Review of Environmental Factors: Bundeena Coast Eco Lodge request alternative right of way

1 April 2017
Office of Environment and Heritage
  • ID OEH20160446
  • File PDF 4.1MB
  • Pages 78
  • Name review-environmental-factors-bundeena-coast-eco-lodge-request-alternative-right-way-160446.pdf


The NSW Land and Environment Court approved the Development Application for the Bundeena Coast Eco Lodge in March 2017. The proposed development is located on private land, an inholding, partially surrounded by residential properties, paper roads and the Royal National Park, near Bundeena.

The Office of Environment and Heritage received this review of environmental factors (REF) requesting access along an existing sealed management trail in the Royal National Park. The access trail would provide a legal means of access to the proposed Bundeena Coast Eco Lodge site at 60–70 Bournemouth Street, Bundeena. The requested access comprises 440 metres of existing sealed trail through the national park.

A map of the proposed eco lodge site and surrounding area (PDF 1MB) is available.

Public consultation

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 this review of environmental factors (REF) across two exhibition periods, from 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.

Summary of submissions

A total of 2655 submissions were received in relation to the exhibited REF: 1744 in response to the first exhibition and a further 911 submissions in relation to the second exhibition. All submissions were carefully considered in the review.

Ten submissions supported the proposal.

The points raised in submissions that objected to the proposal for both public exhibition periods were largely consistent and most issues raised fell under 4 main themes: ecological impacts, traffic and parking, legal and statutory issues and bushfire safety.

  • inadequate ecological assessment, especially impacts on endangered ecological communities
  • degradation of biodiversity values, including loss of vegetation, invasion of weeds and loss of habitat.
  • 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.
  • 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.
    <li>procedural and administration issues, generally criticising the exhibition process and/or the materials placed on exhibition</li>
    <li>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</li>
    <li>inability to separate or consider the access road from the eco-tourist facility.
    <li>construction impacts</li>
    <li>geotechnical conditions on the access road.</li>

The current situation

NPWS has issued a licence that allows for access to an existing sealed management trail to the property. This is consistent with the inholding policy, which enables owners of private inholdings to access their land. The access granted will involve the limited use of the existing management trail and some upgrading to meet fire management standards for safety.

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.

More information

For further information on the request for access email: