Re: Inquiry into the status, health and sustainability of Australia's koala population

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8 February 2011

Committee Secretary
Senate Standing Committee on Environment and Communications
PO Box 6100
Parliament House
Canberra ACT 2600
Email to:,au

Dear Sir/Madam,

Re: Inquiry into the status, health and sustainability of Australia's koala population

Thank you for the opportunity to comment on the Inquiry into the Status, Health and Sustainability of Australia's Koala Population. The Urban Development Institute of Australia (Queensland) (UDIA (Qld)) is the peak industry body representing the development industry in Queensland. The development industry in Queensland directly employs 235,000 fulltime equivalent employees, around 10.9% of the total Queensland workforce with indirect employment reaching a further 143,800 families.

Critical to the industry and the economic benefits it provides is an efficient, comprehensible and equitable environment in which to operate. A clear regulatory environment that provides adequate development land supply, efficient processes and minimum costs on development enables an affordable housing supply with the social benefits this brings together with wider economic benefits. In addition a clear regulatory environment can reduce community disruption and disputation as the location for development is made clear and the areas preserved for biodiversity protection are safeguarded.

UDIA (Qld) has worked intensively with the Queensland state government, as recently as late last year regarding the South East Queensland (SEQ) Koala Conservation State Planning Policy and SEQ Koala Conservation State Planning Regulatory Provisions to define appropriate development locations and measures to safeguard and enhance Koala habitat. The work has developed a sophisticated new regime for Koala protection in South East Queensland.

UDIA (Qld) does not make claims as to present Koala population numbers or other scientific aspects. We do however seek that any decision is made on sound scientific information. It is clear to us, that at least in Queensland, issues around Koala population protection are very substantially affected by emotional or other views based on values which can lead to incorrect outcomes. It is critical that this hyperbole is stripped away and true scientific measures utilised.

Legislative Environment – Environmental Protection and Biodiversity Conservation Act

UDIA (Qld) stated in our letter to the Department of the Environment, Water, Heritage and the Arts in June 2010 concerning the Environment Protection and Biodiversity Conservation Act 1999 (EPBC) nomination to list Koalas as a threatened species, that it would not support such a listing. We considered this as being premature, perhaps overly influenced by issues in limited locations and not clearly (at least to the Institute) based on unambiguous scientific evidence. The listing would create a difficult regulatory load that is particularly of concern given the ailing state of development activities and construction employment in Queensland and particularly is unnecessary at this time as a consequence of recent new controls for SEQ applied by the Queensland government.

Whilst the Act is focused on matters of national environmental significance, the effect of promulgation of a species under the Act in additional to or as an overlay on other sustainability policy and legislation is leading to a piecemeal outcome that diminishes its ability to address the overall sustainability of the country and the communities that the Australian government serves. The urban development industry is not seeking to weaken environmental outcomes but to ensure environmental assessment is conducted at the appropriate time within the development cycle to provide certainty to developers and the community whilst allowing appropriate flexibility based on clear and transparent, scientifically based policies.

In the industry's experience, due to the lack of certainty about what is required, the lack of defined thresholds and the legal uncertainty of other government agencies, many developments are being referred that are not significant under the Act. There is a need for clearer guidelines on when a development project needs to be (or is recommended to be) referred. The current framework provided by the Act for the conservation of Australia's biodiversity appears to be driven on a project by project basis without sufficient understanding of the broader status of the listed species, which limits its effectiveness. The Act tends to focus on habitat retention at all costs rather than the current and future needs of the species in question.

Management of Land Use in the Context of Koala Habitat Protection

In light of the Industry's experience with Queensland State Government's draft Koala SPP and SPRP for South-East Queensland, the following recommendations are offered as a means of clarifying how competing social, economic and environmental interests need to be carefully managed: