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'~,., ~"""\.~",",,~~'E A....~ ~ 19 014 N Buderim, Qld 4556 Sere /' Ovember 2014 M'dore

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'~,., ~ SCC CORRESPONDENCE 11\\111\1\11 \\1\1 11\\\ 11111 \\1\\ 111\1 \1111 1\\1 1\\1 ~.- :-.- ' !:: X0130357 'c' ~\. RECEIVED -:: '~,., ~"""\.~",",,~~'e a....~ ~ 19 014 N Buderim, Qld 4556 seRe /' ovember 2014 M'dore /.... NOV;-r -'('(, Devei81~,J~'~t - ,", Sunshine Coast Council r ,...I nJ. .1,.r'I'I"".\ Attn: Mr Marc Cornell -U~1i IlC'r Planner Principal Development 19 Locked bag 72 NOV 2014 SUNSHINE COAST MAIL CENTRE QLD 4560 r\/ ..~ I ",10."....."'0'" or~i ~.,!.,..r li\....OJ"r:l,.I t.; Dear Mr Cornell, '. _~>_.,. -'-------- RE: PROPOSED DEVELOPMENT ON LOT 200 ON SP269010 FROM ONE (1)RESIDENTIAL LOT INTO TWO (2)RESIDENTIAL LOTS (APPLICATION NO. REC14/0057) ~'CJ I,~~-....~~-....... ,lot owner and resident at-"\."\.. ~,,~~~ C-~ am writing to you in opposition to the proposed development on Lot 200 on SP269010 from one (1) Q \:)\..::>~~.. residential lot into two (2)residential lots (application no. REC14/0057). My opposition is based on: 1. Threatened species occurring on the site 2. The development cannot comply with the intent of applicable Planning Areas, Precincts and Precinct Classes, and Codes of the Maroochy Plan 2000. 1. Ecology I am aware, having seen and heard, or it has been reported to me by neighbours, that both threatened flora and fauna occur on and/or traverse through the whole of this site. These species include, but are not limited to, the following: Common name Scientific name Status EPBC Act NC Act koala Phasco/arctos cinereus V V (SEQ Bioregion) tusked frog Ade/otus brevis - V green-thighed frog Litoria brevipa/mata - NT Richmond birdwing butterfly Ornithoptera richmondia - V elf skink Eroticoscincus graci/oides - NT Richmond birdwing vine Pararist%chia praevenosa - NT Notes: E - Endangered, V - Vulnerable, NT - Near Threatened Quite prolific numbers of Richmond birdwing butterfly can be seen at times along the edge of the forest suggesting that the entire habitat, not just the remnant riparian notophyll vine forest, is very suitable for the butterfly and the preferred larva food plant, the Richmond birdwing vine. Also, only recently it was reported that a koala was seen in Buderim Forest Park in the vicinity of the proposed Lot 2. Koalas have also been seen traversing through backyards and crossing the road to gain access to habitat. The location of the development is immediately adjacent to two stream order 1 waterways that converge to form a stream order 2 waterway that discharges into Martins Creek within Buderim Forest Park at the eastern end of the proposed development. The proposed Lot 2 house and fire buffer 1 "-..... ~ footprint essentially means the entire width (north to south) of the lot in the vicinity of the junction of the two stream order 1 waterways will be cleared, effectively severing connectivity through the remnant open eucalypt forest with rainforest understorey because of the removal of the eucalypt canopy species as a significant component of the connectivity for specific species. In addition, the proximity of the clearing and earthworks for this development to the stream order 2 waterway raises serious concerns for mitigating impacts in relation to erosion and sediment control and stormwater runoff from the finished development, not just to the waterway but also to the fringing remnant riparian notophyll vine forest and the species dependent upon it. I have reviewed the ecological assessment report (EAR)prepared by North Coast Environmental Services, 2014 for the proposed development and raise the following concerns with that report: a) It is primarily a flora assessment report and not an ecological assessment report as there was no field assessment of fauna for the site. A desktop search reviewed historical fauna data for the site, however, did not include a field assessment for the threatened species. In this respect the report is deficient and of limited value, and a proper assessment of the impact of the development cannot be undertaken without a full detailed fauna assessment for the trigger species. This requirement though may be redundant and an unnecessary cost because I believe there is sufficient evidence confirming the presence of some, if not all, of the identified threatened species, and there may be more, such that the development cannot achieve compliance with the Maroochy Plan 2000, as detailed below, and should be refused b) Connectivity is discussed in very general terms but does not elaborate on the value of each of the regional ecosystems present for their individual significance to the corridor and the habitat that is provided for the movement of specific threatened and non-threatened species more suited to either habitat. The report states that "The capacity of the site to continue to act as a functional component of the pre-existing east-west wildlife corridor in the locality would be retained under the proposal. This statement has no basis in fact and is not