26^th June 2008

 

Mr Paul O’Sullivan

General Manager

Lismore City Council

43 Oliver Avenue

GOONELLABAH  NSW    2480

 

 

Dear Mr O’Sullivan,

 

Re: DA 08/233: Champion’s Quarry

 

In relation to the above Development Application, the Friends of the Koala Inc (FOK) would like to register its objection to the development as proposed and provides the following comments:

 

1.         History of Koalas at Tucki Tucki

 

The Koala population at Tucki Tucki has a long history of involvement and concern for local residents and citizens of the north coast of NSW. This history of human concern about the Tucki Koala population dates back to the formation of the Tucki Tuckurimba Koala Preservation Committee in 1958. Together with Lismore Rotary the Committee’s members developed and maintained the Tuckurimba Koala Sanctuary. The area was gazetted as a Fauna Reserve in 1963 and the National Parks and Wildlife Service (NPWS) took over control in 1967, establishing the Tucki Tucki Nature Reserve. The Reserve is in close proximity to the proposed quarry development.

 

Records held by FOK show that Koalas recorded and dealt with by the group in the Quarry vicinity (Tucki Tucki/Tuckurimba) from 1989 to February 2008 are 150 in number. Of this number 84 were deceased and 19 were confirmed car hit fatalities in the same area of Wyrallah Road. These numbers could be considered very conservative, as they do not include any animals that could not be located by Koala rescuers or animals that were not reported.

 

In relation to the local populations of the Koala we note that NPWS (now part of the Department of Environment and Climate Change (DECC)) as land managers in the locality are managing their lands for the primary purposes of Koala conservation, protection and monitoring. The specific management objectives for the Tucki Tucki Nature Reserve are to:

 

·                 conserve, protect and monitor the reserve’s Koala population;

·                 manage vegetation in the reserve, including fire regimes suitable for Koala habitat;

·                 ensure that the use of the reserve is principally for scientific and educational purposes compatible with Koala conservation and other values of the reserve;

·                 encourage regeneration and protection of Koala habitat on adjoining lands;

·                 recognise the long standing contribution of the community in the conservation of Koala habitat in the area and continue to involve the community in the management and protection of the reserve’s values;

 

·                 protect the traditional and contemporary Aboriginal cultural heritage values associated with the reserve in partnership with the local Aboriginal community; and

·                 encourage appropriate research into the values of the reserve, and in particular, the Koala and its habitat.

 

 The Plan of Management identifies the following threatening processes to the Tucki Koala population:

Loss, fragmentation and degradation of habitat are the major threats to Koalas in the area. Most Koala deaths in the reserve and surrounding area can be attributed to disease, cars, fire and dogs.

 

As an indication of the significance of the Tucki Koala population the Tucki Tucki Nature Reserve, in close proximity to the quarry site, is identified on the State Heritage inventory, in recognition of the local community’s long history of involvement in the conservation of Koala habitat. It is also listed in the Lismore Local Environmental Plan 2000 as a Heritage Item.

 

2.         Koala Survey Methodology

 

The ecological assessment of the site undertaken involved insufficient time, a lack of seasonal replication, inadequate survey effort, inadequate reporting and invalid impact assessment.  The assessment fails to conform to “Threatened Biodiversity Survey and Assessment: Guidelines for Developments and Activities” (DEC (now DECC) 2004), which sets standards for undertaking such an assessment in relation to statutory requirements (including the Threatened Species Conservation (TSC) Act 1995), and it is not adequate for the purposes of an Environmental Impact Statement for a proposal of this scale.

 

The EIS does not provide any data to indicate the results of any of the searches for Koala scat and scratch marks on the site. No tracking of Koalas in the area was undertaken to provide evidence for the statement in the DA that ….. it is possible that the site forms part of a Koalas home range and they may occasionally traverse the site.

 

It is claimed that the Koala was recorded off site but no records are provided to assist in evaluating the potential use of the site by the Koala. For the purpose of this submission we have been informed by a renowned Koala expert that he personally radio-tracked a Koala through the eastern portion of the site in the 1990’s.

 

FOK members have been involved in assisting professionally mounted Koala surveys previously and would be willing to do so again in order to fully survey the usage of the site by Koalas.

