MINOR CHANGE - Attachment 3 - Updated Ecology Advice Gondwana Ecology Group.pdf

Page 2

3.0 Project Ecology Outcomes
Despite no offset being required by the State, it was suggested that the applicant would plant
a minimum of 120 koala habitat trees. I had recommended these be planted in areas of the
existing golf course where they would enhance the local vegetation and connected patches
of bushland. In addition, it was also recommended that a species such as Eucalyptus
tereticornis be planted (because it is a locally known preferred food for koala, rather than the
brushbox (which is the dominant “koala” tree on the project land). It is common knowledge
that the brushbox is a less preferred species by koalas.

In addition to the planting of gums, I also recommended that at least 25 she-oak
(Allocasuarina littoralis) be planted to enhance foraging resources for glossy black-cockatoo.

Resources for these species have been recommended because they are considered “iconic”
fauna in the Noosa area.

Also, within the development area, a weed control exercise followed by replanting with
suitable native species will enhance the ground-storey/mid storey area associated with the
bushland patch in the north. The updated (2025) Landscaping Plan by Place Design Group
identifies areas of the open space to be landscaped and rehabilitated. Native species,
including koala habitat trees and “less flammable” species are identified for each zone.

The proposed landscaping exercise includes the use of brushbox, i.e. the few native regrowth
trees within the mapped area that are proposed to be removed. The landscaping plan will also
provide a range of resources for native fauna through the planting of a diversity of suitable
species.

It was also recommended that:

   •   Nest-boxes be installed within the golf course or other land as supported by Council;
   •   Habitat material (hollows/dead wood/logs) be salvaged for use elsewhere in the
       landscape; and
   •   A protective mechanism (e.g. covenant) if Council considers this necessary, for the
       retained vegetation in the north.

4.0 Biodiversity Mapping
Council’s Biodiversity Mapping shows and area in the north and along the eastern boundary
as supporting “Areas of Biodiversity” (refer Extract 1). Of this mapping, a small area in the
north is mapped as Koala Habitat (refer Extract 2). Notably the Council mapped areas in the
east are not State core koala habitat or State remnant vegetation.

The ground-truthed/actual values within the mapped area has been previously described
(Gondwana Ecology Group reporting) and it is noted that the mapped areas do not support


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3.0 Project Ecology Outcomes

Despite no offset being required by the State, it was suggested that the applicant would plant
a minimum of 120 koala habitat trees. | had recommended these be planted in areas of the
existing golf course where they would enhance the local vegetation and connected patches
of bushland. In addition, it was also recommended that a species such as Eucalyptus
tereticornis be planted (because it is a locally known preferred food for koala, rather than the
brushbox (which is the dominant “koala” tree on the project land). It is common knowledge
that the brushbox is a less preferred species by koalas.

In addition to the planting of gums, | also recommended that at least 25 she-oak
(Allocasuarina littoralis) be planted to enhance foraging resources for glossy black-cockatoo.

Resources for these species have been recommended because they are considered “iconic”
fauna in the Noosa area.

Also, within the development area, a weed control exercise followed by replanting with
suitable native species will enhance the ground-storey/mid storey area associated with the
bushland patch in the north. The updated (2025) Landscaping Plan by Place Design Group
identifies areas of the open space to be landscaped and rehabilitated. Native species,
including koala habitat trees and “less flammable” species are identified for each zone.

The proposed landscaping exercise includes the use of brushbox, i.e. the few native regrowth
trees within the mapped area that are proposed to be removed. The landscaping plan will also
provide a range of resources for native fauna through the planting of a diversity of suitable
species.

It was also recommended that:

e Nest-boxes be installed within the golf course or other land as supported by Council;

e Habitat material (hollows/dead wood/logs) be salvaged for use elsewhere in the
landscape; and

e A protective mechanism (e.g. covenant) if Council considers this necessary, for the
retained vegetation in the north.

4.0 Biodiversity Mapping
Council’s Biodiversity Mapping shows and area in the north and along the eastern boundary

as supporting “Areas of Biodiversity” (refer Extract 1). Of this mapping, a small area in the
north is mapped as Koala Habitat (refer Extract 2). Notably the Council mapped areas in the
east are not State core koala habitat or State remnant vegetation.

