Arcare MCU Submission

Page 2

Given the applicant’s intention to clear the majority of the site, the development will directly impact
the following species identified in the applicants “Ecological Evaluation Assessment”.

Species threatened by this proposal:

         Koala
         Ground Parrot
         Wallum Sedge Frog
         Wallum Rocket Frog
         Wallum Froglet

We note the applicant’s environmental evaluation attempts to diminish the sites importance due to
the claim the property only contains remnant or regrowth vegetation. However the Noosa Planning
Scheme, Ecological Assessment Guidelines contain policies which recognise this category of
vegetation as important, particularly when it is situated in the vicinity of a National Park.

“Noosa Planning Scheme, Ecological Assessment Guideline 2 Planning Scheme Policy (3 Feb 2006)

a) supports native vegetation (remnant and/or regrowth); b) the potential to support rare,
threatened, migratory or other significant species2 ; c) located in or adjacent to a protected estate (a
national park, conservation park, state forest, etc.); d) located within a water supply catchment area
or in close proximity to a stream, river wetland or waterway; or e) the site is considered part of a
critical habitat area or a linkage in a vegetation/wildlife corridor”

2. The IPA, the EPBC Act and the Noosa Planning Scheme

IPA - Considering the applicant has conceded the proposal signifies a threat to the above species,
development of this land conflicts with the stated purpose of the Integrated Planning Act, which is to
ensure Ecological Sustainability. The applicant also concedes the proposal sits adjacent to vegetation
considered to contain “significant ecological values”.

EPBC - We note the site is essentially a habitat extension of the Noosa National Park. This area is
described in the Environmental Protection and Biodiversity Conservation Act Protection as a:

(a) Threatened Ecological community -ƒ Lowland Rainforest of Subtropical Australia; and
(b) Threatened Ecological community -ƒ Subtropical and Temperate Coastal Saltmarsh

We have specific concerns this application threatens the habitat of the 68 listed Threatened species
and 68 Migratory species listed in the adjacent National Park, as described in the EPBC Act.

Noosa Planning Scheme – Given the threat to biodiversity and desired outcomes of the
abovementioned Federal and State legislation, the proposal clearly conflicts with the Noosa Planning
Scheme.

We note the Noosa Planning Scheme:

“PART 3 - DESIRED ENVIRONMENTAL OUTCOMES 2016 1 3.1 Desired environmental outcomes 3.1.1
The desired environmental outcomes are based on ecological sustainability as defined by IPA and are
the basis for the measures of the planning scheme”

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Page 3

Without listing all ‘desired outcomes’ in Part 3 of the Noosa Planning Scheme, considering the
proposal is described in the Noosaville Biodiversity Overlay mapping as Open Space, Environment
and Conservation area, it is indisputable use of the site for urban activity conflicts with the intended
land use.

We believe the ecologically significant adjacent habitat, in conjunction with the existing vegetation
on the property must be preserved to provide connectivity for a range of threatened species,
including the Koala.

The Noosa community’s economy is sustained by an ecologically (nature) based tourism industry and
preservation of our remnant habitats and species is vital to our future prosperity.

This is outlined in the NOOSA PLANNING SCHEME POLICY 18— ECOLOGICAL ASSESSMENT
GUIDELINES

“Introduction - Council recognises the amenity and lifestyle enjoyed by residents and visitors is
significantly dependent upon the protection and enhancement of the natural environment and
ecological values found within the Shire.”

3. Biodiversity Offsets

The Applicant has endeavoured to mitigate the adverse environmental impacts of this site through
reliance on:

“Queensland Governments Offsets Policy (Version 1.1) December 2014 for 1.01 hectares of Koala
habitat.”

We note the proponent is unable to identify a physical area in the region appropriate to provide an
offset and in contrast has offered a cash payment to Council as an offset. We contend this offer only
amplifies the importance of the remnant vegetation on the site for conservation and rehabilitation.
Regardless of where Council may use monies to conduct environmental works, given the physical
constraints of the National Park and surrounding remnant vegetation, removal of this habitat
diminishes the overall environmental value of the area.

Due to already approved uses surrounding the site and the position of the road network, there are
simply no options to enlarge the area for conservation purposes.

Offsetting biodiversity impacts with cash payment or other rehabilitative works may be appropriate
in some circumstances (particularly to provide infrastructure) however in this case, the applicant has
failed to prove an overriding need for the development in the public interest.

4. Residential (Urban Activity) on protected land

The applicant considers a need exists for an expansion of aged care services within the Shire and
contends Council should set aside the planning conflicts on this basis. However there are less
environmentally significant places in the region where such a rezoning could be considered. We
suspect the applicant’s only reason to prefer this particular site is by virtue of ownership. This is not
a reason to allow a material change of use and we contend the reason the applicant is proposing this
application is for the betterment of their own interests as opposed to the publics.

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Page 4

We note the Noosa Planning scheme provisions for determining approval of residential development
states:

“RESIDENTIAL USES Urban and rural settlement for residential use is contained within the defined
urban growth boundaries shown on zoning maps ZM1- ZM9. It is developed to be consistent with—
the landform, natural environmental and climatic conditions of the locality; v energy efficiency and
water conserving design principles; vi convenience and accessibility to urban services employment
and infrastructure; and vii suitable separation from incompatible land uses.”

We contend this application presents itself as an inconsistent use with the natural environment and
is uncompliant as it does not provide a suitable separation from incompatible land uses.

We also note the Noosa Planning Scheme states:

“Factors such as changing demographics, changing composition of households, ageing and in-
migration to Noosa Shire alter the housing needs of the community. Whilst it is necessary to cater for
these changing needs, resultant development should not impact on the amenity of residential
neighbourhoods or environmental values.”

Therefore the applicants argument the requirement for aged care should be a consideration in this
proposal, fails to overcome the conflict with the Noosa Plan priority to protect its environmental
values.

5. Bushfire Risk

The site in question may be exposed to significant bushfire risks.

Although there may be bushfire mitigation programs in the area, with increased risk of wildfire from
climate change impacts and the difficulty in predicting future weather conditions, we consider
reliance on prevailing winds as a defence is insufficient to protect a development immediately
adjacent to a highly combustible forest area.

It is likely the applicant would have to remove vegetation in extensive buffer areas to reduce wildfire
risks and therefore would be required to undertake more habitat removal than has been proposed.

6. Stormwater Run-Off

We have concerns development of this site will have inevitable pollution impacts from flood events.
Considering the site is surrounded by bushland, oil, grease, litter, fertilisers from gardens, weed
seeds and pollutants such as tyre rubber may adversely affect the adjacent natural environment.

The risk of urban activity to the surrounding National Park is significant and we note the Noosa
Planning Scheme states under 3.1.3

“Sensitive areas of native bushland need protection from urban impacts such as domestic animals,
escaped garden weeds, fertilisers and stormwater run-off”.




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Considering the various conflicts with the Noosa Planning Scheme as outlined above in points 1 – 6,
we request Noosa Council recommend refusal of MCU16/0081. Should you have any questions
regarding this correspondence or require further information please do not hesitate to contact us on
0487 658 497.

We look forward to your response.

Yours Sincerely,

Aaron White and Kim Luff




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