and adjacent to the proposed development footprint, and no
protected plants listed as Endangered, Vulnerable, or Near Threatened (EVNT) under the Nature Conservation Act 1992
were identified.
Whilst the proposed reconfigured boundary is located within 100m of the high risk area, no action associated with this
development application is proposed that would potentially affect the presence of EVNT taxa and further, no species
considered as EVNT taxa have been identified,
Consequently, a Protected Plant Survey permit is not considered to be required prior to establishment and sealing of the
proposed lot reconfiguration.




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6.2       Matters of Local Ecological Significance
Vegetation along the existing subject site boundary is mapped as Areas of Biodiversity Significance under the NP2020
Biodiversity, Waterways and Wetlands Overlay. With consideration to the proposed reconfiguration, it is integral to
consider that only one new boundary is to be established under the proposal running east-west centrally through the
existing land parcel. As such, potential indirect impacts from the application are wholly limited to those indirect effects
related to consequential clearing outcomes (i.e. exempt or accepted development scenarios that allow clearing for
boundary line maintenance, bushfire management and / or fencing allowances).
With consideration to the potential accepted development or exempt clearing potential associated with the site that
would result from lot reconfiguration the following must be considered.
          ▪    Essential Management clearing for bushfire risk reduction purposes. The establishment of a necessary fire
               management line to a maximum width of 10m is considered accepted development (operational work)
               pursuant to the PR2017 pursuant to Schedule 21 of the PR2017 and additionally, pursuant to Schedule 6 of
               the PR2017, clearing of this nature cannot be made assessable development by a local categorising
               instrument. It is noted that a Bushfire Hazard Assessment and Management Plan has been prepared to
               accompany the development application in which appropriate mitigation strategies have been identified.
               Within this plan no requirement for clearing to establish firebreaks has been recommended. Given the
               bushfire management plan will represent an ‘on title’ obligation binding the future landholder to the
               recommendations within, it would not be considered that adoption of the Essential Management firebreak
               exemption would be necessary and as such the condition allowing for its use to clear vegetation cannot be
               achieved. Given the above the proposed reconfiguration will not result in consequential clearing
               associated with essential management purposes.

          ▪    Installation of fences (outside of riparian buffers) allowing clearing up to 5m in width pursuant to the
               definition of exempt development under the Noosa Plan 2020 (on freehold lots).

Whilst no clearing is directly proposed to establish the new boundary between proposed Lot 1 and proposed Lot 2, the
consequential clearing outcome (i.e. fence installation pursuant to the NP2020) has potential to result in accepted or
exempt operational works impacting approximately 189m2 (collectively) comprising of 45m2 at the north-south boundary
junction and 144m2 at the eastern boundary junction where the alignment of the new boundary intercepts the
Environmental Significance Overlay (NP2020).
All other site boundaries are to be retained in their pre-development alignment and as such no further consequential
clearing outcomes that would not be considered as existing ‘as of right’ will occur as a result of development approval.
Table C below provides our response to the Biodiversity, Waterways and Wetlands Overlay Code which indicates the
proposed road can achieve the relevant acceptable outcomes (AO) or performance-based outcomes (PO) and comply
with the overall intent of the code.



7. Code Compliance
Environmental Significance Overlay Code
Pursuant to the City Plan, the site is mapped within the Biodiversity Areas Overlay, Vegetation Management Overlay, and
Wetlands and Waterways Overlay subcategories of the Environmental Significance Overlay Code. As such, a review of
acceptable and performance outcomes of relevant council codes has been undertaken identifying compliance of the
activities with relevant AO’s and PO’s.
Refer to Table C below for our response to the relevant NP2020 Biodiversity, Waterways and Wetlands Overlay Code.




