SARA RFI - Attachment 3 - Gondwana Ecology Group Response.pdf

Page 2

NJKHT will be potentially impacted by the proposed development. The submitted material does not promote measures to
improve connectivity to allow usage for koala habitat of the remaining NJKHT on site or the impact to Matters of State
Environmental Significance (MSES) by the removal of the 19 NJKHT.

Further information is required to demonstrate that all reasonable avoidance, minimisation and mitigation measures of
development have been undertaken in order to ensure that the proposed development will not impact koala habitat or MSES.

Action
It is requested that applicant provide further information on PO1 and PO5 of State code 25: Development in South East
Queensland koala habitat areas (State code 25) of the SDAP.

Provide a report prepared by an appropriately qualified ecologist that:

    •    identifies the number of NJKHTs on site that are proposed to be impacted including those that could be impacted from
         the future use of the site (e.g. infrastructure, excavation or fill) and as exempted development (as defined in Schedule
         24 of the Planning Regulation 2017) which would apply as a natural and ordinary consequence of the development.

3.0 Response – Offsets (Council)
In accordance with the State Offset legislation, the offsets are proposed to be delivered by way of financial payment.
Section 5.4 of the Gondwana Ecology Report (dated February 2020) states the following:

        The impact area (koala habitat in SEQ3) for the subject land in hectares is 19 X 0.004ha = 0.076ha. This
        equates, based on the financial calculator, to $8,702.76.

It is anticipated that the offset requirement would be a condition of approval.

4.0 Response – Koala Habitat (SARA)
As requested by the State, I can confirm that am an appropriately qualified ecologist 4. I (Justin Watson) have more
than 30 years research, academic, conservation and consulting experience.

Gondwana Ecology Group provided a report (2020) on the site’s ecological values, including koala habitat,
connections and site context for this species.

The author of that report (and this correspondence) has a PhD in ecology, is an Associate Professor and Certified
Environmental Practitioner. The author has also worked with koalas since 2000 across south-east Queensland and
northern New South Wales and is familiar with the area surrounding the locality, both through historical work and
ongoing research for local projects, conservation organisations and for Council (including an ongoing rehabilitation
project for that will remove weeds and plant koala habitat trees to the east – refer marked up area on ATTACHMENT
A). The author regularly provides expert witness and peer review services to the State and Council. The author has
also undertaken koala research activities with the Koala Research Group at UQ and has provided peer review for
Strategic Koala Management Plans.

The 2020 koala report confirms 19 koala habitat trees will be removed. It is my understanding that no other koala
habitat trees need to be removed for the project. This includes for infrastructure, earthworks or bushfire purposes 5.
The new tennis courts are proposed at the location where the current tennis courts are with an additional small
area further north and serve as a separation between the retained bushland and the buildings.

It is important to understand the site context and vegetation on the subject land. This has been described in the
ecology report of 2020. For completeness, in summary, the majority of the subject land is improved by car parking,

3 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).
4 A curriculum vitae can be provided if requested.
5 Bushfire specific matters are addressed separately by a bushfire consultant.

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NJKHT will be potentially impacted by the proposed development. The submitted material does not promote measures to
improve connectivity to allow usage for koala habitat of the remaining NJKHT on site or the impact to Matters of State
Environmental Significance (MSES) by the removal of the 19 NJKHT.

Further information is required to demonstrate that all reasonable avoidance, minimisation and mitigation measures of
development have been undertaken in order to ensure that the proposed development will not impact koala habitat or MSES.

Action
It is requested that applicant provide further information on PO1 and POS of State code 25: Development in South East
Queensland koala habitat areas (State code 25) of the SDAP.

Provide a report prepared by an appropriately qualified ecologist that:

e identifies the number of NJKHTs on site that are proposed to be impacted including those that could be impacted from
the future use of the site (e.g. infrastructure, excavation or fill) and as exempted development (as defined in Schedule
24 of the Planning Regulation 2017) which would apply as a natural and ordinary consequence of the development.

3.0 Response — Offsets (Council)
In accordance with the State Offset legislation, the offsets are proposed to be delivered by way of financial payment.

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.

It is anticipated that the offset requirement would be a condition of approval.

4.0 Response — Koala Habitat (SARA)
As requested by the State, | can confirm that am an appropriately qualified ecologist*. | (Justin Watson) have more
than 30 years research, academic, conservation and consulting experience.

Gondwana Ecology Group provided a report (2020) on the site’s ecological values, including koala habitat,
connections and site context for this species.

The author of that report (and this correspondence) has a PhD in ecology, is an Associate Professor and Certified
Environmental Practitioner. The author has also worked with koalas since 2000 across south-east Queensland and
northern New South Wales and is familiar with the area surrounding the locality, both through historical work and
ongoing research for local projects, conservation organisations and for Council (including an ongoing rehabilitation
project for that will remove weeds and plant koala habitat trees to the east — refer marked up area on ATTACHMENT
A). The author regularly provides expert witness and peer review services to the State and Council. The author has
also undertaken koala research activities with the Koala Research Group at UQ and has provided peer review for
Strategic Koala Management Plans.

The 2020 koala report confirms 19 koala habitat trees will be removed. It is my understanding that no other koala
habitat trees need to be removed for the project. This includes for infrastructure, earthworks or bushfire purposes>.
The new tennis courts are proposed at the location where the current tennis courts are with an additional small
area further north and serve as a separation between the retained bushland and the buildings.

It is important to understand the site context and vegetation on the subject land. This has been described in the
ecology report of 2020. For completeness, in summary, the majority of the subject land is improved by car parking,

3 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).

4 A curriculum vitae can be provided if requested.
5 Bushfire specific matters are addressed separately by a bushfire consultant.

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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 (see marked up area on ATTACHMENT A). Only 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.

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.

SARA have requested consideration of PO1 and PO5 of the State Code 25. PO1 and PO5 are essentially the same
performance outcomes, with neither having any acceptable solution. The Code assumes that an area that has trees
that are “koala habitat trees” means the area is “koala habitat”.

The site context, including size of patch, use by koalas, access for koala and surrounding bushland needs to be
considered. The purpose of the State Code results in:
        1. no net loss of koala habitat area
        2. does not contribute to fragmentation of koala habitat areas
        3. maintains or improves connectivity within and between koala habitat areas to ensure safe koala movement

The redevelopment of the site will result in the loss of 19 trees that are, by definition, species of tree that koalas
use for feed or refuge. The site is not an area where koalas are known to occur. No koalas were recorded on the
site (over several years of survey). The site is fenced from surrounding bushland and is part of the existing golf
course, club house, car parking and tennis courts.

The redevelopment will not fragment koala habitat because it is a minor additional encroachment beyond the
existing tennis courts. The redevelopment will not prevent koalas from moving through the landscape.

Current connectivity is limited because the site is fenced, and the area of vegetation (and trees) is small. The patch
is not part of any koala corridor. No new roads are proposed, and the northern vegetated part of the site will remain
vegetated and enhanced with a weed management exercise and infill planting.
PO1 Development interfering with koala habitat (including interfering with koala habitat as a result of material change of use
and interfering with koala habitat as a result of reconfiguring a lot) does not occur unless the application demonstrates the
interfering with koala habitat has:

        1. been reasonably avoided; or
        2. been reasonably minimised where it cannot be reasonably avoided; and
        3. mitigated the impacts of the interfering with koala habitat values.

PO5 Development:

        1. avoids impacts on matters of state environmental significance; or
        2. minimises and mitigates impacts on matters of state environmental significance after demonstrating
        avoidance is not reasonably possible; and
        3. provides an offset if, after demonstrating all reasonable avoidance, minimisation and mitigation
        measures are undertaken, the development results in an acceptable significant residual impact on a
        matter of state environmental significance that is a prescribed environmental matter.

The proposal is for the redevelopment of the existing developed area. The intact bushland in the surrounding area
and at the northern end of the site is avoided. These are the areas of greater value as they are part of the broader
conservation estate and connected bushland.

The development retains several koala habitat trees and a small patch of bushland. The new tennis courts are
positioned on the existing tennis courts with minor realignment northwards to facilitate a better use of the existing


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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 (see marked up area on ATTACHMENT A). Only 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.

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.

SARA have requested consideration of PO1 and POS of the State Code 25. PO1 and PO5 are essentially the same
performance outcomes, with neither having any acceptable solution. The Code assumes that an area that has trees
that are “koala habitat trees” means the area is “koala habitat”.

The site context, including size of patch, use by koalas, access for koala and surrounding bushland needs to be
considered. The purpose of the State Code results in:

1. no net loss of koala habitat area
2. does not contribute to fragmentation of koala habitat areas
3. maintains or improves connectivity within and between koala habitat areas to ensure safe koala movement

The redevelopment of the site will result in the loss of 19 trees that are, by definition, species of tree that koalas
use for feed or refuge. The site is not an area where koalas are known to occur. No koalas were recorded on the
site (over several years of survey). The site is fenced from surrounding bushland and is part of the existing golf
course, club house, car parking and tennis courts.

The redevelopment will not fragment koala habitat because it is a minor additional encroachment beyond the
existing tennis courts. The redevelopment will not prevent koalas from moving through the landscape.

