The newest newsletter from this group argues that a small inclusion of the 250m buffer by an access road for EPBC 2022/9054 will have a significant impact on the Curlews roosting at night due to car headlights.

River Heads Review April 2022, page 19;

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RHAG key concerns with the current proposal
• High density development adjacent to low-density residential (minimum 2000 square metres) zoning.
• Sewerage Treatment Plant: Separation distances to housing and wetland; potential noise and odour issues; and alteration to the water table.
• Encroachment of road network within the 250-metre migratory bird buffer: Main access road partially inside buffer zone.
• Noise and light disturbance to the migratory birds by day and at night when vehicles turn into the development”

Development density is not a matter for assessment under the EPBC 1999.

There will be no noise, odour or alterations to the water table as a result of the ENVIRA STP (If a member of the RHPA attends the information session they can discuss that with the ENVIRA representative)

Minister Leys conclusion on impacts to the RAMSAR wetland from WQ were’

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68. Consistent with the conclusion on water management at [50] above, I consider that any changes in the quantity and quality of water entering the GSS Ramsar site as a result of the proposed action could be carefully managed so that they do not alter the hydrological regime in the GSS Ramsar site or cause a decline in water quality. On the basis that any such changes could be adequately managed.”

RHPA will need to provide solid independent science reporting from a site survey that vehicles at an average distance of 250m would create a significant impact to Curlews, which contradicts the findings of the Tractor videos taken at the site.

Noise and light disturbance to Curlews is not an issue as Minister Leys conclusion was;

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87. I am satisfied on the basis of the additional information and commitments made by the proponent in response to the Recommendation Report that the avoidance and mitigation
    measures proposed by the proponent and summarised at [30] above, particularly in subparagraph (30.h)], would adequately minimise any significant impacts which may have arisen from light disturbance.“

The irony is that the curlews do not roost on the mudflat at night, due to predation from foxes.