Nature conservation

Parks, reserves and protected areas

Royal National Park: request for trail access at Bundeena

Review of Environmental Factors requesting access across a fire trail in the Royal National Park, at Bundeena.

The Office of Environment and Heritage (OEH) received a Review of Environmental Factors from an applicant requesting access along a trail in the Royal National Park as a legal means of access to the proposed Bundeena Coast Eco Lodge site at 60-70 Bournemouth Street, Bundeena.

Submissions closed 4 August 2017.

Where is the fire trail?

The trail is located at the south-eastern end of Beachcomber Avenue. The requested access comprises 440 metres of existing sealed trail through the national park.

What does this request for access involve?

The access granted will involve the limited use of the existing management trail and some upgrading to meet fire management standards for safety.

What has happened so far?

The applicant was required to commission an independent review of the potential environmental impact of the access on the fire trail. National Parks and Wildlife Service (NPWS) consulted with the community on the Review of Environmental Factors: Bundeena Coast Eco Lodge request alternative right of way (PDF 4.1MB) for a period of 6 weeks, across 2 exhibition periods, Thursday 1 June to Thursday 15 June 2017 and again from 5 July to 4 August 2017.

What is the current situation?

OEH has now assessed the REF. All matters that could affect the environment were taken into consideration in the review.

A licence under section 153C of the National Parks and Wildlife Act 1974 has been granted. The licence includes conditions that ensure environmental and safety issues are addressed.

The submission process

The submission process is designed to seek public comment on proposed activities to assist Government decisions on such activities. In addition to this submissions process, an assessment of the proposal includes rigorous investigation by experts to determine an activity's impacts on the environment. A combination of these processes helped inform the decision on whether the activity is appropriate and sustainable.

A total of 2655 submissions were received in relation to the REF. All submissions were carefully considered in the review process.

A summary of submissions is available.

Summary of submissions

The Bundeena Coast Eco Lodge Request Alternative Right of Way Review of Environmental Factors (the REF) was exhibited on 2 separate occasions, as follows:

  • 1 to 15 June 2017 (14 days)
  • 5 July to 4 August 2017 (30 days).

A total of 2655 submissions were received – 1744 in response to the first exhibition and a further 911 submissions in relation to the second exhibition.

There were 10 submissions received in support of the proposal.

The points raised in submissions objecting to the proposal that were made in response to both the first and second public exhibition periods are largely consistent.

We identified 4 major themes following a review of the submissions received. These were:

Ecological Impacts

  • Inadequate ecological assessment, in particular assessment of impacts on Endangered Ecological Communities.
  • Degradation of biodiversity values - loss of vegetation, invasion of weeds and loss of habitat.

Traffic and Parking

  • Pedestrian/vehicle conflict.
  • Underestimation of traffic volumes.
  • Exacerbation of existing traffic and parking problems at the end of Beachcomber Ave – impacts on resident amenity.

Legal/Statutory Issues

  • National Parks and Wildlife Act 1974 – contrary to the intent and purpose of national parks; contrary to the Royal National Park's Vehicle Access Policy.
  • Environmental Planning & Assessment Act 1979 – Part 5 requires full assessment of indirect and direct impacts as well as cumulative impacts.
  • Proponent has no legal title over the paper roads.

Bush Fire Safety

  • Access road cannot provide safe access/evacuation route.
  • Inability of the access road to satisfy Rural Fire Service (RFS) requirements.
  • Locked gate at the end of the Beachcomber Ave is contrary to RFS requirements for unobstructed access.

While most issues raised in the submissions fell into the themes discussed above, a variety of other matters were also raised in individual or comparatively small numbers of submissions. These include:

  • Procedural/administration issues – generally criticising the exhibition process and/or the materials placed on exhibition.
  • Private use of public land/precedent – concern that in allowing access through the National Park to a private commercial development constitutes an alienation of this section of the Park and sets an undesirable precedent.
  • Inability to separate/consider the access road from the eco-tourist facility.
  • Construction impacts.
  • Geotechnical conditions on the access road.

Disclaimer: OEH has compiled this publication in good faith, exercising all due care and attention. No representation is made about the accuracy, completeness or suitability of the information in this publication for any particular purpose.

Further information

For more information email:

Page last updated: 07 December 2017