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Table C - Compliance with Table 8.2.2: Environmental significance overlay code – for assessable development
 Performance Outcomes                                              Acceptable Outcomes                                                   Comments

 Ecologically important areas
 PO1                                                               AO1.1                                                                 AO1.1
 Development is sited and designed to protect the physical and     Ecologically important areas are conserved or improved to             The proposed development proposes to conserve the biological diversity of
 ecological integrity and biodiversity of ecologically important   ensure their ongoing contribution to the natural resources and        Noosa Shire by retaining all vegetation existing within the subject site. Whilst it is
 areas through protection of:                                      biological diversity of Noosa Shire.                                  acknowledged that the establishment of the new boundary between proposed
      a) existing habitat areas and ecological linkages; and                                                                             Lot 1 and Lot 2 results in a consequential clearing envelope of approximately
            existing riparian vegetation, waterways and wetland    AND                                                                   189m² of NP2020 mapped Area of Biodiversity Significance, there is no intent to
            habitat values.                                                                                                              directly impact vegetation within these areas. Further, the eastern boundary is
                                                                   AO1.2                                                                 wholly mapped under the NP2020 biodiversity overlay thus establishment of
                                                                   Buildings, structures and associated works are located within         boundary junctions unavoidably traverse Matters of Local Environmental
                                                                   existing cleared areas or areas of lowest ecological value.           Significance. Additionally, it is considered that impact within the small
                                                                                                                                         consequential clearing envelope would not significantly affect the ecological
                                                                   AND                                                                   processes or biodiversity value of the site or surrounding locality.

                                                                   AO1.3                                                                 AO1.2
                                                                   Where constructing a dwelling house or community residence,           The proposed reconfiguration locates new boundary lines within areas
                                                                   buildings and associated structures are not located on land           predominately cleared or holding landscaped garden with low ecological value.
                                                                   identified as an area of biodiversity significance on a               As aforementioned, no direct clearing is proposed to establish the new boundary,
                                                                   Biodiversity, Waterways and Wetlands Overlay Map.                     however the consequential clearing outcomes have been duly considered. The
                                                                   or                                                                    minor unavoidable impact to 189m² of vegetation within area identified as
                                                                   Clearing vegetation (other than for a driveway access) does not       holding Biodiversity Significance envelope would not be considered to have
                                                                   extend beyond—                                                        significant ecological impacts to existing biodiversity values of the site.
                                                                        b) 30 metres of a habitable building or 10 metres of a
                                                                               class 10 structure on lots greater than 10 hectares; or   AO1.3 Not Applicable
                                                                        c) 10 metres of a habitable building or class 10 structure       The locations of future dwellings are not proposed at this application stage.
                                                                               on lots 10 hectares or less but more than 3,000m2; or
                                                                        d) 3 metres of a habitable building or class 10 structure
                                                                                                                                         AO1.4
                                                                               on lots 3,000m2 or less.
                                                                                                                                         Whilst no clearing is proposed, the potential 5m clearing for boundary fences
                                                                   AND
                                                                                                                                         intercepting matters of local environmental significance has been duly considered
                                                                                                                                         in this assessment and potential consequential clearing outcomes identified.
                                                                   AO1.4
                                                                   (a)     Clearing of vegetation for a boundary fence does not
                                                                           extend beyond 5 metres either side of the fence.

