26 July 2017 Mr David Mooney Team Leader Secretariat Planning Assessment Commission Level 3, 201 Elizabeth Street, Sydney NSW 2000 Dear David, SSD 15_7228, SYDNEY ZOO On behalf of Elanor Investors Group, the owners and operators of Featherdale Wildlife Park, we make the following response to the Social Impact Assessment by UTS for the Sydney Zoo dated 11 July 2017 (UTS SIA) and the response of Sydney Zoo dated April 2017 (Zoo RTS) lodged in support of the above SSD application. In summary we submit: 1. That the PAC cannot be satisfied with the response provided by the proponent to its request for additional information, and the PAC should not accept the UTS conclusions; 2. The development application should be refused for the reasons outlined in the Urbis letter dated 3 November 2016 because there is likely to be a material impact on the visitor numbers to Featherdale (an impact not denied by the UTS SIA although ranked as a lower risk based on UTS’s but not Urbis’ predictions) and therefore on the ability of Featherdale to maintain programs which have material positive environmental, economic and social benefits. These programs have developed over a 45 year period and cannot readily be replicated in the locality. 3. If the PAC determines to approve the development application, it should only do so with the imposition of a condition prohibiting the exhibition of any native animals so that the operations of Sydney Zoo and Featherdale are differentiated and complementary. Sydney Zoo response to PAC request for further information We have not been provided with a copy of the PAC request for further information, but have sought to understand the request from the contents of the Zoo RTS. We note that the Zoo RTS is heavily redacted and it is not possible to comment on the proposed species list. However, we understand from the other documents submitted by Sydney Zoo and the Zoo and Aquarium Association’s Collection Online Planning System list submitted by Sydney Zoo (attached at Annexure C) that the proposed native animal exhibition will cover about 25% of the exhibition space and be diverse (at least 40 species), with proposals to exhibit kangaroos, wallabies, wombats, emus, koalas, insects, reptiles and other nocturnal natives, Tasmanian devils and quolls. We submit that this diversity of native animals does not sufficiently differentiate the Sydney Zoo offering from Featherdale. Rather it PAC Submission (Final) largely replicates the key offerings at Featherdale. The Urbis Socio Economic Impact Report dated November 2016 (Urbis 2016 Report) indicates that the key reasons for visitors attending Featherdale is to touch animals that they like, close to home and at a good price. More alarmingly, it is noted on page 71 of the Zoo RTS that all Australian species are available but that not all exotic animals are available. This means that there is nothing stopping Sydney Zoo operating with a majority of native animals when the only proposed condition on exhibition of native animals is that the area be limited to 1.6ha. For this reason the PAC can have no comfort that there will be differentiation and no impact on Featherdale’s programs unless there is a condition restricting the exhibition of native animals. Social Impact Assessment by UTS (UTS SIA) We attach to this letter detailed responses to the UTS SIA – Annexures A and B (in the footnotes). In summary: 1. The UTS SIA has not been prepared in accordance with the SIA and CBA Guidelines because it does not meet many material requirements of those Guidelines. For instance, the SIA makes no attempt to quantify whether the benefits resulting from the Sydney Zoo development would outweigh its negative economic and social costs/impacts. Therefore, the UTS SIA conclusion that the Sydney Zoo will result in net benefits cannot be relied on. 2. The online survey and stakeholder consultations relied on in the UTS SIA are poorly designed, biased and unreliable. UTS is not neutral in the questions it has asked, has bias in the selection of stakeholders interviewed (includes former Featherdale employees and Sydney Zoo employees), does not draw a sample from the relevant market of regular animal attraction visitors, and does not independently verify proponent information. This makes the results misleading and they should be given little if any weight. 3. The Co-existence Scenario is the least likely scenario. Sydney Zoo has told Featherdale that it wants to match Featherdale’s offering but at Sydney Zoo. There is no intent by Sydney Zoo to co-exist. The conclusion that the Co-existence Scenario is the most likely scenario is not based on robust empirical evidence. The Hill PDA and Urbis Reports demonstrate the risk of closure or reduction in environmental and social programs is higher. 