The ground-truthed/actual values within the mapped area has been previously described
(Gondwana Ecology Group reporting) and it is noted that the mapped areas do not support

Page 3

the values that would be associated with an “area of biodiversity”. For the most part, these
areas support cleared areas, infrastructure, and landscaping works. The area in the north
supports native canopy species, but has no native mid or ground storey, being dominated by
weed species. The patch of vegetation in the north is proposed to be retained, i.e. the area
that does support biodiversity of some value.




 Extract 1. Council Mapping - Areas of Biodiversity (Noosa Plan 2020)




 Extract 2. Council Mapping – Koala Habitat (Noosa Plan 2020)


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the values that would be associated with an “area of biodiversity”. For the most part, these
areas support cleared areas, infrastructure, and landscaping works. The area in the north
supports native canopy species, but has no native mid or ground storey, being dominated by
weed species. The patch of vegetation in the north is proposed to be retained, i.e. the area

that does support biodiversity of some value.

 

 

 

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5.0 Minor Change (2025) Proposal
I am aware 2 that despite support by Council’s environmental team, some Councillors have
concerns over the extent of development and coincidence with areas mapped as
“biodiversity”. More specifically, I understand the following was raised:

      a) The proposed development is an overdevelopment of the land, at the expense of the
         natural values of the land and involves a reduction of land in the Recreation and Open
         Space zone.
      b) The proposed development would result in the overdevelopment of the subject land,
         at the expense of its environmental values, as it proposed that an area of existing open
         space be developed.
      c) It results in the unacceptable clearing of vegetation in an ecologically important area
         and an environmentally sensitive area.

In my opinion, these concerns can be allayed as there is no ecological basis because:
      1. The natural values of the land are degraded or non-existent for the most part
      2. The development is centred on existing developed and or cleared land.
      3. The small area supporting native canopy species (with a weed understorey) is to be
         retained and rehabilitated.
      4. The mapping does not reflect the values of the land, and as such characterising the
         vegetation/area as being “ecologically important” or environmentally sensitive”.
      5. On ground site inspections confirms this to be the case (i.e. mapping is not correct or
         relevant). The on site inspections have been completed in association with Council’s
         environmental officers.
      6. The vegetation to be cleared is not of any significant or important value. As noted, the
         area of value has been retained.
I understand that GH Properties has decided, in an attempt to respond to the concerns of
Councillors, to reduce the development footprint where it interferes with the mapped Area of
Biodiversity 3. This causes the reduction in a building and a reduced overall footprint.
The amended layout is provided in ATTACHMENT C.


6.0 Changes (Ecological) to Plans
With reference to the Proposed Plan (ATTACHMENT B) and the Amended Plan
(ATTACHMENT C), the following is noted (refer comparison illustrated in ATTACHMENT D):


      •    The building in the east, between the existing tennis courts and Resort Drive has been
           removed.
      •    A total of 1562m2 of the mapped “Areas of Biodiversity” would be cleared under the
           Proposed Plan.



2
    General Committee Meeting 20 July 2023.
3
    I understand other changes are also made to address non-ecology concerns.


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CES

5.0 Minor Change (2025) Proposal
| am aware? that despite support by Council’s environmental team, some Councillors have

 

concerns over the extent of development and coincidence with areas mapped as
“biodiversity”. More specifically, | understand the following was raised:

a) The proposed development is an overdevelopment of the land, at the expense of the
natural values of the land and involves a reduction of land in the Recreation and Open
Space zone.

b) The proposed development would result in the overdevelopment of the subject land,
at the expense of its environmental values, as it proposed that an area of existing open
space be developed.

c) It results in the unacceptable clearing of vegetation in an ecologically important area
and an environmentally sensitive area.

In my opinion, these concerns can be allayed as there is no ecological basis because:

1. The natural values of the land are degraded or non-existent for the most part

2. The development is centred on existing developed and or cleared land.

3. The small area supporting native canopy species (with a weed understorey) is to be
retained and rehabilitated.

4. The mapping does not reflect the values of the land, and as such characterising the
vegetation/area as being “ecologically important” or environmentally sensitive”.

5. On ground site inspections confirms this to be the case (i.e. mapping is not correct or
relevant). The on site inspections have been completed in association with Council’s
environmental officers.

6. The vegetation to be cleared is not of any significant or important value. As noted, the
area of value has been retained.

| understand that GH Properties has decided, in an attempt to respond to the concerns of
Councillors, to reduce the development footprint where it interferes with the mapped Area of
Biodiversity®. This causes the reduction in a building and a reduced overall footprint.

