Koala Action Group Qld Inc

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Friday, 14 February 2014 02:31

KAG comments on Draft EPBC Act Referral Guidelines for the Vunerable Koala

auto0February 7, 2014



The Director

Species Information and Policy Section

GPO Box 787

Canberra, ACT, 2601


COMMENTS ON DRAFT EPBC ACT REFERRAL GUIDELINES FOR THE VULNERABLE KOALA (combined populations of Queensland, New South Wales and the Australian Capital Territory)


The Koala Action Group Qld Inc. (KAG) was established over 25 years ago in response to community concerns about the long term survival of the large number of koalas living in the Redlands area. Since that time KAG has accumulated much knowledge in koala habitat usage, assisted scientists with koala surveys, restored habitat and carried out a program of public awareness of koala issues. Individual members have gained valuable experience working with sick and injured koalas on the Council and State run Koala Ambulance and rearing orphaned koalas. As our experience was developed mainly in the Redlands area our observations and comments are divided into two broad areas:


Section A:   Koala Coast Population (South East Queensland)


Section B:  General concerns about the efficacy of the referral guidelines



Section A:   Koala Coast Population (South East Queensland)


1.      Ineffectiveness of the koala habitat assessment tool.

It is hard to imagine a less helpful mechanism for EPBC referral in our locality than the “Table 3: Koala habitat assessment tool”. In spite of having one of the densest populations of koalas in the densest areas there would be very few situations where the koala assessment tool would give a score of ≥ 5 because of the unrealistic vegetation composition and connectivity conditions. Much of our best koala habitat on the fertile soil areas was cleared many years ago but koalas continue to live on good quality isolated trees which do not satisfy the forest or woodland classifications. The habitat connectivity ratings are similarly absurd – contiguous habitat of ≥ 500ha is impossible for most local habitat areas to satisfy.

To use key existing threats as a means of downgrading protection is also absurd and will lead to the extinction of every valuable koala population under threat. The higher the koala population, the more visible is the mortality which will markedly skew the scores. These are populations that need more protection, not less.

The recovery value of habitat criterion score is highly subjective and encourages negative assessments which can be easily twisted to justify development.



2.      The habitat assessment tool must be improved

The presence of koalas must be weighted more heavily. It is the height of arrogance to presume that all is known about koalas’ habitat requirements. The science is lacking in finer detail of what constitutes good koala habitat as researchers readily concede. The very presence of koalas in the Koala Coast means they have managed to survive so obviously the habitat contains values that are not necessarily picked up in the simplistic habitat assessment table. Koalas survive in good numbers regardless of whether their food trees fulfil the criteria to fit into human definitions of things such as structural type or particular species. Our observations over many years support the complexity of koala food choice involving mixing and matching of what seem to be counter-intuitive tree species.  Although koala habitat has to be assessed using some sort of method in areas that have no koalas for historical reasons, if there are good known populations of koalas it should be self-evident that good koala habitat exists.

KAG recommends that the coastal vegetation criterion wording in Table 3 be widened to include areas that have been cleared but still have useful koala trees:

Has forest or woodland or grassland with 2 or more

known koala food tree species in the canopy


The habitat connectivity attribute totally discounts smaller corridors and patches. This is exactly what connectivity is – using smaller patches and corridors to connect to larger areas of habitat! The only criterion given in the table, “part of a contiguous landscape” does not facilitate connecting pieces of habitat. Valuable smaller areas as found in the urban/rural matrix must be explicitly included in the wording.

Key existing threats should be used to increase the protection measures, not give an escape clause for proposed developments.

The recovery value attribute should consider the effects of projected climate change and recognise the value of habitat that is not subject to extremes of heat and drought.

The habitat assessment tool would be much improved by weighting for “important populations of koalas”. In spite of the issue being side-stepped in the guidelines, there are a few obvious criteria that should be included, such as genetically distinct or diverse populations and those which show increased resilience to changes such as a warming climate. If we are to take the long term view and avert the slide to extinction, we must protect as much genetic variation as possible.


Section B:  General concerns about the effectiveness of the referral guidelines


1.      The “self-assessable” nature of the guidelines is unlikely to lead to positive outcomes

Although there are warnings about non-referral in the case of significant impacts on koalas, where is the mechanism that will deal with such cases?

Bias in consultant reports has always been a feature when the proponent is paying for reports. There must be a way found to bring accountability into the process.

Third party referrals are potentially useful as an accountability measure and should be mentioned in the guidelines so that proponents are aware of the possibility. Additionally, the endorsement of reports by independent local koala experts should be mandated.



2.      Incremental habitat loss is encouraged by the guidelines

While the loss of ≤ 2 ha of habitat may appear acceptable in the situation of large areas of habitat, loss of this amount in a critically important corridor could be catastrophic to the local koala population. When there are many losses of≤ 2 ha of habitat with different applications in a local area they would add up to significant habitat loss. The cumulative effects of the hypothetical examples of actions and decisions given in the guidelines could far outweigh the individual losses and the wider area must be taken into consideration.


3.      Mitigation standards and Offsets

Mitigation standards appear quite sound but it must be made clear that they never should be used as an excuse to remove important habitat.

It is inappropriate to even mention offsets even though the guidelines make it clear that they are not considered in the referral process. The mention of offsets can lead to a mindset that anything can be solved with offsets, which is counter-productive. The use of offsets to facilitate habitat loss is potentially a driving force in present-day habitat loss. Many of the struggling koala populations need food sources today, not in twenty years time.


4.      Mixed messages given on the translocation of koalas

KAG completely agrees with the statement:

The EPBC Act does not allow for compensatory measures (such as translocating individuals) or positive impacts (such as offsets) to be considered at the referral stage. At the referral stage, significance is based on the residual impact of the proposed action only.Furthermore, the department does not consider translocation or salvage translocation of koalas, to be an effective measure to mitigate the impact of an action, as it is unlikely to result in positive conservation outcomes for the species. Translocation is generally considered to result in the loss of the translocated individuals.

However, the last sentence (below) does not make sense given the meaning of the preceding sentences (above):

Where translocation is being proposed, its potential detrimental impacts, such as introducing a disease to the recipient site, needs to be considered.

The wording “needs to be considered” is too open to misinterpretation and almost suggests that after it is considered it may be done. KAG recommends deleting the last sentence as at best it is giving a mixed message, at worst is telling developers that translocation is an option to be considered.





The draft referral guidelines in their present form are a recipe for extinction of the koala. The only populations that would conceivably be helped by these guidelines are mythical populations that are living in ideal habitat. This is not a realistic view!

EPBC referral should focus on important populations that need help to survive in this day and age. The problems caused by urbanisation must be faced full-on. Rampant expansion of urban areas will lead to the loss of the koala populations that are vital to the long-term survival of the species. It is not acceptable that the Australian Government believes in the fond hope that somewhere, some isolated koala populations will survive into the long-term. Now is the time for decided action.


Yours sincerely,



Lynn Roberts B Sc – KAG Policy Advisor

360 Boundary Road

Thornlands Q 4164

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