Please see attached

Submission - Proposed North Byron Parklands Cultural Event Site (SSD
8169) I submit that Parklands should not be granted approval to
operate further events at the above site and should find another site
upon which to conduct their activities for the following reasons:- The
social and ecological impacts of festivals at Parklands are
unacceptable with excessive noise, traffic, trash, trespass, illegal
camping and anti-social behaviour in the residential neighbourhoods
near the site. Flooding / Stormwater / Potential loss of life: The
severe impacts and loss of life associated with the recent unexpected
storm and flooding events in Murwillumbah and Lismore are testament to
the unpredictability of extreme storm events now effecting our region.
These are expected to become even more severe and unpredictable due to
climate change. The effectiveness of the Flood Risk Management Plan
relies too much on the early evacuation of patrons from the site. For
this reason and due to the unpredictability in the severity of storm
events, the site should not be used for large or medium cultural
events during Spring and Summer.. The NSW Police report (11 January
2017) details numerous issues relating to safety and security on the
Parklands site and in the areas around it. The Tweed / Byron Police
Force cannot provide the level of response needed to ensure the safety
of the local community as well as the safety of festival patrons at
current trial crowd levels. The proposed number of patrons allowed at
the events is too great to be able to provide effective emergency
evacuation of the site. It appears that volunteers, performers and
workers have not been taken into account when assessing impacts and
evacuation planning for the site. This needs to be addressed prior to
consideration being given to the application. Pollution: Pollutant
traps are inadequate as trials have identified large amounts of
rubbish found at the site. This rubbish can escape the site during
storm and flood events. Patrons, their possessions and their rubbish
should be removed from flooding and low lying areas. This will not be
practical as early evacuation is necessary. For this reason the site
should not be used for events during the spring and summer rain
season. Noise: I can hear music from the festivals where I live in
Pottsville 8.5 km from the site (video footage available on request).
This problem has persisted throughout the five-year trial period and
has had a severe adverse impact on the amenity of local residents.
Noise levels will be much higher than those at the trial events. Noise
monitoring was not adequate during trial events Trial events have not
tested the effects of the forecasted increase in patronage and the
consequences are unknown. Therefore the application for use of the
site for permanent cultural events should not be granted. Compliance
conditions are unlikely to be fulfilled as the event grows in size.
Ongoing community concerns were identified during trial events. There
may be legal ramifications as a result of noise levels should new
owners purchase the properties adjacent to the site. . An independent
peer review should be undertaken to assess predicted noise levels.
Endangered Species: The local koala population east of the Pacific
Highway between the Brunswick and Tweed Rivers is listed as an
Endangered Local Population under the Threatened Species Conservation
Act 1995. Koalas are now known to reside in the bushland adjacent to
the Parklands site (refer NSW Bionet Atlas). There is a wildlife
overpass over the Pacific Highway in very close proximity to the
Parklands site. The crossing is there to provide a link from the
bushland surrounding the Parklands site to wildlife corridors west of
the highway. It is essential that this link is effective in providing
connectivity to the western corridors for koala movement in order to
enhance gene diversity in the Tweed / Brunswick endangered local koala
population. Lack of gene diversity in koala populations causes
inbreeding leading to high incidence of disease and death. Increased
traffic on Tweed Valley Way will severely increase the potential of
koala death due to vehicle strike where it crosses the wildlife
corridor immediately adjacent to the wildlife overpass over the
Pacific Highway. I submit that environmental impacts associated with
the festival site have a strong likelihood to compromise the
effectiveness of the wildlife overpass. Koala expert Dr Steve Phillips
has published a paper titled Aversive behaviour by koalas
(Phascolarctos cinereus) during the course of a music festival in
northern New South Wales, Australia (see attached including supporting
documentation). The findings of this study should be taken into
consideration. Section 94A of the TSC Act and s. 220ZZA of the FM Act
provide that the Minister for Climate Change, Environment and Water
and the Minister for Primary Industries, with the concurrence of the
Minister for Planning, may prepare assessment guidelines to assist in
the interpretation and application of the factors of assessment. These
guidelines have been prepared to help applicants/proponents of a
development or activity with interpreting and applying the factors of
assessment. The aim of the guidelines is to help ensure that a
consistent and systematic approach is taken when determining whether
an action, development or activity is likely to significantly affect
threatened species, populations or ecological communities, or their
habitats either directly or indirectly. It is clear that it is very
difficult to forecast the cumulative impacts of events of the kind
conducted at the Parklands site on the ecology of the area. The
Threatened Species Guidelines state: Application of the precautionary
principle requires that a lack of scientific certainty about the
potential impacts of an action does not itself justify a decision that
the action is not likely to have a significant impact. Considering the
Endangered status of koalas in the local area and based on the
findings of Dr Phillips' study and the assessment guidelines, I submit
that no further festivals should be conducted at the North Byron
Parklands site in order to ensure that there is no significant impact
on the local koala population. Traffic: The Environmental Impact
Statement contradicts itself by defining the use of the access road
onto Wooyung Road as both an Emergency Access Road and an access road
to service the Tweed Coast catchment. Wooyung Road is subject to
flooding and can't be relied on for an emergency access. The use of
postcodes to estimate traffic generation for Gate E is flawed. Traffic
from other areas outside the region will use Gate E if other gates are
clogged with traffic and it is unacceptable to assume that the
associated camping area will be used only by local residents. These
matters need to be factored into the traffic assessment and Traffic
Management Plan . The Traffic Assessment does not provide enough
information on road upgrades needed as a result of Gate E or its
effects on coastal roads. Impacts of shuttle bus services to the site
on Coastal Community traffic networks need to be assessed.