 

3.         Wildlife Corridor Value

 

As indicated above, statements are repeated throughout the DA that the site may be used by Koalas as part of their normal movement through their territory.  No evidence has been provided in the DA about this. The DA includes a statement that 19 Koalas were reported sighted on one day in Hazelmount Lane, immediately adjacent to the quarry site. Surely this constitutes a significant Koala colony in the area and should have involved extensive and longer-term monitoring of Koala movements over the quarry site and surrounding areas.

 

Research has shown that habitat links for Koalas include both forested and mainly cleared land as studies have shown that Koalas will travel over cleared land containing only scattered trees and the area in question forms an integral habitat link in the area. Koalas live in complex social groups and contrary to popular opinion, they are not migratory animals. Koalas are highly territorial and in stable breeding groups, individual members of koala society maintain their own "home range" areas. A territory is usually defined by a number of mature food trees available to the colony and can be up to 25-50 hectares in size. The further apart the food trees, the larger the territory and therefore the further Koalas will travel.

 

The development will lead to the disruption of Koala movements along the corridor, isolation of habitat, and place the Koalas moving through the area at increased risk of dog attack and road strike. For such a fragile local Koala community struggling with these risks and Chlamydial infection, which is exacerbated by stress, this development poses significant effects on their survival. It is pertinent to note that there is now reliable data to demonstrate that even a slight increase (eg 1-2% above natural levels) in Koala mortality at the population level can be enough to tip the scales in favour of decline.

 

4.         Environmental Planning and Assessment Act

 

In accordance with the Environmental Planning and Assessment Act in particular s79C (1) (b)(c) &(e) Council must assess the DA in this overall context of the locality within which Koalas are featured and consider the appropriateness of this type of mega quarry on the site in the locality.  

 

5.         Tree Planting

 

The DA includes a proposal to plant a 10 metre wide Koala food tree corridor on the Northern side of the quarry site. FOK considers that the siting of this corridor is ill conceived and will lead and situate Koalas adjacent to a known black-spot for car hits, Wyrallah Road. More work needs to be done on monitoring Koala movements in the area to ensure any compensatory tree plantings are appropriately placed.

 

6.         Other Threats and Abatement Measures

 

The 7-part test has underestimated the potential impact of the quarry development on Koalas. In particular the proposed access to and from the site will be along Wyrallah Road the additional traffic generation as part of the operation of the Quarry is substantial (up to 24 trucks per day) will pose additional threats to koalas moving through the area as described above, and unreasonable given Wyrallah Road is a known black spot for Koalas and any escalation of traffic volume clearly increases the probability of Koala road strike, more so given the proximity of the Tucki Tucki Nature Reserve, the adjoining flood reserve, and revegetated farm land.

 

The DA does not include any provisions to provide Koala exclusion fencing from Wyrallah Road, the quarry access road or any of the quarry working sites.  There was no statement on how the additional noise will impact on the koala population or whether increased dust levels could impact on the palatability of koala food trees on adjacent lands. There was no proposal to provide any wildlife bridges, underpasses or overpasses to ensure wildlife corridors are maintained and there was no proposal to ensure that koala monitoring was undertaken by a qualified wildlife biologist for the next 5 or so years to ascertain the impact on the local koala population, particularly around the Hazelmount Lane area.

 

 

In conclusion our opinion is the DA has ignored or underestimated the impact of the proposed development on the significant koala population in the area surrounding the quarry.  The statement made in the DA that… the proposed excavation occurs only within the subject lands and will not impact on flora and fauna on adjoining lands… is at best ill-informed and in our view, very untrue.

 

Koalas in northern NSW have a very delicate hold on existence at present. They have a complex social structure, very specialised feeding habits, are very difficult to re-locate because of their well-defined ‘homing’ instinct and do not react at all well to the stresses of habitat removal. The major threats to Koalas in the region continue to be habitat removal, ensuing disease, deaths due to road kills and dog attacks.

 

This proposal will exacerbate all of these critical mortality factors. Serious consideration needs to be given to whether the effects on the Koala population by this development have been adequately considered and catered for.

 

Yours faithfully

 

 

 

Mark Wilson

Trees Officer

Friends of the Koala Inc