1. At 534.6 hectares, the site is 136-hectares bigger than Kings Park, and larger in area than New York’s Central Park and London’s Hyde Park - combined.  The area is part of an International Biodiversity Hotspot supporting highly sensitive and complex ecosystems that are known to be under threat.

2. At least 160 hectares, or 53.9% of intact forest 300 hectares at North Stoneville, will be totally cleared.  This is the same amount as in the original plan because Satterley’s removal of ‘Lot 1’ (20 hectares) is irrelevant because Lot 1 is not zoned for Urban development.  

3. There are almost 300 hectares of Moderate to Excellent Quality (Dept of Environment WA 2020), Black Cockatoo foraging and roosting habitat on the site that will be disturbed or destroyed by Satterely’s North Stoneville - in contravention of WA’s SPP 2.8 Bushland Policy for Perth Metropolitan Region - and  SPP 2.0 Environment & Natural Resources. This should again be rejected based on contravention of SPP 2.8.

4. Much of the site outside of the conservation area will become a “managed landscape” to reduce BAL ratings for housing, which will result in more habitat destruction. The developer admits that “clearing practices may also result in accidental clearing of vegetation and trees proposed for retention” resulting in extended clearing of natural vegetation.

5. Black Cockatoo Impacts: A detailed environmental EPA assessment must be done.
                   
6. The cumulative impacts of clearing Black Cockatoo habitat for North Stoneville, 160 hectares, then North Parkerville, 100 – 200 hectares, should be taken into account when assessing the level of habitat destruction. If the currently un-funded EastLink proceeds, approximately 1000 more hectares of habitat destruction would occur. - - The Commonwealth of Australia’s new Referral Guidelines for the 3 WA threatened Black Cockatoo Species 2022 states that:
  a.loss of greater than 1 ha of potential nesting habitat must be referred
  b.nest trees and potential nest trees must be protected
  c.assessment must be done by a person qualified in black cockatoo assessment

7. All three threatened and endangered Black Cockatoos have been observed, nesting, foraging, and roosting on the site, and a site survey identified 27 potential nesting trees (which take 200 years+ to develop suitable nesting hollows).  At least 15 of those 27 trees will be destroyed.
  a.Endangered - Carnaby’s Black Cockatoo (Calyptorhynchus latirostris)
  b.Endangered soon to be listed as Critically Endangered - Baudin’s Black Cockatoo
  (Calyptorhynchus baudinii)
  c.Vulnerable  - Forest Red-tailed Black Cockatoo (Calyptorhynchus banksii naso)

8. The three Cockatoos are listed as Matters of National Environmental Significance and protected under the National environment - ‘EPBC’ Act. Satterley’s original North Stoneville plan never got approval under the EPBC Act despite 5 years of effort. - - Planned ‘offsets’ (buying land elsewhere to compensate for the losses at North Stoneville and offering money for ‘Black Cockatoo research’,) have proven unacceptable to the EPBC office.   

9. Ongoing habitat loss through the destruction of native vegetation has been identified as a key threat contributing to the continued decline of all three Black Cockatoo species to levels that are leading them to be extinct within 20 years.

10. At least 50,000 mature Jarrah and Marri forested trees will be bulldozed if this development is approved. The ecological devastation caused by this is incomprehensible. - - Over the next 27 years, (to 2050) these trees will remove 35,640 tonnes of CO2 - a major contribution to the WA Govt’s legislated commitment for net zero emissions by 2050.

11. The site provides habitat for Chuditch (Dasyurus geoffroii – Vulnerable) and Brush Tailed Phascogale (Phascogale tapoatafa – conservation dependent.) Habitat destruction and the introduction of cats and dogs will have a disastrous impact on these species.

12. The previous plan was rejected by WAPC under SPP 2.0 Environment & Natural Resources and should again be rejected given no new updates aligned to increasing Climate Change impacts have been considered, along with the State’s new Biodiversity Act.  The original environmental reports produced by the developer were superficial and inadequate, not conducted across all seasons, observations regarding nocturnal animals were taken during daylight-only surveys, and flora surveys were not representative of seasonal changes. Updated surveys have not been undertaken for this amended plan despite an increased recognition of Climate Change, a State Govt ministerial Climate Action portfolio has been created since the first Satterley report of 2018, along with heightened awareness around the importance of protecting our native flora and fauna, and an updated WA Biodiversity Act. The Minister for Environment and Climate Action, the Hon, Reece Whitby will ‘release the State Govt’s Climate Action Adaptation Strategy mid-2023’ - too late for public submissions relating to this issue, but available for WAPC to include in your considerations of this matter.  

13. A stranded community such as this will rely on private vehicles (The Public Transport Authority will not commit to a bus route before 2038), resulting in an increase in greenhouse gas emissions at a time when the State Government is actively  establishing a framework for responsible emissions reductions to meet WA’s goal of net zero by 2025.

14. Climate Change impacts or actions, aligned to meet the State Government’s formal Climate Change Policy, have not properly been factored into the proposed development. Land clearing will result in mass habitat loss and release of carbon from the clearing of at least 160 hectares.

15. CSIRO/BOM State of the Climate Report 2018 and 2022 predict a hotter, drier climate for the South West of WA with longer, more intense fire seasons further placing this fragile habitat at increasing risk.