13.2.2018 To: NSW Planning and Environment From: Dr Andrew Benwell
(ecologist) PO Box 641, Mullumbimby NSW 2482 Cultural Events Site -
State Significant Development Application (SSD - 8169) Preliminary
Submission and request of extension Dear Sir/Madam, I would like to
register my objection to the EIS for SSD 8169 for permanent approval
and expansion of the cultural events site at Yelgun.. I wish to apply
for an extension of two weeks (longer if possible) to complete my
submission. I have set out the main dot points in my submission below,
as requested In my opinion the conclusion of the ecological monitoring
program, which underpins the EIS, that there were no significant
negative impacts on wildlife during the five year music festival trial
is invalid for the following reasons: * Impacts during the pre-event
construction period were not monitored or assessed prior to the actual
EIM (Event Impact Monitoring). * The bird sampling strategy was biased
with more control sites than impact sites. * Monitoring data was never
included in the monitoring reports for public examination. * Bird
monitoring was limited to Paperbark swamp forest on the floodplain. *
Impacts on uncommon or low frequency bird species, which make up the
majority of the avifauna were not assessed. * Lumping approach to data
analysis obscures site specific changes. * The experimental design
implicit in the monitoring program was poorly planned and flawed from
the outset. * There was no effort to collect systematic baseline. *
Quantitative evidence of negative impact on birds evident in many
results not discussed. * Inappropriately complex statistical analysis
methods in documents meant for the general public. There is
considerable evidence, direct and indirect, that conduct of a music
festival venue in the high conservation value locality at Yelgun will
have a serious, long-term, deleterious effect on the biodiversity of
the festival site property and surroundings, undermining more 30 years
of effort by the community, the State Government, Byron and Tweed
Shire Councils and the National Parks and Wildlife Service to conserve
the area's biodiversity for future generations. Can you please confirm
receipt of this preliminary submission and request for an extension.
Regards, Andrew Benwell (Dr)

SGBCA submission is attached.