Submission on Draft Pesticide Use Notification Plan
- January 2007

Submission on Draft Mid North Coast Regional Strategy (MNCRS)
- April 2007

Submission on Nambucca River Management Plan Draft Report
- September 2007

Submission on Improving the NSW Planning System
- February 2008

Submission on Draft Growth Areas for the Regional Strategy
- February 2008

Submission on Tourism in National Parks
- August 2008
Submission on Nambucca Shire Council State of the Environment Report
- November 2008

Proposed use of Community Land, Pacific Highway & Link Road Nambucca Heads
- May 2009

Community Workshop Issues Paper – Nambucca River Master Plan
- May 2009

Submission on Draft Integrated Water Cycle Management Plan
- August 2009

Submission on Proposed Bellwood Link Road
- August 2009

General Manager
Nambucca Shire Council
PO Box 117, Macksville, NSW 2447

9^th January 2007

Dear Mr Coulter,

Submission on Nambucca Shire Council Draft Pesticide Use Notification Plan

The NVCA has on many occasions raised the issue of public notification of pesticide use in public places by Council, with no success to date.  It is therefore heartening to see Council developing a Pesticide Use Notification Plan, although we are aware that this will be requirement under Part 4B of the Pesticides Regulation 1995 starting 1 February 2007.

This Association opposes the use of pesticides in public places on human and environmental health grounds and believes that alternative methods eg mechanical, manual and non-chemical methods of pest (insect and vegetation) control are more economically and environmentally sustainable in the long run.

As Council does and will continue to use pesticides in public places, the NVCA emphasises that people’s ‘right to know’ when and where chemicals are to be applied and which chemical is to be used, is paramount along with genuine attempts by Council to minimise and hopefully one day eliminate pesticide use whenever and wherever possible.

In the introduction section of the Plan, reference is made to the fact that Council ensures that pesticides are used without harm to the community or environment.  It is difficult to understand how such a claim can be made without ongoing monitoring of either.  One action which could be taken to partially achieve harm minimisation however would be the avoidance of chemical use in certain identified areas.  Such an action would be in the interests of human health, the developing local organics industry and of liability on Council’s part.  With this in mind, we request that Council develop a register of properties adjacent to which residents have requested no chemicals be used on grounds of chemical sensitivity and/or the organic status of their property. 

We ask that the following public places be added to the list covered by the Plan:
  N     Bus shelters
  N     Public halls
  N     Sporting field amenities blocks
  N     Libraries
  N     Shire Chambers (we note that the Chambers are referred to on p3 as part of the notification section but not on p1 as a public place covered by plan or the table on p2)

The exterior and surrounding grounds of Council owned public buildings should be included for notification, not just the interiors as proposed.

During roadside spraying, signs should be prominently displayed both on the vehicle and at either end of section being sprayed, to allow road travellers the option of not passing through the spray area or at least to wind windows up to minimise exposure.

Page numbering is also amiss on the document.

Thankyou for this opportunity to provide comment on this much needed plan.

Yours sincerely,

Maureen Gallagher
Secretary 

Department of Planning
Locked Bag 10
Grafton NSW 2460
Email northcoast@planning.nsw.gov.au

26 April 2007

Dear Sir/Madam

Submission: Draft Mid North Coast Regional Strategy (MNCRS)

The Nambucca Valley Conservation Association (NVCA) has operated for over 25 years in the Nambucca Shire with an average of 50 individual and group members.  Our members maintain a keen interest in sustainable land use management and planning, through active involvement in campaigns and regular newsletters. 

Our Association is a member group of the Regional Alliance for Sustainable Planning (RASP), the regional alliance of conservation groups and individuals formed last year to discuss and respond to the State Government’s proposed regional strategic plan.  We concur with all points and recommendations made in the RASP submission to the draft MNCRS, in particular those made which refer specifically to the Nambucca catchment, namely areas unsuitable for future urban, industrial and rural residential growth and areas identified for future protection based on their high conservation values.

The NVCA is concerned at the lack of any growth and conservation areas mapping in the draft plan.  This renders the community consultation process virtually meaningless with regard to the core issues of interest for our members. 

We consider the proposal to prepare these maps in consultation only with relevant councils and state government agencies to be inappropriate and unacceptable.  A fair and transparent means of planning for the future will allow the public to comment on growth and conservation area maps.  These should have been included in the draft MNCRS as has been the procedure with other regional strategic plans so far prepared by the DoP.

We therefore formally request that before signing off on the MNCRS, the DoP consults further with stakeholders by providing the draft final proposed growth areas and conservation areas mapping and allowing adequate time for comment. 

As the NVCA participated in the preparation of the RASP submission which covers the broader draft document, we intend to focus mainly on Nambucca Shire specific matters.  Given the lack of detail regarding the Nambucca in the MNCRS, our comments relate mainly to NSC’s proposals contained in the draft Nambucca Shirewide Structure Plan (NSSP) recently prepared by Sutherland and Koshy on behalf of Nambucca Shire Council (NSC).  Our understanding that DoP will be consulting with (NSC) and drawing on information contained in the Shirewide Structure Plan in its finalisation of the MNCRS, has prompted this focus.  
 

REGIONAL CHALLENGES

Environment

We are surprised at the reference in the foreword, and again on page 5, claiming that the region is rich in natural resources such as fisheries, timber and ground water.

Numerous reports have shown fish stock numbers are declining in the region due to over-fishing, habitat loss, pollution, dams and weirs.  The Department of Natural Resources on its website with regard to the NSW east coast claims:  NSW estuaries are not rich in commercial fisheries resources.  Declines in commercial fisheries have been experienced in recent years.  Reports of serious over-fishing and declines in fish stocks have occurred.  There is a serious lack of accurate data on fish catches in many estuaries.  www.dnr.nsw.gov.au/estuaries/issues.shtml

Evidence of unsustainable logging practices in public forests is also well documented.  The results have meant a decline in timber resources, forest biodiversity and jobs in the timber industry.  Dwindling private native forests are now being hit hard across the region with no code of practice yet in place.  Forests resources are far from rich.

Ground water extraction is largely uncontrolled (as is surface extraction) as metering does not exist, sustainable yields have not been established, illegal bores are widespread and new bores being drilled at an unprecedented rate.

NVCA believes that the region’s natural resources are already stretched past the limit.  Without clear mechanisms to protect sensitive ecosystems and natural resources through evidence-based planning, the government will not meet the identified environmental challenges referred to on page 6, namely to improve protection and enhancement of environmental assets.

NSC has a very poor record on natural resource management.  It continues to refuse to introduce a tree preservation order or native vegetation management plan, despite increasing public demands for action to remedy tree vandalism and pre-emptive clearing in urban zones.

NSC failed to use the most recent native vegetation mapping available to it (Nambucca Catchment Vegetation Survey - Kendall & Kendall, 2003), in the constraints mapping carried out for the draft NSSP.  The Kendall & Kendall survey and report was undertaken for NSC and the then Mid North Coast Catchment Management Board.  NVCA is concerned at NSC’s unwillingness to take ESD principles seriously in its planning process, as demonstrated by the proposed future urban, industrial and rural residential land areas identified in the SSP which contained significant areas of high conservation value native vegetation.  Had the Kendall & Kendall Report been referred to in the process of identifying the NSSP growth areas, the HCV vegetation could have been identified on the constraints maps an ecologically sustainable proposal could have been put forward in the draft, one which meets NSC own LEP and Management Plan objectives and legislated requirements to consider ESD principles and state planning guidelines.

In response to the community backlash at its failure to use the Kendall & Kendall report, NSC has now resolved to receive the report (after four years), but not adopt or apply it to any planning processes, despite the fact that DEC, DNR and CMA have been doing so for years. 

This woeful situation emphasises the need for a consistent approach to native vegetation management in urban zones within the region that will require consideration of environmental values and consent prior to removal of native vegetation. 

We urge DoP to require Nambucca Shire Council to implement a tree preservation order across urban zoned and public land within the shire.

We support the proposal in the draft NSSP to prepare a conservation plan for the shire and have requested that this happen prior to any finalisation of new release areas.  The same principle should apply to regional planning with regard to the finalisation of a regional conservation plan as the fundamental step prior to finalisation of growth area maps.

The MNCRS should require NSC’s input to growth area maps to include all available vegetation mapping (including Kendall & Kendall 2003) and to consider all constraints based not only on listed threatened species and SEPPs, but also under reserved vegetation communities.

We refer to the Nambucca Constraints Map produced and submitted by RASP detailing the areas of potential development which clash with HCV vegetation and request that the MNCRS ensure these vegetated areas are excluded from growth area maps.
 

PROJECTED POPULATION IN THE NAMBUCCA SHIRE

NSC has significantly overestimated future growth in the Nambucca Shire.  It has done this by relying on development application lodgement figures (largely influenced over past few years by speculative subdivision) rather than ABS and occupation certificate figures.

This distorted picture of demand, along with the misguided assumption that growth at any cost will result in economic prosperity, led NSC to plan for a doubling of its population in the preparation of the NSSP.  Doubling of the population equates to 3% growth, a rate not seen in the shire for many years.  This inaccuracy has distorted the entire NSSP process with inflated land release, housing, infrastructure and water requirements.

Nambucca is one of the slowest growing areas of the MNC.  ABS data shows it to have growth of 0.8% last year and an average over the past five years of 0.9%.  This is less than the 1% average used in the DMNCRS for the entire region.  In reality growth is more likely to be no more than 1% per year (27% over 25 years) and therefore result in growth of 5100 people over 25 years.  At this rate, using a household average of 2.1 people and 15 dwellings per ha, only 2430 extra dwellings would be required rather than the 7000 over 20 years touted in the draft NSSP.  By achieving a 50% infill rate, only 1215 dwellings would need to be on greenfield sites, resulting in a demand for 81ha of new land for housing, instead of the 543ha over 20 years quoted in the SSP.

The MNCRS must ensure that any proposed future growth areas for the Nambucca catchment reflect evidence-based projected population figures.
 

LAND AVAILIBILITY

Nambucca Shire currently has an over supply of rural residential land much of which is unsuitable for development due to environmental constraints.  Nambucca experienced a rush of speculative development applications in 2003 and 2004 as its rural residential quota ran out.  Council has still yet to prepare a rural residential release strategy.  Many sub-divided blocks remain unsold.  As the

population ages, we predict that demand for these labour intensive and unproductive ‘lifestyle’ blocks will drop as will demand for rural residential blocks.

Rural residential development in the Nambucca has resulted in significant loss of native vegetation, especially in light additional asset protection zone requirements.  Cleared areas are generally replaced with expansive lawns and exotic gardens which require extensive mowing and demand high water use.  They are not an environmentally sustainable form of residential development.

The NVCA does not support the further release of rural residential blocks.  However, given that it is likely they will be pursued in this shire, we believe that it is important there should be no further loss of native vegetation as a result of any rural residential development.

NVCA considers a 50% greenfield and 50% infill ratio for new dwellings to be appropriate given greenhouse gas emissions, infrastructure, urban sprawl and local demographic considerations.

The draft NSSP proposes new rural residential land releases in areas of extreme environmental sensitivity such as the acid sulfate soil area east of Macksville and south of the Nambucca River and  the Bald Hill area, which is almost entirely covered in high conservation old growth and under reserved native forest and falls within the DEC identified regional wildlife corridor.

NVCA does not support any new areas to be zoned for rural residential development in the Nambucca catchment.

The proposed urban release areas in the draft NSSP are excessive and also needlessly involve areas of significant environmental sensitivity.

NVCA supports DCP 17 South Macksville Urban Release area.  This area will yield over 600 lots in close proximity to existing infrastructure and services.  Importantly the DCP 17 area is relatively unconstrained.

Proposals in the draft NSSP for future urban areas at South Valla Beach and south Scotts Head are strongly opposed as not required to meet demand and significantly constrained.

NVCA opposes the proposal for development of the Boggy Creek area which would involve the removal of areas of significant native vegetation.
 

NATURAL HAZARDS

The MNCRS must pay closer attention to the potential impacts of climate change such as sea level rise and storm surges.  Residential and industrial development should no longer be allowed on flood plains and in close proximity to riverbanks and low lying coastal zones.

Considering climate change, and as a precautionary measure, no development should occur below the 1-in-200-year flood level.
 

WATER SUPPLY

All new urban dwellings should be self sufficient for all but non potable water.  All new rural residential developments should be 100% self sufficient for water with enough contingency water for drought and fire fighting purposes.  Local Governments should be assisted by State and Federal Governments to recycle all sewerage treatment plant outputs and stormwater runoff as a high priority. 

Investment in the proposed off stream water storage facility at Missabotti  should be deferred until Council has adopted an integrated water cycle management plan and implemented critically needed actions such as rainwater capture, grey water recycling, storm water capture and STP recycling.

The NVCA does not support inter-basin transfers of water or in-stream dams.
 

THE NAMBUCCA ESTUARY

The 13ha sand island zoned 6 (a) public recreation in the inner harbour of the Nambucca Estuary contains significant under reserved vegetation including saltmarsh and swamp oak.  It is frequented by numerous bird species and is in close proximity to the breeding colony of the endangered Little Terns on the northern tip of Gumma Peninsula.  This island also forms the southern boundary of an area of water known locally as The Glen, which is well known to divers and snorkellers for its excellent diving and highly diverse marine life.  Dr Stuart Blanch recently wrote to various Ministers nominating The Glen as an aquatic recreational reserve.  Both the island and The Glen together, if protected as reserves, could potentially provide opportunities for passive recreation eg safe diving and bird watching and local low impact passive eco-tourism ventures.

The sand island is worthy of protection and must not be developed.  NVCA requests that it be considered for inclusion in the coastal reserve system along with ‘The Glen’ section of the estuary to the immediate north.
 

GENERAL COMMENTS

The NVCA supports the aim of concentrating growth and redevelopment of the region’s four major regional centres and six major towns as a means of protecting sensitive coastal and natural environments.  We support the concept of ‘shop top’ housing.

We also support protecting the coast by limiting urban sprawl, by focusing new settlement in areas identified on local strategy maps (if they have been prepared using all available environmental data) and restricting unplanned new urban or rural residential settlement.

NVCA does not support the proposal to allow additional development sites outside of agreed local strategies.  The five year review process should be used to review and consider proposals outside the defined development areas.  The review process should ensure transparency and certainty for all stakeholders.  The sustainability criteria do not provide certainty and are considered such a glaring loophole as to potentially render the regional planning process invalid. 

The MNCRS should only apply the sustainability criteria to areas designated for development in the Strategy.  Additional development sites outside of agreed local strategies should not be allowed.  Any variations to the designated development areas should only be considered at the  5 year review phase through a public process. 

Thankyou for the opportunity to comment on the draft MNCRS.  We look forward to providing further comment once the draft future growth areas and conservation areas mapping is released for comment.

Yours sincerely,
Paula Flack
President

Mr Michael Coulter
General Manager
Nambucca Shire Council
PO Box 177
Macksville NSW 2447

4^th September 2007

Dear Mr Coulter,

Submission on Nambucca River Management Plan Draft Report

The Nambucca Valley Conservation Association (NVCA) would like to provide the following comments on the abovementioned draft management plan;

The overarching management objectives listed on p1-3 are fully supported by this Association.

Prioritisation of management strategies

O       Full support for the identification of improving overall riverbank condition, in particular improving riparian habitats on all major streams and waterways as priority #1.  Without improved bank stability and riparian vegetation, estuary health cannot be achieved.  This strategy underpins all others and should be the focus of local government and riparian landholder’s efforts to improve river health and water quality.

O       Strategy EC-1 should be afforded a higher rank.  Much misinformation has been circulated in the valley about the need to dredge the river to save it from ‘completely choking’ from sedimentation.  The NVCA is concerned that many people have been misled into believing the current sediments in the river are a new ‘problem’ which can be simple fixed by dredging.  Raising community awareness as to the historically high sediment loads in the estuary, the dangerous river mouth and normal estuary processes are a critical step in achieving sustainable use and development of the estuary.  This strategy should be ranked 4 or 5.

O       Strategy WQ-1 should be afforded a higher ranking - we suggest 10.  Establishing a coordinated and consistent approach to water quality at strategic points throughout the estuary as early as possible, will provided good baseline data to assess the success or otherwise of the implementation of the strategies outlined in this plan.

O       Apart from the above points, the NVCA agrees with the order of priority in Table 1-2.

 Comments on the Management Strategies

 1          Management Strategy BE-1

O       Uncontrolled grazing of riverbanks should be identified as a causal factor in bank instability in the first paragraph in the description section.  It is rightly mentioned in the second para as a preventable threatening process.

O       Suggest an additional action - to raise public awareness locally of state and federal government assistance programs for improving riparian land management and the benefits to landholders of undertaking riparian rehabilitation works.  Good examples exist in the shire of such works, demonstrating improved water quality and quantity, improved infrastructure (gates, pumps, off river stock watering points, fencing), improved stock health, increased land values, protection of valuable grazing lands from further loss through bank collapse and increased ecological function.  This action would be the responsibility of NSC, NV Landcare, CMA and DNR.  Mechanisms could include workshops, field days, media and testimonials from landholders in particular farmers, with successful projects.  This action may go some way to addressing the issue raised in the footnote on p2-2.

O       The NVCA feels strongly that over use of rock revetments alone, whilst stabilising banks does not result in improving or maintaining overall ecosystem function.  Large stretches of rock revetment (which appear to be increasingly used in estuary riverbank ‘restoration’ projects in the Nambucca) provide no shade to surface water, are hostile environments for both natural and manual revegetation, present a sterile and ugly look and make access for humans difficult and dangerous. Greater effort should be made by NSC to incorporate native vegetation in particular mangroves into estuary riverbank rehabilitation works, especially where road stabilisation in close proximity to river is to be achieved.

O       The strategy of protecting and rehabilitating the best sections of river bank first and leaving the worst for later has been around for some years now.  Is there evidence that this is actually the best approach?  In some cases, particularly in the upper catchment, rehabilitated and stable areas can be threatened by excessive bank erosion from degraded areas upstream.  Gravels and sediments can suffocate aquatic vegetation and overly narrow the channel.  A previous trial by the then Department of Land and Water conservation in a freshwater section of the Nambucca River, which involved burying chains in gravel inner bars and relocating them post flooding, showed that mobile gravels to not travel very far downstream even in high flow events.  NVCA supports the reach based approach to rehabilitation/management which allows flexibility in addressing areas of varying bank conditions concurrently if necessary.  Sediments and gravels washed down from eroding banks upstream should be stabilised with plantings or removed and returned to projects upstream (only if they pose a threat to a stable and protected reach downstream).  This practice would ensure no further loss of the bed and bank material from the system. Lyall & Macoun Consulting Engineers state “Where possible gravel should be relocated to a position in the channel near the removal site to ensure that the local system does not lose gravel”, (Nambucca Valley River & Catchment Study Executive Summary.  Lyall & Macoun 1999).

2          Management Strategy LTU-3

O       This strategy is appropriately identified as #2.  Increasing developer interest and pressure to develop sensitive coastal areas in close proximity to rivers highlights the importance of strong development control plans to regulate such activities.  NSC does not have a DCP to control soil erosion and sedimentation from development sites.  Hopefully this inadequacy will be addressed soon.

O       NSC should introduce a comprehensive Vegetation Management Plan or Tree Preservation Order, to ensure impacts to native vegetation are carefully considered and regulated in all new development on private and public land.

