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 sulphate 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