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RFI - Attachment 4A - Response by Native Foresters
Native Foresters
Natural Resource Management Consultants
10th December 2023
Cody Johnston and Mark Borgert
Noosa Council
RE: Response to Information Request – Noosa Landfill Expansion Project – Environmental
Items
Native Foresters has been requested to provide updated information regarding the Information
Request received from Noosa Council on the 23/11/2023. Shane Adamson has nominated
that responses are required to the following items:
Item 6 – Refer Updated Flora and Fauna Assessment -Noosa Landfill – Northern Section –
Revision 4; which provides updated responses to the Biodiversity Waterways and Wetlands
Overlay Code.
Item 7 – It is determined that the State Government Supported Infrastructure Koala Policy
2017 applies to the development. Refer to Table 1 and 2 below for an assessment of the
application against this policy and the updated Flora and Fauna Assessment -Noosa Landfill
– Northern Section – Revision 4.
Item 8 – It is determined that the Paperbark Wetland in the subject site does not meet the
criteria for a EPBC Act Threatened Ecological Community (Coastal Swamp Sclerophyll
Forest of NSW and SEQ), for the following reason:
• The subject area does not meet the patch condition and threshold criteria within the
Coastal Swamp Sclerophyll Forest TEC Conservation Advice due to the high level of
weeds in the ground layer. Whilst the criteria for dominant species and patch size is met
(i.e., size >0.2ha that is contiguous with a large patch (EPBC Act,1999). As a result, is not
protected under the EPBC criteria.
Item 9 – As noted above it is determined that the MNES listed Coastal Swamp Sclerophyll
Forest of NSW and SEQ is not present onsite. It is also determined that the site is not providing
breeding or foraging habitat for the MSES listed Glossy Black Cockatoo for the following
reasons:
• No hollow bearing trees or trees showing early stages of hollow formation were observed
in the survey area that would provide suitable breeding habitat for Glossy Black
Cockatoo.
• No Glossy Black Cockatoo food trees of the Casuarina or Allocasuarina spp are present
onsite.
Refer to the updated MNES/MSES Assessment – (Noosa Landfill RRC -291123 - Revision 2)
for the project.
Noosa Landfill & RRC – Response to RFI – Environmental Items (Dec 2023) 1
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TABLE 1: Assessment of Project against State Governments Supported Infrastructure Koala Policy 2017
Column 1: Column 2: Column 3:
Requirements that apply to all Government RESPONSE Government Supported Infrastructure RESPONSE Self-Assessment Criteria SELF –
Supported Infrastructure development in SEQ development in a KHA that is exempt from the ASSESSMENT
Self-Assessment Criteria of Column RESPONSE
1. Where possible, development avoids Complies 1. Development in a State Development N/A Development in an area that is both a KPA and a KHA See Table 2
fragmenting KHA within the land to The clearing is on the edge of Area. 1. Where interfering with koala habitat, occurs, public assessment
which the development applies. retained vegetation and sector entities, in addition to any relevant criteria of below.
cleared areas. Column 1, must also self-assess against the
requirements in Table 2.
2. Where possible, development does Complies 2. Development for a Coordinated N/A Development in an area that is a KHA outside a KPA N/A
not impede or restrict the movement The vegetation is an area Project. 2. Where interfering with koala habitat is unavoidable,
of koalas within the land to which the 1.02ha which is “jutting” into development in a KHA, in addition to any relevant
development applies and provides the landfill site; and currently criteria of Column 1, must:
safe koala movement measures does not provide a corridor or a. minimise interfering with koala habitat; and
between highly connected patches of link from the remaining
retained KHA. vegetation on site (to the east
of the landfill) to another
patch of vegetation.
3. Clearing of koala habitat trees must Complies 3. Development in a declared Priority N/A b. where possible, mitigate any impacts that N/A
be carried out in a way that complies Council will clear from the Development Area or a declared Provisional interfere with koala habitat values; and
with sequential clearing conditions. landfill towards the retained Priority Development Area.
vegetation.
4. Development must ensure that: Complies 4. Development that involves interfering with N/A c. where interfering with koala habitat results in N/A
a. measures are taken in A Wildlife Spotter Catcher koala habitat to: Proposed a significant residual impact, deliver an
construction practices to not experienced in koala spotting a. a total area of 500m2 or less; or clearing is offset:
increase the risk of death or and relocating, will be b. a total of 12 non juvenile koala 1.02ha i. in accordance with the requirements
injury to koalas; and required during all clearing habitat trees or less on the land to of the current Queensland
b. native vegetation in an area works. which the development applies. Environmental Offsets Policy or
identified by a proponent to be Works will also be
retained as a safe koala undertaken in accordance
movement measure is with a CEMP.
progressively restored if it must
be impacted during site
operations. N/A
Noosa Landfill & RRC – Response to RFI – Environmental Items (Dec 2023) 2
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Column 1: Column 2: Column 3:
Requirements that apply to all Government RESPONSE Government Supported Infrastructure RESPONSE Self-Assessment Criteria SELF –
Supported Infrastructure development in SEQ development in a KHA that is exempt from the ASSESSMENT
Self-Assessment Criteria of Column RESPONSE
5. Where appropriate in the context N/A 5. Development that involves interfering with N/A ii. where the public sector entity has a N/A
of the landscape, landscaping koala habitat where the development is for pre-existing offset, the offset must be
activities provide food, shelter necessary fire management. delivered in in accordance with the
and movement opportunities for requirements of the current
koalas consistent with the site Queensland Environmental Offsets
design. Policy with the exception of the offset
site location preferences; or
iii. as an alternate compensatory action, N/A
where the development is for transport
infrastructure, and if the alternate
compensatory action will achieve a
conservation outcome equal to, or
greater than, the conservation
outcome that would otherwise be
achieved through the delivery of a
land-based offset under the current
Queensland Environmental Offsets
Policy
6. Development that involves interfering with N/A 3. Clearing of koala habitat trees in a KHA are Complies
koala habitat to remove or reduce a undertaken under the guidance of a koala spotter Council will
foreseeable, imminent or ongoing: where koala habitat trees have a trunk of a undertake
a. risk of serious personal injury; or diameter of more than 10cm at 1.3m above the clearing in
b. risk of damage to Government ground. accordance
Infrastructure or private property; or c. with a CEMP
risk to public safety. and a Wildlife
Spotter
Catcher will be
present during
all clearing.
7. Interfering with koala habitat where it is N/A
necessary to undertake maintenance work New landfill
or repair work on Government area
Infrastructure. proposed.
8. Interfering with koala habitat where it is N/A
necessary to undertake retrofit work on
existing transport infrastructure to install
koala mitigation or management structures.
Noosa Landfill & RRC – Response to RFI – Environmental Items (Dec 2023) 3
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Column 1: Column 2: Column 3:
Requirements that apply to all Government RESPONSE Government Supported Infrastructure RESPONSE Self-Assessment Criteria SELF –
Supported Infrastructure development in SEQ development in a KHA that is exempt from the ASSESSMENT
Self-Assessment Criteria of Column RESPONSE
Commonwealth EPBC Act obligations N/A
9. Development that involves interfering with
koala habitat where the development is
identified as having, or is likely to have, a
significant impact on a matter of national
environmental significance and is
subsequently determined as a controlled
action by the Commonwealth Government
under the Environmental Protection and
Biodiversity Conservation Act 1999,
provided the assessment decision requires
that a koala offset be delivered
10. Development that: N/A
a. was assessed against the
requirements of the previous policy It is noted
and the development has that the
commenced; or application
b. is submitted for approval or received to Council
an approval to proceed and funding was
approval for the development, issued withdrawn
by the Queensland Cabinet Budget and has
Review Committee or other project- been
specific governing body, relevant resubmitted,
Minister or Federal Government but SARA
including being listed on Qld has
Transport Roads Implementation previously
Program, within 12 months of the approved
commencement of this policy; or the works.
c. received a development approval,
issued prior to the commencement of
this policy, as a result of a
development assessment process
under the Planning Act 2016 or other
relevant Act.
