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.

In March 2017, the NSW Land and Environment Court approved the Development Application for the Bundeena Coast Eco lodge. The proposed development is located on private land, an inholding, partially surrounded by residential properties, paper roads and the Royal National Park, near Bundeena. A map outlining the site is available to download.

Map of proposed Bundeena Coast Eco Lodge

The Office of Environment and Heritage (OEH) received a Review of Environmental Factors (REF) from an applicant requesting access along an existing sealed management 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.

What has happened so far?

The applicant was required to commission an independent review of the potential environmental impact of the access on the management trail. The 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 two exhibition periods, Thursday 1 June to Thursday 15 June 2017 and again from 5 July to 4 August 2017.

In addition to the exhibition and resulting submissions process, an assessment of the proposal for access via the management trail was undertaken by the Office of Environment and Heritage and included 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 use of the management trail is appropriate and sustainable. A total of 2655 submissions were received in relation to the exhibited REF. All submissions were carefully considered in the review.

A summary of submissions is available below.

Summary of submissions

The Review of Environmental Factors: Bundeena Coast Eco Lodge request alternative right of way (the REF) was exhibited on two separate occasions:

  • 1 – 15 June 2017 (14 days)
  • 5 July – 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.

Ten submissions were received in support of the proposal.

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

Four major themes have been identified following a review of the submissions received. These were:

Ecological impacts

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

Traffic and parking

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

Legal and 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 and 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.

Bushfire safety

  • Access road cannot provide safe access or evacuation route.
  • Inability of the access road to satisfy Rural Fire Service (RFS) requirements.
  • Locked gate at the end of the Beachcomber Avenue 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 included:

  • Procedural and administration issues, generally criticising the exhibition process and/or the materials placed on exhibition.
  • Private use of public land and precedent, with concern that 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 or consider the access road from the eco-tourist facility.
  • Construction impacts.
  • Geotechnical conditions on the access road.

Where is the management trail?

The management 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 is the current situation?

The NPWS has issued a licence which allows for access to an existing sealed management trail to the property consistent with the inholding policy which specifically enables owners of private inholdings to access their land.

Under section 153C of the National Parks and Wildlife Act 1974, access through a park is often granted to property owners along public roads or park roads to gain entry to inholdings.

Any matters relating to the Land and Environment Court who approved the development applications (DAs) for the eco-lodge are for the Land and Environment Court to consider.

Further information

For more information email:

Page last updated: 26 February 2018