General Manager

Byron Shire Council

PO Box 219

MULLUMBIMBY  NSW  2482

 

 

email: council@byron.nsw.gov.au

 

Dear Madam

 

Ref:  DA 10,2007.462.1 Amended Proposal: Splendour in the Grass (SIG), Pacific Highway/Jones Road, Wooyung

 

Friends of the Koala, Inc. is a wildlife rehabilitation group with an energetic involvement in habitat restoration and enhancement as well as research, community education and advocacy.  Our 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.  We have been pursuing this aim for some 22 years.

 

We appreciate the opportunity to make this submission on the Amended Splendour in the Grass Proposal and trust that it will be considered, in conjunction with our original submission of 27 September 2007, so that all the points we raise are taken into account.

 

As a general statement we find little of substance in this amendment.  Neither the Species Impact Statement we asked for, nor any other comprehensive, reliable assessments of proposed impacts have been forthcoming.  Whilst the ecological assessment includes a seven-part test for the koala, the test is inadequate and in places incorrect  Thus this amended proposal is merely tweaking a flawed development which, quite frankly, is located in the wrong place for the Shire’s koala populations which are already ‘on the brink’.

 

The specifics of our objection to the Amended Proposal are:

 

The proposed Marshalls Ridge (Jones Road) ‘overpass’ is located in a 7(k) Habitat Zone and is contrary to the zone’s objectives and the special provisions of clause 38A (Cross Hatching (CH)) of the Byron Local Environment Plan as the crossing will be permanent infrastructure requiring tree removal, earthworks, cut and fill, rock walls, culverts, etc. which will severely impact on a regionally significant wildlife corridor which enables the movement of animals.

 

·        The assessment of the barrier effect resulting of the proposed ‘overpass’ crossing is completely inadequate. The author of the ecological assessment bases his entire assessment on a 3 day effect which is clearly incorrect. The barrier effect will be far more substantial than assessed. The DA is unambiguous that a substantial ‘bump in’ and ‘bump out’ period is required and that period of time will be at least one month if not longer.

 

·        The seven-part test for the koala is incorrect. At clause d(ii) the ecological assessment incorrectly states that no area of habitat for the koala is likely to become fragmented or isolated from other areas of habitat as a result of the proposed action. This is incorrect and invalidated because an area of habitat will be fragmented and isolated.  

 

·        Further, at clause f the assessment does not identify the Threat Abatement Plan or the Draft Recovery Plan relevant to the Koala. The proposed road ‘overpass’ is not consistent with the Threat Abatement Plan or the Draft Recovery Plan for the species. In this regard the ecologically assessment again is incorrect.

 

·        There is not adequate data to assess that a significant impact on the koala as a result of the proposed development is not likely to occur and the assessment is too flawed to be relied upon.

 

In conclusion, Friends of the Koala is very disappointed in the calibre of the impacts assessment work in relation to the koala.  The application brings into question the proponent’s intentions and capacity to address sensitively the footprint of this trial event. 

 

Again we urge Council to insist that the developer prepares a Species Impact Statement before further consideration is given to the venture.

 

 

Yours sincerely

 

 

 

 

Lorraine Vass

President

14 May 2008