Noosa Landfill & RRC – Response to RFI – Environmental Items (Dec 2023) 4
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TABLE 2: Self-Assessment Criteria where interfering with koala habitat in an area that is both a KPA and a KHA, is unavoidable
Public Sector Entities must: RESPONSE
1. Minimise interfering with koala habitat The proposed clearing is required to extend the landfill facility in accordance with the Noosa Council Master Plan for the Noosaville Waste Management Facility.
Lot 77 SP298776 is 322.13 hectares in total and the landfill use currently has an approximate area of 49 hectares (i.e. 15% of Lot 77). The site contains
approximately:
• 235 hectares of Core KHA, and
• 31 hectares of Locally refined KHA.
The works will result in impacting:
• 0.21 hectares of Core KHA, and
• 0.81 hectares of Locally refined KHA.
• A total of 1.02 hectares of mapped KHA (which equates to impacting approximately 0.4% of the mapped KHA within Lot 77).
2. To the best extent possible mitigate any impacts that As detailed in Table 2 and Section 4 of Impact Assessment Report for MNES & MSES by Native Foresters dated 10th December 2023 (Doc. No.: 220716-
interfering with koala habitat has on koala values. MNES/MSES- Rev 3) there are a number of mitigation actions proposed to reduce impacts to koala habitat, as summarized below:
• Fauna spotter catcher to undertake pre-clearance survey.
• Clearing supervised by a Fauna spotter catcher
• Clearing to be sequential as outlined in NCA 1992 requirements.
• Clearing area to be delineated prior to work and no entry to adjacent protected vegetation by personnel or machinery is allowed during works.
• If possible, works will occur outside breeding season.
• Machinery hygiene protocol enforced during works to reduce potential to spread weeds.
• Weed management plan within retained vegetation to ensure Singapore daisy infestation is controlled, as well as other RIP’s.
3. Ensure that, where interfering with koala habitat results in a
significant residual impact, and offset if delivered:
a. at a multiplier of 6 (unless the offsets calculator It is proposed to establish a total rehabilitation area of 1.8 hectares to mitigate impacts to Koala habitat. The rehabilitation will involve:
is a greater amount) and otherwise in • A dedicated Koala Tree Offset planting for Lot 77 which will nominate an offset in suitable habitat which is larger than the koala habitat to be cleared
accordance with the requirements of the of 1.02ha. The rehabilitation area is to be designed to improve and or create vegetated Koala movement corridors and provide for the offset of koala
Queensland Environmental Offsets Policy at the trees.
time of the project approval; or • Within the Koala rehabilitation works a minimum of 0.21ha of designated revegetation aimed to achieve RE 12.5.3 (Eucalyptus racemosa subsp.
racemosa woodland on remnant Tertiary surfaces (DES, 2022), to mitigate the impacts to Endangered RE.
As a significant residual impact is not relevant for this proposed clearing, the requirement for a 6 to 1 offset is not necessary. Council is proposing a 1.8 ha
Offset for the 1.02 ha of area been cleared.
Noosa Landfill & RRC – Response to RFI – Environmental Items (Dec 2023) 5
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b. at a multiplier of 6 (unless the offsets calculator “as above”
is a greater amount) and otherwise in
accordance with the requirements of the
Queensland Environmental Offsets Policy at the
time of the project approval, except for the offset
site location preferences if the public sector
entity has a pre-existing offset; or
c. as an alternate compensatory action, where the N/A
development is for Transport Infrastructure, and
the alternate compensatory action includes:
i. the design, prior to the
commencement of impacts, of a
Koala Management Plan that:
a) demonstrates that the alternate N/A
compensatory action will deliver
a conservation outcome equal
to, or greater than, would
otherwise be achieved through
the delivery of a land-based
offset in 3 (a) or (b) above; and
b) demonstrates that the alternate N/A
compensatory action is based
on proven scientific methods
and contemporary data; and
c) involves an assessment of the N/A
number of koalas at risk from
the development;
d) demonstrates how individual N/A
koala welfare will be managed,
i.e. how will koalas be
protected during the
development.
4. Ensure clearing of koala habitat trees in a KHA are Complies
undertaken under the guidance of a koala spotter where Council will undertake clearing in accordance with a CEMP and a Wildlife Spotter Catcher will be present during all clearing.
koala habitat trees have a trunk of a diameter of more than
10cm at 1.3m above the ground.
Noosa Landfill & RRC – Response to RFI – Environmental Items (Dec 2023) 6
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Item 11 - The following measures will be implemented to minimise and mitigate the impacts
on Ecologically Important Areas (EIA) onsite:
• Establishment of a total rehabilitation area of 1.8ha to mitigate the combined impacts to
Koala Habitat and Endangered RE 12.5.3, which is designed to include the following:
➢ Provision of a dedicated Koala Tree Offset planting for Lot 77 which will provide an
area of 1.8ha located within the Landfill Facility to offset the 1.02ha of land to be
cleared. The rehabilitation area is to be designed to improve and or create
vegetated Koala movement corridors and provide for the 3:1 offset of koala trees
where 3 trees are planted for each 1 cleared.
➢ Within the Koala rehabilitation works a minimum of 0.21ha of designated
revegetation aimed to achieve RE 12.5.3 - Eucalyptus racemosa subsp. racemosa
woodland on remnant Tertiary surfaces (DES, 2022), to mitigate the impacts to
Endangered RE.
• Preparation and implementation of a Site Weed Management Plan which includes weed
management in areas of retained vegetation onsite, and within the landfill site where
weeds are likely to start encroaching i.e., Singapore daisy from the green waste areas of
the landfill. Emphasis will be placed on undertaking weed control works within the buffer
within the landfill area adjacent vegetation; retained vegetated areas adjacent to existing
landfill on Lot 77 SP298776; and areas within proximity to mapped watercourses. The
Site Weed Management Plan is to inform the Site Based Management Plan for the landfill
operations.
• A Koala Spotter Catcher will be required to work through the area prior to commencement
of works and during clearing to relocate any fauna found, to suitable undisturbed habitat.
• Clearing works will be undertaken in a sequential manner beginning in cleared areas and
moving towards areas of retained vegetation to facilitate the movement of Koala and other
fauna out of the works impact zone.
• Site design does not change drainage patterns in relation to the Koala breeding habitat
contained within the impact area. All stormwater flows from the landfill and access roads
are to be directed to a sediment control pond / biobasin or discharge to the south of the
site, away from the remnant vegetation and wildlife habitat area.
• Works to comply with provisions of Construction Environmental Management Plan
(CEMP) which details the methodology for clearing works.
• A Stormwater Management and Erosion and Sediment Control Plan will be implemented
during the construction phase of operation, including water quality monitoring
requirements. A whole of site Stormwater Management Plan is to be developed to inform
the Site Based Management Plan to be in place during the landfill operation phase.
• Site management to conduct regular site inspections during landfill operations in
accordance with the Site Based Management Plan. This includes general site inspections
and audits against approval conditions and standard procedures.
• Construction quality assurance will be implemented during construction of the landfill
facility to provide confidence that the construction meets the design requirements and
specifications.
Noosa Landfill & RRC – Response to RFI – Environmental Items (Dec 2023) Page|7
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• Additional / alternative environmental requirements to be implemented using adaptive
management principles as required.
Item 12 - The new HES Basin and RRA pad will be setback from the adjacent vegetation in
order to allow for maintenance of the grassed buffer zone between the infrastructure and the
adjacent retained bushland. This will allow for the implementation of a weed free maintenance
zone to ensure that there is no transmission of weed species or other contaminants associated
with the operation of the new Landfill infrastructure. The site Weed Management Plan will also
ensure that existing weed infestations are properly eradicated with follow up monitoring and
treatments as specified, in the retained vegetation adjacent to the landfill.
Item 13 - Refer to the updated Flora and Fauna Assessment -Noosa Landfill – Northern
Section – Revision 4 by Native Foresters.
Item 14 - An assessment of impacts on the flora and fauna communities on the site associated
with potential changes to the natural surface water and ground water hydraulic regimes was
undertaken by Native Foresters and Dr Ed Meyer (amphibian specialist) Refer Noosa Landfill
Expansion – Flora and Fauna Survey and Assessment of Impacts on adjacent ecosystems –
Native Foresters - Document No: 190707-FF – Revision 3. Relevant information from the report
is provided below:
Groundwater Level Changes Impacts - Flora:
• Potential fracture/breaching of a shallow, indurated layer with potential impacts on
moisture-dependent species in the lower strata of adjacent ecosystems.
• Moderate impacts to RE 12.3.13
o Melalueca communities typically have standing water on the surface for three months
of the year. Any desiccation resulting from groundwater lowering may lead to a decline
in sedges and a shift towards less water-demanding grasses in the understorey. The
Melaleucas in the canopy will persist in drier conditions.
• All adjacent vegetation and soil may be affected by the groundwater drainage system outflow.
Areas that provide the receiving environment for groundwater flows (RE12.5.3/12.5.4/12.3.13)
may become wetter over time with resulting impacts on community structure i.e. the understorey
may become more dense (shrubs and sedges) and composition i.e. more Melaleucas.
Surface water Changes Impacts - Flora:
• Moderate impacts for RE12.5.3 and 12.5.4 as detailed below:
o Localised waterlogging favouring wet sclerophyll/Melaleuca species around
stormwater drain areas and discharge outlets.
o Shift in vegetation community composition towards species adapted to wetter
conditions, such as Melaleuca quinquenervia and sedges, reducing recruitment of dry
sclerophyll species, predominantly in the understorey. As the canopy species which
define the ecosystem type are likely to persist, this shift to a wetter understorey would
not constitute effective clearing under the Vegetation Management Act 1999.
o Increased growth of ground cover species assisted by increased soil moisture, with
resultant increases in fire fuel loads and more intense fire events. Manage with a Site
Bushfire Plan.
Noosa Landfill & RRC – Response to RFI – Environmental Items (Dec 2023) Page|8
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o Introduction of nutrients and propagules of invasive plant species into typically nutrient
poor soils, leading to an increase in invasive plant species which will need to be
managed through active and ongoing weed control operations.
• Moderate impacts for RE12.3.13 as detailed below:
o Increased/intermittent surface water/ stormwater inputs to the north of the works
impact area and the closed heathland / wetland Land Zone 3 ecosystems that occur
there, are likely to lead to:
▪ Changes in water quality north of the works impact area (i.e. increase in pH,
increase in nutrient concentrations);
▪ Changes to soil chemistry (i.e. altering soil pH levels to a less acidic state);
▪ Changes in vegetation community structure favouring denser understorey of
sedges and ferns.
o Intensification and further spread of existing weed outbreaks which will need to be
managed through active and ongoing weed control operations.
.
The following impacts and potential impacts to native fauna from landfill expansion works have
been identified:
Groundwater Level Changes Impacts - Fauna:
• Excavation for the infrastructure may potentially breach/fracture any indurated material
underlying areas of shallow ‘perched’ groundwater, reducing surface expression of
perched groundwater. This could be detrimental to Swamp Crayfish and/or Wallum Froglet
inhabiting these areas.
• Areas that receive inputs from the groundwater drainage management system may
become wetter over time, with resulting changes in species composition and vegetation
structure. Grasses and dry sclerophyll species may be replaced by sedges and wet-
sclerophyll species. This may improve the habitat value of these areas for amphibians,
although whether Wallum Frog species will be favoured will depend on the quality/pH of
the groundwater.
