Mr Michael Coulter
General Manager
Nambucca Shire Council
PO Box 177
Macksville NSW 2447
4th 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 
w 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.
w 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.
w 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.
w 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
w 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 paragraph as a preventable threatening process.
w 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.
w 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.
w 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
w 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.
w 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
w 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
w 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. 
w 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
w 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.
w 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.
w 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.
w 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.
w 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
w 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.
w 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. 
w 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
w The actions recommended in this strategy are fully supported
8 Management Strategy HM-2
w 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. 
w 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.
w 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. 
w 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.
w 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
w 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’.
w 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
w 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?
w 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. 
w 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. 
w 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.
w 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. 
w Why is there only a ‘no tow’ zone rather than both no tow and wash minimisation to the east of Stuarts Island?
w 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.
w Suggest considering extension of ‘no wash’ area to confluence with Newee Creek to minimise impact of pollution runoff from highway crossing at Newee Creek.
w Should consider opportunities to tie various boating, swimming, habitat signage together wherever possible to minimise the number of signs around the estuary. 
w 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
w 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.
w We agree with a review of use of Wellington Boat Ramp for small craft only and removal of rock ballast.
w 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. 
w 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
w 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. 
w 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
w Signs should be multi lingual catering to tourists eg German & Japanese.
w 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
w 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
w 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
w Figure 1-1 requires a legend explaining black & red line, ie tidal limit and roads. 
w Figure 2-2 text too small to read.
w 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.
w Table 6-1 text on legend too small to read.
w Suggest page number at bottom right of landscape pages to allow quick flick for pages.
General Comments
w 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.
w 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.
w 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.
w 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