4. The SIA relies on generic academic research about tourism clusters where apparently differentiation is stated as the key factor to success. The proposed condition B6 limiting native animal exhibits to 1.6ha does not ensure differentiation where Sydney Zoo proposes 40 Australian species with no limit on the species being exhibited. Sydney Zoo intends to match not differentiate the key native animal offerings of Featherdale being “hands on” experiences with native animals and particularly mammals and marsupials (see Urbis 2016 Report findings). Given the very close physical proximity between Sydney Zoo and Featherdale, true “thematic complementarity” will only occur where one operations has exotic animals and the other native animals. Where one operation offers A and the other A + B, it is common sense that A will receive less visitors. This common sense outcome is reflected in the outcomes of the random survey in the Urbis 2016 Report. 5. The SIA accepts at face value that the social, educational and environmental programs proposed by Sydney Zoo will be implemented. The programs conducted by Featherdale PAC Submission (Final) 2 have taken 45 years to develop and no other zoo anywhere has looked to fill the role on the tiger quolls or its endangered bird programs. Not one of the “programs” attributed to Sydney Zoo by the UTS SIA are the subject of a statement of commitment or draft condition of consent except: (a) That Sydney Zoo must consult on regional tourism initiatives (C9). “Consultation” does not ensure a positive outcome. (b) That Sydney Zoo is to collaborate with Muru Mittigar and registered Aboriginal parties on an Aboriginal heritage experience strategy and demonstrate an ongoing role of Aboriginal people. There is no commitment to the 10% employment target or that participation will be materially significant (C21). 6. The majority of potential consumers would not attend both Sydney Zoo and Featherdale, and would not prefer Featherdale over Sydney Zoo. The practical reality is that potential consumers will be constrained (for reasons of cost, time and interest) from attending both facilities. 7. Sydney Zoo will not increase overall visitor participation. There is no compelling evidence presented that the market is large enough to support both Sydney Zoo and Featherdale. The UTS conclusion is flawed and not based on any robust empirical evidence. The Urbis market research on the other hand frames and links questions regarding future usage to real behaviour, making it more robust than the UTS survey. Most of the visits to Sydney Zoo would be a re- direction of already existing business from other facilities. The majority of the visits to Sydney Zoo will not be additional demand and will not generate additional economic benefits. Therefore, the UTS SIA like the KPMG and HillPDA reports overstate the extent of economic and social benefits claimed. 8. Featherdale’s social, education and conservation programs have significant material value. The fact that certain programs offered by Featherdale are not ‘unique’ does not necessarily mean that they do not provide value for the purposes of the PAC’s determination as to whether Sydney Zoo will give rise to overall adverse social impacts in the locality. 9. Featherdale’s social, education and conservation programs cannot be readily replicated in the locality which is the Blacktown LGA and Western Sydney Region which will be grossly contrary to the interests of Western Sydney and the environment, specifically conservation biology.. There is no compelling evidence presented that the Featherdale’s social, education and conservation programs will be replicated at Sydney Zoo. 10. Approval of Sydney Zoo will result in significant net adverse social impacts in the locality because it will most likely result in the closure of Featherdale, Featherdale’s social, educational and conservation programs have significant value, and these programs will not be replicated by Sydney Zoo or any other facilities in the locality. It is evident from the CPOS species list that Featherdale is heavily involved in active breeding programs and not just for display purposes, more so than indicated by Sydney Zoo in its CPOS species list request – Annexure C. 11. The SIA does not address or respond to the matters identified in the Urbis Socio Economic Impact Report dated November 2016. PAC Submission (Final) 3 Accordingly, the PAC should give greater weight to the Urbis 2016 Report by refusing the application for the reasons in our letter dated 3 November 2016 being: 1. The proposal is inconsistent with the aim of the SEPP (Western Sydney Parklands) to deliver ‘beneficial social and economic outcomes to Western Sydney’. 2. The proposal will result in unacceptable adverse social and economic impacts in the locality associated with the likely closure of an existing facility that provides tourism, employment, environmental and social services to Western Sydney. 3. The suggested differentiation of the proposed zoo (Sydney zoo) to the existing zoo (Featherdale) is not certain or enforceable unless a condition was imposed requiring no native mammals to be displayed.