See the Draft North Coast Regional Plan Update

The North Coast Regional Plan is the strategic plan for the future of the this region

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Submissions closed 24 August 2022

Caldera Environment Centre

To NSW Dept Planning & Environment

Submission: Draft North Coast Regional Plan 2041 (NCRP).

The Caldera Environment Centre Inc. (C.E.C.) is a Tweed Shire environmental group, a registered Voluntary Conservation Organisation, a registered Charity and an Incorporated Association of 25 years standing.

Re Land for New Housing

We note the following regarding land for new housing from the draft plan:
“… population growth in the region is expected to be particularly strong.
“Before approving secondary dwellings or detached dual occupancies in rural areas, councils should consider possible land use conflicts and impacts on local agricultural activities.
“Housing delivery targets for new housing will be achieved though development of land generally within the urban growth area boundary … the extension of the urban footprint for future
growth … infill housing is to be prioritised as it takes advantage of existing infrastructure and services and is a more sustainable option … greater residential density within the urban growth area boundary … maximising the density of land proposed to be rezoned for urban purposes.”
“The priority will be to direct growth to existing zoned land and investigation areas within existing urban growth area boundaries in the first instance.”

Caldera Environment Centre Comment: Whilst the urban infill and extension strategy is supported, in regard to the stated objective of protecting agricultural land we note the irony and perhaps insincerity of the strategy given the approval by the NSW Government of the recently built Tweed Valley Hospital on arguably the best agricultural land in the region against widespread community opposition.

Re: Biodiversity Protection

The draft plan proposes to:
“… ensure new or more intensive development is located in areas of least biodiversity sensitivity and that HEV lands are protected through the planning system.”

Caldera Environment Centre Comment: HEV lands should of course be mapped and protected. The Caldera Environment Centre is distrustful and cynical of NSW and Federal Governments claims of seeking to protect HEV lands given the removal of forest protections and focus on ‘resource extraction’.

The draft plan further states:
“… any residual biodiversity impacts [of housing developments] are considered under the Biodiversity Offset Scheme.”

Caldera Environment Centre Comment: The Caldera Environment Centre is highly distrustful of the Biodiversity Offset Scheme. Given the Ecological Crisis it is imperative that remaining biodiversity be preserved intact rather than destroyed and ‘offset’ against another already existing or future planned biodiverse area.

Re: ‘Renewable’ Energy

We note the following statements from the draft plan:
“The Department of Regional NSW will investigate opportunities to source affordable biomass and develop regional bioenergy industries.
“… key opportunity for the region will be to source affordable and local sustainable biomass and develop regional bioenergy industries.”
“… 11 active trial sites investigating biomass production from native tree species … .”

Caldera Environment Centre Comment:
1.) Claims that woody biomass as a carbon neutral replacement for coal in electricity generation plants are deliberately misleading: (i) burning woody biomass is dirtier than burning coal, (ii) if sourced from existing forests it immediately destroys the existing mature carbon sink capacity, and (iii) arguments that replacing forests with seedlings is cyclically neutral are purposefully misleading given the urgency of efforts to decarbonise energy production. 2.) for Native forest biomass as a replacement for coal in electricity generation is not ‘ecologically sustainable’, native forest ecologies are irreplaceable, any plans for woody biomass should purposefully exclude native forest biomass.

Re: Crown Lands and Aboriginal self-determination

We note the following statements from the draft plan:
“The NSW Government is committed to the prompt, equitable and efficient resolution of Aboriginal Land Claims on Crown land … pave the way for strategic and collaborative land use opportunities.”

Caldera Environment Centre Comment: Tweed Shire has highly diverse Crown Land system which over the past years have been the subject of CEC campaigns. Increased Aboriginal involvement in the management of Crown land to conserve cultural and heritage values as well as environmental values is strongly supported. The Caldera Environment Centre is distrustful and cynical of NSW and Federal stated plans to commercialise the use of crown lands through pursuit of arrangements with original peoples once native title claims are confirmed.

Caldera Environment Centre


Earth Learning .org Submission

To NSW Dept Planning & Environment

Re Draft North Coast Regional Plan 2041 (NCRP)

Earth learning is an ACNC registered charity group based in the Northern Rivers. Our core focus is environmental protection and advocacy of the biodiverse assets and ecosystems of this area.  We ask you to accept the following comments on this plan.

We note that the population of the N Coast & the Tweed region is expected to grow substantially over the plans time frame.  Appropriate urban planning will be critical to the future of this area.  As we have just seen in Lismore & elsewhere – in the face of climate change the disaster risk from poor planning can result in entire townships becoming unviable and even unliveable.

Housing growth

  • The report notes that new land release areas that do not have issues with natural biodiversity, cultural heritage, farmland or natural hazards are increasingly difficult to find.  Therefore, urban growth planning should prioritise infill development in already existing urban zones taking advantage of existing infrastructure and transport networks.   
  • Urban Infill will not be enough for future growth demand so new rural residential housing will be needed.  The report notes, and we strongly agree, that greenfield housing must promote sustainable outcomes and be outside environmentally sensitive land – particularly the coastal strip. 
  • HEV (High Value Environmental) land needs to be accurately identified and mapped at site map scale.hs been sorely lacking due to  years of environmental neglect by governments.
  • HEV lands should be OFF LIMITS and protected through the entire planning system.  The idea of “Offsets” even as a last resort is totally unacceptable.  There is NO REPLACING the delicate ecosystems that still exist once they are damaged or destroyed.  Climate change impacts like the horrifying bushfires we have experienced are already wreaking irreparable damages – it would be criminally negligent for us to add further damage.
  • NSW regional plans have a target of 40% multi dwelling and 60% single dwelling new homes by 2036. It is important to match supply with the demand demographic which is primarily single or 2 person households (an average 2.19 people is expected per household by 2041).  Consequently, low maintenance homes, manufactured home estates and caravan parks must play a central role to create the housing diversity required in the near future.  Council planning must adapt to meet this demand and to reduce the current dominance of 3-bedroom homes in the mix.
  • The NSW $30 million grant program to support regional Councils needs to meet these stated objectives.

The 2022 Flood Enquiry makes  logical and coherent suggestions on the balance between the need for urban development and the environmental consequences. Recommendation #20 states that NSW has no cohesive approach to appropriate development on floodplains.  Recent flooding disasters have shown us the consequences.  This flood enquiry offers guiding principles for floodplain management:

  • Treat floodplains as an asset.  Their uses must be productive, minimising risk during sever weather events.  They could be used for sporting & recreation, for gardens, agriculture, forestry and agriculture and renewable energy production.  Floodplain ownership could be moved to Government leasehold. Where houses and businesses are in high-risk areas conversion to leasehold can be accelerated with swaps and buybacks.
  • Floodplains could be developed in parallel with urban structures near the edge of the floodplain.  For instance, highrise apartments could be given access to community gardens or recreation on the floodplain connected to it with a layer of sustainable transport.
  • Floodplain development must let watercourses flow naturally – not be barricaded with levees and mitigation schemes to stop floods
  • These planning guidelines must be communicated to the NSW population but in particular to affected communities at the time of planning and construction

The NCRP is remiss in failing to provide a serious consideration of development of floodplains. This is a serious omission especially in light of current extreme climate and weather events.  The NSW Government has had ample opportunity to manage floodplains over the years. The previous planning minister started to address the issues of the risk of further development in flood risk areas. He recommended a precautionary approach – his department delivered guidelines for urban development in areas with a growing risk of flooding due to climate change. However, the minister was dismissed and his guidelines were overturned, just as the North Coast was hit with the most severe, widespread, flooding in history.  

Since the flooding we continue to see mismanagement of this issue. Temporary housing for misplaced victims has been notoriously slow to deliver.  In one town, Mullumbimby, 60 temporary modular homes have been built in the middle of a flood zone that was inundated during the floods.  A local civil engineer exclaimed that the placing of fill on a floodplain will only worsen the impacts –  the extra fill will create a worse effect for nearby properties he said.  Many affected residents are still asking what the transition plan is beyond the next two years?. Kingscliff residents say no-one was consulted or has since been told about arrangement plans for returning to their homes or to another permanent residence.  

If the NCRP is to be effective and worthy it must encompass the results of the 2022 Flood Enquiry. It must include the  recommendations for development on floodplains in respect of climate change and the ongoing impacts on our environments.

Environmental sustainability

NSW has a net zero emissions target by 2050.  The NCRP states this will be supported with initiatives around electricity generation – rebalancing coal & petrol with renewables and investigating hydrogen and energy efficiencies for primary industries.  The report discusses the creation of a circular economy in which products are produced, assembled, used and sold creating minimum waste and environmental impact.  It states that wind and solar are the cheapest form of electricity generation and the most environmentally friendly.  When paired with batteries, pumped hydro or gas fired generators they can reliably supply electricity at all times.  The report states that the North Coast has several potential sources of renewable energy – solar, bio waste, small scale hydro, wind, geothermal and wave power.

However – the discussion on biofuel/bioenergy raises alarm bells.  The report starts to talk about affordable and local sustainable biomass from agricultural industry waste, sludge from wastewater treatment, general biowaste or organic waste from households.  It mentions that the NSW Government Biomass for Bioenergy project is part of the NSW Climate Change Fund (therefore subsidised by the taxpayer).  It is therefore alarming that the example used is of Grafton and 11 similar active trial sites where native tree species are being used to create woody biomass pellets to combust for electricity.  It is suggested that combustion from pelletised wood be used for electricity to feed into the grid and provide heating. 

