Honourable Rob Stokes
Minister for Planning
14th December 2015
Northern Councils E Zones Recommendations
Dear Mr Stokes
Members of Caldera Environment Centre would like to submit their concerns in relation to the recommendations of the E Zone review of northern councils as they relate to Tweed Shire.
A recent public workshop on the recommendations was held by our group and the EDO at Murwillumbah. Those attending, approximately 40, overwhelming supported the implementation of E Zones in areas of native vegetation. This is a similar response to that at community consultation sessions during the period of the review. There have been very few issues against the implementation of E Zones in Tweed Shire.
The main considerations being the confirmation of the primary use being for environmental conservation or management and also fulfilling the criteria for E2 or E3 is impractical and onerous. These considerations are unrealistic in that this is a reversal of accepted practice to map and assess vegetation of conservation value, it will be time consuming and costly for Council and/or landholder to determine primary use as environmental conservation or management and likely to lead to disputes. Instead of a scientific approach to verify environmental values this is an ad hoc “use over past 2 years” approach. Similarly to verify the attributes to fulfil the E2 or E3 criteria to be undertaken by the listed methods such as site assessment, aerial photo interpretation and up to date flora and fauna studies will require significant allocation of expertise and funds by Council. It is likely that some areas of high conservation value vegetation currently zoned as environmental protection may not fulfil the recommended criteria.
Even when the land fulfils both criteria then it is not mandatory for the Council to apply the E2 or E3 zone. This certainly does not make sense.
Permitting extensive agriculture in E2 Zones, with consent, and E3 Zones without consent, will be detrimental to the conservation significance of the land within the zone. The example of activities provided in the document being, understorey grazing, can reduce the native seed bank and deplete groundcover and midstorey native plant species. This will result in a loss of biodiversity as there will be a lack of regenerating native plants and introduction of exotic species and loss of structure and function of the plant community.
The recommended removal of Scenic Protection and Aesthetic Values from E Zones will result in the loss of currently protected Scenic Escarpment which is a valuable asset to the tourism industry and also ensures stabilization of the steeper slopes by retaining the vegetation.
The mandatory objectives of E Zones in the Standard Instrument LEP are not met if permitting extensive agriculture is recommended. The objectives of E2 and E3 zones focus on protecting, managing and restoring areas with ecological, scientific, cultural and aesthetic values.
The recommendations are premature as there are current reviews of Biodiversity legislation and Coastal Management Reforms.
This recommended approach to E Zones has the potential to significantly undermine existing biodiversity values and has the potential to decrease future improvement in protection and enhancement of biodiversity values of the north coast.
The Caldera Environment Centre is extremely concerned by the recommendations as Tweed Shire and the other north coast council areas are of high biodiversity significance and there should be insurance that this is not depleted or lost.
Caldera Environment Centre