council@snowymonaro.nsw.gov.au

Re. Planning Proposal: 56 Hilldowns Road, Kalkite

Friends of Grasslands (FOG) is a community group dedicated to the conservation of natural temperate grassy ecosystems in south-eastern Australia. FOG advocates, educates and advises on matters to do with the conservation of native grassy ecosystems, and carries out surveys and other on-ground work. FOG is based in Canberra and its members include professional scientists, landowners, land managers and interested members of the public.   

FOG’s response is limited to consideration of the likely or possible direct and indirect impacts on biodiversity from the proposed changes to land use zoning.

Summary

FOG does not support changes to land use within Precinct 2 or 3 to Environmental Living. Additionally, FOG does not object to development within Precinct 1 only if direct impacts in the precinct and indirect impacts to the surrounding landscape are properly controlled. FOG has come to this conclusion based on the report detailing the ecological considerations related to this site. This report identifies that the planning proposal will have significant impacts on native flora and fauna, and particularly on ecological communities listed under the NSW Biodiversity Conservation Act (2016). Furthermore, it is apparent that there is minimal probability that ecological values will be maintained, let alone improved, as a result of the changes to land use in Precincts 2 and 3.

Therefore, FOG recommends that the entire areas of Precincts 2 and 3 should be identified for Environmental Conservation.

Detailed comments

Precinct 2 and 3: Environmental Living and Environmental Conservation

FOG does not support the change in land use to Environmental Living in precincts 2 and 3 for the following reasons:

1.       The precinct contains ecological communities threatened under the Biodiversity Conservation Act and there is limited likelihood that these communities will retain biodiversity values if subdivided.  We believe that it is not appropriate to compromise the ecological integrity of these areas.

2.       The area contains potential habitat for koalas.

3.       Minimisation of potential future development impacts is not acceptable. The statement, “The extent of impacts of future developments is unknown at this stage and will need to be further assessed in a relevant biodiversity impact assessment report which will accompany future DAs for the subject site” (p.26,  Addendum Biodiversity Report) indicates that there has been inadequate weight given to the consequences of the sub-division of these precincts caused by:

• The erection of six dwellings,
• Tree clearance: 10 m tree clearance along driveways, requirements for a cleared 40 m width Asset Protection Zone around the houses,
• erection of fencing,
• a powerline easement and
• changes to management of the land. 

4.       Avoidance and minimisation measures identified in the biodiversity report do not counter the impacts on the landscape and remnant biodiversity values of the zones and beyond the zones.

• For example, pre-clearing and clearing surveys are identified as a minimisation measure, where it is clear that such a survey would only identify what will be lost.
• Varied abilities and interest of landholders in dealing with pest plants and animals and ability to ecologically manage the EECs and other biota cannot ensure condition of these precincts will be retained. 
• Sub-division will increase fragmentation and reduce connectivity across and beyond the precincts.
• Likely direct impacts including increased light, noise, transfer of weeds and increased fauna pests from soil disturbance and modification to habitat.
• Impacts from small-scale intensive farming of domestic stock and presence of pets on native fauna and flora and habitat within and beyond the precincts.
• Likely incompatible planting of introduced or native species may result in increases in populations of aggressive birds and consequent losses of smaller birds including Pardalotes. Likely indirect effects include increased risk and impacts on surrounding areas, including introduction of new weeds, increases in fauna pests and bushfire risk.

5.       The statement in the No Go Option on P30 of the Biodiversity Study amendment report, relating to the retention of the area as RU1 Primary Production, “Therefore, over time, there is potential for the extent of the existing TECs areas to be reduced and for the native vegetation to continue to degrade via weed invasion, edge effects, etc.” is misleading and patently cannot be assumed, if the existing landholders undertake what they are legally obliged to do to control weeds and pest animals and prevent impact on remnants of CEECs.

Therefore, the entire areas of Precincts 2 and 3 should be zoned and maintained as Environmental Conservation. However, clarity must be provided to identify how the areas identified for Environmental Conservation will be managed for conservation outcomes, including how external pressures resulting from the increased village population will be managed.

Precinct 1: Village and associated uses

FOG does not object directly to the development of Precinct 1, with the exception of the area of Snow Gum – Candlebark derived woodland on the western edge of the development; as a threatened ecological community under NSW legislation, this area should be retained and managed to retain and improve conservation values.

However, there are going to be increased impacts associated with the development of Precinct 1, including increases in light and noise, clearance of trees for individual house blocks and bushfire protection requirements and a likely increase in hunting of reptiles by pet animals (dogs, cats) inside and beyond the precinct and changes to the quality and quantity of run-off into Lake Jindabyne. Explicit management assurances must be given that these matters will be addressed, including:

1. ensuring cat containment,
2. provision of fenced off-leash areas for dogs,
3. suitable garden plant guides and adherence and
4. appropriate measures to reduce contaminated stormwater run-off into rivers, streams and the lake.

Thank you for the opportunity to provide feedback on the planning proposal for the village of Kalkite, which if approved will see the rezoning of land at 56 Hilldowns Road from Primary Production to a variety of new zones. We welcome the opportunity to discuss this submission further if it would be beneficial.

Yours sincerely

 

Professor Jamie Pittock

President, Friends of Grasslands

21 August 2023