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 extent 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