As a community representative on the Regulatory Working Group, I have the
privilege of access to some of the intricacies of the North Byron
Parklands operation and an understanding of what this involves. This
informs my submission as a private individual. NBP have been able to
manage the two large festivals on site at current capacity limits with
limited inconvenience to the general community. However, I have key
concerns regarding the proposal to expand the patron numbers and
festival days as outlined in the SSD application. These are: 1. the
inadequate Economic Impact assessment (Appendix W); 2. the lack of
provision for any ongoing contributions to the local council; 3. the
way in which numbers on site are reported and discussed; 4. the
proposed increase in patron numbers; 5. the proposed incremental
increases in patron numbers at three times the rate of incremental
increases during the temporary approval. 1. Economic Impact assessment
This report is woefully inadequate as it does not provide strong
evidence to support its claims, and is self contradictory, indicating
a flawed model. While claiming that the increase in patron numbers and
festival days will result in increased opportunities for local
businesses and increased employment, with specific numbers given, on
page 22 of the report it notes that "increased demand for a product is
assumed to imply an equal increase in production for that product. In
reality, however, it may be more efficient to increase imports or
divert some exports to local consumption rather than increasing local
production by the full amount" (my emphasis). Furthermore, the
multipliers that have been used are stated as "not appropriate for use
in economic impact analysis of projects in small regions." These
statement undermine the quality of the report to such an extent that I
think it should be discounted. The lack of any independent modelling
or reporting on the economic impact of such a major development is a
serious flaw in this approvals process. 2. Contributions to Byron
Shire Council The Economic Impact assessment refers on page 4 to the
fact that NBP can "leverage" on Byron Bay's "well-established national
and international brand and reputation." There is no provision,
however, for any ongoing contribution to the local council to help
support the proposed increase in visitor numbers, while acknowledging
that patrons do spread out from the site and use local facilities. NBP
is required to make Section 94 contributions, but this is a one-off
contribution and does not reflect the ongoing stress on the community
and its infrastructure (such as roads, amenities). I understand NBP is
in talks currently with council about a potential per-ticket levy to
go to council. This is a good start, however, I would like to see a
commitment to this prior to consent being considered. 3. Reporting of
numbers on site The proposed increase in patron numbers discussed
generally and with community groups is not the actual number of people
on site, which is greater. Thus 35,000 patrons means 40,290 people on
site, and 50,000 patrons means 57,850 people on site (page 35 of EIS).
I understand that the total number is accounted for in emergency
services planning, but the larger numbers have not been mentioned in
any press releases, or been raised in community consultations unless
prompted. I do not feel the community has been appropriately briefed
by NBP on the numbers, and would like to see the total numbers of
people on site being the benchmark number referred to, rather than the
patron numbers. For example, rather than 50,000 people, the discussion
should focus on the `real' number of just under 60,000. 4. Proposed
increase in patron numbers I have not been convinced by anything in
the EIS and supporting documents that the proposed increase in patron
numbers will be of benefit to a shire of 32,000 residents. The
increase in numbers will certainly benefit the owners of the site and
the promoters of the flagship festivals, but due to the poor economic
modelling and the lack of commitment to ongoing financial
contributions to the local council, I would like to see the patron
numbers kept as they are, which in reality means the influx of just
over 29,000 for Falls Festival and just over 40,000 for Splendour in
the Grass. I do support the conference centre development, assuming it
stays at the size proposed, and the small and minor event days. 5.
Proposed incremental increases in patron numbers Although I am opposed
to an increase in patron numbers, if this is granted, the incremental
increases need to be adjusted. During the temporary approval period,
NBP has been allowed to increase patron numbers by 2,500 per year,
subject to meeting KPIs. This has allowed them to iron out any issues
that have arisen. This process has worked well to date, but this
success is not in itself proof that an increase of 7,500 patrons per
year (subject to meeting KPIs) is workable or advisable. If an
increase in patron numbers is considered at all, experience shows that
2,500 per year is an appropriate number. Furthermore, for Falls
Festival there is no proposed incremental increase from 25,000
(current) to 35,000. While smaller than Splendour in the Grass, Falls
Festival occurs at peak tourist time in the region and an extra 11,040
people (that is the projected increase in people on site), is
significant. Incremental increases of 2,500 patrons (subject to
meeting KPIs) would make much more sense in order to assess the impact
on the area. In conclusion, while I can see benefits of having a
permanent approval in terms of being able to have better
infrastructure and improve facilities, I cannot support this
application for the reasons outlined above. Thank you for this
opportunity.

This development is inappropriate given the location of the proposed
venue, the nature of the surrounding environment and the lack of
infrastructure to support such a development. The proposed development
will reportedly host festivals at least 20 days per year, and includes
an international conference centre and hotel bar (golden view bar).
The proposal would result in a regular influx of patrons twice the
number of Byron Shire and up to four times the number of rate payers.
The festival patrons will be paying a company with 51% ownership by an
international events company (Live Nation). The current fesitvals held
at the proposed development location (i.e., Falls and Spendour) have
already had a major impact on our neighbourhood and have resulted in
such negative changes to the community (incuding noise, poor behaviour
and increased traffic and noise pollution) that some members of the
immediate neighbourhood have sold their houses. If successful, the
proposed venue has the potential to attract patrons who may not behave
in ways that are responsible or on keeping with the ethos of the
surrounding community. Already during festivals we see people sleeping
on the beach between Wooyung and South Golden Beach, fires on the
beach, an increase in litter on the beach and anti-social behaviour in
our streets and nature reserves. This past summer there were also
instances of predatory behaviour on the beach, which were reported to
the police.

1. Common sense tells us that if local residents' windows rattle, one
kilometre away due to festival noise, as ours do, then wildlife will
of course be distressed. 2. The festival organiser's 'study' the
impacts of noise on wildlife. The businesses providing this service
have a vested not independent interest, meaning if they bring back a
negative result they will likely not have their contract renewed, and
thus be more inclined to sway the result to favour the organiser's
interests. Therefore, it is not an independent study and there are NO
independent studies related to their events impacts. 3. The
organiser's could use the fully functional, large enough Blues
Festival site, a site that was and is well up and running before their
site was. Perfect venue already there, we do not need multiple
festival sites in the same shire and most importantly it does not
negatively impact the Yelgun Wildlife Corridor site. 4. No amount of
'vegetation rehabilitation' (largely financed by government grants and
volunteer labour) entice wildlife to remain subjected to intense noise
levels and massive patron numbers and their cars. And by making this a
permanent site, with increased events and attendance we run the risk
of causing irreversible damage. Since moving here I have sadly heard
how the koalas that used to be quite common in the trees around the
area (out the back of our houses and along the Optus trail) are no
longer returning, sadly we have not seen one. 5. The organiser's
monitor noise levels. Only CONOS Inc have independently monitored
noise levels and found that the organiser's are not truthful and have
exceeded the noise limits many times. There have been numerous stories
and articles in the local newspapers, along with personal experience,
of the surrounding community hearing the festival loudly and clearly,
then finding out they breached their noise thresholds, resulting in a
little fine and slap on the wrist. This clearly is not a deterrent for
them to stay within their so called limits and they cannot be trusted
to do so. 6. Only the Sydney-based NSW environment department oversee
whether the organisers follow the rules. They are rarely seen here and
as mentioned above its left to the organisers to abide to and they
clearly have little respect for following and upholding these rules.
7. The festivals have a history of breaking the rules and only
receiving minor fines. So for them it is worth it. For us a community
it is not, it is damaging to our surrounding environment and frankly
unnecessary they don't follow the rules, there is a perfect
operational site they could relocate to and this would remove the
treat to the Yelgun Wildlife Corridor.

The festival site is part of the Yelgun Wildlife Corridor. I live several
kilometres away and the noise is clearly audible. This must
significantly distress local wildlife. The closest suburbs are small
coastal towns with no infrastructure. We are overwhelmed with festival
goers illegally camped in the streets. Telecommunications fall over
completely during festivals. No mobile signal and internet dies. I
work from home several days a week. This impacts on my livelihood. The
corridor is often bone dry with a large peat content. If there was a
fire the loss of life would be catastrophic. The festival organiser's
'study' the impacts of noise on wildlife. We don't believe them. There
are NO independent studies. The organiser's could use the Blues
Festival site. There is no need to use the Yelgun Wildlife Corridor
site. No amount of 'vegetation rehabilitation' (largely financed by
government grants and volunteer labour) entice wildlife to remain
subjected to intense noise levels and massive patron numbers and their
cars. The organiser's monitor noise levels. Only CONOS Inc have
independently monitored noise levels and found that the organisers are
not truthful and have exceeded the noise limits many times. Only the
Sydney-based NSW environment department oversee whether the organisers
follow the rules. They are rarely seen here. 7. The festivals have a
history of breaking the rules and only receiving minor fines.

I am writing on behalf of the organisation that is responsible for the
workplace heath and safety at the two events held at North Byron
Parklands. We regularly induct between 1500 to 2000 workers,
contractors and volunteers into our site safety management system, and
I can state, thanks a significant relationship with Safework Australia
and ongoing development of stringent practises and guidelines we have
no notifiable incidents to report. Certainly there is some minor
scrapes and bumps but out qualified first aid on site deals with
those, however, with all the high risk work taking place (forklifts,
cranes, trucks etc) and the number of staff our protocols have reduced
the hazards so dramatically we are operating in a virtually risk free
environment. Both Splendour and Falls use experienced contractors,
short term staff and unpaid labour, meaning we have a variety of
levels of expertise on site for sometimes nearly 28 days. The
management of these folks is dealt with by implementing regimes and
processes as high as any major construction site across the country.
Both events processes rival Australia's largest multi-national
construction organisations however integrate this with market stall
holders, local family run food vendors and local creative people. I
can say without refute that because we have been developing these
system since NBP began we are at the forefront of WHS practise - a
fact reiterated by Safework Australia in that organisations internal
publication. Importantly, the has allowed my organisation to create
more work opportunities across Australia, namely JSES is the national
Safety Consultant for Laneway Festival, same for Winton's Way Out West
Festival and have worked for Qld government managing the Maroon
Festival in Southbank in 2017. North Byron Parklands has allowed my
small business to employ pope and grow, to keep my family working and
living in the area, and I wholeheartedly support it's future in it's
location.

Great community and cultural events site that boasts beautiful surrounds.
Stimulates the local economy.

I fully support these applications. My family of 4 including 2 teenage
boys have attended Splendour for a number of years. Friends and family
from outside the area come and stay with us and at local accommodation
to attend both Splendour and Falls. They eat at local restaurants and
buy local products. These applications give rise to the opportunity
for North Byron Parklands to work with local businesses, generate
employment and support creative industries in the Northern Rivers
region. One of my sons has already worked at the site the other wants
to play there. For these reasons I passionately support these
applications.

I have worked and lived at and near Ocean Shores since 1973. Many of the
opponents of Parklands were also responsible for taking most of the
original Ocean Shores estate and locking it up into 1000 Ha of nature
reserves with no humans allowed. Ocean Shores is the largest
residential town in the Byron Shire. It has no high school, university
outreach TAFE, public or community health facilities or services,
usable public space, town centre, government offices or services,
minimal footpaths, cultural centre, art gallery as promised etc.
Nothing can be provided because there is no land left for public use.
Parklands give us back something of what is lost. Please make it
permanent and stop the activists at last.

Having worked on the construction of North Byron Parklands, I believe it
is a great venue and I support the sites ongoing use for cultural
music events. Regards Scott Roberts

Ocean Shores has been deprived of much of its territory and
infrastructure by environmental plunderers subsuming promised public
land into giant nature reserves. They are trying to do the same with
the Parklands site.Most of the town's 6000 residents are in favour of
this cultural events site because it gives back to the people
something of what was originally promised. Permanency to Parklands
means employment, training, small business opportunities, music,
culture and fun! The best 2019 50th Birthday gift to the town is a
permanent flourishing cultural events site within Ocean Shores'
boundaries. OSCA has supported this since 2008..