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Reconfiguring a Lot

PO2                                                                     AO2                                                                 AO2
New lots are only created if they maintain ecological linkages and      Where clearing vegetation for the purpose of Reconfiguring a Lot:         a)   The proposed reconfiguration creates one additional lot whilst
minimise the clearing of vegetation.                                        a) new boundaries to lots do not transect and fragment                     maintaining ecological linkages and minimising vegetation clearing.
                                                                                  existing native vegetation;                                          The new boundary alignment has been designed to run east-west
                                                                            b) new lots are created to allow for suitable building                     centrally through the existing land parcel, avoiding transection of
                                                                                  envelopes for future buildings and works to be                       significant native vegetation communities to the greatest extent
                                                                                  located within existing cleared areas or areas of low                possible.
                                                                                  ecological value;                                               b)   Whilst not directly nominated within this application, the proposed
                                                                            c) building envelopes are designated for each lot; and                     new lot holds adequate area to establish building locations that avoid
                                                                            d) ecological linkages and ecologically important areas                    matters of local environmental significance.
                                                                                  are secured by environmental covenant or transferred            c)   Refer response to B above.
                                                                                  to public ownership or through gazettal of a nature             d)   Ecological linkages within and adjacent to the site are maintained
                                                                                  reserve.                                                             through the retention of all existing vegetation in its current alignment,
                                                                                                                                                       with no direct impacts to riparian corridors, habitat trees or significant
                                                                                                                                                       vegetation communities proposed as part of this application. Whilst
                                                                                                                                                       minor consequential clearing outcomes have been identified as a
                                                                                                                                                       result of the proposed reconfiguration, the limited extent of impacts
                                                                                                                                                       associated with them (should they ever be enacted) would not be
                                                                                                                                                       expected to materially alter connectivity on a landscape scale.
PO3                                                                     AO3.1                                                               AO3.1
Development is designed and sited to manage adverse impacts on          Where clearing of vegetation cannot be practicably avoided, the     Whilst it is acknowledged that the new boundary establishment results in
ecologically important areas by:                                        development:                                                        consequential clearing envelope of approximately 189m² within mapped
     a) minimising the total footprint within which all activities,          a) ensures the design and siting limits the loss of            biodiversity significance area, there is no plan or intent to directly impact
           buildings, structures driveways and other works are                    vegetation to the smallest extent possible;               vegetation within these areas. Notwithstanding, the proposed development has
           contained;                                                        b) protects and retains ecological values and ecosystem        been designed and sited to run east-west centrally through the existing land
     b) locating development in existing cleared areas or areas                   processes to the greatest extent possible within and      parcel through areas of predominantly cleared or low ecological value, retaining
           of low ecological value over other areas to the greatest               adjacent to the site;                                     ecological values and ecosystem processes to the greatest extent possible within
           extent possible; and                                              c) provides measures to allow for safe movement of             and adjacent to the site.
     c) incorporating siting and design measures to protect and                   fauna through the site; and
           retain ecological values and ecosystem processes within           d) provides suitable habitat replacement and replanting        AO3.2
           or adjacent to the development site; and                               in accordance with PSP3 Ecological Assessment             No habitat trees, recruitment habitat trees, or roosting, breeding and feeding
     d) where adverse impacts have been minimised, any                            Guidelines.                                               areas are proposed to be impacted as part of this reconfiguration.
           residual impacts on ecological values are compensated
           for through suitable habitat replacement and replanting      AO3.2




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          on site in the first instance or in a way that results in a     Habitat trees, recruitment habitat trees, and roosting, breeding
          net gain and enhancement of the overall habitat values          and feeding areas are protected for native fauna habitat.
          of Noosa Shire.
PO4                                                                       AO4.1                                                                AO4.1
Development provides for effective measures during construction           Vegetation is protected from disturbance or damage from              As aforementioned, whilst a consequential clearing envelope of 189m2 is created
and operation to protect ecological values including:                     construction and operation activities by:                            with the establishment of the new boundary, the establishment of the proposed
     a) avoiding disturbance to or clearing of vegetation in and               a) clearly marking trees to be retained with flagging           lot reconfiguration will not require operational works to be undertaken. As such
          within the vicinity of the site;                                           tape;                                                     compliance with AO4 is achieved.
     b) managing habitat disturbance and physical harm to                      b) installing protective fencing around the dripline of the
          fauna from noise, vibration, dust, light, dewatering or                    vegetation and avoid filling and excavating in these      AO4.2
          excavating; and                                                            fenced areas;                                             Existing vegetation on site is proposed to be retained, and the potential removal
     c) avoiding clearing in areas where erosion or slippage                   c) ensuring stockpiling, storage and vehicle parking            of vegetation within the consequential clearing envelope would not cause
          could occur.                                                               occurs outside the identified vegetation areas; and       significant or material impact to buffers between different land uses or a buffer
                                                                               d) using low impact construction techniques around              against pollution, light spillage or noise.
                                                                                     vegetation.
                                                                                                                                               AO4.3
                                                                          AO4.2                                                                No lighting is proposed as this stage of development.
                                                                          Vegetation which is capable of forming or contributing to a buffer
                                                                          between different land uses or a buffer against pollution, light     AO4.4
                                                                          spillage or noise is retained.                                       Existing vegetation on site is proposed to be retained, and the potential non-
                                                                                                                                               material removal of vegetation within the consequential clearing envelope would
                                                                          AO4.3                                                                not cause or contribute to hillslope erosion, bank erosion, or slippage should the
                                                                          Lighting associated with development:                                clearing exemption ever be acted upon.
                                                                                a) does not contribute an unacceptable level of
                                                                                     illuminance (greater than 1 lux) for light sensitive
                                                                                     species within or at the boundary of an ecologically
                                                                                     important area; and
                                                                                b) does not contribute to an unacceptable level of
                                                                                     illuminance on landward horizons along coastal areas
                                                                                     and known marine turtle nesting beaches.

                                                                          AO4.4
                                                                          Clearing of vegetation does not involve clearing that may cause
                                                                          or contribute to hillslope erosion, bank erosion, or slippage.

Connectivity




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PO5                                                                  AO5                                                                 AO5
Development is designed and operated to maintain and enhance         Development is designed and operated to maintain ecological         It is acknowledged that the establishment of the new boundary results in
connectivity between and across ecologically important areas and     linkages and maximise opportunity for connectivity and the          approximately 189m² of mapped biodiversity significance area falling within the
connecting habitat and support unimpeded and safe movement of        movement of fauna by:                                               consequential clearing envelope. Notwithstanding, there is no plan or intent to
terrestrial and aquatic fauna.                                            a) ensuring protection of wildlife refuges;                    directly impact vegetation within these areas as part of this application. Should
                                                                          b) maintaining vegetation in patches of the greatest           any future exempt or accepted operational works occur within this envelope, it is
                                                                                possible size and within the smallest possible edge-     considered that the potential clearing of this area would cause minimal effects to
                                                                                to-area ratio;                                           biodiversity value and ecosystem processes given the limited extent of potential
                                                                          c) enhancing connectivity through planting and                 consequential clearing and retention of the sites broader biodiversity significance.
                                                                                rehabilitation works, including across property
                                                                                boundaries, to areas of national park, state forest or
                                                                                reserve;
                                                                          d) avoiding the creation of physical barriers and safety
                                                                                hazards (such as roads, pedestrian access and
                                                                                instream structures) along and within the ecological
                                                                                linkage;
                                                                          e) providing mitigation measures such as wildlife
                                                                                movement infrastructure, fauna exclusion and
                                                                                directional fencing, underpasses/overpasses and
                                                                                traffic calming devices, signage and lighting; and
                                                                          f)    where offsets are necessary, delivering offsets that
                                                                                support and enhance ecological linkages.




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Waterways and Wetlands

PO6                                                                   AO6.1                                                                Complies with AO6.1
The biodiversity and ecosystem values of waterways, wetlands and      Development and clearing of vegetation does not occur within:        The proposed lot configuration does not propose clearing of vegetation within the
adjacent riparian zones are protected by:                                  a) a riparian buffer area;                                      identified riparian buffer area.
     a) avoiding any new development in a riparian buffer area             b) a wetland area; or
           and wetland area;                                               c) 10 metres either side of the centre line of other            AO6.2 Not Applicable
     b) retaining aquatic and terrestrial habitat in riparian                   waterways identified on a Biodiversity, Waterways          Rehabilitation of land within the identified riparian buffer area is not required as
           zones;                                                               and Wetlands Overlay Map.                                  clearing of vegetation is not proposed.
     c) maintaining and enhancing wildlife corridors and              AO6.2
           connectivity along watercourses and drainage lines for     Development provides for the rehabilitation of land within:          AO6.3 Not Applicable
           native fauna movement;                                          a) a riparian buffer area;                                      The proposed lot reconfiguration does not propose recreational facilities.
     d) avoiding edge effects and damage from adjacent land                b) a wetland area; and
           uses;                                                           c) 10 metres either side of the centre line of any other
     e) maintaining stream integrity and bank stability by                      waterway identified on a Biodiversity, Waterways and
           minimising bank erosion and slumping;                                Wetlands Overlay Map.
     f)    maintaining water quality through filtering sediments,     AO6.3
           nutrients and other pollutants; and                        Recreational facilities (eg. playgrounds, pergolas, barbeques) are
     g) removing pest species and replacing them with local           setback a minimum of 10 metres from the top of the bank of a
           native species.                                            waterway.

