Nora Creina PER is flawed

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We recently provided comment on the Public Environmental Report (PER) for the Nora Creina Golf Course and Tourism Resort that is being proposed near Robe in the South East of the state. The Minister for Planning declared the project a Major Development pursuant to Section 46(1) of the Development Act 1993 in March 2014. It was then referred to the Federal Environment Minister who declared it a controlled action under the Environment Protection & Biodiversity Act 1999 (EPBC Act). If approved, the development will result in the clearance of approximately 240 hectares of remnant native coastal vegetation and impact upon matters of national and state environmental significance such as the Little Dip Spider-orchid (Caladenia richardsiorum) and Orange-bellied Parrot (Neophema chrysogaster) listed as Critically Endangered under the EPBC Act. The PER was required as part of the EPBC referral process for the proposal and has been prepared pursuant to Section 46C of the Development Act 1993.

Download the full submission

The ecological impacts of the proposed development identified in the PER were largely based on a ‘ramble survey’ conducted by a private consultant over 8 hours to assess the type and condition of vegetation across the area. Further targeted surveys were also conducted in October 2015 to assess for the presence of the Little Dip Spider-orchid but were restricted within a 2 week timeframe. Our submission recommended more comprehensive biological surveys be conducted to determine the actual biodiversity values of the site given the size, extent and resultant impact of the proposal. We strongly believe that, due to limitations of the baseline vegetation surveys a high potential exists for additional EPBC and state listed species to occur in the project area that have gone undetected and therefore have not been addressed in the PER.

The land where the development is being proposed is privately owned but, the remnant native vegetation that occurs there provides an important connection between Little Dip Conservation Park and a property located immediately south that is under a Heritage Agreement.  The Australian Government’s Threatened Species Scientific Committee has identified the South East of South Australia as one of Australia’s 15 biodiversity hotspots. This listing indicates that the South East has a high number of endemic species and the current or predicted future level of threat to biodiversity is high. It also has less that 10% of the original pre-European native vegetation remaining due to clearance for agriculture. Although a small part of the proposed development is to be situated on already cleared agricultural land, most of it will occur within remnant coastal vegetation that is currently within the Coastal Conservation Zone outlined in the District Council of Robe Development Plan. The development clearly does not meet the Objectives or Desired State for this Zone and, given the extent of vegetation recovery on the dunes over the past four decades, it would now be considered as intact vegetation and unlikely to be granted approval under the Native Vegetation Regulations.

The images below show the location of the proposal and concept plan for the development.