Common Mistakes When Responding to a Council Ecological Information Request
You have lodged a development application, and a few weeks later the assessing authority sends you a letter asking for more ecological information. This is an information request, and how you respond to it can make or break your DA timeline.
At Queensland Ecologists we regularly help applicants recover from poorly handled information requests across Brisbane, Logan, Moreton Bay, Ipswich, Redlands, the Gold Coast, Sunshine Coast, Noosa and the Scenic Rim. Here are the most common mistakes we see, and how to avoid them. The short version: the moment you spot an ecological matter in the letter, get advice from an ecologist. Calling early, before you commit to a scope, almost always saves time and money.
3 months to respond
Under the Development Assessment Rules you generally have 3 months to respond to an information request, extendable by agreement. One of the first things we do is confirm your real date, so the clock does not catch you out.
What Is an Ecological Information Request?
When you lodge a development application that triggers an environmental overlay or a state assessment matter, the assessing authority can ask you for more information before it decides the application. This is dealt with under the information request part of the Development Assessment Rules, made under the Planning Act 2016. It is a distinct process from complying with a referral agency’s response, and despite what some templates suggest, it is not a “Section 62 request”.
Two points trip people up:
- It can come from more than one body. The assessment manager (usually your local council) can issue an information request, and so can a referral agency. For ecological matters that referral agency is often the State Assessment and Referral Agency (SARA), which deals with matters of state environmental significance (MSES), waterways, wetlands, vegetation clearing under the Vegetation Management Act 1999, and koala habitat in South East Queensland. You may receive a council request, a SARA request, or both, and they can ask for different things against different benchmarks.
- It asks you to respond to the codes, not to prove a negative. The authority is not asking you to prove there are no ecological values on the site. It is asking you to assess the site against the relevant overlay codes and state assessment benchmarks, and to show how your proposal responds to them.
Getting this wrong wastes time, costs money, and can push your project back by months. The common triggers behind an ecological information request include a biodiversity overlay information request, an environmental significance overlay response, a koala habitat information request, a vegetation clearing information request, or a waterway or wetland overlay information request.
The First Move: Get the Letter in Front of an Ecologist
The single most valuable thing you can do in the first couple of days is not to start scoping surveys yourself - it is to get the request in front of an ecologist who reads these letters every week. Working out which items are genuinely ecological, which benchmark applies, and what each one actually requires is exactly where applicants who go it alone lose time and money. Send us the letter and the site address, and here is what we sort out for you before you commit to anything:
We confirm the real deadline
Under the Development Assessment Rules you generally have 3 months to respond, extendable by agreement. We confirm your date and whether an extension is worth seeking, so the clock does not catch you out.
We work out who is actually asking: council, SARA, or both
The ecological scope and the benchmarks differ depending on who is asking. We read the letter and separate the council assessment manager requests from any SARA referral agency requests, so each is answered against the right benchmark.
We pull the genuine ecology out of the noise
Information requests routinely bundle ecology in with stormwater, bushfire, traffic, engineering and landscaping items. We identify the genuinely ecological matters so nothing is over-scoped or missed.
We tell you what each item really needs
Some items need a field-based survey, some a targeted seasonal survey, some a mapping correction such as a PMAV or regional ecosystem verification, and some only a written planning and ecology response. They are not the same job and they do not cost the same - we tell you which is which before you spend anything.
We handle the extension if you need one
If seasonal survey timing or site access means you need more time, we help you request the extension early with a clear justification rather than scrambling at the deadline.
Responding With a Generic Desktop Report
The applicant engages someone to produce a desktop ecological report - pulling together database searches, aerial imagery and state mapping - without anyone visiting the site.
Desktop reports have their place. But a desktop-only response is risky when the information request asks for site-specific ecological values, ground-truthed vegetation mapping, habitat features, or an impact assessment. In those cases the assessing authority usually expects:
- Field-based flora and fauna surveys conducted on the property
- Vegetation community mapping ground-truthed against what is actually growing on the ground
- Habitat assessments that document features like hollow-bearing trees, watercourses and fauna movement corridors
- Seasonal survey requirements met where they apply, for example koala surveys or migratory shorebird counts
Send a desktop report into a request like that and you can reasonably expect a second information request and further delays.
When a Lighter Response May Be Enough
The flip side matters too, because doing more than the request needs is its own waste of money. Not every information request calls for a full field survey. Sometimes the matter is narrow, the mapping trigger is clearly wrong, or the site is already cleared, and a written response or a mapping correction such as a PMAV or regional ecosystem verification is enough to resolve it. The catch is that telling the difference reliably takes an experienced eye, and getting it wrong in either direction costs you. Working out whether fieldwork is genuinely required, or whether a lighter response will satisfy the authority, is exactly the judgement we make for you when you send us the letter, rather than defaulting to the most expensive option on every job.
Not Addressing the Specific Overlay Code Requirements
Each planning scheme has overlay codes that set out performance outcomes and acceptable outcomes for development in mapped areas, and the information request will usually reference the exact codes that apply.
A common mistake is submitting a general ecological report that describes the site’s values but does not address the overlay code requirements point by point. Assessing officers want a clear, structured response that demonstrates compliance, or proposes suitable mitigation or offsets where full compliance is not achievable. A strong ecological assessment report includes a dedicated compliance table mapping each applicable performance outcome to the relevant site findings and proposed response. If your report does not do this, expect it to come back.
Submitting an Environmental Management Plan Instead of an Ecological Assessment
These are two different documents, and confusing them is a surprisingly frequent mistake.
- An ecological assessment report identifies and maps ecological values, assesses impacts, and demonstrates how the proposal addresses overlay code requirements. This is what the authority wants at the DA stage.
- An environmental management plan (EMP) is a construction-phase document that sets out management actions, monitoring and responsibilities. It is usually conditioned as part of the approval, and it comes later.
If the request asks for an ecological assessment and you submit an EMP, you have answered the wrong question. The assessment must come first, because the EMP depends on its findings.
Using an Ecologist Who Does Not Know the Local Scheme or the State Codes
Queensland has more than 70 local government areas, each with its own planning scheme and overlay codes, and ecological requirements vary significantly between them. The triggers and terminology in the Brisbane City Plan are not the same as those in Moreton Bay, the Sunshine Coast, Noosa, Logan, Redlands, Ipswich, the Scenic Rim or the Gold Coast.
On top of the local scheme, SARA matters such as MSES, waterways and wetlands, vegetation clearing and koala habitat are assessed against state codes, not the planning scheme. An ecologist who does not work across both layers can produce a report that misses key requirements, uses the wrong terminology, or addresses the wrong benchmarks. When you engage someone, ask whether they regularly work with that council’s scheme and with the relevant state codes.
Treating the Request as All-or-Nothing
You are not obliged to silently do everything the letter lists. Under the Development Assessment Rules, when you respond you can provide all of the requested information, part of it, or none of it, and you can ask the assessing authority to proceed to decide the application. That flexibility is genuinely useful, because information requests are sometimes overbroad or poorly scoped, and a targeted response can be smarter than blindly commissioning every survey listed.
Used well, this lets you push back on items that are not justified, provide the ecological information that genuinely matters, and keep the assessment moving. Used badly it backfires, so it is a decision to make with advice.
On timing, do not rely on the myth that a late response simply makes your application lapse. You generally have 3 months to respond, extendable by agreement. If you do not respond within the response period, the assessment continues from the day after that period ends. The real risk is that the authority decides your application without the information it asked for, which makes an unfavourable condition or an outright refusal far more likely. Going quiet is the worst option on the table.
What a Strong Response From Us Includes
When we prepare your information request response, a strong submission usually brings together:
| Element | What it involves |
|---|---|
| Field-based ecological assessment | Survey methods clearly described, where the request warrants it |
| Vegetation mapping | At property scale, ground-truthed and aligned with the Regional Ecosystem framework |
| Fauna habitat assessment | Including targeted surveys where required |
| Compliance assessment | Against each relevant overlay code and state benchmark, presented clearly, typically in table format |
| Impact assessment | With proposed avoidance, mitigation and offset measures where needed |
| Supporting maps, photos and data | That demonstrate the basis for the conclusions |
The report should be written with the assessment officer in mind. Clear structure, proper referencing and direct responses to the code make the officer’s job easier, and make approval more likely.
How Queensland Ecologists Can Help
Received a council or SARA ecological information request for an ecological report? We help applicants across South East Queensland respond efficiently and correctly the first time, whether the right answer is a desktop response, a targeted field survey, or a full ecological assessment report. We handle the full process: reviewing the request letter, distinguishing council from SARA matters, scoping the work, conducting surveys, and delivering a compliant report ready for lodgement.
Received a council ecological information request? Send us the letter and your site address. We will review the request, identify what ecological work is actually required, and advise whether a desktop response, a field survey or a full ecological assessment is the right pathway. The earlier you call, the more time and money you save. Request a quote or call (07) 3018 7538 to talk it through with our team.