To: Department of Planning Industry & Environment. Re: Koala Habitat Protection SEPP

The new koala protection guidelines rely heavily on the “Koala Development Application Map”. However, land clearing for “logging operations” on private lands” are exempt from these guidelines, as these operations do not normally require DA approval.  

For logging on private lands Koala protection is supposed to be based on local “Comprehensive Koala Plans of Management” (KPoM). 

HOWEVER – since 1995 only 6 Council KPoMs have been approved and only 3 of them contained Core Koala Habitat.  

This is clearly a giant hole in the proposed koala protection policy.

What measures are in place to fast-track Council KPoMs to align with the introduction of these new “Koala Protection Laws”? 

In 2017 the EDO warned that new Native Vegetation Codes could allow rural land clearing of hundreds of hectares at a time without a DA and without reference to the Koala SEPP.  They recommended that koala mapping be in place before the new land clearing system commenced.  The EDO also recommended that the new Koala SEPP must also apply to rural land-clearing proposals that exceed the Code limits to ensure these land clearing proposals are assessed by the new “Native Vegetation Panel”.  (EDO NSW Jan 2017)

However – a recent report has revealed a startling increase in levels of land-clearing in NSW since 2017.  In 2018/19 37,000 ha of clearing was approved – 13 times the annual average in the ten years prior!  Between 2017/18 – 60% of clearing was ‘unexplained’.

Much of this clearing was in contravention of new land clearing regulations but the lack of a robust Koala SEPP (with the caveats suggested by the EDO) was clearly a missing layer of protection and may have prevented such devastating habitat loss.

When we add the damage this intense land clearing has done to the damage wrought by recent extreme fires in NSW we are looking at a catastrophic outcome for wildlife habitat and koala habitat.

This is the calamitous environment in which the new Koala Protection SEPP must work.

Its stated intent remains as:

The aim of the SEPP … will continue to be to protect koala habitat to ensure a permanent free-living population over the present range and reverse the current trend of koala population decline. 

If there is any hope of achieving this in NSW it is absolutely imperative that:

The NSW Government fast track shire-wide Koala Plans of Management that comprehensively identify core Koala Habitat.  They must assist with the mapping of this habitat and have a 5 year implementation time frame for achieving this across all the relevant shires in NSW

Development Applications must be required for all logging and clearing of likely koala habitat identified in the “Koala Development Application Map”

This requirement must be put in place immediately.  It must remain in place until Councils Comprehensive Koala Plans of Management are in place.

The development approval process does not allow important koala habitat to be offset or cleared in exchange for money as the BAM (Biodiversity Assessment Method) allows.  The approval process must achieve the aims of protecting resident koala populations and reversing population decline.

Koalas in NSW were in serious trouble even before these devastating fires and extreme land clearing.  North East NSW saw 50% population declines over the last 20 years primarily due to land clearing and logging.  Since the fires we have lost a third of koala habitat in this area with koala losses of 80-90% recorded. 

The classification of the Koala as “Vulnerable” may well need to be revised to “Critically Endangered” particularly in areas of high impact.  Koala expert Steve Phillips has estimated the once viable Port Macquarie population will be extinct within 20-50 years.  Many other species are set to follow this path as fires increase in frequency and intensity and other impacts of climate change take hold – intensified drought, heat and flooding rains will also take their toll on native habitat.

NSW plans for “intensive logging” of 142,000 ha of State Forest is incongruous with the aims of the Koala Protection SEPP and in the current circumstances will cause it to fail entirely.   Intensive logging has replaced “tree selection”.  Every single tree is clear-felled except for occasional clumps which cannot harbour any viable wildlife populations.  Extinction of koalas, arboreal animals and others is almost guaranteed.

Although only the Koala Protection SEPP is currently under review it seems to be imperative that the department considers this policy in relation to other policies it has the power to influence.   The situation has evolved dramatically since decisions were made on land clearing and land clearing laws in NSW.  Surely there is now an urgency to revisit the policies and decisions that will impact the success of this new Koala SEPP and the survival of koalas in the wild in NSW for generations to come?