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DeVantier RACV ecocabin submission to Noosa Council 6Feb23

Attached to the e-mail PM Submission - Lyndon DeVantier - MCU22/0118.

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Application Number: MCU22/01181

Address: 94 and 142 Noosa Drive, Noosa Heads QL 4567

Nature of Proposed Development: Development permit for a material change of use for short-term
accommodation (16 Eco-Cabins) and new lagoon pool

Submission by: Lyndon DeVantier PhD, Noosaville

Date: 6 February 2023

I ask that the Noosa Council refuse the development proposal (MCU22/0118) from RACV for a
material change of use for short-term accommodation and new lagoon pool at 94 and 142 Noosa
Drive.

My main objection is that the proposed development is within core koala habitat. The site hosts
koala feed trees that also provide shelter. The site also acts as part of a connection corridor between
a few of the remaining areas of suitable koala habitat in the general vicinity.

RACV’s amended proposal for building 16 'eco-cabins' and lagoon pool would require removal of at
least 89 trees, 44 or more of which are koala feed trees. A further 20 trees including 10 feed trees
may also be removed or severely impacted. The fate of other flora and fauna species on the site
from the proposed development are not thoroughly addressed.

The QLD State Assessment Referral Agency (SARA) notes: “The site provides an important connection
between Noosa National Park to the north through to Leslie Park and larger, interconnected areas of
bushland that are mapped as Koala habitat area (KHA) in a Koala Priority Area (KPA) to the
southeast. Furthermore, there are 107 records of koalas within 1 km of the site, and four records of
koalas on the site. SARA considers that the impacts of the proposed development may result in an
unacceptable impact on KHA, particularly as it relates to connectivity, fragmentation and safe koala
movement.

Based on the information submitted with the application material, it is recommended the applicant
consider whether development of the site is appropriate, considering the current threats facing
koalas in South-East Queensland.”

If the development were to proceed, will koalas be likely to use or even move through the site
during construction? I am not a koala specialist, so I do not know the answer, but I do think such
considerations are important in the decision, given that the development works could take months
or longer.

As part of its response, the applicant offered a financial offset for the koala habitat trees being
removed. Offsets are not a panacea for habitat loss, as it is not possible to match ‘like with like’ –
every site has unique characteristics. What is clear is that our present approach to wildlife
conservation is failing our threatened species, particularly endangered species like koala, glossy
black cockatoo and others that are lesser known, pushing them ever closer to extinction. South-east
Queensland, and indeed the Noosa Shire, are cases in point, here despite the many decades of
stalwart effort by local conservationists. Australia has national and international obligations to foster
recovery of threatened species, the latter as a signatory to the United Nations Convention on
Biological Diversity. Noosa Shire is an IUCN Biosphere reserve, with additional obligations inherent
therein. If there is any risk to threatened species from this, or indeed, any future development, then
I think it incumbent on decision-makers to refuse such applications.
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My own lived experience in the Shire dates to the late 1950s. In respect of riparian zones, the
destruction of Hay’s Island for the Noosa Sound development in the early 1970s, and subsequent
relocation of the rivermouth, have remained with me for half a century as disgraceful exemplars of
what should not be done. Nancy Cato’s ‘The Noosa Story’ tells that woeful tale. In those cases, the
corrupt Bjelke-Peterson regime was a major player. Today, we should know better. The present case
may be considered ‘small change’ in as much as it is a small site, albeit riparian, with nothing like the
destruction wreaked on Hay’s Island or indeed many other parts of our and neighbouring shires (eg.
Peregian Springs). Nonetheless, we are now at a point in the extinction vortex for threatened species
where every parcel of habitat, and particularly corridors, are crucial. Noosa’s remnant bushland is
literally facing ‘death by a thousand cuts’. Instead of removing carbon-sequestering trees to facilitate
tourism development, we should be conserving remnant native vegetation. Riparian vegetation and
coastal wetlands play crucial roles in ameliorating storm and flood damage. It is a lot more effective,
and a lot less costly, to protect remnant vegetation than planting, which if successful, would take
years to establish.

 The applicant argues that the proposal would enhance koala habitat by the removal of frangipani
vines and damaged trees, and replanting. But such good work can be done without putting in yet
more tourism accommodation and car parks. Exotic species (including the frangipani vine which is
not a declared invasive weed in Australia) could be brought under control, assisting recovery and
regeneration of koala trees and other native vegetation. RACV, having profited from the resort for
many years, could fund the weed removal efforts, as well as initiatives in providing safe passages for
koala and other wildlife (eg. adequate and well maintained exclusion fences) to reduce roadkill and
injuries. Such contributions should not be conditional on the approval of the current development
proposal. Indeed, they would be a good example to other resorts as to what responsible
developments can achieve in a Biosphere Reserve.

On the ‘big picture’, climate disruption and sea level rise will increasingly impact the site, as
elsewhere in the Shire, as flood maps testify. IPCC is inherently conservative and estimates of sea
level rise in particular, over the coming decades, have large margins of error, the uncertainties tied
to the rate of destabilization of the huge Antarctic glaciers, among other major sources. It is well
past time for councils to adopt the much-lauded but rarely applied Precautionary Principle in all
these matters.

With thanks,

Lyndon DeVantier, PhD

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