Friends of the Koala, Cudgen Nature Reserve, Caldera Environment Centre Representation to the Member for Tweed, the Hon. Geoff Provest, MP

The issues on which we seek representation: 

1. Local Land Services Amendment (Miscellaneous) Bill 2020 – Adverse impact of Private Native Forestry (PNF) Amendments and ‘Allowable Activity Land’

The amendments to the discredited Local Land Services Amendment (Miscellaneous) Bill 2020 not only sought to double the duration for PNF plans (to0 30 years), it proposed to remove Tweed Council’s power to assess and monitor PNF operations. PNF would no longer need consent under Tweed’s Local Environment Plans – meaning that core koala habitat could be cleared without consultation or approval. That this amendment would have removed Council’s consent for ANY type of forestry (not just PNF) was even more concerning. The amendment could have been used as a precursor to urban development – particularly in the Tweed where much urban development is in the pipeline.

The Bill also sought to extend the operation of ‘allowable activities’ on ‘rural regulated land’ and ‘allowable activity land’ without authorisation. Such land includes land that has been identified through application of the Northern Councils E Zone Review Final Recommendations Report (2015) as having ecological, scientific or cultural values sufficient to be identified as an environmental zone. In effect koala habitat where it meets the E Zone criteria could be cleared for construction timber, firewood, power lines, fences, roads, tracks, sheds, tanks, dams, stockyards etc, whether these are for an agricultural purpose or not. The proposed amendments were an over-reach and provided unnecessary risk to koalas and their habitat given the current existing use rights, E Zone methods and criteria and the State Environmental Planning Policy (Vegetation in Non-Rural Areas) 2017. It is essential to understand that these amendments would have applied to all landowners in rural zones and that the amendments therefore could not be genuinely labelled as being for the benefit of ‘farmers’. If made law, this amendment also would have provided opportunity to clear as a precursor to urban development.

Most of the Tweed coastal area relies on environmental protection provided by Tweed’s Local Environmental Plans 2000 and 2014 and various State Environmental Planning Policies. The Bill’s amendments would have over-ridden these environmental zonings thereby undermining Council’s work of many years identifying and mapping these areas for protection. This would have affected not only koala habitat but also coastal wetland, littoral rainforest, etc.

Further, west of the highway is also problematic as the amendments would have made most land available for logging – or clearing for allowable activities. Mt Nullum could be opened up for logging and the corridor between it and Wollumbin National Park could be significantly degraded.

We request that the NSW Government uphold the absolute integrity of the statutory Tweed Environmental Plan 2000 and Tweed Environmental Plan 2014 by:

1. (a)  not allowing land clearing for infrastructure (fences, roads, pipelines, sheds, dams, stockyards), farm timber, grazing, gravel pits, airstrips, firebreaks etc. (i.e. ‘allowable activities’) in Environmental Zones without requiring Council’s consent ; and
2. (b)  not removing the requirement for development consent on private native forestry and other forestry operations.

2. Tweed Coast Comprehensive Plan of Management

Rhonda James and Lorraine Vass both served on the Tweed Coast Koala Advisory Group which drafted the Tweed Coast Comprehensive Koala Plan of Management and continue to serve on the Tweed Coast Koala Management Committee which is overseeing its implementation. After the Plan was approved by Council in February 2015 it was forwarded to the Department of Planning & Environment for approval.

In May 2015 the Department hosted a meeting with local government to advise and give direction on the preparation and operation of comprehensive koala plans of management in light of recently received advice. At issue was a new requirement of separating out which part relates to the “core koala habitat” requirements of State Environmental Planning Policy 44 (SEPP 44) for approval by the Secretary. Other information, including preferred habitat outside the core areas, or delineation of areas suitable for koala habitat if appropriately managed might still be included but should be termed a koala management strategy or take the form of a development control plan. The advice to Tweed Council was that their Plan be re-drafted to clearly separate it into individual sections.

Tweed Council took the view that such action would considerably weaken its Plan which had been included in its statutory Tweed Environmental Plan 2014. It was only with the introduction of State Environmental Planning Policy (Koala Habitat Protection) 2019 in March 2020 that Tweed Council again forwarded its Plan for approval under the new SEPP’s transition provisions.

Recommendation 25 NSW Upper House Koala Inquiry stated “That the NSW Government urgently approve comprehensive koala plans of management previously submitted to the Department of Planning, Industry and Environment in a timely and transparent manner”. The Government claimed to ‘support’ the recommendation. Nevertheless, the Local Land Services Amendment (Miscellaneous) Bill 2020 would have limited all future protection of “core koala habitat” to just the five comprehensive koala plans of management/strategies approved by the Department prior to October 2020. It is imperative that the Tweed Coast Comprehensive Koala Plan of Management is ratified with its current regulatory powers.

We request the immediate approval by the NSW Government of the Tweed Coast Comprehensive Koala Plan of Management (2015)

3. Tweed Coast Koala Research Hub and the Koala Chlamydia Vaccine

A key component in the case presented to the NSW Government in support of purchasing two important parcels of land at Pottsville in 2017 was the opportunity to construct a koala holding facility and soft release site to enable the vaccination of koalas against chlamydia.

It was pointed out that Currumbin Wildlife Hospital admitted more than 200 koalas from northern NSW in 2016 and that the number of such admissions was increasing. The Hospital had critical need for a holding facility because vaccination against chlamydia (still in field trials and therefore conducted under a scientific licence), involves the application of two vaccine doses 30 days apart.

The NSW Government purchased the land and the facility, capable of accommodating up to 12 koalas, has been built with significant NSW Government funding assistance.

