As a local expert in Biodiversity Planning matters, I object to this development on the grounds of failure to meet the minimum requirements of the SEARs particularly in relation to "Biodiversity Impacts".

The Threatened Species Assessment Guidelines (OEH 2007) (http://www.environment.nsw.gov.au/resources/threatenedspecies/tsaguide07393.pdf)
details the minimum requirements for development assessment to assess impacts upon threatened species, ecological communities and populations listed under the Threatened Species Conservation Act 1995 pursuant to s. 5a of the Environmental Planning and Assessment Act 1979 (EP&A Act). These guideines (OEH 2007) state:
"The assessment of significance is the first step in considering potential impacts. When a significant effect is likely, further consideration is required and is more appropriately carried out when preparing a species impact statement."

The guidelines further state:
"A species does not have to be considered as part of the assessment of significance if adequate surveys or studies have been carried out that clearly show that the species:
* does not occur in the study area, or
* will not use on-site habitats on occasion, or
* will not be influenced by off-site impacts of the proposal.
Otherwise all species likely to occur in the study area (based on general species distribution information), and known to use that type of habitat, should be considered in the rationale that determines the list of threatened species, populations and ecological communities for the assessment of significance"

The Ecologist Consultant (Stacy Wilson of Eco Logical Australia) states (on Page 4 of the Flora and Fauna Assessment):
"It is noted that some threatened fauna species that are highly mobile, wide ranging and vagrant may use portions of the subject site intermittently for foraging. For these fauna species, the habitat present and likely to be impacted is not considered to be important to the threatened species, particularly in relation to the amount of similar good quality habitat remaining in the surrounding landscape. As such, an assessment of significance in reference to State or Commonwealth legislation was not considered necessary."
This is an illegitimate rationale/reason to avoid preparing a formal "Assessment of significance" (AoS) ('7-part test) pursuant to the provisions of the EP&A Act and the Threatened Species Assessment Guidelines (OEH 2007) or the Commonwealth Environment Protection and Biodiversity Conservation Act 1999 Protected Matters Impact Assessment Guidlines.

Stacy Wilson (Eco Logical 2017) stated that foraging habitat occurred on the subject site for the vulnerable Grey-headed Flying fox, Large-eared Pied Bat, Little Bentwing Bat, Eastern Freetailed Bat, Large-footed Myotis, and Eastern Bentwing Bat but arbitrarily chose not to prepare an 'Assessment of Significance' in accordance with the EP&A Act and Guidelines (OEH 2007). In 'Appendix A : Table 2' of the Flora and Fauna Assessment, under the column 'Impact Assessment Required' Stacy Wilson of Eco Logical Australia states "No. Impact to foraging habitat negligible in comparison to habitat within the locality".
One cannot simply reject the need to
prepare an Impact Assessment (AoS) pursuant to the EP&A Act. The guidelines (OEH 2007) clearly state that if a threatened species has potential occur on a site, the first step is to undertake an AoS (aka 7-part test) on that species pursuant to the provisions of the EP&A Act.
Without this having been undertaken for the threatened fauna listed as "potentially occurring" on site, the Flora and Fauna Assessment (Eco Logical Australia 2017) fails to meet the minimum requirements of the SEARs.

Further to this Eco Logical Australia (2017) rejects the potential for the vulnerable Powerful Owl to occur on the subject site, despite the presence of 80 records of this species in the surrounding area and the presence of large trees within the subject site (see Figure 1) that are likely to support the main prey of the Powerful Owl (possums. flying-foxes a large birds). It is our professional opinion and likely that of most, that the mobile, Powerful Owl is likely to utilise the subject site for
foraging purposes.

The highly mobile, vulnerable Little Lorikeet is also likely to occur on the subject site (owing to the presence of at least three known feed tree species, especially Eucalyptus tereticornis). Stacy Wilson (Eco Logical Australia 2017) assessment of the liklihood of this species occurring on the subject site is wrong, as like the Powerful Owl, it is likely the Little Lorikeet would occur at a point in its lifecycle. An adequate AoS of the proposed
works on both of these species is required but has not been done.

The level of ability held by the Ecologist who undertook the site assessment is questionable and quite likely inadequate to assess biodiversity impacts from
this type of development. 'Appendix B: Flora species recorded in site' contains an unusually low flora species richness (even for an urban school ground in Sydneys Northern Beaches).
The flora list lacks any ground cover species (including grasses
or weeds) typical of any garden/outdoor area in Sydney. This reflects insufficient survey effort and/or the authors lack ability to effectively assess the landscape of biodiversity values on a development site.

The Ecologist (Eco Logical Australia 2017) does not provide any reliable reason/explanation as to why "Estuarine Swamp Oak Forest (endangered under the TSC Act) previously mapped within the locality by SMCA 2016. " was confirmed to not occur on the subject site, when the site species list contained the two primary canopy species of this community (Casuarina glauca and Melaleuca quinquinervia). Adequate explanation
for the lack of an EEC (that has been previously mapped in the area) must be provided.

Overall the Flora and Fauna Assessment (Eco Logical 2017) that accompanies this SSD is poorly prepared and fails to
meet the fundamental requirements of a Flora and Fauna Assessment for this scale
of project.

For this reason the SSD should be rejected until an alternative Ecologist Consultant with local expertise is selected to prepare a revised Flora and Fauna Assessment that effectively addresses the true flora and fauna values of the subject site, to the level of detail required to meet the legislation and guidelines.

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