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Ecological Assessment Technical Memorandum
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
www.thereforgroup.com.au 24-0565E/BF | Sunshine Butterflies | Ecological Memorandum | 12.03.2026 | Version 1.0 14
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