Overview of Review of Environmental Factors (REF)

The purpose of a REF is to provide the public with independent information relating to the environmental impact of an activity, in this case, the proposed off-leash dog trial at Station Beach. In November 2018 Council commenced its community consultation process by issuing a Review of Environmental Factors that had been prepared in 2008, over a decade earlier. Given this process error, the Palm Beach Protection Group called on Northern Beaches Council to extend the consultation period to enable the community to review an updated REF, noting the old document was outdated and prepared against repealed planning legislation. An updated document was released to the public in May 2019.

The REF proposes 31 mitigation measures and are reproduced in the table below. The full Review of Environmental Factors, prepared by Cardno NSW report is available from Northern Beaches Council

In summary, the report highlights the ecological vulnerability of the Station Beach and Pittwater offshore seagrass meadow and marine ecosystem. The report seeks to mitigate the impact from off-leash dog swimming and trampling activity by proposing a three-metre buffer in front of the seagrass. The consequence of this is that dogs will not be able to swim in low tides. Practically, managing such an exclusion zone is flawed, and the report relies upon over 30 mitigation measures. In our view, the close proximity of off-leash dogs to seagrass meadows, despite the proposed controls, still represents an unnecessary and unacceptable risk.

In the report, Cardno acknowledges the risk of compliance breaches, even observing first hand, general disregard for the existing policy. The numerous mitigation measures only highlight how environmentally sensitive Station Beach is, requiring protection rather than the introduction of new threats, which is what off-leash and on-leash dogs represent.

Significantly, while Council has introduced on-leash dog activity on Station Beach from 1 January 2020 based on the approved resolution to support off-leash dogs in August 2019, it has done so without applying the REF’s proposed mitigation measures. In practice, throughout 2020 at Station Beach, most dogs are being allowed off-leash onto Station Beach in breach of permitted times and without the protection of mitigation measures proposed in the REF.

Table 6-1 Summary of proposed off-leash dog mitigation measures.


Mitigation Measures

Traffic and access

  • Monitor traffic conditions during the 12-month trial;
  • Limit off-leash hours to non-peak hours to offset traffic impacts;
  • Provide clear signage displaying parking bays and limits;
  • Increased patrols by Council officers;
  • Improve pedestrian access points at both the north and south ends of the beach; and
  • Council to consider undertaking a risk assessment in regards to golf balls exiting the golf course onto Station Beach and take action as required.

Marine biodiversity

  • Increased compliance patrols by Council officers to ensure compliance with permitted high tide swimming periods;
  • Prior to commencing with the DSA, a minimum buffer zone to the edge of the seagrass closest to – and running parallel to the beach should be identified and marked. This buffer zone line should be located as a minimum 3m east of the edge of the seagrass bed landward;
  • Install markers to sign the minimum buffer zone to the edge of the seagrass. Markers should not interfere with water craft navigation. Prior to installing the markers, consultation with relevant authorities should be undertaken;
  • Dog swimming only to be allowed east of the minimum buffer zone;
  • The southern end of the proposed DSA should be shortened to avoid interaction with the endangered population of australis seagrass bed that occurs close the shore;
  • Carry out a seagrass, the white seahorse and water quality monitoring during the trial event to assess potential impacts of the activity;
  • Install signs educating site visitors about taxifolia, including how to minimise its spread in the area should be placed at both ends of the site; and
  • Other human activities not related to the trial such as boating, anchoring, mooring, etc may interfere in the trial results. Such activities should be taken into account when assessing the potential impact of the off-leash dog trial on the marine environment.

Hydrology, water quality, and sediment

  • Install dog waste bins (with waste disposal bags available) at each access point and consider a third in the middle section of the beach;
  • Clearly signpost requirements for beach users to dispose of dog faeces and outline penalties for failing to comply under the Companion Animals Act 1998;
  • Monitor water quality through the trial period;
  • Install signs informing users that dogs must not be allowed to run through seagrass beds;
  • Include erosion information on beach signage;
  • Increased compliance patrols by Council officers to ensure compliance with permitted dog access areas and times; and
  • Conduct visual inspections of dune health throughout trial period.

Terrestrial biodiversity

  • During the water quality and seagrass monitoring events, undertake observations of potential presence of migratory and threatened birds at the proposed trial area. If shorebirds are observed during the monitoring events, notify Council to assess whether a shorebird monitoring program should be implemented.


  • Council to consider undertaking a risk assessment in regards to golf balls exiting the golf course onto Station Beach and take action as required.
  • Install signage with information for dog owners of their responsibility to maintain control of their dogs while both on and off-leash in public spaces (Companion Animals Act 1998); and
  • Monitor and investigate any complaints made to Council of aggressive dogs in or around the proposed trial area.

Waste management

  • Provide waste separation bins (general and recyclable waste) at each access point.


  • Ensure signage is clear indicating times and off-leash boundaries to minimise dogs approaching sensitive receivers;
  • Not to undertake the trial within the initial 30m (southern end) of the original proposed trial area; and
  • Monitor any noise complaints received through Council’s online complaints management system.


  • If any unexpected archaeological items are uncovered during the proposed trial Council must be notified; and
  • If any skeletal material is uncovered, trial must cease immediately with access restricted, and Council, OEH and NSW Police must be notified.