Current connectivity is limited because the site is fenced, and the area of vegetation (and trees) is small. The patch
is not part of any koala corridor. No new roads are proposed, and the northern vegetated part of the site will remain
vegetated and enhanced with a weed management exercise and infill planting.

PO1 Development interfering with koala habitat (including interfering with koala habitat as a result of material change of use
and interfering with koala habitat as a result of reconfiguring a lot) does not occur unless the application demonstrates the
interfering with koala habitat has:

1. been reasonably avoided; or
2. been reasonably minimised where it cannot be reasonably avoided; and
3. mitigated the impacts of the interfering with koala habitat values.

PO5 Development:

1. avoids impacts on matters of state environmental significance; or

2. minimises and mitigates impacts on matters of state environmental significance after demonstrating
avoidance is not reasonably possible; and

3. provides an offset if, after demonstrating all reasonable avoidance, minimisation and mitigation
measures are undertaken, the development results in an acceptable significant residual impact on a
matter of state environmental significance that is a prescribed environmental matter.

The proposal is for the redevelopment of the existing developed area. The intact bushland in the surrounding area
and at the northern end of the site is avoided. These are the areas of greater value as they are part of the broader
conservation estate and connected bushland.

The development retains several koala habitat trees and a small patch of bushland. The new tennis courts are
positioned on the existing tennis courts with minor realignment northwards to facilitate a better use of the existing

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site. The associated earthworks for the new tennis courts have been reduced (i.e. from the initial designs 6) to avoid
the clearing of more trees, i.e. the tree loss is limited to a few (19) trees. These trees, as described in the 2020
report, are not used by koalas and do not offer other ecological values (i.e. not large/old growth trees or trees with
hollows) 7 and are (relatively) not of any high ecological value.

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. Surveys over several years have failed to record
koalas on the site. This is likely due to the site being fenced and the habitat not of particular important value for
the koala. Koala is known to occur elsewhere in the local landscape and in more intact, connected and areas with
more suitable feed trees.

The proposed redevelopment avoids greater potential impact because the majority of the development will occur
within the area already developed/disturbed. The earthworks for the tennis courts have been minimised to avoid
additional tree loss.

The proposed redevelopment will not fragment koala habitat and the rehabilitation (and landscaping) exercise will
enhance the remaining patch of bushland and local site values.

In accordance with the State offset legislation, it is proposed that the koala habitat trees to be removed will be
offset by way of financial contribution.

Noting the context of the site, scale and design of the proposed re-development and minimal impact to ecology
values, it would be expected that the development could be approved with reasonable and relevant conditions.

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




6 At the authors request during the initial assessment stage in 2019 and early 2020.
7 While not necessarily important for koalas, these are important features to consider in the broader landscape.

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site. The associated earthworks for the new tennis courts have been reduced (i.e. from the initial designs®) to avoid
the clearing of more trees, i.e. the tree loss is limited to a few (19) trees. These trees, as described in the 2020
report, are not used by koalas and do not offer other ecological values (i.e. not large/old growth trees or trees with
hollows)’ and are (relatively) not of any high ecological value.

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. Surveys over several years have failed to record
koalas on the site. This is likely due to the site being fenced and the habitat not of particular important value for
the koala. Koala is known to occur elsewhere in the local landscape and in more intact, connected and areas with
more suitable feed trees.

The proposed redevelopment avoids greater potential impact because the majority of the development will occur
within the area already developed/disturbed. The earthworks for the tennis courts have been minimised to avoid

additional tree loss.

The proposed redevelopment will not fragment koala habitat and the rehabilitation (and landscaping) exercise will
enhance the remaining patch of bushland and local site values.

In accordance with the State offset legislation, it is proposed that the koala habitat trees to be removed will be
offset by way of financial contribution.

Noting the context of the site, scale and design of the proposed re-development and minimal impact to ecology
values, it would be expected that the development could be approved with reasonable and relevant conditions.

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

© At the authors request during the initial assessment stage in 2019 and early 2020.
7 While not necessarily important for koalas, these are important features to consider in the broader landscape.

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ATTACHMENT A – Subject Land and Surrounds




Notes:

   •     yellow dashed area to east = Gondwana Ecology Group rehabilitation project for threatened species, including koala.
   •     red dashed line = Site fence
   •     white marked area = Area for loss of 19 trees
   •     mark-ups and areas = indicative only




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ATTACHMENT A — Subject Land and Surrounds

 

2e2157'S BISA

 

2625'S'S 15F527'E

 

 

 

e yellow dashed area to east = Gondwana Ecology Group rehabilitation project for threatened species, including koala.
e red dashed line = Site fence

e white marked area = Area for loss of 19 trees

e@ — mark-ups and areas = indicative only