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                                                                                 Gondwana Ecology Group Pty Ltd
                                                                                                     ABN 20 143 747 326


                                                                                                      PO Box 535
                                                                                                        Kenmore
                                                                                                       QLD 4069


                                                                                               25 April 2022
Attention: Shane Adamson

Adamson Town Planning Pty Ltd
PO Box 894
COOROY QLD 4563

Mr Adamson

RE: RESPONSE TO AMENDED PROPOSAL AND KOALA SUBMISSIONS - 61 NOOSA SPRINGS DRIVE, NOOSA HEADS


1.0 Background
The land is part of the existing Noosa Springs Golf Estate with the subject site formally identified as Lot 4
on SP 178340 and encompasses some 3.8ha. The proposed development is for the redevelopment of part
of the land to a luxury boutique hotel.

An aerial photograph of the subject land is provided in ATTACHMENT A.

Gondwana Ecology Group prepared an ecological assessment report dated February 2020. Site inspections
have been completed as follows:

      •      28 October 2017 (preliminary site inspections, threatened species searches)
      •      29 January 2018 (detailed flora survey and target threatened species surveys)
      •      19 September 2020 (threatened species surveys)
      •      6-7 October 2020 (detailed tree survey and threatened species surveys)

In addition, Gondwana Ecology Group is involved (in conjunction with Council) in the rehabilitation of the
land to the east and has completed several targeted surveys for threatened fauna (i.e. koala and glossy
black cockatoo) in the immediate locality, in 2021 and 2022.

2.0 Amended Proposal
It is noted that further changes have been made to the proposal plans since the response to the information
request. These changes have been made in response to the submissions received during public notification,
which raise some valid planning issues. The changes made to the proposal plans (ATTACHMENT B) can be
generally summarised as follows:

      •      increased building setbacks for the buildings closest to Resort Drive to the east, with the removal
             of the outdoor terrace areas
      •      the removal of six (6) units from Building 2 closest to the existing Day Spa and Gymnasium
      •      the addition of another tennis court to the south of the existing tennis courts, located over the top
             level carpark
      •      the addition of a new tennis pavilion beside Tennis Court 1; and
      •      other changes made to the roof design to lower height and provide additional areas for solar panels.




Gondwana Ecology Group Pty Ltd                                                                                       1


[OCR of page images]
Gondwana Ecology Group Pty Ltd

ABN 20 143 747 326

PO Box 535
Kenmore
QLD 4069

 

25 April 2022
Attention: Shane Adamson

Adamson Town Planning Pty Ltd
PO Box 894
COOROY QLD 4563

Mr Adamson

RE: RESPONSE TO AMENDED PROPOSAL AND KOALA SUBMISSIONS - 61 NOOSA SPRINGS DRIVE, NOOSA HEADS

1.0 Background

The land is part of the existing Noosa Springs Golf Estate with the subject site formally identified as Lot 4
on SP 178340 and encompasses some 3.8ha. The proposed development is for the redevelopment of part
of the land to a luxury boutique hotel.

An aerial photograph of the subject land is provided in ATTACHMENT A.

Gondwana Ecology Group prepared an ecological assessment report dated February 2020. Site inspections
have been completed as follows:

e 28 October 2017 (preliminary site inspections, threatened species searches)
e 29 January 2018 (detailed flora survey and target threatened species surveys)
e 19 September 2020 (threatened species surveys)

e 6-7 October 2020 (detailed tree survey and threatened species surveys)

In addition, Gondwana Ecology Group is involved (in conjunction with Council) in the rehabilitation of the
land to the east and has completed several targeted surveys for threatened fauna (i.e. koala and glossy
black cockatoo) in the immediate locality, in 2021 and 2022.

2.0 Amended Proposal

It is noted that further changes have been made to the proposal plans since the response to the information
request. These changes have been made in response to the submissions received during public notification,
which raise some valid planning issues. The changes made to the proposal plans (ATTACHMENT B) can be
generally summarised as follows:

e increased building setbacks for the buildings closest to Resort Drive to the east, with the removal
of the outdoor terrace areas

e the removal of six (6) units from Building 2 closest to the existing Day Spa and Gymnasium

e the addition of another tennis court to the south of the existing tennis courts, located over the top
level carpark

e the addition of a new tennis pavilion beside Tennis Court 1; and

e other changes made to the roof design to lower height and provide additional areas for solar panels.

Gondwana Ecology Group Pty Ltd 1

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Page 2

It is my understanding the additional tennis court and pavilion will not result in the removal of additional
koala trees or native vegetation; however, please check on this.


3.0 Community Information - Koalas
I have also been requested to consider the information presented in the media (in early 2022) regarding
the proposed development and alleged impacts to the koala.

There are two components to this response, i.e.
    1. The proposed development impacts and compliance with regulatory benchmarks; and
    2. The mis-information presented in the media regarding the project, potential impacts to koala and
    general koala ecology.

My responses are restricted to koala matters. I have also completed a further site and surrounds inspection
in March 2022 to consider the extent of koala habitat in the landscape.

4.0 Project Ecology Outcomes
Most of the subject land is improved by car parking, tennis courts, the Noosa Springs golf clubhouse and
associated buildings and infrastructure. The land is bordered to the north, south and east by Resort Drive
and by Links Drive and the golf course to the west. The site is enclosed by way of a fence. A small area of
“bushland” occurs adjacent to the existing tennis courts. There is no access to the surrounding bushland
for most larger terrestrial fauna.

Nineteen trees that are “koala habitat” (by definition), will be removed. The proposed redevelopment
largely encompasses the existing tennis courts and car parking area in the north.

The proposed redevelopment intends to retain the balance vegetation and trees, despite the lack of
connection to the surrounding landscape. It is proposed to enhance this area through a weed control and
rehabilitation exercise. The landscaping programme throughout the new development also intends to
enhance local resources for native fauna (i.e. through dense and suitable planting). This will improve the
area for local fauna.

The development, noting the site context, mapping and on ground values, will have a negligible adverse
impact to koalas. Importantly, the development is compliant with both Council and the State’s relevant
koala assessment benchmarks.

In accordance with the State Offset legislation, the project proposes to deliver “offsets” by way of financial
payment which will be a condition of approval. Section 5.4 of the Gondwana Ecology Report (dated
February 2020) states the following:

          The impact area (koala habitat in SEQ 1) for the subject land in hectares is 19 X 0.004ha =
          0.076ha. This equates, based on the financial calculator, to $8,702.76.



1 https://apps.des.qld.gov.au/offsets-calculator/ - The Financial Settlement Offset Calculator was designed to calculate the financial

settlement offset using hectares. Therefore in SEQ the number of non-juvenile koala habitat trees being impacted must be converted
into an area in hectares. Using an average tree density of 250 tress per hectare for koala habitat in SEQ, the total area of impact for
a single non-juvenile koala habitat tree in SEQ is taken to be 40m2 (0.004ha).

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It is my understanding the additional tennis court and pavilion will not result in the removal of additional
koala trees or native vegetation; however, please check on this.

3.0 Community Information - Koalas
| have also been requested to consider the information presented in the media (in early 2022) regarding
the proposed development and alleged impacts to the koala.

There are two components to this response, i.e.
1. The proposed development impacts and compliance with regulatory benchmarks; and
2. The mis-information presented in the media regarding the project, potential impacts to koala and
general koala ecology.

My responses are restricted to koala matters. | have also completed a further site and surrounds inspection
in March 2022 to consider the extent of koala habitat in the landscape.

4.0 Project Ecology Outcomes

Most of the subject land is improved by car parking, tennis courts, the Noosa Springs golf clubhouse and
associated buildings and infrastructure. The land is bordered to the north, south and east by Resort Drive
and by Links Drive and the golf course to the west. The site is enclosed by way of a fence. A small area of
“bushland” occurs adjacent to the existing tennis courts. There is no access to the surrounding bushland
for most larger terrestrial fauna.

Nineteen trees that are “koala habitat” (by definition), will be removed. The proposed redevelopment
largely encompasses the existing tennis courts and car parking area in the north.

The proposed redevelopment intends to retain the balance vegetation and trees, despite the lack of
connection to the surrounding landscape. It is proposed to enhance this area through a weed control and
rehabilitation exercise. The landscaping programme throughout the new development also intends to
enhance local resources for native fauna (i.e. through dense and suitable planting). This will improve the
area for local fauna.

The development, noting the site context, mapping and on ground values, will have a negligible adverse
impact to koalas. Importantly, the development is compliant with both Council and the State’s relevant
koala assessment benchmarks.

In accordance with the State Offset legislation, the project proposes to deliver “offsets” by way of financial
payment which will be a condition of approval. Section 5.4 of the Gondwana Ecology Report (dated
February 2020) states the following:

The impact area (koala habitat in SEQ’) for the subject land in hectares is 19 X 0.004ha =
0.076ha. This equates, based on the financial calculator, to $8,702.76.

1 https://apps.des.qld.gov.au/offsets-calculator/ - The Financial Settlement Offset Calculator was designed to calculate the financial
settlement offset using hectares. Therefore in SEQ the number of non-juvenile koala habitat trees being impacted must be converted
into an area in hectares. Using an average tree density of 250 tress per hectare for koala habitat in SEQ, the total area of impact for
a single non-juvenile koala habitat tree in SEQ is taken to be 40m? (0.004ha).

Page 3

The proposed redevelopment intends to retain the balance vegetation and trees, despite the lack of
connection to the surrounding landscape. It is proposed to enhance this area through a weed control and
rehabilitation exercise. The landscaping programme throughout the new development also intends to
enhance local resources for native fauna (i.e. through dense and suitable planting). This has the potential
to improve the area for local fauna.

5.0 Response – Media Information
It is apparent that the information presented in the media has been prepared in the absence of an accurate
appreciation of the proposed redevelopment project or an understanding of koala biology.

For clarity, please note the following:

    •   The proposal is not going to “relocate a koala colony”.
    •   Koalas do not live in colonies.
    •   The development will clear koala habitat (by definition) but is also an area that (by definition) does
        not support koalas. The only “koala habitat” to be cleared are the 19 trees which are defined as
        koala habitat but essentially not used by koala and include small trees.
    •   The removal of the 19 trees (noting they are only koala habitat by definition) are within an area
        that is fenced from surrounding bushland, bordered by a road to the north and east, tennis courts
        to the south and car parking to the west and only contains a few trees) and is not going to cause
        the “end of the koala population”.
    •   There is no information to suggest a “koala population” exists in the locality. The local area would
        support koalas with preferred habitat (i.e. a large open area with a diversity of suitable mature
        koala feed trees) occurring within the golf course.
    •   The clearing of a few trees (noting the site context) is not going to be an “absolute threat to the
        koala and other species”.
    •   Clearing this “block of land” (note the site context) is not going to “isolate the koalas”. The area in
        question is currently isolated from koalas and surrounded by a developed landscape. Koala
        movement in the landscape will not be impacted by the redevelopment of a fenced, disturbed and
        isolated small patch of bush.
    •   As above, the site is not a “koala corridor” and the development will not prevent koalas from
        moving through the landscape.
    •   While it is irrelevant in the context of the project (particularly noting the abundance of koala habitat
        in the landscape, including on the golf course), it is mis-leading to suggest that it takes 5-10 years
        “before koalas can use a tree”. Koalas will feed on a tree as soon as there are leaves, including
        trees less than 2m in height and less than 2 years (pers. obs.).

5.0 Recommendations
While it is acknowledged that the proposed project redevelopment is compliant with the relevant State and
Council koala assessment benchmarks, and that a financial offset payment arrangement is accepted to
address the loss of trees, I have suggested that additional (i.e. over and above the financial offset) trees be
planted in the local area where koala habitat and movement can practically be enhanced.