3          Management Strategy CH-1

O       NVCA does not consider a golf course appropriate land use for Stuart Island given its environmental and Aboriginal cultural sensitivity.  However given that the current situation prevails, this Association supports removing the obstruction to natural flow which currently exists due to the causeway.  A well designed simple bridge which would afford best possible flow is our first preference to reinstate natural flow.  Careful monitoring of silt movement and seagrass beds should be undertaken following alteration of the flow regime between Stuarts Island and mainland.  This Association does not support increased development of the Island, such as upgraded boat ramp as suggested on p 12-6.

4          Management Strategy BWU-2

O       The NVCA supports raising community awareness as to the environmental impacts of boating.  This should also stipulate jet-skis, which are frequently observed especially in holiday time being ridden at speed and executing tight ‘donuts’ in close proximity to banks. 

O       Letters to the editor of our local newspaper and feedback from our members highlights the lack of knowledge and extent of misunderstanding and misinformation which exists in the community regarding river processes, health and sustainable management practices.

5          Management Strategy FOA-3

O       Numerous tyres exist in the estuary river either as homemade wharves, bank stabilising structures or random pollution (mainly escapees from upstream ‘placement’).  Their existence and the risks posed to water quality and aquaculture needs to be acknowledged in this strategy.  Many loose tyres could be easily retrieved however some other ‘structures’ may require financial assistance to private landholders to remove or replace these with environmentally sustainable materials.

O       The NVCA has been concerned for many years regarding the failure of NSC to address sewerage pollution events in times of high rainfall, particularly from the relatively new Macksville STP and at least one pumping station in Macksville.  Any action to remedy this situation is fully supported.

O       The NVCA believes the oyster industry deserves a higher degree of support from NSC through increased efforts to minimise pollution inputs into the river and support of boating and river management measures which minimise negative impacts on this important local industry.

O       Action 9 for this strategy should support programs focussed on assisting not only intensive agricultural industries, but any agricultural industry willing to make a genuine commitment to minimising its impacts on water quality.

O       Figure 6-1: It is not clear whether the red dash at Wellington Rock denotes an oyster lease or hand collect site?  This map should also identify know sources of pollution input into the river which impact on the oyster industry ie Macksville STP, Newee Ck (documented poor water quality), acid sulfate run off from Gumma Gumma Wetland and Watt Ck.  Beer Creek/drain directs town stormwater runoff into the Nambucca River and especially should be listed.  Recently the disastrous West Street development has discharged huge silt loads into Nambucca River via Beer Creek during every rain event, having a direct impact on oyster leases in the immediate vicinity of the confluence.

6          Management Strategy HM-1

O       To achieve the objective of Habitat Management (HM) to which this strategy relates, NSC should adopt a native vegetation management plan.  This should be included as a recommended action.

O       We acknowledge and support the inclusion of the first dot point in the action list on p7-2.  NSC has the information to guide it in modifying boundaries to 7(a) & 7(b) zones in the report Nambucca Catchment Vegetation Survey (Kendall & Kendall May 2003).  Disappointingly however, it has formally resolved to ignore this information in its planning and natural resource management activities. 

O       Action list on p 7-2 refers to Figure 7 showing species listed under the TSC & FM Acts, however the figure legend only refers to ‘unprotected significant habitat’?  Legend should acknowledge where the zones originated from ie Nambucca Shire LEP.

7          Management StrategyLTU-1

O       The actions recommended in this strategy are fully supported

8          Management Strategy HM-2

O       The description section for this strategy recognise soil disturbance from stock impacts, but surprisingly fails to mention impacts on vegetation from stock grazing.  These far reaching impacts, in particular loss of understorey and succession (recruit) plants, over time result in decline in species and age diversity and therefore ecological integrity.  Areas of high ecological and/or conservation value should be protected from grazing or at the very least have an agreed stock management regime in place which protects the integrity of the ecosystem in perpetuity.  Various grant & incentive programs already exist to support landholders to achieve this.

O       Another activity not recognised as threatening remnant areas of high ecological and/or conservation value, is that of legal and illegal clearing for development or agricultural purposes.  Legal land clearing occurs because of a lack of regulatory mechanisms covering residentially zoned lands in the shire (no Tree Preservation Order).  Therefore opportunities are missed to identify and protect important remnant vegetation.

O       Plant removal either by landholders or poachers – in particular rare and threatened species such as orchids is another activity which threatens integrity and viability of HCV habitats.  Whilst perhaps not being a large scale activity, it is known to occur.  Incremental removal of rare plants has a devastating impact on declining and isolated populations of rare species and deserves a mention.

O       Use of information already available to NSC in the mapping data of the Kendall & Kendall Vegetation Study would assist in the actions recommended in this strategy.

O       P9-2 regarding rehabilitation of habitats and mechanisms to achieve this; stock are a major threat to newly revegetated areas.  Any revegetation project must include a stock management plan (if stock are involved) to exclude them from any newly revegetated areas.  Any funded project should set out an agreement with the landholder as to how stock will be managed to ensure maximum success of the revegetation program.

9          Management Strategy EC-1

O       The statement in last para on p 10-1 re ‘Smaller, albeit temporary works such as minor dredging may be considered where problems become critical’ would benefit from an example of what the consultants consider ‘temporary’, ‘minor’ and ‘critical’.

O       Fully support the recommendation to promote the use of shallow draft vessels where navigation is constrained.  The NVCA recognises that the constrained areas of navigation shift around in the lower estuary as sediments shift.  This has been documented from earliest European records of the river mouth and estuary.  Clear signage and responsible boating/navigation practices will enable boating activities to continue as per usual without the unsustainable and unnecessary intervention of dredging which would benefit only large boat users for a short period of time.

10        Management Strategy BWU-1

O       Figure 11-1 Signage is needed at the entrance to Warrell Creek clearly stating high conservation value area to whatever length upstream is deemed so and also any applying speed limit.  Why is Shelley Beach Boat Ramp not proposed for signage?

O       The NVCA supports the staged strategy to (1) raise awareness of the impacts to riverbanks and other river users of excessive speed and boat wash, through strategy BWU-2 and Action 1 of BWU-1 and (2) revising allowable boat speeds if implementation of (1) does not result in a reduction of bank erosion and improved outcomes for other river users.

O       NVCA agrees with NSW Maritime’s proposal to reduce speed in the inner harbour to 4 knots and with its immediate introduction.  A member recently witnesses a small aluminium boats enter the inner harbour through the ‘hole in the wall’ during mid tide at great speed (faster that 8 knots) and skirt the NW section of the sand island in a way that had a snorkeler, swimmer or dolphin surfaced in their path there would have been no chance to avoid a collision.  The need for increased monitoring and regulating of boat speeds is apparent.

O       It is likely that responsible boat/river users will understand the reasoning behind this important strategy to reduce bank damage and will support its implementation.  The NVCA is aware that again there exists considerable misinformation in the community about the proposal ranging from a blanket reduction of speed to 4 knots through the entire estuary to eventual ‘lock out areas’!  This emphasises the need for the Action Table relating to this strategy to carefully and clearly worded and set out, to avoid confusion and misinterpretation.

O       The reasoning behind the no wash areas is fully supported, however we are aware that it may have contributed to the misunderstanding by some boaters that boating will be virtually prohibited by its implementation.  Any boat movement will create wash of some kind but it is the level of wash that is of concern especially in actively eroding areas.  These areas may be better identified as ‘Wash Minimisation Zones’ with signage to that effect.  The desired outcome from this signage would be clear and achievable.

O       Why is there only a ‘no tow’ zone rather than both no tow and wash minimisation to the east of Stuarts Island?

O       Also supported is the proposal for a no wash or speed limit in Warrell Creek in recognition of its high conservation value and for amenity of other river users.

O       Suggest considering extension of ‘no wash’ area to confluence with Newee Creek to minimise impact of pollution runoff from highway crossing at Newee Creek.

O       Should consider opportunities to tie various boating, swimming, habitat signage together wherever possible to minimise the number of signs around the estuary.

O       We acknowledge that NSW maritime are already planning to reduce speed in the inner harbour irrespective of what this plan may propose or what NSC might decide.

11        Management Strategy BWU-4

O       Waterskiing should be prohibited in narrower reaches identified as having unstable banks such as the Bowraville reach, at least until such times as the banks are fully stabilised and revegetated.

O       We agree with a review of use of Wellington Boat Ramp for small craft only and removal of rock ballast.

O       The Apex Park boat ramp should be kept open but for the use of small pleasure craft such as tinnies, canoes and kayaks only.  No jet skis or waterskiing craft should be used in this highly degraded reach.  It is agreed that access is a problem to Apex Park and this should be addressed with good entry/exit design and signage.  Any facilities provided for the public at this site should apply best practice design to ensure no contamination of the river from runoff from sewerage.  Fresh water could be provided via rain water tanks and captured from either toilet block or picnic shelter.

O       Table 12-1 should be more specific re proposal for minor dredging at jetty near Stuarts Island.  What is meant by ‘minor’ - to what depth and extent and for what purpose?  Small craft only should be launching from this ramp.  With shifting sands the ‘problem’ may no longer exist.  The altered flow regime following changes to the causeway may alter the shoaling pattern at the boat ramp.

12        Management Strategy LTU-2

O       As expressed earlier in this submission the NVCA is concerned by the number of tyres currently existing in the estuary either as structures or as pollution.  This strategy should include a recommendation to systematically remove tyres from the estuary, through ‘Green Team’ clean up programs, incentives for property owners to clean up and staged decommission of artificial wharves and bank structures which involve tyres. 

O       A USA study Waste Tyres in Sub-Grade Road Beds (Minnesota Pollution Control Agency 1990) found that ‘metals are leached from tyres in the highest concentrations under  acid conditions with laboratory studies showing barium, cadmium, chromium, lead, selenium and zinc  as constituents of concern’.  Tyres in saturated conditions were found to present greater concern with the conclusion ‘potential environmental impacts from the use of tyres can be minimised by placement of tyre material only in the unsaturated zone of the roadway sub-grade’.  As a result of the report, the Minnesota Pollution Control Agency introduced guidelines to stop the use of tyres in saturated conditions.

13        Management Strategy BWU-3

O       Signs should be multi lingual catering to tourists eg German & Japanese.

O       The NVCA does not support closing the ‘hole in the wall’.  Such action is likely to further manipulate the natural flow through the inner harbour.  Improved warning signage and public education regarding the dangerous conditions is supported.

14        Management Strategy EC-2

O       NVCA does not support dredging of the estuary.  Providing and maintaining a deep permanent channel is a pipe dream of the development lobby in this shire.  The Nambucca estuary is small and relatively unchanged in sections, especially Warrell Creek.  Many tourists and residents come to the Shire to enjoy these values.  Clever strategic planning and sensitive development of the estuary will encourage strong economic growth without compromising the scenic and ‘unspoilt’ values of the estuary.  The challenge for NSC is to firstly identify and protect areas where estuary development is clearly inappropriate and unsustainable and to apply ESD principles to areas deemed potentially suitable for development.  If this were to occur rather than developer pressure and economic drivers taking precedent in planning decisions, our shire could stand alone from other neighbouring over developed ones, attracting greater number of tourists seeking ‘unspoilt’ locations.

15        Management Strategies CH-2

O       NVCA acknowledges the importance of protection of Aboriginal & European cultural heritage.  We stress the importance of NSC working closely with the Aboriginal community to finalise the Aboriginal Cultural Heritage Management Plan and to apply the information and recommendation it contains to all planning and development approval matters.

16        NVCA fully supports Management Strategies TM-1 (Rank 16), FOA-1 (Rank 17), FOA-2 (rank 18), WQ-1 (Rank 19), CCSLR-1 (Rank 20) – graph/legend on p 21-1 requires clear explanation, BWU-5 (Rank 21), HM-3 (Rank 22), HM-4 (Rank 23), CL-1 (Rank 24), LTU-4 (Rank 25) and  TM-2 (Rank 26).

Formatting

O       Figure 1-1 requires a legend explaining black & red line, ie tidal limit and roads.

O       Figure 2-2 text too small to read.

O       To improve user friendliness of document, it would be helpful to have a brief title for each strategy eg MANAGEMENT STRATEGY BE1 (RANK 1) Improve Overall Riverbank Condition, MANAGEMENT STRATEGY LTU-3 (RANK 2) Minimise Environmental Impact of New Development etc.  This would also help when strategies other than the one being looked at are referred to in the document eg on p 12-1 (last line) it states ‘see StrategyBE-1’, but lack of title and page number make this suggestion more difficult than it need be.

O       Table 6-1 text on legend too small to read.

O       Suggest page number at bottom right of landscape pages to allow quick flick for pages.

General Comments

O       A pollution issue exists in the river which does not appear to be mentioned and does not necessarily fit into any particular category.  Blue barrels (presumable escaping from oyster leases where they are used as floats) are an environmental pollutant often seen floating in the estuary or washed up near banks.  They also pose a significant threat to boating.

O       The draft plan does not include any recommendation regarding monitoring and review of the management plan itself.  NVCA suggests that this is considered in final document.

O       The NVCA commends NSC on the level of community consultation undertaken in the development of the Estuary Management Study and trust that this Association’s comments will be carefully considered in the preparation of the final document.

O       Overall this Association believes the management plan if fully implemented, over time will result in significant improvements to both the environmental and economic viability of the Nambucca estuary.

Thankyou for the opportunity to provide input to this important draft document.

Yours sincerely,
Paul Davies
NVCA Committee member and representative on Nambucca Shire Council’s Estuary & Coastline Management Committee

Planning Reforms
Department of Planning
GPO Box 30
Sydney NSW 2001

14 February 2008

Dear Sir/Madam

Submission on Improving the NSW Planning System

Further to our email of 8 February regarding the abovementioned document, we would like to make the following comments. 

 1          Timing and staging of reforms

• The Nambucca Valley Conservation Association (NVCA) believes the planning reforms are moving too quickly to allow for genuine and thorough community consultation.  In particular exhibiting this document over the Christmas holidays, when many (including Mums and Dads) are having a well earned break from work is unfair and unacceptable.  We believe the exhibition period should be extended until at least May 2008 and greater detail provided on key aspects.  Our Association experienced difficulties gathering comments from members and finding the time to prepare this submission over the Christmas holiday period, hence the late lodgement.
   
• The discussion Paper lacks the required detail to be able to fully understand the implications of the proposed changes.  How will the model codes and targets be set for complying development to achieve the 40 – 50% level hoped for?  How will the Regional Planning Panels and the Planning Assessment Commission be established and with what mix of representation/expertise?  How will the accountability for private certification be improved specifically?
   

2          Snapshot of NSW planning system

·         The snap shot refers to 80% of DAs lodged in 2005-06 being from families and small business, but fails to define small business.  Is a developer who lodges a DA for say one or two dwellings a year considered a small business?  This figure should have been broken down to families (single dwelling) and developer, to offer a truer picture.

·         No consideration is given to the fact that many DAs lodged with local governments are incomplete or incorrect, resulting in a delay to determination and pushing up the determination time.  This situation is partly due to lack of or inconsistent information available to those wishing to lodge a DA, but is also often due to sloppy applications.  Standardising LEPs across the state will go some way to addressing this problem, however it is unacceptable that councils with good turn around times (mostly non metro councils) should be penalised with reduced assessment and determination powers because of other (mostly metropolitan) councils with poorer performance.  Rather the underperforming councils should be required to review their processes and policies to ensure minimum DA turn around time. 

·         Another contributing factor affecting turn around times for DAs which does not appear to have been considered, is that of the enormous planning reforms workload currently placed upon existing local government planning staff, such as the new LEPs, DCPs and strategic plans.  These demanding tasks have had a particular impact upon regional councils which due to financial constraints often find it difficult to provide employment packages lucrative and attractive enough to entice experience planning staff away from cities.  The burden of state and federal government cost shifting onto local government without matching resources has compounded this situation.  Nambucca Shire Council (NSC) has been understaffed in its planning department a number of times recently due to the inability to recruit suitably qualified staff, with the resultant delays to planning and DA determination activities.  Despite this, NSC’s turnaround times for Jan – Nov 2007 have been 46.81, 59.06, 31.88, 39.19, 54.80, 48.65, 52.72, 66.55, 61.65, 57.74 and 72.25 days respectively, an acceptable outcome.

3          Gateway approach

·         We see this as a means of fast tracking rezonings but with no certainty as to the type or level of community consultation.

·         The paper’s proposal that community consultation would be established as part of the ‘gateway process leaves us wondering about the likelihood of public exclusion from the process on controversial rezoning proposals, in particular those involving environmentally sensitive lands.  We have no alternative but to oppose the ‘gateway approach’ until such time as we can be clear that there has been no eroding of public opportunity to view and comment on any rezoning proposal at an early stage.  Ideally community participation in these far reaching decisions should be enhanced as should concurrence requirements.

4          Public consultation and participation

·         NVCA believes that public participation is a fundamental right of the people and that it must remain as a key foundation of the planning system.

·         No clear information exists within the Discussion Paper as to how public participation will occur for the various types of DA.  No detail is provided on the proposed community consultation guidelines.  We have no choice but to remain sceptical.

5          Planning Panels

·         This proposal raises many questions.  NVCA is particularly opposed to the removal or overriding of local government’s powers with regard to DA assessment.  As the level of government closest to the community, local government is in the best position to understand the basis for local strategic plans and to assess DAs in this context.  This approach allows for the diversity of different communities and localities.  It helps to maintain local character.

·         It is difficult to comment other than to highlight opposition due to the complete lack of detail in the discussion paper as to how these planning panels will be formed, who will sit on them and their terms of reference.  This information should have been provided.  Any planning panel must include environmental representatives with an appropriate level of expertise.

6          Concurrence requirements

·         Although often the cause of delays to DA determinations, having various agencies consider relevant aspects of DAs is critical and must not be changed.  This approach provides the depth of assessment and consideration expected by the community to ensure environmental, social and economic matters are fully considered.

·         The proposed reduction in concurrence requirements is not acceptable.  The planning system should retain the invaluable input and expertise provided for integrated development assessments in particular in regards to native vegetation, threatened species, critical habitat and water resources.

·         How will the level of concurrence required be established?

·         Agency participation should be improved with increased resources for the process rather than reduced or removed.  This would reduce the backlogging which often results in DA’s taking longer than the minimum 40 days required of local government to determine a DA.

7          Exempt and complying development

·         Basing the target for exempt and complying development on a simple proportion ie 50% with policies developed to achieve that target, is putting the cart before the horse.  Policies for exempt and complying development should be based upon clear and justifiable parameters which are acceptable to the wider community not just developers. 

·         We support the mandatory listing of solar panels as complying development.
 

• If Complying Development Certificates are used, local government and/or affected parties should be allowed a minimum of 15 working days to challenge instead of the insufficient 7 days proposed.

8          Private certification

·         The NVCA does not support private certification under the current system and lack confidence that the proposed changes will satisfactorily address our concerns.

·         This is a system clearly vulnerable to abuse through the very nature of the work.  A private certifier is unlikely to want to make life difficult for a developer who is a current and future source of income.  Put simply a private certifier is unlikely to bite the hand that feeds him/her.

·          The proposal to limit the number of jobs to three which a certifier can undertake for any one developer is evidence of the government’s lack of trust in the process.  However we are not at all convinced that this measure will negate the opportunity for corruption.

• One option for improvement could be to establish a register of private certifiers with DoP who would then select the appropriate certifier according to expertise and departmental and peer review of previous work.  The certifier would not be paid directly by the developer but from a trust fund into which the developer had lodged the appropriate fee to pay the certifier and processing charges.

·         Local Governments should be adequately resourced to assess and determine developments in its own planning area.

• Local Government should be able to supervise, challenge and overrule certifiers, especially if certifiers.  This work should be funded, not by council, but through a bond lodged by the applicant and the certifier so that they jointly have a desire to avoid misrepresentation in the DA.

