The Manager

Planning and Aboriginal Heritage Section

Environment Protection and Regulation Group

Department of Environment, Climate

 Change and Water

Locked Bag 914

COFFS HARBOUR  NSW  2450

 

email: neb.recp@environment.nsw.gov.au

 

Dear Sir

Re: Draft Far North Coast Regional Conservation Plan

Thank you for the opportunity to comment on the draft Plan. This submission is written on behalf of Friends of the Koala’s 370 members. We are a voluntary specialist koala rehabilitation group with an energetic involvement in koala rescue, health, habitat restoration and enhancement as well as advocacy, research, and community education. We have been engaged in this work for some 23 years on the Far North Coast of NSW.

Friends of the Koala is licensed by the NSW Department of the Environment, Climate Change and Water to rescue, rehabilitate and release koalas in the six local government areas covered by the Plan. In the year 1 July 2008 to 30 June 2009 we dealt with reports of well over 550 koalas.

Friends of the Koala’s mission is conserving koalas, particularly in the Northern Rivers Region of New South Wales, in recognition of the contribution the species makes to Australia’s biodiversity and its value to the local community.

Throughout 2005 we participated vigorously in the community consultative process associated with drafting the Far North Coast Regional Strategy (the Strategy), pointing out the fragile status of the region’s remaining koala populations. We were disappointed that the Strategy did not take more account of our input, particularly in regard to the remnant coastal koala populations.

In a submission forwarded to the then Minister for Planning, The Hon. Frank Sartor, in May 2006 we supported the requirement of a statutory Regional Conservation Plan which, in our view, “…should identify, protect and enhance areas of high conservation value…and be informed by a fully funded biodiversity assessment, with conservation targets and standards, including protection of biodiversity on private property.”

The Koala’s Plight

The Far North Coast is acknowledged as a major stronghold for Koala Phascolarctos cinereus. The species is widely distributed throughout the region and there is ongoing concern for its survival (you may be aware that the Australian Koala Foundation has recently estimated the maximum number of koalas remaining in the electorates of Richmond and Page at 1,180 – www.savethekoala.com/images/conservation/koalanumbers/nswelectorates.jpg)

As is eloquently pointed out in the Plan, habitat destruction, fragmentation and biodiversity loss, continues at an alarming rate in the North Coast Region. This loss is occurring in private and public lands.

Unfortunately there are no Comprehensive Koala Plans of Management and few tree preservation orders in place in local government areas on the Far North Coast. Expertise and resources within local councils to deal appropriately with land-use issues involving koala habitat are very patchy.

There is little by way of scientific studies into koala population and health status. The latter is of particular concern to Friends of the Koala as 65-70% of animals we admit into care are suffering from disease most notably associated with chlamydiosis and koala retrovirus (KoRV). (We strongly recommend that the impact of disease be referred to in Case Study 3: Koala, p.54).

Research is suggesting that koalas are likely to be subject to further stresses from the impacts of climate change that may affect habitat quality.

State Environmental Planning Policy No. 44 – Koala Habitat Protection (SEPP 44) is in urgent need of revision.

The loopholes in the Native Vegetation Act 2003 of routine agricultural maintenance activities (RAMAs) and a basically self-regulated private native forestry code of practice ensure continuation of legal habitat clearance.

Forest Dieback is rife. Exploitative logging regimes in the Forests NSW estate continue with widespread impacts on biodiversity (see Forest authority accused of overlooking destruction, SMH 13 Jan.2010, p.5).

The existing regulatory framework and environment is weak. Without a rigorous, mandatory approach to address these sorts of problems it seems to us that there is little chance of the Plan’s aims being achieved.

Comments on the Regional Conservation Plan

We acknowledge the Plan’s ambitiously innovative approach set out in the Introduction and note that its conservation assessment and recommendations are based on the potential loss of native vegetation from areas identified for development by the Strategy as well as the high conservation value vegetation in areas that are currently zoned for development purposes. We note too that the Koala is identified as a priority fauna species which is and will continue to be a significant loser of habitat.

In general the idea that offsets (including the vaunted but unproven BioBanking Scheme (see Credit crisis strikes green bank, SMH 9-10 Jan.2010, p.7)) can compensate for biodiversity loss in areas of core koala habitat is simplistic, underestimating both the complexity of ecosystems and the social organisation of koalas which are the subjects of considerable on-going research.  