I have identified two areas within the Noosa Springs Golf Course (refer ATTACHMENT C) where in the order
of 60 trees (i.e. more than a replacement ratio of 3:1) could be planted.

The planting of trees in these areas will provide additional koala feed trees, a variety of habitat tree species
and “close gaps” between existing koala habitats. The golf course and planting areas are also adjacent to
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The proposed redevelopment intends to retain the balance vegetation and trees, despite the lack of
connection to the surrounding landscape. It is proposed to enhance this area through a weed control and
rehabilitation exercise. The landscaping programme throughout the new development also intends to
enhance local resources for native fauna (i.e. through dense and suitable planting). This has the potential
to improve the area for local fauna.

5.0 Response — Media Information
It is apparent that the information presented in the media has been prepared in the absence of an accurate
appreciation of the proposed redevelopment project or an understanding of koala biology.

For clarity, please note the following:

e The proposal is not going to “relocate a koala colony”.

e Koalas do not live in colonies.

e The development will clear koala habitat (by definition) but is also an area that (by definition) does
not support koalas. The only “koala habitat” to be cleared are the 19 trees which are defined as
koala habitat but essentially not used by koala and include small trees.

e The removal of the 19 trees (noting they are only koala habitat by definition) are within an area
that is fenced from surrounding bushland, bordered by a road to the north and east, tennis courts
to the south and car parking to the west and only contains a few trees) and is not going to cause
the “end of the koala population”.

e = There is no information to suggest a “koala population” exists in the locality. The local area would
support koalas with preferred habitat (i.e. a large open area with a diversity of suitable mature
koala feed trees) occurring within the golf course.

e The clearing of a few trees (noting the site context) is not going to be an “absolute threat to the
koala and other species”.

e Clearing this “block of land” (note the site context) is not going to “isolate the koalas”. The area in
question is currently isolated from koalas and surrounded by a developed landscape. Koala
movement in the landscape will not be impacted by the redevelopment of a fenced, disturbed and
isolated small patch of bush.

e As above, the site is not a “koala corridor” and the development will not prevent koalas from
moving through the landscape.

e =While it is irrelevant in the context of the project (particularly noting the abundance of koala habitat
in the landscape, including on the golf course), it is mis-leading to suggest that it takes 5-10 years
“before koalas can use a tree”. Koalas will feed on a tree as soon as there are leaves, including
trees less than 2m in height and less than 2 years (pers. obs.).

5.0 Recommendations

While it is acknowledged that the proposed project redevelopment is compliant with the relevant State and
Council koala assessment benchmarks, and that a financial offset payment arrangement is accepted to
address the loss of trees, | have suggested that additional (i.e. over and above the financial offset) trees be
planted in the local area where koala habitat and movement can practically be enhanced.

| have identified two areas within the Noosa Springs Golf Course (refer ATTACHMENT C) where in the order
of 60 trees (i.e. more than a replacement ratio of 3:1) could be planted.

The planting of trees in these areas will provide additional koala feed trees, a variety of habitat tree species
and “close gaps” between existing koala habitats. The golf course and planting areas are also adjacent to

3

Page 4

conservation land, a further benefit to planting and enhancing the area. Locally refined koala habitat is also
mapped along the southern and south eastern portions of the golf course, contiguous with a planting area.

The golf course supports the most intact and valuable koala habitat in the local landscape, notably large
open space area with a diversity of koala habitat trees for feed, refuge and movement opportunities and
generally free from dangers such as dogs and cars. Planting koala habitat trees in this area will enhance the
existing environment for koalas.

An important and further benefit of planting in this area is the capacity of on-site dedicated ground staff
that have the ability and resources to maintain any planting areas.