Surface water Changes Impacts - Fauna:
• Changes to vegetation community composition and structure associated with increased
surface water flows may affect the amenity or suitability of the habitat for breeding, foraging
and dispersal by native fauna:
o Localised waterlogging around HES Basin outlets and proliferation of water-
dependent native flora species (e.g. Melaleuca, sedges and ferns) will enhance the
amenity and suitability of these areas for amphibians and crayfish, however Wallum
Frog competitor species are likely to be favoured by the higher pH typical of surface
runoff.
o The spread of weed species forming dense infestations (e.g. Para grass, Setaria
grass, and Singapore daisy) around stormwater outlets is likely to intensify which will
need to be managed through active and ongoing weed control operations.
• Changes to soil chemistry and water quality associated with increased surface water flows
may potentially alter the suitability of the heathland / wetland habitats for breeding by acid-
specialist Wallum frogs, where the mixing of surface flows with groundwater has a diluting
effect, resulting in higher pH.
• Potential deleterious effects of nitrogen enrichment on amphibians and amphibian larvae
if elevated concentrations (>10mg/L nitrate-nitrogen) are released, including:
o Lethal effects (e.g. increased larval mortality); and
Noosa Landfill & RRC – Response to RFI – Environmental Items (Dec 2023) Page|9
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oSub-lethal effects (e.g. reduced size at metamorphosis; increased frequency of
abnormalities; increased time to hatching or time to metamorphosis).
o Aquatic ecosystem eutrophication which increases amphibian disease risk.
• A long term shift in amphibian community composition towards the more common/tolerant
competitor species (Eastern Sedgefrog, Striped Rocketfrog and Beeping Froglet) may
occur as a result of changes to soil chemistry/water quality.
Item 15 - A comprehensive Weed Management Plan for the site is been prepared which will
detail how the impact of invasive plants will be managed both in the short term through a
targeted eradication program and in the medium and long term through ongoing management
and monitoring of invasive species both on the Landfill site and in the retained natural;
vegetation areas adjacent to the facility.
Item 16 - Noosa Council is committed to delivering a Rehabilitation Offset Plan in accordance
with the Environmental Offsets Act 2014. Council will enter into an agreed delivery
arrangement to deliver this environmental offset. The Council proposed offset area is shown
in Figure 1.
Figure 1 – Proposed Offset Plant Area - NLRCC
The area selected for Offset works is within the Landfill facility in the south-eastern sector of the
site. It is noted that the proposed Offset area has undergone modification with swales and
channels created to manage water flows. These contours will be considered in the site
rehabilitation plan to ensure appropriate species selection consistent with the RE types 12.3.13
and 12.3.5. The large drainage channel which flows to the north is both topographically and
hydraulicly suited to a Melaleuca planting due to its low lying nature. The Scribbly gum species
which are present in the RE12.3.5 can be placed on the mounded areas on the top of the swales.
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Item 17 – A concept Offset Rehabilitation Plan will be provided at the Operational Works application stage of the project. The following points regarding the proposed plan are noted: A The pre clear RE Mapping for the site indicates that the proposed Offset area contained the mapped Regional Ecosystems 12.3.13 and 12.5.3. This is the same as the ecosystem been cleared and is therefore considered to provide a suitable area to provide a like for like Offset planting. B The clearing of 1.02ha remnant vegetation will result in the loss of approximately 500 non- juvenile Koala habitat trees. The proposed Offset Rehabilitation plan will include provision for 1500 Koala habitat trees spaced at 3 metre centres. Additional plantings will include both mid storey and groundcover species. If you require any further information, please contact me on 0407 757 872. Yours sincerely, Simon McVerry Director – Native Foresters Noosa Landfill & RRC – Response to RFI – Environmental Items (Dec 2023) P a g e | 11