supported by referenced published scientific research literature. Species with a preference for a more open forest community are more likely to favour movement through the remnant open eucalypt forest with rainforest understorey rather than the remnant riparian notophyll vine forest. Additional clearing of the open eucalypt forest for the proposed Lot 2 considerably increases the threat of fragmentation and will cause major disruption to these species' normal movement and feeding patterns through this landscape. The retained expanse of vegetation within the site is NOT considered sufficient to continue to support potential wildlife movement through the site. In this respect the development cannot achieve compliance with the Maroochy Plan 2000, as detailed below, and should be refused c) Subdivision of the Lot 200 into two lots (Lot 1 (east)and Lot 2 (west)changes the assessment of the extent of clearing such that it should be assessed per new lot (as subdivision occurs prior to construction) rather than on the original Lot 200. On this basis the proposed Lot 2 is actually likely to be cleared to about 50%. The impact of the development on habitat for fauna is discussed claiming only 17% of the original site will be cleared. This is clearly misleading and based on this figure the report very subjectively determines that "the expected impact to habitat resources for current fauna assemblages is anticipated to be only minor". This statement has no basis in fact, is completely unsubstantiated, demonstrates a total lack of understanding of the impacts of this form of development on these species, and is not supported by referenced published scientific research literature. The nature and extent of the development across the width of the proposed Lot 2 (north / south) and edge effects will likely have a considerable impact on the habitat resources for current fauna assemblages. In this respect the effective clearing / degradation of the site will be greater than 30% and, therefore, the development cannot achieve compliance with the Maroochy Plan 2000, as detailed below, and should be refused d) Assessment of the proposed Lot 2 development against the planning scheme codes appears grossly deficient and lacking in details to effectively assess compliance with the acceptable measures. Indeed, some statements appear to be completely erroneous and unsubstantiated. 2 2. Maroochy Plan 2000 Review of the Maroochy Plan 2000 confirms the site is mapped as: a) A Special Management Area (Nature Conservation Management Area) on Regulatory Map 1.1 Nature Conservation Management Areas The importance of the regional ecosystem vegetation communities associated with the development are highly significant in terms of their relationship to nature conservation and habitat connectivity around Buderim Forest Park and the wider natural areas retained around the Buderim escarpment. Both regional ecosystems are interlinked and provide ecosystem services to each other and the adjoining areas, and cannot be considered separate entities to be carved up just because one may be classified differently at a State or National level b) A Special Management Area (part of proposed Lot 2 is mapped within 50 m of a waterway while the majority of the remainder of this lot is mapped within 100 m of a waterway) on Regulatory Map 1.2 Waterways Two stream order 1 (S01)and one stream order two (S02)waterways flow through and adjacent to the proposed Lot 200 with both the 50 m and 100 m buffer zones extending across the majority of the proposed Lot 2 development site. These tributaries discharge directly into Martins Creek, which flows adjacent to the site in the adjoining Buderim Forest Park and, which is mapped as a Local Wetland at this junction on the Wetlands and Fish Habitat Areas Code Map Figure 4-2.1.2. Any intensification through development is likely to have a worsening effect on these waterways and wetlands through increased sediment and nutrient loads and storm water quantity (increases to time to peak discharges and actual peak discharges) from impervious areas, and the potential for land slips and erosion, including increased incising of the channel bed. c) A Special Management Area (Moderate to High Landslip Hazard) on Regulatory Map 1.3 Land Slip Hazard The area is mapped as a moderate and high hazard area on the Landslide Hazard & Steep Land Overlay Map (i) (Landslide). Removal of vegetation from the site will only disturb the area further and increase the potential for landslips to occur into the tributaries and subsequently Martins Creek. Land slips are known to occur in the area with considerable stabilisation works required for a subdivision back up the escarpment on Bell Road, lateral cracking in Martins Creek road adjacent to the small playground park indicating possible perpendicular displacement of the regolith either south-west and/or north-east beneath the pavement, and on the western side of Jones Road as a consequence of natural instability and development impacts increasing that instability.
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