5.0 Conclusion
The proposed development is for the “re-development” of an existing developed site with some minor
expansion beyond the existing tennis courts. The minor expansion area contains a small patch of bushland
which also contains some trees defined as “koala habitat trees”. The site (and patch of vegetation) is fenced
from the surrounding bushland and is disturbed by a heavily weed infested ground cover. Koala is known
to occur elsewhere in the local landscape and in more intact, connected and areas with more suitable feed
trees (particularly the larger E.tereticornis and E.robusta on the golf course).

The proposed redevelopment will not fragment koala habitat, nor “isolate” koalas, and will not compromise
koala movement in the local landscape. The information presented in the media is simply incorrect,
misleading and not based on factual circumstances.

The project complies with both State and Council koala assessment benchmarks and the “offset” is to be
provided by way of financial contribution.

As per the recommendations herein, additional tree planting will provide a practical and functional, on site
enhancement of the local environment for the koala. This is over and above the statutory requirements.

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

Kind regards




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

Encl.
ATTACHMENT A – Subject Land and Surrounds
ATTACHMENT B – Amended Proposal
ATTACHMENT C – Proposed Supplementary Koala Habitat Planting Areas




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conservation land, a further benefit to planting and enhancing the area. Locally refined koala habitat is also
mapped along the southern and south eastern portions of the golf course, contiguous with a planting area.

The golf course supports the most intact and valuable koala habitat in the local landscape, notably large
open space area with a diversity of koala habitat trees for feed, refuge and movement opportunities and
generally free from dangers such as dogs and cars. Planting koala habitat trees in this area will enhance the
existing environment for koalas.

An important and further benefit of planting in this area is the capacity of on-site dedicated ground staff
that have the ability and resources to maintain any planting areas.

5.0 Conclusion

The proposed development is for the “re-development” of an existing developed site with some minor
expansion beyond the existing tennis courts. The minor expansion area contains a small patch of bushland
which also contains some trees defined as “koala habitat trees”. The site (and patch of vegetation) is fenced
from the surrounding bushland and is disturbed by a heavily weed infested ground cover. Koala is known
to occur elsewhere in the local landscape and in more intact, connected and areas with more suitable feed
trees (particularly the larger E.tereticornis and E.robusta on the golf course).

The proposed redevelopment will not fragment koala habitat, nor “isolate” koalas, and will not compromise
koala movement in the local landscape. The information presented in the media is simply incorrect,
misleading and not based on factual circumstances.

The project complies with both State and Council koala assessment benchmarks and the “offset” is to be
provided by way of financial contribution.

As per the recommendations herein, additional tree planting will provide a practical and functional, on site
enhancement of the local environment for the koala. This is over and above the statutory requirements.

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

Kind regards

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

Encl.

ATTACHMENT A — Subject Land and Surrounds

ATTACHMENT B — Amended Proposal

ATTACHMENT C - Proposed Supplementary Koala Habitat Planting Areas

Page 5

ATTACHMENT A – Subject Land and Surrounds




Notes:

   •     red dashed line = existing fencing
   •     white marked area = area for loss of 19 trees
   •     illustrated areas = indicative only




                                                         5


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ATTACHMENT A — Subject Land and Surrounds

 

26297'S BISA

 

26 2510'S 18S FE 2625'E'S 15FS27E

 

 

 

Notes:

e red dashed line = existing fencing
e white marked area = area for loss of 19 trees
e illustrated areas = indicative only

Page 6

 

ATTACHMENT B — Amended Proposal

 

 

 

 

 

 

 

 

 

 

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Page 7

ATTACHMENT C – Proposed Supplementary Koala Habitat Planting Areas




Notes:

   •     illustrated areas are indicative only
   •     yellow shaded area = project site “impact” to vegetated area
   •     red shaded areas = koala habitat enhancement/planting areas




                                                                        7


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ATTACHMENT C - Proposed Supplementary Koala Habitat Planting Areas

 

 

 

 

 

Notes:

e _ illustrated areas are indicative only
e — yellow shaded area = project site “impact” to vegetated area
e red shaded areas = koala habitat enhancement/planting areas

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