The amended layout is provided in ATTACHMENT C.

6.0 Changes (Ecological) to Plans
With reference to the Proposed Plan (ATTACHMENT B) and the Amended Plan

(ATTACHMENT C), the following is noted (refer comparison illustrated in ATTACHMENT D):

e The building in the east, between the existing tennis courts and Resort Drive has been
removed.

e A total of 1562m? of the mapped “Areas of Biodiversity” would be cleared under the
Proposed Plan.

? General Committee Meeting 20 July 2023.
3 | understand other changes are also made to address non-ecology concerns.

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       •   The Amended Plan causes a reduced impact to the mapped “Areas of Biodiversity”,
           i.e. 1182m2.
       •   The percentage “mapped” Area of Biodiversity is reduced from 26% to 19%.

Importantly, 455m2 of the 1182m2 impacted area consists of low impact pathways and
decking. These areas have little to no ecological impact as they can be constructed to avoid
any trees/features of value and provide access (including for rehabilitation maintenance) to
the open space area. This effectively means the “residual impact to the mapped areas 4” is
only 727m2 or 12%.

The changes to the plan are positive in terms of an improved ecological outcome, i.e. because
an additional area of 380m2 of mapped “Areas of Biodiversity” is retained. No other changes
negatively impact the ecological outcome.

I understand that the previously proposed positive ecological outcomes remain part of the
application. These include:


       •   Retention of the mapped koala habitat and bushland in the north;
       •   Weed management exercise to remove/control the invasive weed species (including
           Barleria, Asparagus, Glycine)
       •   Landscaping and rehabilitation with the use of suitable native species (incorporating
           appropriate bush-fire specific plantings)
       •   Planting of 120 E.tereticornis (a preferred koala habitat tree)
       •   Planting of at least 25 Allocasuarina littoralis (feed tree for glossy black-cockatoos)
       •   Relocation of any hollow logs and installation of nest boxes

As before, the development does not cause any adverse ecological impacts, does not involve
a disturbance to an ecologically important or an environmentally sensitive area.

Overall, the project can deliver a positive and net benefit to the local environment, primarily
because:


       •   The project area is not an area of any ecological importance
       •   Is not part of any large, connected patch of bushland
       •   Is separated from other bushland by fencing and roads
       •   Areas of value are retained
       •   Areas of less or no value are developed
       •   At least 145 native trees are to be planted
       •   Weed control and rehabilitation will enhance (create) ecological values


4
    Noting much of the mapped area supports no or very little ecology value due to current/historical use.


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e The Amended Plan causes a reduced impact to the mapped “Areas of Biodiversity”,
i.e. 1182m?.

e The percentage “mapped” Area of Biodiversity is reduced from 26% to 19%.

Importantly, 455m? of the 1182m? impacted area consists of low impact pathways and
decking. These areas have little to no ecological impact as they can be constructed to avoid
any trees/features of value and provide access (including for rehabilitation maintenance) to
the open space area. This effectively means the “residual impact to the mapped areas*” is
only 727m? or 12%.

The changes to the plan are positive in terms of an improved ecological outcome, i.e. because
an additional area of 380m? of mapped “Areas of Biodiversity” is retained. No other changes
negatively impact the ecological outcome.

| understand that the previously proposed positive ecological outcomes remain part of the
application. These include:

e Retention of the mapped koala habitat and bushland in the north;

e Weed management exercise to remove/control the invasive weed species (including
Barleria, Asparagus, Glycine)

e Landscaping and rehabilitation with the use of suitable native species (incorporating
appropriate bush-fire specific plantings)

e Planting of 120 E.tereticornis (a preferred koala habitat tree)

e Planting of at least 25 Allocasuarina littoralis (feed tree for glossy black-cockatoos)

e Relocation of any hollow logs and installation of nest boxes

As before, the development does not cause any adverse ecological impacts, does not involve
a disturbance to an ecologically important or an environmentally sensitive area.

Overall, the project can deliver a positive and net benefit to the local environment, primarily
because:

e The project area is not an area of any ecological importance
e ls not part of any large, connected patch of bushland

e ls separated from other bushland by fencing and roads

e Areas of value are retained

e Areas of less or no value are developed

e Atleast 145 native trees are to be planted

e Weed control and rehabilitation will enhance (create) ecological values

4 Noting much of the mapped area supports no or very little ecology value due to current/historical use.

Page 6

      •    The landscaping proposal uses a mix of suitable native species 5 which will replace the
           weed infested areas associated with the existing facility and open space

7.0 Conclusion
An amended (Minor Change) plan has been proposed to address the concerns of Councillors
that the development is (i) excessive and (ii) interferes with ecologically important area and
an environmentally sensitive area.

