ATTCH 2 - IR Response - Ecological and Bushfire IR Response (Cardno)

: WE17035                                                                    4
13 November 2017


At a meeting with Council held on the 18th of October 2017, Council clarified that its concern with the analysis
presented within the Ecological Assessment Report are that:

     a) the vegetation on the Site is classified on relevant vegetation mapping as being comprised of remnant
        RE12.2.14 - Strand and fore dune complex;

     b) RE12.2.14 is listed as being a “rare or naturally restricted” vegetation community within the Vegetation
        of Noosa Shire (Ed 2, 2003); and

     c) on that basis the entire Site warrants classification as an Environmental Protection Area.

In respect of this particular issue the following points are noted.

     a) The analysis presented in Table 5-3 in Section 5.3.1 of the Ecological Assessment Report (Cardno, 8
        August 2017) specifically recognised the Vegetation of Noosa (Ed 2, 2003) classification of RE12.2.14
        as being a “rare or naturally restricted” vegetation community.

     b) An analysis of data concerning the extent and distribution of different vegetation types contained within
        the Vegetation of Noosa (Ed 2, 2003) was undertaken to verify that the classification of RE12.2.14 as
        a being a “rare or naturally restricted” vegetation community was in fact warranted.

     c) The results of that analysis are summarised in Table 5-3 of the Ecological Assessment Report
        (Cardno, 8 August 2017) and formed the factual basis of the submission that the classification of
        RE12.2.14 as a being a “rare or naturally restricted” vegetation community is not warranted.

     d) Given that Council was not satisfied with that previous analysis, a more detailed analysis of the data
        presented in the Vegetation of Noosa (Ed 2, 2003) comparing the variation in extents of the 62 different
        RE types classified as being either “rare or naturally restricted” or not, was carried out. The results of
        that analysis, which excluded RE12.2.14 to avoid confounding the analysis, is presented in the Table
        1-1.

           Table 1-1          Extents of REs in Noosa Shire relative to their “rare or naturally restricted” status
                                                  Total Area within Noosa Shire (Hectares) – Sourced from Table 15.2 in
                                                                     Vegetation of Noosa (Ed 2, 2003)
             “rare or naturally
             restricted”                       0 Quartile                                      2nd Quartile                  4th Quartile
                                                                      1st Quartile                            3rd Quartile
                                              (Minimum)                                         (Median)                     (Maximum)

             No                                     12                     367                      702         1,651          2,588

             Yes                                    4                       25                      55           107           3,668

             Yes (RE12.9-10.1
                                                    4                       25                      53           102             267
             adjusted)

           The RE12.9-10.1 adjustment row presented in Table 1-1 is required due to the fact that RE12.9-10.1
           is the most extensive RE within the Noosa Shire encompassing an area of 3,668 hectares and yet was
           classified as being “rare or naturally restricted”, which it clearly is not.

           The analysis presented in Table 1-1 confirms the previous findings that RE12.2.14, which has an
           extent of 606 hectares, has an extent:

                      similar to the Median extent for all RE classified as not being “rare or naturally restricted”; and

                      more than twice the Maximum extent of REs classified as being “rare or naturally restricted”.

     e) Furthermore, a more recent analysis of the conservation significance and associated protection
        requirements for different vegetation communities within the Noosa Shire has been completed by
        Ecological Australia Pty Ltd on behalf of Council and the findings of that assessment are presented in
        the Noosa Biodiversity Plan - Biodiversity Assessment Report (December 2016). That report is “ the



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