9          ePlanning

·         NSC’s recent community survey showed that of the 400 people survey only 12% had visited council’s website.  This result is perhaps not surprising given the depressed socio economic status of the Nambucca and the high proportion of over 60 year old (38.4%) who often do not use the internet.

·         ePlanning certainly has its merits, but how will those not using internet be catered for.  People need a choice in how information is disseminated.

10        General comments

·         The NVCA understand the need to improve the planning system in NSW however we do not accept the rhetoric that this is about streamlining the process for ‘Mums and Dads’.  The proposed changes will result in less input into DA assessment and approval by local government, in particular elected representatives and reduced opportunity for community consultation.

• NVCA recognises that there needs to be a higher level of accountability within the local government system with regard to planning and development application determinations; however that is not a reason to remove powers and place them further away from public scrutiny via panels, private certifiers and increased exempt and complying developments.
   
• The NSC recently conducted a community survey where respondents were asked their attitude to development.  39% considered themselves anti development, 35% were neither for nor against and only 25% were pro development.  One wonders what the results of the same survey would be if extrapolated across the state in particular the coastal regional areas.  We feel confident that the results would be similar.  How do these proposed planning reforms cater for the concerns of the majority of residents?  The reforms should be advocating a tightening of development controls rather than the contrary which is proposed in the planning reforms.

11        Conclusion

It is difficult not to conclude that the proposed changes are more about greasing the wheels of development in NSW with the emphasis on economic growth and less about social and environmental consideration and outcomes. 

Together with other new state plans and policies, such as the draft Regional Strategic Plan which drastically over allocates land for development beyond projected needs and BioBanking which allows development in critical habitat, these proposed planning reforms open the door for excessive development, even where it may not be needed or appropriate.

The NVCA believes the development industry lobby groups have been extremely successful in their bid to have environmental protection weakened in NSW.  They have had the sympathetic ear of the NSW Government.  We are now witnessing a piecemeal dismantling of environmental protection instruments.  This is an extremely disappointing outcome given that previous state planning instruments for environmental protection were already woefully inadequate and failed to even slow the steady decline of biodiversity in this state. 

In view of global climate change and increasing loss of biodiversity, our members are not confident that the current planning reforms will result in truly sustainable planning or land management - they will not protect environmental values and biodiversity for future generations.

We trust you will accept our feedback on this important issue.

Yours sincerely
Georgette Allen
Secretary

Manager
Department of Planning
Locked Bag 9022 Grafton NSW 2460
Email: northcoast@planning.nsw.gov.au

18 February 2008

Dear Sir,

Submission on Draft Growth Areas for the Regional Strategy

Further to our submission of 29 April 2007 regarding the Draft Mid North Coast Regional Strategy, we make the following comments regarding the proposed Future Growth Areas identified as part of the regional strategy.  Our submission is in two parts firstly general comments regarding the proposed regional growth areas and secondly, specific comments relating to the Nambucca area.

1          General comments

·         We support the concept of identifying sufficient land for projected needs, but are astounded that the Department of Planning (DoP) has identified so much land for future urban and industrial development.  The amount identified in the Draft Growth Areas is, by the NSW Governments own figures, 1,157% too high for residential land and 979% too high for industrial land!  We strongly object to this proposed blatant securing of an oversupply of land. 

• Residential land has been over supplied in all local government areas except Coffs Harbour in the Draft Growth Area Maps.  2,138ha of the areas identified for residential growth are vegetated, with 633ha consisting of Endangered Ecological Communities.

·         Kempsey, Great lakes and Nambucca suffer the most over allocation with 323%, 276% and 260% over allocation for residential land respectively.  We consider this a land grab by the development industry.

·         All local government areas except Bellingen are over allocated for employment (industrial) land, with Nambucca, Clarence and Taree being the worst off at 4,300%, 3,809% and 3,048% over allocation respectively.

·         The proposal to review the Strategy every five years is supported.  It should be this mechanism which responds to any changing demographics trends, if they occur, so that any requirement for further rezoning of land can be demonstrably evidence based.

·         If such an oversupply was to be ‘locked’ into the final growth area maps, then property owners and investors will hold local and state govt to ransom if those rights were threatened with any proposal to back zone.

·         By ‘locking in’ this gross over allocation of land, the State Government is denying itself and the community flexibility and options for future land use or protection in these areas.  This prospect flies in the face of responsible planning, especially in view of climate change impacts, in particular sea level rise, which are under considered in this process. 

·         In view of the above dot point, the Precautionary Principle should be applied and the final Growth Areas should be adjusted down to reflect the Government’s projected growth figures and when doing so, the primary principles should be 1) no loss of native vegetation or at the very least no loss of vegetation listed as rare, vulnerable or endangered under the TSC Act or identified as under reserved; 2) no filling or drainage of the floodplain; 3) avoidance of sites at risk from future inundations caused by worst case scenario sea level rise and 4) preference for sites adjacent to existing centres and services.

·         We find it difficult to understand how ESD principles can be met through this strategy without firstly developing a Conservation Plan.  Before adopting a final Strategy the NSW Government must develop a Conservation Plan for the Mid North Coast which provides protection for biodiversity in perpetuity.

·         The NVCA does not support the following sites as new growth areas; West Yamba, James Creek, Lawrence, Corindi, Arrawarra Headland, Safety Beach Golf Course, Mastracolis Road, North Boambee Valley, Bonville, Boggy/Cow Creek, South West Rocks, Scotts Head, Lower Nambucca, the expansion of Thrumster, Dunbogan, Area 15, North Tuncurry and Balberook and North Arm Coves.

·         Some sites identified in the Draft Growth Areas have significant conservation values and should not be included, however if the NSW Government does not reject these sites, it should establish a Sensitive Sites Panel akin to that used for the South Coast Regional Strategy, to allow a closer examination of the sites and related issues.

·         The NVCA strongly objects to the sustainability criteria, which enables development to occur outside areas identified in the Strategy.  The glaring loophole defeats the purpose of developing a Regional Strategy in the first place.  

2

2          Nambucca Shire proposed future growth areas

·         This Association’s comments put to DoL in its 29 April MNC Regional Strategy submission regarding Nambucca Shire Council’s proposed future growth areas still stand.  These areas were identified through Council’s 20 Year Shirewide Structure Plan process with considerable community consultation, however the NVCA lacks confidence in the Community Reference Group established to inform Council on community views regarding the plan, as it was established without clear criteria and lacked any conservation representative to balance the views of participants with obvious pro development objectives. 

·         NSC’s Structure Plan was based on previously identified future growth areas which were established many years earlier without the benefit of contemporary knowledge of ecological values, planning standards or considerations such as climate change impacts.  The NVCA was disappointed that areas clearly unsuitable for development continued to remain in NSC’s proposed growth areas despite considerable community feedback as to their ecological sensitivity and biodiversity values.  As a result we now are faced with a new layer of planning being based on poor, ill informed and outdate planning decisions of the past.

·         We hold little confidence in assurances that Future Growth Areas are over allocated to allow for ‘no go’ areas to be established within them at a later date.  Neither the State Government nor NSC has yet even commenced preparation of promised conservation plans.  Indeed there is no certainty as to whether a Conservation Plan will ever be prepared, let alone which areas might (if ever) be identified for ‘no go zones’.  This is a most disappointing and worrying outcome.

·         Without up front criteria for protection of biodiversity values, there is no certainty that those lands within identified Growth Areas will be subsequently unavailable for future rezoning for development, as such they may be more vulnerable to destruction following adoption of the Regional Strategy, than they are currently. 

• There is an enormous oversupply of both urban and employment lands allocated for the Nambucca Area.  Nambucca has one of the lowest growth rates on the mid north coast.  Removing the most inappropriate areas ie South Scotts Head, Lower Nambucca and Boggy/Cow Ck would still leave sufficient land for the next 25 years.  If growth rates increases during that time the 5 year review process could identify further lands if necessary.
   

• Experience has shown that back zoning is unacceptable to landowners in terms of lost development opportunity and to government.  Therefore, locking in a massive over allocation of land effectively restricts local and state government’s future options in terms of best land use management which reflects contemporary planning and conservation goals and community expectations.
   
• NVCA supports the South Macksville Urban Release area.  This area will yield sufficient lots for the shires growth needs for the next 25 years.  Importantly this area is relatively unconstrained and close to services and facilities.
   
• The proposed growth area to the south of Scotts Head road is opposed outright on grounds of significant environmental constraints, its sensitive coastal location and it being superfluous to needs.  This proposed area is in direct conflict with the small coastal village character which was identified through the Shirewide Structure plan consultation process as requiring preservation.  NVCA is aware of incremental pre-emptive clearing of native vegetation occurring on this site over past years, however this fact and the consequent compromising of biodiversity values does not render it unworthy of exclusion from future development.
   
• Although not included in the DoP future growth area mapping, the NVCA is aware that NSC intends to resubmit Lot 1046, DP 826440 at Warrell Ck to the DoP for inclusion as future employment land.  We do not support this proposal.  Lot 1046 is isolated from other industrial lands in the Macksville area.  At least half of the lot is below the 1:100 year flood level, the site is identified and mapped as significant farmland and lies immediately adjacent to Warrell Creek which is a recognised high conservation value waterway, with enormous tourism and ecological values.  It is therefore a most unsuitable site for industrial use.  This lot was proposed to NSC by the owner after completion of the Shirewide Structure Plan and has therefore not been subject to local community consultation.  Employment lands are already vastly over allocated for the Nambucca Shire in the DGAMs without the addition of this block.  We understand the DoP have already rejected Lot 1046 once before and urge it to stand by this decision and not include it in the future growth areas for the Nambucca.
   