Priority and Other Focus Areas

It is difficult for an experienced, voluntary group to understand how the notion of identifying regional conservation priority focus areas and other offset focus areas and a range of voluntary mechanisms to achieve Koala conservation and management will halt the decline of this widely distributed and cryptic species.

A number of doubts and questions spring to mind.

Using the Cudgen Coast (priority) and Byron Bay-Broken Head (other) areas as examples relevant for the Koala, both supporting relatively small, remnant populations, we make the following points.

The present situation regarding habitat destruction on the Cudgen Coast is bad enough: wildfires in 2006 and towards the end of 2009, on-going illegal clearance and lawful disturbance brought about by on-going development and infrastructure, camphor-harvesting and other poorly regulated activities.

The impact of 7,500 additional people at Kings Forest can be expected to overrun any protective measures introduced, no matter how well-intentioned. The sheer weight of compromising human behaviour, including increased vehicular traffic, uncontrolled companion animals, vandalism and fire-lighting will ensure failure.

To a lesser degree the same can be said about Byron Bay-Broken Head. As we write, the koala assessment on a site at Tyagarah which will be the home of a major international music festival (and probably other events as well), is revealing an extraordinary population density. The koalas are isolated by the Pacific Freeway (which also accounts for numerous fatalities despite the fencing) and natural barriers.

Whilst the Byron Bay-Broken Head area may not be subject to the same degree of sustained pressure of human occupation as further north, it is naïve to think that the relatively low-level of disturbance which exists at present will be maintained. The aforementioned festival attracts a patronage of some 26,000 people over its four-day duration.

The Plan recognizes that the value of the habitat of a threatened species is difficult to incorporate into a regional assessment. We suggest there is a place for clear guidance that species-specific focus areas will be essential.

Urban Lismore which presently supports a significant koala population is an example where most of the growth predicted for the local government area (8,000 additional dwellings) will occur in and around the city. Koalas can be expected to continue being displaced over time. Designation of a Koala Focus Area at Monaltrie-Tregeagle-Wyrallah, identified as the Koala Critical Precinct in the Draft Comprehensive Koala Plan of Management for the South-eastern Portion of the Lismore Local Government Area, would contribute significantly to enhancing primary habitat and perhaps sustain the urban population into the future.

Biodiversity Offset Guide

Given that strategic land-use planning by local government is one of the ‘conservation mechanisms’ referred to, we are very surprised that SEPP 44 is not specified in the repertoire.

Incorporation of the results of recent research into koala habitat would undoubtedly improve the SEPP’s effectiveness. Nevertheless, its preference for the preparation of landscape-scale Comprehensive Koala Plans of Management (CKPoMs) is incontestable. Although a couple of councils in the region have embarked on preparing CKPoMs none are in place. In this context we assert that since the SEPP’s introduction 15 years ago, local government has presided over the decline of the Koala through inadequate planning and case by case development decisions.

We believe the Regional Conservation Plan should be sending a clear message to local government that the preparation and implementation of CKPoMs under SEPP 44 is a basic tenet of the Approved NSW Recovery Plan of the Koala (Phascolarctos cinereus) published twelve months ago.

We strongly recommend that biological certification not be granted to any North Coast council unless it has a CKPoM in place.

Conclusion

We agree that identification, protection and management of high conservation value lands on the Far North Coast are essential. The Plan’s authors are honest enough to express caution as to the capacity for the basically speculative and voluntary approach being advocated to achieve it.

Attempting to mitigate the impact of 60,400 additional humans on the Far North Coast landscape from within the existing legislative and policy framework appears to us a recipe for perpetuating failure.

The emotional and financial cost of failed strategies, poor planning decisions and bureaucratic indifference and compromise which characterizes management of the Koala, a pre-eminent, and declining Australian species, is, in the view of our dedicated members, an on-going disgrace.

Unfortunately, we can see nothing in the draft Plan that will arrest the decline in the region’s koala habitat and population health. Nevertheless, our comments and suggestions are made in good faith. We trust they will be received as helpful and constructive.

Yours sincerely

 

Lorraine Vass and Noel Parker

 on behalf of the Management Committee

22 January 2010