The Amended Plan of Development has reduced the interference with Council mapped
“Areas of Biodiversity”. The Proposed Development caused the impact to 1562m2 of mapped
area, while the Amended Plan causes a reduced extent of 1182m2 of the mapped area to be
disturbed.

From an ecological perspective the proposed changed plans are a positive ecological
improvement. The previously proposed environmental outcomes remain and will ensure an
acceptable ecological outcome, generating a net benefit. In terms of planning, the change
while positive, would be considered a minor change, as it –


      •    does not cause any new impacts, nor
      •    does it exacerbate any existing/proposed impacts.

Please do not hesitate to give me a call on 0407 410 099 if you need to discuss further.

Kind regards




Justin Watson (PhD; CEnvP.)
Director/Principal Ecologist
Gondwana Ecology Group

Encl.
    •      ATTACHMENT A – Subject Land (Aerial)
    •      ATTACHMENT B – Proposed Development (Current)
    •      ATTACHMENT C – Amended (Minor Change) Development (2025)
    •      ATTACHMENT D – Comparison of Impact Area (Biodiversity Overlay)

Note: refer Marchese Partners for original set of plans




5
    Which are consistent with the bushfire protection/management requirements.


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e The landscaping proposal uses a mix of suitable native species® which will replace the
weed infested areas associated with the existing facility and open space

7.0 Conclusion

An amended (Minor Change) plan has been proposed to address the concerns of Councillors
that the development is (i) excessive and (ii) interferes with ecologically important area and
an environmentally sensitive area.

The Amended Plan of Development has reduced the interference with Council mapped
“Areas of Biodiversity”. The Proposed Development caused the impact to 1562m? of mapped
area, while the Amended Plan causes a reduced extent of 1182m7? of the mapped area to be
disturbed.

From an ecological perspective the proposed changed plans are a positive ecological
improvement. The previously proposed environmental outcomes remain and will ensure an
acceptable ecological outcome, generating a net benefit. In terms of planning, the change
while positive, would be considered a minor change, as it —

e does not cause any new impacts, nor

e does it exacerbate any existing/proposed impacts.

Please do not hesitate to give me a call on 0407 410 099 if you need to discuss further.

Kind regards

Justin Watson (PhD; CEnvP.)
Director/Principal Ecologist
Gondwana Ecology Group

Encl.
e ATTACHMENT A - Subject Land (Aerial)
e ATTACHMENT B - Proposed Development (Current)
e ATTACHMENT C - Amended (Minor Change) Development (2025)
e ATTACHMENT D - Comparison of Impact Area (Biodiversity Overlay)

Note: refer Marchese Partners for original set of plans

5 Which are consistent with the bushfire protection/management requirements.

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ATTACHMENT A – Subject Land (Aerial)




Source: Nearmap October 2024




Gondwana Ecology Group Pty Ltd         7


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ATTACHMENT A - Subject Land (Aerial)

Source: Nearmap October 2024

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Page 8

 

ATTACHMENT B - Proposed Development (Current)

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

  

 

 

 

 

 

 

 

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Page 9

ATTACHMENT C - Amended (Minor Change) Development (2025)

  

 

 

 

 

 

 

 

 

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Page 10

 

ATTACHMENT D - Comparison of Impact Area
BIODIVERSITY OVERLAY - PREVI APPLICATION

 

 

 

 

SITE AREA OF BIODIVERSITY SIGNIFICANCE: 5988m? HEME sooversiry sicwiricance overtar
DEVELOPMENT FOOTPRINT IMPACT: 1562m? (26.0%) {EB ~ovevetopnenr rooreRint mpacr

 

 

 

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Page 11

 

 

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SITE AREA OF BIODIVERSITY SIGNIFICANCE:
DEVELOPMENT FOOTPRINT IMPACT:

 

 

DEVELOPMENT FOOTPRINT IMPACT REDUCTION:

 

5988m?
1182m? (19.7%). NOTE: 455m? CONSISTS OF LOW IMPACT PATHWAYS / DECKING
380m? (6.3%)

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11