• NVCA opposes the proposal for development of the Boggy/Cow Creek area.  This new satellite area will virtually be a town in its own right.  However, it will be remote from services in particular in the early stages and therefore unattractive especially to older buyers, requiring access to transport and medical facilities and services.  The western section contains almost 5ha of Endangered Ecological Community.  There simply is not the demand to justify such a large area.  The Cow Ck/Boggy Ck area was touted as a future growth area many years ago by NSC, despite it never being zoned Future Urban in the 1995 NLEP.  Local land holders claim they were given verbal assurance by elected representatives years ago and have invested and sat tight on land on the premise that their rural land would one day be subdividable for urban development.  This is hardly a sound basis for planning such a major new development area.  We are astounded that not only have local landholders now amalgamated and engaged consultants to develop a master plan for the area but NSC is actively involved in the process.  We trust this pre-emptive activity will not undermine the integrity of the Regional Strategy process in terms of assessing submissions and finalising Future Growth Areas.
   
• The NVCA does not support the South Nambucca (Lower Nambucca) employment land area because of its extremely environmentally sensitivity and flooding constraints.  Development of this area would constitute unacceptable ribbon development.
   
• The 2ha site at Nambucca 3 for urban growth is not supported due to the existence of swamp sclerophyll forest which is inadequately reserves in the region.

In Summary

The NVCA is most alarmed at the enormous increase in area allocated for future development in the draft Growth Area Maps, compared to the figures in the draft MNC Regional Strategy and urges a major adjustment down to realistic and sustainable levels.

In fact we believe that allocating land for future development should only be undertaken following sustainability assessment of resources available within each catchment particularly in terms of water resources.

Thankyou for the opportunity to participate in this important process.

Yours sincerely
Georgette Allen
Secretary

The Secretary,
Taskforce on Tourism and National Parks
GPO Box 7050, Sydney 2001

30 August 2008

Dear Sir/Madam

Re: Submission on Tourism in National Parks

The Nambucca Valley Conservation Association (NVCA) considers the two page media release on the above subject lacks detail and sufficient information to make a subjective submission.

The Taskforce faces a huge challenge in identifying an acceptable source of income revenue, without compromising the natural and biodiversity values of National Parks or alienating the people of NSW against National Parks.

The following comments are offered for consideration:

Aims:

It is essential that National Parks and their environments, including Wilderness areas continue to be protected under the regulations of the National Parks Act 1974 and the Wilderness Act 1987.

National Parks have traditionally been used by those seeking a nature experience, so ‘Appropriate Use’ must not endorse or adopt any practice or usage that threatens or compromises the environmental values or sanctity of parks.

Priority must be given to environmental protection from visitor impacts in natural areas and maintenance of biodiversity in parks through clear, enforceable Plans of Management.

"Creating a platform’, should consider the establishment of ‘off park’ bases in adjacent towns, communities or on neighbouring opening space (that does not involve clearing of native vegetation). It is unacceptable to assume that increasing tourism can only be met by enlarging development areas within a national park.

Criteria for increasing tourist numbers should not be focused firstly on raising revenue, but rather raising public awareness of the importance of our natural assets, biodiversity and conservation. 

Tourism expenditure should be focused on securing adjoining or nearby suitable property for accommodation, auxiliary entertainment and activities, rather than diminishing park values with purely revenue generating tourism infrastructure.

There is still a strong need to continue research within National Parks, as the discovery of the Wollemi Pine suggests.

The NSW Government must continue to fully fund the National Parks estate from core revenue, in recognition of the outstanding public good which it provides to all the citizens of NSW – including those who do not even visit such areas.  The search for revenue must not out-price National Parks accessibility for the community or affect the environment of our National Parks in a detrimental way.

Terms of Reference:

Point 1
This proposes development on a projection basis. How is the demand justified in all areas of  the National Park estate?  How will proposed development costs be based on projected income figures if tourism numbers are a projection of requirement by 2016?  Who will be able to afford a visit to a National Park, based on projected fuel availability and cost?  Amendments should be via a transparent process and involve community consultation.

Point 2
Consider developmental consultations with other agencies and private bodies that will minimize proposed developments on National Parks estate in the longer term and the utilization of alternate departmental lands as an alternative.  The implication of this point is that the National Parks Service will be advised by other agencies on the best use of its estate lands.

Point 3
This point appears to overlook some of the expertise that has previously provided outstanding interpretive signage and brochures and is available internally.  If this point is given the consideration it deserves, what is the advantage in identifying the first two aims?

Point 4
The NVCA encourages the strengthening of constraints for environmental protection, not the seeking means to “overcoming any such barriers”.  The NVCA totally opposes point 4.

Point 5a
‘developing opportunities associated with the park’s estate’ -  What a broad ranging cover all excuse to escape responsibilities under the National Parks or Wilderness Acts.  Any such opportunities in National Parks estate must be individually identified and discussed in the public forum.

‘Adaptive re-use of existing facilities’- Great idea, on existing built or provided facilities, but should not  be considered as an excuse to expand or developed facilities without thorough justification established by demand.

‘Volunteering opportunities’ - The NVCA fully supports the use of trained/qualified volunteers for interpretive work or as research assistants.  Volunteers can effectively reduce costs and provide a valuable human resource.  They also provide a valuable training base for personnel undertaking higher educational training and deserve to be positively identified.

‘Opportunities for other new tour/experienced-based products’ – The NVCA supports in principle new opportunities providing they are appropriately controlled, monitored and reviewed.  Any such activity or commercial agreement must not result in any loss or degradation of biodiversity or environmental values within the park involved.  Any proposal to increased commercial access to pristine or wilderness areas must be subject to an environmental Impact Statement undertaken by independent experts, specifically aimed to protect the environment from such an activity.

The NVCA does not support any roading for vehicular access or off road 4wd activities in parks under any circumstances.

Point 5b
Without consideration of the basic wage earner, single income family, single parent family, there should be no thought to increasing National Park visitor fees.  Transport, accommodation and food costs are all major points to be considered in evaluating the impact any increase to visitor fees will have on the average park visitor.

Point 5c
All existing and any proposed commercial operations/tours in National Park estate should be reviewed annually.  Such review must weigh up the revenue generated against impacts and cost of mitigating/managing impacts to park infrastructure and natural assets.  Any financial benefit must demonstrate that park values have not been compromised and that such use is sustainable in perpetuity.

Point 5d
Appropriate training of staff and volunteers, interpretive signs, interpretive facilities help to promote National Parks.  There is no better advertisement than an employee or volunteer who is informative, knowledgeable, keen and courteous.

Point 6
Leave this purely as a study in tourism conservation benefits.  Trying to compare with case studies overseas or even from other states on themes that are similar/different can become complicated and may not be productive, considering seasonal, environmental and visitation differences.  Use what is locally working and expand/explain.

Point 7
The preparation of an MOU is admirable, but it must include all Federal and State departments with any specific or inferred interest in the adjacent area of a National Park.  Why is it being restricted to an MOU between DECC and Tourism NSW, it could possibly involve a large portion of other State Govt. departments as well as external private bodies.

Point 7a
Stated visitation objectives must be agreed to by all parties involved and funded/developed as approved on a pro rata basis.

Point 7b
The NVCA supports the continuing protection of conservation and biodiversity values without any attempt to subvert these values or decrease their effectiveness being considered in the future.

Point 7c
The NVCA objects to any legislative amendments which would allow development in National Parks for unjustified tourism or purely for the sake of income generation.

Point 7d
This is considered to be the most difficult point that the Taskforce has to consider. How to increase tourism without alienating the tourist or compromising the conservation and biodiversity values of the National Park estate.  The NVCA does not support any increase per se, in the application of fees, as a revenue maker to support research.  The association does however strongly support the need for continuing research.

Utilization of natural resources in National Parks is absolutely opposed by this Association.

Resource information, substantive research and the benefits to come from such works cannot be over-emphasized.

Any increase in income generated as a result of this process should be supplimentary to substantial and recurrent core funding of the National Parks and Wildlife Service from both State and Federal government.

The NVCA considers that the Taskforce has been given the onerous task of justifying unsustainable and unacceptable development within National Parks for purely revenue generating purposed.  Whilst this Association supports increasing park visitation it does not support the primary objective of raising funds through development and increased (other than bushwalkers) accessed to sensitive areas.

Paula Flack
President
Nambucca Valley Conservation Association

Michael Coulter
General Manager
Nambucca Shire Council, PO Box 177, Macksville NSW 2449

1 November 2008

Dear Mr Coulter

Submission on Nambucca Shire Council State of the Environment Report

 1          Community Consultation

 The NVCA has in the past requested that Council exhibit its supplementary State of the Environment (SOE) Report as well as the comprehensive four year version, believing that it is the most effective and transparent means of fulfilling the legislative requirement to undertake community consultation as part of the preparation of the annual SOE Report.  We therefore commend Council for exhibiting this supplementary report, although we understand that this has occurred due to administrative anomaly involving a previous resolution of Council and the timing of the local government elections, rather than an intention to exhibit the annual supplementary report.

Either way, given the significant changes to the format of the report this year, it is appropriate that the public is offered the chance to make comment on the draft.

In its Review Report to Nambucca Shire Council (August 2008), the Department of Local Government (DLG) recognised the need for Council to improvement to the way in which engages the community in its SoE reporting.  It states on p36 that ‘The SoE report does not indicate how the Council involves the community in its environmental programs or what input the community has into the priorities that are assigned to environmental issues.  Council is encouraged to start thinking about how it will deal with getting the community’s views.’  The DLG goes on to recommend that ‘Council should encourage greater involvement from community groups who may contribute environmental data that could be incorporated effectively into the State of the Environment reports.’

The NVCA acknowledges that Council contacted community groups in June this year requesting feedback regarding their environmental activities.  We apologise that due to limited resources, we were unable to respond to this request.  We have however included in this submission at section 4, reference to our primary projects for your consideration for final document.

The NVCA wishes to point out the significant difference between seeking information from community groups regarding their particular activities (for inclusion in the draft) and calling for submissions on the draft itself.  We note on p1, reference to Council calling for submissions from community groups in July 2008, but the reference is unqualified in terms of the nature of the request ie seeking information rather that seeking comments on the draft itself.

The NVCA requests once again that in the future Council exhibit its annual supplementary SoE Report as well as the comprehensive reports, for community input.