PO7                                                                   AO7                                                                  PO7 Not Applicable
Vegetation within 400 metres of the full ponded water within Lake     No acceptable outcome provided.                                      The site does not contain vegetation which is 400m from full ponded water within
Macdonald is retained.                                                                                                                     Lake Macdonald.

PO8                                                                   AO8.1                                                                AO8 Not Applicable
Development on land adjacent to a waterway or wetland                 Development adjacent to a waterway or wetland provides that:         The subject site features mapped riparian buffer area in the northeast extent of
maintains appropriate extent of public access to waterways and             a) no new lots directly back onto a riparian buffer area;       the site which traverses into the greater locality. However, the proposed
wetlands and minimises edge effects.                                          and                                                          reconfiguration does not propose any impact on any existing vegetation in or
                                                                           b) new public roads are located between a riparian              within direct vicinity to mapped riparian buffer areas. As the proposed lots are
                                                                              buffer area or riparian zone and the proposed                within private lots, the development maintains appropriate extent of public
                                                                              development area.                                            access to waterways and minimises edge effects by retaining all existing
                                                                                                                                           biodiversity values. As such, the proposed reconfiguration complies with PO8.

PO12                                                                  AO12                                                                 PO12
Bushfire management measures are adopted based on ecological          No acceptable outcome provided                                       Refer to the Bushfire Hazard Assessment and Management Plan prepared by
principles, which:                                                                                                                         Therefor Group dated February 2026 which details bushfire management
     a) maintain and enhance biodiversity;                                                                                                 measures to ensure any future development are exposed to tolerable levels of




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b)   minimise threat of fire to the natural environment, as                                                                        bushfire risk. As no clearing works are proposed as a mitigation measure, it is
     well as life and property; and                                                                                                determined that works are consistent with the intent of PO12.
c)   provide for effective use and maintenance of buildings
     and structures.




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8. Summary and Recommendations
This report has advised upon the relevant ecological factors and potential impacts to those factors associated with the
proposed lot reconfiguration. The footprint consists of predominately non-regulated Category X vegetation, characterised
by landscaped gardens and native Eucalypts and Melaleucas confined to drainage lines and garden beds. Remnant
Category B vegetation is located in the northwestern extent of the subject site. Following points highlight the proposal's
compliance with relevant legislative requirements:
            ▪   The site contains 272m² of Category B Remnant vegetation characteristic of RE 12.5.2 along the
                northwestern boundary. The new boundary line is not in close proximity to this ecosystem and no impacts
                are anticipated.

            ▪   The proposed boundary traverses through Category X non-regulated under the Vegetation Management
                Act 1999. The proposed development does not trigger a referral to SARA, with assessment delegated to
                Noosa Shire Council.

            ▪   The site is mapped as Koala Priority Area (KPA) and contains Koala Habitat Areas (KHA). Whilst no direct or
                indirect impacts to KHA are proposed, Compliance with Schedule 11 Part 2 of the Planning Regulation 2017
                is demonstrated in Table B.

            ▪   No EVNT protected plants were identified during desktop or field surveys. A Protected Plant Survey permit
                is not required prior to establishment and sealing of the proposed lot reconfiguration.

            ▪   One (1) low order fish passage is located in the northeast boundary of the site. No interference with the
                waterway is proposed and no assessment against waterway barrier work provisions is required.

            ▪   The eastern and southern extent of the proposed boundary falls within mapped Areas of Biodiversity
                Significance under the NP2020. Whilst approximately 189m² falls within the consequential clearing
                envelope, there is no intent to directly impact vegetation within these areas. Table B details the
                performance-based solutions addressing the relevant performance outcomes stipulated within relevant
                sections of the NP2020.



Based upon this conclusion and the provided recommendations, considering ecological constraints, the proposed
development footprint generally conforms to relevant State and Local requirements and, subject to relevant assessment,
is recommended for development consent approval.


Yours sincerely,




 Shan-Ying Barr                                                       Stephen Hayes
 BSc(Env)                                                             BSc(Env) Hons GradCertBfireProt ESA MEIANZ
 Environmental Consultant                                             Director Environment
 Therefor Group                                                       Therefor Group Pty Ltd




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