At a recent meeting of the Tweed Coast Koala Management Committee held on site, Currumbin Wildlife Hospital’s Senior Veterinarian advised those present that an application to obtain a NSW scientific licence had been unsuccessful. The Hospital has secured funding from sources in Queensland and has obtained a Queensland scientific licence, thus only koalas from Queensland’s Gold Coast are being sought for participation in the vaccine trials.

Given the NSW Government’s considerable investment in developing the Tweed Coast Koala Research Hub, we request clarification of the anticipated participation of Northern Rivers koalas in any chlamydia vaccine trials in which the Currumbin Wildlife Hospital is a partner.

4. Funding regional koala conservation and recovery in the Northern Rivers

The far north coast councils of Tweed, Byron, Ballina and Lismore and Friends of the Koala have been working together for many years on koala conservation and recovery projects with remarkably successful outcomes. In addition to collaborative projects, each council has demonstrated long-term commitment and investment in the conservation and recovery of local koala populations through the development, adoption and implementation of koala conservation strategies and comprehensive koala plans of management. Friends of the Koala is a crucial partner to all councils in the region.

The recently completed 4-year ARC Linkage project, Conserving and restoring koala populations in the NSW Far North Coast, which introduced a novel approach combining ecological and sociological research to the challenge of landscape-scale koala survival, provided an ideal and unique foundation for an ongoing regional koala recovery project by delivering:

• the first regional koala activity survey that has significantly increased knowledge of the location and significance of koala habitat and tree species preferences throughout the region;
• social research that investigates the integration of spatial data to assess conservation opportunities and priorities, and demonstrates the validity of crowdsourced wildlife observations for conservation;
• modelling of landscape-scale priority koala habitat based on contemporary habitat mapping and detailed local-scale knowledge of threats;
• direct application of the outcomes through implementation of the North East Hinterland KoalaConservation and Recovery Project;
• development of a framework for a regional koala conservation strategy that integrates the outputs of all aspects of the project; and
• publication of the research in relevant peer reviewed journalsA proposal to prepare and implement a Far North Coast Regional Koala Conservation Strategy to encompass the local government areas of Tweed, Kyogle, Byron, Ballina, Lismore and Richmond Valley would continue and extend this successful project model to deliver:
  1. (a)  development of a regional koala conservation strategy
  2. (b)  monitoring of regional koala activity at 3-yearly intervals
  3. (c)  implementation of the regional koala conservation strategy

  A request for funding over a 5-year period which was costed at approximately $550,000, was lodged with your colleague, the Minister for Energy and Environment, the Hon. Matt Kean MP by the Mayor of Tweed Shire Council, Cr Chris Cherry in October 2020.

  A few months earlier, in July, the Minister had announced his intention to double the number of koalas in NSW by 2050 and instructed the Chief Scientist and Engineer to assemble an expert panel for that purpose. We expect the panel’s report, which is due in the next month or so, to be the successor to the NSW Koala Strategy 2018-2021.

  We request that the NSW Government fund the preparation and implementation of a Far North Coast Regional Koala Conservation Strategy developed from a collaborative 4-year Australian Research Council (ARC Linkage) funded project as part of its new plan for koala recovery in NSW.

  5. Extension of the national parks estate in Tweed Shire

  Koala conservation in Tweed has been concentrated on the land east of the Pacific Motorway and included in the Tweed Coast Comprehensive Plan of Management. Recent and proposed purchases are Lot 919 at Koala Beach and the residue block from the subdivision on Clothiers Creek Road. These purchases are certainly beneficial but still do not provide a link between the east and west areas of Cudgen Nature Reserve. Large tracts of continuous protected land are required to sustain a viable population of koalas.

  Little attention has been taken to koala habitat west of the Pacific Motorway and as already pointed out, important areas like Mt Nullum and the corridor between it and Wollumbin National Park are unprotected.

  Although NSW Government funding has been provided through the North East Hinterland Koala Conservation and Recovery Project (cited repeatedly in the response to the Upper House Koala Inquiry recommendations), this project has secured only token parcels of private land which are not adjacent to NPWS reserves, see Figure 1. (p.6).

  To secure the future of hinterland koalas additional lands are required to extend the current reserve system, see Figure 2 (p.6).

  We request that NPWS investigate and purchase additional adjoining land to Cudgen Nature Reserve and western reserves such as Wollumbin, Mt Jerusalem, Mebbin and Mooball.

Figure 1 – North East Hinterland Project – …………………………Tweed

Figure 2 – Lack of connectivity between Wollumbin NP – Mt Jerusalem NP and Mooball NP

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Summary of representations

1. We request that the NSW Government uphold the absolute integrity of the statutory Tweed Environmental Plan 2000 and Tweed Environmental Plan 2014 by:

1. (a)  not allowing land clearing for infrastructure (fences, roads, pipelines, sheds, dams, stockyards), farm timber, grazing, gravel pits, airstrips, firebreaks etc. (i.e. ‘allowable activities’) in Environmental Zones without requiring Council’s consent; and
2. (b)  not removing the requirement for development consent on private native forestry and other forestry operations

2. We request the immediate approval by the NSW Government of the Tweed Coast Comprehensive Koala Plan of Management (2015)
3. We request clarification of the anticipated participation of Northern Rivers koalas in any chlamydia vaccine trials in which the Currumbin Wildlife Hospital is a partner.
4. We request that the NSW Government fund the preparation and implementation of a Far North Coast Regional Koala Conservation Strategy developed from a collaborative 4-year Australian Research Council (ARC Linkage) funded project as part of its new plan for koala recovery in NSW.

5. We request that NPWS investigate and purchase additional adjoining land to Cudgen Nature Reserve and western reserves such as Wollumbin, Mt Jerusalem, Mebbin and Mooball.