2          The New Format

2.1     Fantastic photography, but we question the need to have such large colour photos.  We are concerned about the message this sends in terms of ESD ie the use of inks, paper and printing costs (public are charged $10/copy for colour A4), especially given the purpose of this particular report.

Perhaps the photos could be reduced to half page and be less dominant, after all it is the text which is most important.  We trust that the file size of these photos would be significantly reduced for web downloads given the number of Nambucca Shire residents still limited to dial up internet access.

Also the cost of photocopying the document when requested in hard copy would be prohibitive in its exhibited format.  Even if copied in black and white the toner use will be excessive and probably significantly reduced in terms of image quality.  Will modifying the document for different format requests to address these issues mean more administration costs?

2.2     There is distinct lack of detail in facts and figures compared to the old format.  We are concerned by the dumbed down approach to this significant document.  We recognise that it is important to make a document readable for the general public however this must not be at the expense of specifics.  The report must address each identified ‘pressure’ but fails to do so.  Is this simply a result of the new ‘lightweight’ format or is it intended to provide greater depth of discussion and information in the comprehensive report?

2.3     In each section the various ‘pressures’ are listed and then addressed in a subsequent sub section however the responses are dealt with randomly without numbering, heading or grouping.  This approach makes it difficult to use the document ie someone seeking to evaluate a specific response to a specific pressure has to wade through the entire section looking for the information.  Pressures should be numbered and a corresponding ‘response to pressure’ section provided along the lines of the previous format, to make the document reader friendly and allow clear assessment of responses/actions.

2.4     The ‘did you know’ boxes are a good idea and attract the reader’s eye.  Raising awareness is very important, so greater use should be made of them.  To that end all quotes should be Shire specific or if quoting a broader statistic should be put in the context of our local condition/situation.  They must also be fully referenced at the end of the quote to enable the reader to explore further. 

2.5     Flora and fauna are now dealt with in the biodiversity section, however the depth of detail has been lost and is appallingly deficient.  

3          Specific comments by sections as per draft

3.1       Introduction

• The table requires an explanation re how it is applied in the document.
• ESD should be dealt with up front in this section and the core principles of ESD should be spelt out to raise public understanding of ESD and how is can and should be applied.

3.2       Human Settlement

• This section does not belong in a SOE report or at least not in this context.  If it were to relate to pressures of human settlement ON the environment then yes, but this information would be better located in the Social and Community Plans.  The matters dealt with in the ‘response’ section highlight the irrelevance to the state of the environment as it largely relates to community events and activities.

3.3       Land

• Pressures should include the major issue of climate change.
• Logging and agriculture should also be recognised in the list of pressures, especially given the reference to them both in the introduction.
• Fire is a significant pressure which has been overlooked.
• Another pressure throughout the valley which is not recognised is the appalling state of Council’s drains on rural roads, most of which are completely blocked.  The resultant stormwater torrents along unsealed roadsides in rain events, cause scouring and transport large volumes of sediment often directly into watercourses. 
• The tables on p7 are unclear.  The first tables showing the two stars denoting ‘Statistics from Council’s Environment & Planning’ seem to relate to the column heading only?  Similarly the second table – what do the two stars mean?  Which stats are the Department of Industries?  What is the difference between ‘Native forest logged on State Forest land’ and Area of State Forest selectively logged’?  What is ‘Non dedicated State Forest Land’?
• Private logging is a MAJOR threat to land stability and soil sustainability and is occurring in this shire at an alarming rate, with significant negative environmental impacts, minimal regulation and virtually no State Government monitoring or auditing.  Where are the statistics and acknowledgement of this significant pressure?  The NVCA considers this a serious failure in reporting the state of our local environment which should be addressed.
• As mentioned earlier in this submission the unstructured format of the ‘response to these pressures’ section is frustrating and inadequate.  Responses should be clearly numbered and relate directly to EACH pressure listed.
• The quote on page 9 is interesting.  What does newly cleared land mean?  It would make sense that there is less clearing of virgin bush and old growth forest given the incremental loss of this disappearing asset - it is being cleared faster than it can ever regenerate.  This statement suggests less land clearing is occurring, is unqualified and not references.  It should be removed as it paints a dangerously distorted picture.  The facts regarding the extent of land clearing are easily accessible and should be clearly quoted.
• The extend of land clearing in the Nambucca Shire should be identified.  Comparison of aerial photos or satellite photos should be undertaken to give an indication of the extent of ha cleared over recent years.

3.4       Aquatic Systems

·         Extraction of water from the river, creeks and bores has been omitted as a pressure!

·         Stock access has also fallen off the list as a pressure.  It should be recognised as a significant impact on water courses in terms of riparian vegetation, bank stability, water quality and habitat.

·         The table shows chemicals as a source of water pollution but these stats cannot be correct – the NVCA is aware of more complaints being made to council regarding water pollution than are shown eg Beer Creek!

·         The table on p15 refers to ‘regional indicator’ this should read local to avoid confusion.

·         The NVCA does not accept that there is no water licence data pre 2006.  DWR undertook an audit of licenses to inform the water sharing planning process 2000 – 2002

3.5       Biodiversity

• Reference should be made to the high biodiversity of this area due to the biodiversity regions overlap.  The Nambucca falls into the southern area of the overlap.
• We have at least two species of rare flora which occur only in our shire these should be listed.
• It is impossible to believe that climate change could have been left off this list!
• Pressures should also include logging, fire, genetic engineering, chemical use, loss of habitat (not just fragmentation).
• Why is ‘threatened EEC’ listed as a pressure?
• The table is woefully incomplete.  Stats exist for numbers of native fauna and flora species and EECs in the shire and should have been sourced.
• Stats on land clearing and logging should also bee shown here.
• Council’s lack of regulation of land clearing in residential zones in the shire should be acknowledged.

4          NVCA Projects

4.1       Sustainable Integrated Growing Systems (SIGS)

The NVCA received a federal government Envirofund grant for $34,000 in 2006 to undertake its project Sustainable Integrative Growing Systems for the Nambucca Shire (SIGS). The purpose of SIGS is threefold:

·         To ensure biodiversity conservation and the sustainable use of natural resources within the Shire, the NVCA aimed to raise community awareness about integrative, organic systems of growing as sustainable alternatives to genetic engineering (GE).

·         To build and strengthen community networks through the various activities planned in the project, many of which will be ongoing following the completion of the project.

·         Produce an academic paper and information kit to raise awareness about environmental sustainability in various community sectors.  The kit is intended to also serve as a model for other North Coast communities should they also seek to encourage an ecologically sustainable community. 

In addition to undertaking community activities such as the True Food Fair, Backyard Sustainability Day and ‘Germination’ art exhibition and competition, SIGS aims to raise awareness of integrative organic growing systems as sustainable alternatives to genetic engineering by providing information to the community regarding the benefits of the former and the risks of the later.

To this end, the NVCA engaged a locally based consultant to create two educational kits, to be distributed to interested bodies and the local community.  The Academic Kit explores issues of organic agriculture, GE and Ecologically Sustainable Development (ESD) including legal aspects.  It considers evidence illustrating adverse and/or beneficial impacts of both genetic engineering and organic/biodynamic agriculture on human health, environment and society.  Importantly the academic kit investigates the suitability of genetic engineering in agriculture and organic/biodynamic agriculture in the context of the Nambucca Shire.

The general educational kit is aimed at the wider community and is based on the findings of the academic paper but in a simplified form.   

The kits provide a comprehensive overview of the benefits of using integrated organic growing systems, while ensuring the community has ready access to independent, accurate and soundly researched information pointing out the dangers and risks associated with GE

4.2       The NVCA undertakes various community awareness raising and fundraising events each year, highlighting local, regional, state and national environmental issues and encouraging community action.  We participate on various committees as conservation representatives and make submissions to local, state and federal government on various planning and policy issues.  We are in regular contact with the conservation network in particular the North Coast Environment Council and Nature Conservation Council.  Our Association produces a bi monthly newsletter, runs a website and holds monthly meetings.

5          Recommendations

5.1     That in the future Council exhibit its annual supplementary SoE Report as well as the comprehensive reports, for community input.

5.2     Environmental pressures should be numbered and a corresponding ‘response to pressure’ provided along the lines of the previous format, to make the document reader friendly and allow clear assessment of the responses/actions.

5.3     All quotes in the ‘did you know’ boxes should be Shire specific or if quoting a broader statistic should be put in the context of our local condition/situation.  They must also be fully referenced to enable the reader to explore further. 

5.4     Remove the human settlement section or refocus it to human pressures on the environment.

5.5     Include climate change as a significant pressure on land and biodiversity.

5.6     Include logging (both private and public) and land clearing statistics.

5.7     Acknowledge water extraction and stock access to watercourses as pressures to aquatic systems.

5.8     Access and include flora and fauna stats.

6        In Conclusion

Although a more attractive document than the previous format, this SOE report is flimsy, difficult to navigate for specific information and requires far more depth and scope in the reporting to truly reflect the state of our environment.

Please feel free to contact us if you should require any further information regarding this submission, in particular regarding our SIGS project.

Yours sincerely,

Georgette Allen,
Secretary

Resource Design & Management
Mr Michael Lamont
Project Director
Nambucca River Master Plan

25 May 2009

Dear Mr Lamont

RE: Community Workshop Issues Paper – Nambucca River Master Plan

The Nambucca Valley Conservation Association (NVCA) is most concerned that its input provided at the Environment Group Workshop at the Nambucca Entertainment Centre on Monday 6 April 2009 was not recorded and presented along with other comments, in the RDM Community Workshops Issues Paper.

Nambucca Valley Conservation Association takes very seriously such opportunities to participate in planning processes which will impact on the local environment.  Even though comments might have been repeated in other workshops, accurate recording of points raised at each workshop should have been undertaken to clearly reflect each sector’s interests and concerns. 

