Threat to Koalas - A Men's Shed









Most important to read first and foremost before the following is the Independent Review of Flora and Fauna Assessment of Men's Shed Development Application by Dr Steve Phillips.


The Men's Shed Development Application at the Black Rocks sports field was approved at the December 2015 council meeting even though the following critique detailing and explaining its shortfalls, omissions and inadequacies was submitted to outsourced assessors GHD Australia in order to explain why it should not be accepted.


The following contains very technical information, thoroughly researched, as to why the proposed Men’s Shed should have been rejected.  The main thing you need to know is that it would be an industrial-like development in simply the wrong location - too close to the bushland where threatened species like koalas are trying to recover after the Christmas day 2014 fire compounded with ongoing serious human impacts that cause stress leading to death and/or cessation of breeding.


The following critiques the Development Application in detail and explains its shortfalls, omissions and inadequacies in order to explain why it should not be accepted.


REASONS TO REJECT THE MEN’S SHED DEVELOPMENT APPLICATION


The Development Application (D.A.) documentation has not acknowledged and/or adequately taken into account the Threatened status of the koala, environmental values and koala mortalities when assessing the impacts of the proposal on the threatened species at the Black Rocks sports field, access road and surrounding bushland. Nor has it acknowledged:-


1. UNRECOGNISED THREATENED STATUS OF KOALA ENVIRONMENTAL VALUES

2. FLORA AND FAUNA ASSESSMENT DEFICIENCIES

3. INCREASED IMPACTS

4. INADEQUATE PROPOSED ENVIRONMENTAL SAFEGUARDS

5. INCREASED STRESS-RELATED DISTURBANCE

6. INCREASED RISK OF KOALA DISEASE

7. INCREASED RISK OF DOG ATTACK

8. INCREASED RISK OF VEHICLE STRIKE

9. INCREASED RISK OF FIRE

10. RURAL FIRE SERVICE (RFS) DEVELOPMENT CLASSIFICATION

11. HABITAT OFFSET PLANTING

12. ALTERNATIVE SITE

13. UNRESOLVED ISSUES

14. IMPACT ON ENDANGERED BUSH-STONE CURLEW



1. UNRECOGNISED THREATENED STATUS OF KOALA ENVIRONMENTAL VALUES


•     Tweed Coast and Pottsville/Wetlands koala population numbers and decline

•     Preliminary Determination for support of a proposal to upgrade Threatened status of Tweed Coast koalas to 'Endangered'

•     Koala breeding areas and home range

•     Wildlife sightings by local resident David Norris

•     Core koala habitat and extent of primary and secondary koala habitat surrounding the access road

     •       Significance of wildlife corridor the access road bisects

     •       Pottsville Wetlands Christmas Day bush fire

     •       Stress-related chlamydia


2.     FLORA AND FAUNA ASSESSMENT DEFICIENCIES


     •       Outdated koala surveys - Tweed Coast Koala Habitat Study 2011 (TCKHS) which used 2004 vegetation mapping and James Warren & Associates Ecological Assessment 2011

     •       Outdated inaccurate mapping

     •      Only 8 hours on-ground survey by two council officers over 4 days in February 2015

     •      Reference to D.A. being further informed of management measures by the Tweed Coast Koala Habitat Study 2015 which has not yet been completed.

     •      Non-assessment of Endangered Ecological Communities west of the access road and corridor south of access road.

     •      Inaccurate assessment of Endangered Ecological Communities south of access road.

     •      Inconsistency with the objectives of the Black Rocks Independent Koala Plan of Management (IKPoM)

     •      Stated compliance with the Black Rocks IKPoM which is not fully implemented and/or enforced

     •      Deficient development proposal assessment criteria under Black Rocks IKPoM

     •      Non-compliance with objectives of Tweed Coast Koala Plan of Management (KPoM) for land adjacent to the area covered by the Black Rocks IKPoM which will be directly or indirectly affected by this proposal.


     3. INCREASED IMPACTS


Impacts on sensitive koala area

All of the construction works and operation of the Men's Shed will be concentrated in the south-east portion of the sports field, which is the most koala-sensitive area adjacent to the access road (identified in TCKHS 2011, Figure 5.3b as an area of primary koala habitat).


Unrestricted access to koala habitat

Because there is no barrier between the koala habitat and the access road, there will be no restriction to members and associated visitors entering and degrading the adjacent koala habitat/Ecological Endangered Communities.


Risk of contamination to habitat

Risk of contamination to adjacent Endangered Ecological Communities and primary koala habitat during times of flood from sumps (which hold coolant fluids), paints, glues, fuels and solvents which may be housed in the Men's Shed.

Impacts on sensitive koala area

All of the construction works and operation of the Men's Shed will be concentrated in the south-east portion of the sports field, which is the most koala-sensitive area adjacent to the access road (identified in TCKHS 2011, Figure 5.3b as an area of primary koala habitat).


Unrestricted access to koala habitat

Because there is no barrier between the koala habitat and the access road, there will be no restriction to members and associated visitors entering and degrading the adjacent koala habitat/Ecological Endangered Communities.


Risk of contamination to habitat

Risk of contamination to adjacent Endangered Ecological Communities and primary koala habitat during times of flood from sumps (which hold coolant fluids), paints, glues, fuels and solvents which may be housed in the Men's Shed.


     4.     INADEQUATE PROPOSED ENVIRONMENTAL SAFEGUARDS


Until effective mitigation measures are in place, an adequate assessment cannot be made of the additional protection required as a result of the increased impact levels of this proposal. The following proposed environmental safeguards in the D.A. are also flawed and/or inadequate:-


Operational times

The typical operational times stated by Pottsville & District Men's Shed in their handout to councillors and council staff at the 17/7/2014 Council meeting was 1-2 days per week between 9 am and mid afternoon yet the times stated in the Statement of Environmental Effects (S.E.E.) of the D.A., Section 2.5.6, (p.9) was 6 days per week between 7am and 5pm, with an expectation that the building could be occupied outside these times.


Council claims that the increased presence of the Men's Shed will deter anti-social behaviour at the access road and surrounding bushland.  The S.E.E. appears to be misrepresenting the operational times whilst supporting council's promotion of the Men's Shed's increased presence being an effective passive surveillance measure. (NB: The operational times of the Murwillumbah Men's Shed is 2 days per week from 9am and the Tweed Heads Men's Shed is 3 days per week between 9am - 2pm.)


Unproven surveillance mitigation measure

The stated aim of the Australian Men's Shed Association is to provide support for men who are emotionally unstable (see AMSA extracts, APPENDIX 3 end of page). A reliance on men who may be emotionally unstable to provide surveillance and manage and report illegal and inappropriate activities is not an acceptable measure of regulation enforcement and protection for resident and breeding threatened species.


Department of Environment & Climate Change NSW Threatened species assessment guidelines, Making an assessment of significance, (p.12) states:  


‘Proposed measures that mitigate, improve or compensate for the action, development or activity should not be considered in determining the degree of the effect on threatened species, populations or ecological communities, unless the measure has been used successfully for that species in a similar situation.’  


If the above Men's Shed active management and reporting function has not been tried, tested and proven in a similar circumstance, it should not be regarded as an acceptable protection measure.


Supervision of anti-social behaviour

Tweed Coast KPoM p.81, Department of Urban Affairs and Planning Circular No. B35 dated 22 March, 1995 regarding SEPP 44, 1.7 community involvement states:  


If appropriately co-ordinated and supervised, the volunteer labour could significantly reduce any resource implications for council in managing koala populations, within identified core habitat, on lands within its control.’  


A qualified council-appointed person would need to be on duty at all times whilst the Men's Shed is operating in order to appropriately supervise and coordinate members volunteering to assist with koala management by monitoring and reporting anti-social behaviour.


False vandalism reduction claims

The Statement of Environmental Effects 2.5.4, (p.8) incorrectly states: ‘Anti-social behaviour including vandalism at the sports fields has been documented by Tweed Shire Council in the past. However, upon installation of a set of gates at the entry to the sports fields this behaviour has significantly reduced.’  


The following summary provides a snapshot of the evidenced and reported vandalism on the access road and surrounding bushland since vehicular access has been re-introduced (see Impacts ):-


Damaged and/or removed signs

Damage to sports field and access road verge from hooning

Damage to habitat from rubbish dumping

Spud cannon launching

Council infrastructure targeted with golf balls

Attempted break and enter into Council pump shed

Illegal golf practice

Illegal walking of dogs

Illegal motor cycle riding

Illegal drug cultivation.


The removal of the koala protection gates will allow vehicular access at night, and vandalism could be expected to resume to pre-boom gate levels, increasing the risk of fire, disturbance, vehicle strike and dog attack.


False koala protection gate claims (see Enforcement )

Flora & Fauna Assessment (p.4) and 6.2 (p.25) incorrectly state that adequate environmental safeguards are in place to ensure protection of koalas.  On 17 occasions the Flora & Fauna Assessment and the Statement of Environmental Effects cite the koala/dog-proof gates at the access road entrance being locked at night as a management mitigation measure to reduce the risks of impacts on threatened species. However, council minute #283 of 21/5/2015 requires the removal of this gate and replacement with a grid, which will allow vehicular access day and night and reduce koala protection even further. (N.B. As there have been several reported incidences of koalas and bush stone-curlews being active in the day on and near the subject site, day protection is necessary.)


Removal of night protection

On four occasions the Flora & Fauna Assessment and The Statement of Environmental Effects indicate that it is expected that members will also use the access road at night even though council meeting Minute # 698 of 21/11/2013 deemed that the tennis court application PTV12/0022 not proceed because night activities would create an unacceptable level of impact on threatened species and their habitat.


Ineffective speed humps on access road

Hoons and other motorists use the adjacent grass verge to bypass the 3 speed humps, rendering the 20kph speed limit ineffective (click here ).


Limited visibility on access road

Cleared road verges will not ensure visibility. The new car parking bays proposed by the D.A. for the access road will limit visibility on the northern side and the bollards on the northern and southern edges of the access road severely restrict visibility in the area where koalas have been sighted on the ground during the day whilst breeding.


Unenforced dog restrictions

The dog restrictions on the sports field are not obeyed and/or enforced by council.  The three 'no dog' signs have been ignored and there is evidence of the access road and adjacent bushland being used as an off-leash dog exercise area (see Dogs ).


Unregulated activities

Once established, shed members can choose any activity they wish to pursue without monitoring, authorisation or regulation from the local authority. Unregulated unmonitored activities have the potential to significantly impact on the resident and breeding threatened species.


False claims of environmental protection

Flora & Fauna Assessment 8.0, (p.38) states:  ‘Despite the site having been subject to significant and prolonged disturbances, the environmental context of the site requires the management of these values as a key consideration of the proposal.’  


Yet council has demonstrated that it cannot successfully protect environmental values at the sports field as it has failed to regulate prohibited and koala-impactive activities (see Impacts ) by not enforcing the Black Rocks IKPoM (see IKPoM ) and by leaving the koala/dog-proof vehicle access gates open during the day and now resolving to remove them.


     5.     INCREASED STRESS-RELATED DISTURBANCE


Close proximity to koala habitat

Koalas will be vulnerable to disturbance and exposure to edge effects due to the absence of any buffer between the construction/operation Men's Shed footprint and primary koala habitat in the most koala-sensitive area abutting the sports field footprint (south-east corner).  The shed is proposed to be located 20 metres from primary koala habitat.


Construction impacts

* machinery associated with surface scraping of the site, including loud reversal warning signals

* concrete trucks

* construction of prefabricated shed including nail guns, grinders

* machinery associated with trenching for connection of service

* trucks delivering material

* disturbance associated with construction of cyclone fencing

* all vehicular movement and noise associated with the scraping of the soil and concrete construction of the formal parking area

* similar vehicular disturbance associated with the preparation of the landscape and concrete construction of the pedestrian pathway connecting the access road with the shed and amenities

* petrol-driven post-hole digging machinery

* general disturbance associated with construction workers


Construction noise

The Flora and Fauna Assessment 6.3 (p.26) states:  ‘Construction noise will be short-term and similar to building construction in the adjacent estate.’  Koala impacts should not be dismissed because they are short-term. The cumulative effects of short-term impacts will compromise their immune system, leading to stress-related disease.   The D.A. does not indicate how long construction will take nor is there any indication when construction would occur.  If during breeding season it could severely compromise successful koala breeding outcomes.


Koalas have been evidenced in primary habitat trees approximately 35-40 metres from the access road and in branches directly above and immediately adjacent to the proposed cyclone fencing (see Men's Shed Preliminary Concept Design, APPENDIX 2 end of page).  Building construction in the adjacent estate is more than 300m away.


In his email dated 10/6/2015 Dr Steve Phillips states:  ‘We now have evidence that koalas respond adversely to loud noise.


Operation impacts

The ongoing disturbance and associated loud noise from industrial-like activities, as well as vehicular movements from informal parking and car parking bays on the access road, caused by the operation of the Men's Shed will exacerbate existing stress-related disturbance (see Impacts ).


The more regular presence of Men's Shed members in the south-east corner of the access road is likely to drive resident koalas away from this location and force them to compete with other koalas that occupy the remaining koala primary food trees in the area, or subject them to ongoing disturbance if they stay.  In either case koalas will be exposed to increasing incidence of disturbance, stress and disease affecting their life cycle.


Model aeroplanes

One of the proposed outdoor activities is model plane making (which would require testing).  The flying of model glider and petrol-powered aeroplanes in close proximity to this nest by members would exacerbate the existing stress-related disturbance from the regular occurrence of these activities at the sports field site and surrounding bushland.  If petrol-powered aeroplanes crash in the bush, there is a risk of fire.  Furthermore, this activity will increase the attraction of model aeroplane operators to the osprey site.


The osprey nest located 50m north-east of the sports field is one of only two naturally-occurring osprey nests in Tweed Shire.  A summary of Tweed Osprey Group data in the D.A. (4.2.1, Table 2, p.16) states:  


‘Regular (Osprey) breeding had been occurring between 1996 and 2006 with irregular breeding since that time..... reasons for the irregular breeding are...  likely to relate to a range of anthropogenic disturbances and suspected predation on chicks by the White-bellied Sea-eagle.


Construction/operation disturbance levels and disease

The D.A. does not consider whether the disturbance from construction and operation will increase the incidence of disease and the impact on the already declining Pottsville Wetlands-Black Rocks koala source population (see Chlamydia ).


Increased barrier to koala movement

The location of the cyclone fence (see Preliminary Concept Design APPENDIX 2 end of page) will create a barrier to north-south koala movement between the primary koala food trees on the northern, eastern and southern edges of the sports field where koalas have been sighted.


Vehicle movements

Increased vehicular traffic through the middle of a koala breeding area on the access road.


Barrier to dispersing young koalas

The impediment to koala movement created by the location and activities of the proposal will compromise dispersing young koalas' ability to safely move over long distances to establish their home range.


Flawed disturbance levels comparison

The Flora & Fauna Assessment of DA, 6.2, (p.25) states:  ‘Given that operational disturbance levels proposed are not too dissimilar to the existing use at the site, impacts on species movements across the landscape or fragmentation of important home range resources for species (eg hollow or koala feed tree resources) is not considered likely.’


Because of its isolated location the sports field is very rarely used other than by people pursuing illegal, inappropriate and/or koala-impactive activities.  The current activities of an occasional cricket match and casual recreational use are very dissimilar to the proposed regular use by the Men's Shed and associated visitors (which the Statement of Environmental Effects of D.A., 2.5.6, (p.9) states will be at least 6 days a week between 7am and 5pm.


The President of the Pottsville & District Men's Shed (P&DMS) was quoted in the Tweed Valley Weekly, 28 May 2015, p.8 as stating that they currently have 30 active members and that:  ‘We have about 80 formal expressions of interest without having made a big push at all and it is quite clear the demand for a facility like this is enormous.’  


This indicates that there will be a significant increase in disturbance by the number of members and visitors accessing the site, exceeding the existing disturbance levels. Since there has never been an assessment of disturbance levels or a vehicle count undertaken at the access road, the precautionary principle should therefore apply.


Cumulative effects of increased disturbance

The Flora & Fauna Assessment 6.4 (p.27) states that operational disturbance levels will be similar to and slightly increase current levels of disturbance created by current sporting and recreational use.  There is no consideration for the need to reduce disturbance and threats, with mitigation measures in place to achieve this reduction, if koala recovery is to be achieved. There is no justification for endorsing additional disturbance and threats because they already exist.


No focus on koala residency

The D.A. does not focus on maintaining koala residency.  Tweed Coast Koala Habitat Study 2011, p.60 states:  ‘The primary focus of conservation and management efforts must be the maintenance of residency.


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