Mr Reg van Rij
Regional Manager – Residential
LEDA Developments Pty Ltd
PO Box 1914
Surfers Paradise QLD 4217
14 December 2012
Dear Mr van Rij
Thank you for your letter of 6 November 2012, and for the invitation to engage with your company in relation to the Preferred Project Report (PPR) for the proposed Kings Forest development.
The Caldera Environment Centre (CEC) acknowledges some improvements on previous proposals. In particular, the CEC welcomes commitments to ensure that littoral rainforest will remain intact, to install water tanks at residences, to design road crossings that facilitate safe fish passage, to prohibit the keeping of cats, and to utilise appropriate native plant species in landscaping projects. The CEC also acknowledges some nominal improvements to the Threatened Species Management Plan.
However, the CEC maintains deep reservations with the project, and is strongly of the view that a development of the proposed kind and scale lacks both sensitivity and vision, and is inappropriate for a site endowed as it is with such profound ecological value. Disappointingly, Ecological Sustainability Development (ESD) principles appear to have been little more than an afterthought, selectively retrofitted to earlier proposals on the insistence of government agencies.
In addition to these more general observations, I outline in the paragraphs that follow some more specific reservations that CEC maintains in respect of the PPR, relating to:
water management;
the proposed golf course;
preservation of local koala population;
explicit commitments in respect of sustainable residential construction;
ongoing environmental monitoring;
clearing of native vegetation; and,
remediation/revegetation of Black’s Creek.
Water Management
It is expected that water will be implicated in social unrest and even wars throughout the 21st century. In Australia, the dryest continent on Earth, the implications of climate change (and a range of other factors) for Australia’s fresh water resources are very clear: Australia must improve its water management practices if serious and widespread chronic water shortages are to be avoided. To this end, a much greater emphasis will have to be placed upon water recycling and reuse technologies, which will improve water security by diversifying sources and reduce dependence on dams.
While the CEC notes that, compared with earlier iterations, the PPR contains some improvements in water management strategies, it is of the view that further improvements are not only desirable but necessary. The CEC urges LEDA to consider further water management measures; for example, dual reticulation is best practice, yet is conspicuously absent from current proposals.
Golf course
A range of submissions have addressed the issues associated with the likelihood of an increase in nutrients and toxins (originating from synthetic fertilisers and chemicals used in horticulture) draining from the Kings Forest site and into the surrounding environment, including the estuarine system. These effects will potentially be compounded by the presence of a golf course, which typically requires irrigation and significant volumes of chemicals to maintain the turf. In view of this, and in view of the fact that at least three golf courses already exist within an easy drive of the Kings Forest site, the CEC urges LEDA to give further consideration to whether the expense and environmental impact of a fourth golf course can be justified.
If the golf course is to remain a part of the plan, then CEC is of the view that LEDA should commit to environmental best practice – including the use of effluent irrigation (courses can be excellent treatment systems for effluent water), Integrated Pest Management, and use of natural organic fertilisers (if fertilisers are required in addition to the effluent water) – and ensure that this is reflected in the relevant plans.
Preservation of local koala population
The dire plight of the local koala population scarcely requires revisiting. With a population that has been decimated – diminished by an estimated 80 percent over a mere 20 years – the CEC urges LEDA to consider stronger protections for the remaining koalas. For example, the contradictions intrinsic to LEDA’s respective policies on dog and cat ownership is nonsensical: both dogs and cats are known to have deleterious effects on populations of native and protected species, and from CEC’s perspective, it is highly inconsistent (and foolish, frankly) to prohibit one and not the other. CEC is of the firm view that a prohibition of dog ownership – or, at the very least, a prohibition of certain breeds of dog known to be dangerous to koalas – is not only justified, but imperative.
Explicit commitment to ESD principles in design and construction of residences
While the CEC acknowledges that certain elements of the PPR are likely to result in comparatively better environmental outcomes, this should not be equated to an acknowledgement that the proposed development is consistent with ESD principles. Given the near-universal consensus within the physical sciences that the human species has exceeded the carrying capacity of the Earth – that our species is now drawing unsustainably on the Earth’s resources, and running down its natural capital – it seems incredible that ESD principles are not front-and-centre in all development, and particularly in a development of this magnitude.
The CEC believes that if the Kings Forest development is to proceed, then it should be viewed by LEDA as an opportunity to showcase cutting edge sustainable town planning and residential designs. Accordingly, the CEC strongly urges LEDA to reconfigure its Design Guidelines and other relevant documentation to give priority to current ESD principles.
Ongoing responsibility for environmental monitoring and management
The CEC notes LEDA’s dissent to Council’s request for an ongoing role for LEDA in the implementation of Environmental Management Plans (3.7.10 in the PPR, and elsewhere). Various agency and non-agency submissions have proposed certain ongoing roles for LEDA, to which LEDA’s consistent response has been to insist that the imposition of ongoing responsibilities would be unfair and unduly onerous. 3
Given the significant risks to the environment inherent in the Kings Forest development, the CEC believes, contrary to LEDA’s assertions, that there should be a significant role for LEDA following completion of the project. While LEDA may believe this to be unfair, the CEC considers that it is far less fair to expect the public to underwrite the Kings Forest development, and assume responsibility for the risks that it poses.
In the event that LEDA does not volunteer – or is not required – to assume some ongoing responsibilities for environmental impact monitoring and mitigation of identified impacts, then CEC would strongly urge LEDA, as a gesture of good faith, to make a significant donation – or donations – to a suitable and independent organisation or organisations, so that the community is resourced to deal with environmental impacts resulting from the development as they arise. Appropriate conditions could be attached to the donation/s to avoid misappropriation of the funds, and the CEC would be pleased to offer its assistance in identifying a suitable beneficiary or beneficiaries.
Clearing of native vegetation
While the PPR documentation insists that clearing of native vegetation is being kept to a minimum (the claim on p 43
Environmental Assessment Report being representative of such claims: ‘[t]he bulk of vegetation to be removed is highly modified’), the CEC maintains its opposition, in the strongest possible terms, of any clearing whatsoever of non-modified native vegetation. While it may be true that the amount of non-modified native vegetation being cleared is small in percentage terms, the scale of the Kings Forest development means that even a small percentage equates to an unacceptably large area. Native vegetation in the region has been diminished since white settlement to such an extent that very little now remains, and the CEC therefore urges LEDA to consider alternatives to clearing.
Illegal clearing of a nature reserve on the banks of Black’s Creek
Related to the previous point, the CEC notes a history of failure by contractors to clear vegetation around the site in accordance with site plans and the law. The CEC strongly urges LEDA to develop plans, transparently, and in consultation with relevant experts and agencies, and set aside adequate funds for, restoration of the cleared area. This would go some way to restoring faith in LEDA, and signal to the community that LEDA is willing to assume its place as a responsible corporate citizen and custodian of the natural environment.
Invitation to meet
Finally, I note your invitation to meet and discuss the project details as they currently stand. As you will appreciate, the sheer scale of the development and the volume of the documents setting out its details are beyond most voluntary organisations – including the CEC – to comprehensively assess, and even wholly comprehend. I understand that other community-based organisations have requested a tour of the site to get a sense for ‘what will go where, and how’. I encourage LEDA to make arrangements for a tour of the site for interested groups, and I would be grateful if representatives of the CEC were invited to attend.
Yours sincerely
(Signed)
Chris Aitchison
Secretary
Caldera Environment Centre
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