The  Issues paper shows in the ‘Environmental Interest Groups’ section for Study Area 2, only one statement recorded, in Study Area 3 and 4 ‘nil (!) recorded and in Study Area 6 and 7, only two comments recorded. This does not by any means reflect this Association’s input and comments at the workshop.

Therefore we now provide to you in writing, the comments which were made at the workshop, as follows:

Study Area 2. – Stuart Island

·        Aboriginal consultation necessary

·        Do not support any development of north end of Stuart Island

·        Can be enhanced by strategic planting of vegetation to restrict car movement

·        No hard surfaces

Study Area 3 - Bellwood Park

·        Upgrade and maintain amenities and soften impact of toilet block with landscaping

·        Re-vegetate parking area with local native species to create more shade and amenity

·        Do not support a ‘theme park’ idea

·        No development required, natural with picnic facilities is best.

Study Area 4 - RSL area

·        Impacts on estuary from Beer Creek need to be assessed and remediated

·        Vegetation planted on riparian area of Beer Creek to improve its health

·        Do not support further development in this area eg more cafes.
 

Study Area 5 – Gordon Park

Comment about your recording of dot point 2:- Another vehicle link between Bowra St and Wellington drive is not supported as there is already a beautiful road existing. There is also currently a pedestrian link.

Study Area 6 – V Wall

·        Impacts from caravan park on study area investigated and remediated

·        Improve vegetation in whole area

·        Upgrade amenities

Study Area 7 - Sand Island

·        Against any development of sand island

Study Area as a Whole

Comment on dot point 5 is not correct. It should read: Do not support dredging of river as it is ecologically and economically unsustainable

(It is also regulated, but that may not stop it from being dredged).

Please note there are two omissions on the attendance table under the Environmental Interest Group column; Cr Anne Smyth and NVCA member Lloyd Ellis were both in attendance.

We received this Issues Paper on Wednesday 13 May with only two days to comment. We consider this inadequate time for volunteers to review and comment on the document, especially given the omissions which have resulted in our needing to collate our comments and present to you in writing.   We ask that that our comments be taken into consideration and included in the Issues Paper.

The NVCA will also provide more detailed comments on the Nambucca River Master Plan Preliminary Discussion Paper, for your consideration.

Thank you for the opportunity to participate in this important process.

Yours sincerely,
Georgette Allen,
President, NVCA

CC Mr Greg Meyers, Director Environment and Planning, Nambucca Shire Council

Mr Steven Williams
Property Officer
Nambucca Shire Council
PO Box 177, Macksville, NSW 2447

27 May 2009

Dear Mr Williams

Proposed use of Community Land being Lot 3 in DP 1028461,
corner Pacific Highway & Link Road Nambucca Heads

The Nambucca Valley Conservation Association (NVCA) would like to offer the following comments regarding the proposed use of the forested block of community land at the northern entrance to Nambucca Heads.

Our members do not support this land being used to locate the RFS headquarters or any other infrastructure.  This site is not suited to such a purpose, which would require extensive and unacceptable clearing of the remnant native forest existing on Lot 3. 

This site is a high profile ‘front door’ to Nambucca Heads and should be managed in a way which protects and enhances such a valuable natural asset.  Tourism is an important industry in this Shire, and visitors have clearly expressed that they come here because of the natural, undeveloped beauty of the area.  Our front door should say “What you see is what you get”.  We should be proud of our natural assets;  after all, much of our local economy depends upon them. 

Lot 3 should remain forested with the only development being sensitive signage, walking tracks and perhaps a small rest/picnic area for travellers. No clearing of native vegetation should be undertaken. Any development should be carried out in such a way as to minimise impacts on the existing natural features and amenity.

The NVCA is also aware that Council will shortly acquire further land in close proximity to Lot 3.  That is Lot 1 – the southern most section of this ‘island’ of land between Old Coast Rd, Link Rd and the Pacific Highway.  Further, we are aware that these two lots are separated by a road reserve and Lot 2 which was recently acquired by the Nambucca Local Aboriginal Lands Council (NLALC) as part of a land claim.  We do not support Lot 1 being used for the purpose of RFS HQ or other infrastructure either, for the same reason of potential loss of remnant native vegetation.

Most community land in the Shire is cleared for sporting purpose.  Therefore there is a need to provide opportunities for the public to have access to forested bushland close to town and the highway. 

The NVCA believes Council should explore opportunities to work together with NLALC for a co-operative approach to managing all lots for a common purpose, providing existing vegetation is maintained and, where necessary, rehabilitated.

Yours sincerely

Georgette Allen
President

Nambucca Shire Council
PO Box 177
Macksville NSW 2447

15 August 2009

Dear Sir/Madam

SUBMISSION ON DRAFT INTEGRATED WATER CYCLE MANAGEMENT PLAN

The Nambucca Valley Conservation Association (NVCA) wishes to apologise for this late submission which is result of current time constraints on voluntary members.  We trust that if time allows, this submission will be taken into consideration.

The NVCA is a volunteer community group which has operated in the Nambucca Valley for over 27 years and has a strong locally based membership.  We would like to offer the following comments regarding the Integrated Water Cycle Management Plan.

Although very detailed, we find the draft document complicated and confusing in its format and consequently difficult to read and navigate.  The summary sheet, which is the likeliest to be considered by the average community member, whilst a good idea, does not provide meaningful information regarding the costs of each aspect within the scenarios in particular the $58m dam and likely requirement for an filtration plant at a further $20m+.  Neither documents considers the options in terms of ESD ie no account of greenhouse gas emissions are given for the tree clearing, transport and construction works required for the dam (or any other options), nor the enormous power requirements to constantly aerate the dam irrespective of whether it is ever used or run a filtration plant.

Our comments are unfortunately limited due to time constraints and are by no means conclusive.

Firstly, the NVCA is fundamentally opposed to the construction of a dam and is of the opinion that growth management, water demand management, education, recycling and rain and stormwater capture should be the focus of any water security strategy for the Shire.  We also believe protecting low flows in the Nambucca River is long overdue and that water restrictions have in the past been applied too late and too lax.

The NVCA does not believe a dam will achieve protection of low flows.  We are aware pumping well into low flows (95^th percentile and possibly beyond) to fill and maintain dam level whether it is used or not.  This fact simply adds the dam as another water demand pressure on the Nambucca River and groundwater system.

We are concerned that an unrealistic and in accurate predicted growth rate of 2% has been used to justify the need for a dam. The past average growth rate has been in the vicinity of 1% and should have been used in this exercise.  Using a 2% growth rate has in effect inflated the predictions for water demand and also inflated the prediction for developer contributions to cover the costs thus placing much greater cost burden on town water supply users for future growth which is unlikely to occur and may very well be unwanted.

We support the upgrading of existing infrastructure to operate more efficiently, thorough maintenance routines to identify and address leakage and best practice standards being applied to water and sewerage management in the Shire.

Council must invest its resources and seek funding to implement measures to manage our finite water supply sustainably so that a dam won’t be required.  In the intervening seven years since the drought of 2002 when the Shire apparently nearly ran out of water Council has done virtually nothing to secure its town water supply other than this draft document.

The recently installed stormwater capture tanks at the Council’s works depot and modest rainwater tank incentive scheme introduced a few years ago are to be commended.  Lets have more on the ground initiatives (other than a dam), greater consideration of the impacts of water thirsty industry commencing in the valley and a much higher degree of liaising with our existing high water users, nursing homes, the Macksville Hospital, nursery industry, sporting groups.

The alternative to this IWCMP is not as the Summary Sheet suggests "to not implement it".  Clearly this Shire desperately requires an IWCMP.  It is the responsibility of Council, the community, business and industry sectors to change the way they think about and use water.  Building a dam so we can continue to extract unsustainably is not we believe an option, certainly not a sustainable one. 

An alternative to the draft IWCMP should be a new IWCMP which is more realistic, affordable and sustainable, based on 1% growth and with an option without a dam.  The fact that the IWCMP fails to consider an option WITHOUT a dam, demonstrates a lack of willingness by the consultants and Council to truly offer a range of options to the community.  Such a dam free option should have provided and thoroughly explored to demonstrate its suitability or otherwise as a scenario.  We believe Council should require this before signing of on any option.

Yours sincerely,

Phillip Margolis
Vice President

Mr Michael Coulter
General Manager
Nambucca shire council
PO Box 177
Macksville NSW 2447

16 August 2009

Dear Mr Coulter

Re: Proposed Roading through SEPP 14 Wetland at Bellwood

The Nambucca Valley Conservation Association (NVCA) would like to make clear its strong objection to the 180m road proposed to join Marshall Way to Alexandra Drive at Bellwood, which is currently included in the draft S94 Bellwood Local Roads and Traffic Infrastructure Developer Contribution Plan.  We are aware that Council will be considering this matter at its next meeting on 20 August 2009 and would appreciate this correspondence being brought to all Councillor’s attention.

The NVCA opposed what we still consider to be the illegal clearing of the Bellow area for further residential development back in 2003/04 and are very much aware of the serious negative impacts that the destruction of habitat has had on the threatened species recording at the site in particular the Koala and Yellow-bellied Glider and the large forest owls.

We are disappointed that Council is proposing to contribute further to the loss of key habitat of threatened species and sensitive SEPP 14 wetland.  Council has a core responsibility to protect these areas for their biodiversity and ecosystem function, especially given the already compromised status of local fauna and also considering this location’s proximity to the Nambucca River estuary and oyster industry interests.

The NVCA is also aware that this are is of extreme important to the local Aboriginal community and involves a highly sensitive and significant site, for this reason also we opposes the road being constructed.

It is the NVCA’s opinion that the existing community wishes for the two residential areas of Palmwood and Faringdon to remain distinct, without the connection of the two local roads should be respected.  It would appear that only the developer involved wants the two roads connected.  We have yet to hear of a member of the community or local resident who supports the proposal. 

We urge Council to reject the engineering department’s proposal to construct this unnecessary and unwanted section of road.

Yours sincerely,
Phillip Margolis
Vice President

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