 The report states:

“the adoption of biomass as a dispatchable energy option for electricity generation in NSW will lower emissions increase energy security and promote socio-economic growth”

There is extensive evidence to show that burning native forests to create electricity emits more carbon per unit of electricity than burning coal when the carbon sequestration function of the living forest is taken into account.  The claim that native forest fuel is carbon neutral and “lower emissions” is completely false.  It is highly negligent to accept the faulty accounting methods used to make this assertion.  A simple look at the facts shows the consequences from this falsehood.

  • The carbon carrying capacity of the original forests is not considered and the time-frame involved in growing the trees back is not accounted for 
  • Climate emissions targets are delayed by the years it takes trees to regrow
  • Native plantation forest logging for renewable credits gives encouragement to the forestry industry to continue business as usual and claiming the same credits for clear-felling incredibly valuable old growth forests!  This is indefensible when protecting existing forests is undeniably the best method of carbon capture and storage.
  • Woody debris like branches and smaller logs are removed when they would otherwise have been left on the forest floor to continue to sequester carbon
  • The global bioenergy market has been used by the forest industry to replace wood-chip export markets and entrench native forest logging
  • Encouraging native forest logging seriously harms biodiversity and native species survival. This is starkly documented in the damning 2021 State of The Environment Report.
  • Burning native plantations for electricity displaces genuine clean energy solutions redirecting subsidies away from wind, solar and other genuine options
  • It enables unsustainable coal fired power stations to persevere with co-firing arrangements or by converting them from coal to a similarly unsustainable fuel.

That this report recommends subsidising this destructive practice through the NSW Climate Change Fund is totally unacceptable to us and to genuine environmental practices. Etc etc….

(In support of a sustainable “circular economy” the report talks about fostering a regional approach to the rollout of hydrogen refuelling and electric vehicle charging infrastructure that considers potential sites for charging stations, including council-owned land, and how these locations can be activated. We are gratified to hear of an actual, practical initiative toward the critically important target of net zero emissions by 2050) this bit can be put in the previous section

Agricultural land

The report tells us that the North Coast is facing increasing pressures from growth which has resulted in the permanent removal of land from agricultural production and rural land use conflict. This is glaringly visible in the case of the new Tweed hospital currently under construction on the agricultural “red gold” volcanic soil at Cudgen.   The public outcry ran to ten thousand people and the community is still reeling. The report tells us that for agriculture to continue to grow and diversify on the North Coast, it is essential that food and fibre production is protected and supported. It will need more than a report and wishful planning to prevent more acts like this and the continued erosion of food and fibre production in prime agricultural areas of the North Coast. 

It is good that the report plans to limit rural dwelling lot sizes to ensure capacity for sustainable productive agriculture.  Secondary dwellings on rural properties must also be limited in a way that avoided conflict and impact on local agricultural activities.

Importantly in the current environment of a climate crisis is the role agriculture plays in carbon sequestration and ecosystem services. This report recommends programs to reward farmers for including carbon capture and other ecosystem support in their land management. Tweed Landcare’s sustainable farming initiative is a fantastic example of volunteer efforts in this field.

Water management

The report makes very good recommendations for optimal water management through all stage of the planning process. It states the need to: Encourage a whole of catchment approach to land use and water management across the region that considers climate change, water security, sustainable demand and growth, the natural environment and investigate options for water management through innovation. The question arises as to why we haven’t been doing this already? Water – the most precious, limited commodity we have should always have been a prime consideration in any urban residential or other human development.


Of the recommendations for the Tweed we support the following – (with reservations):

•Balance growth in the new housing areas of Cobaki and Kings Forest in conjunction with the urban renewal of Tweed Heads, Kingscliff and Murwillumbah. (These developments were approved under old planning laws and are in many ways not compliant with current practice – particularly the ecological sustainability aims layer out this report.  All effort must be made to redress such problematic issues as these developments progress.)

•Continue to promote nature-based and ecotourism opportunities associated with the various national parks, the Northern Rivers Rail Trail and the coastline, and identify opportunities available with agritourism and the Brisbane 2032 Olympics. (It is absolutely critical that the rail-trail initiative to be developed on Crown Lands is kept in public ownership. There is too long a history of transgressions in the takeover of Crown Lands for private interests causing negative outcomes for the greater community and the natural environment)

Liveable and Resilient 

•Support Tweed Shire’s move toward net zero through low emissions development and transport solutions, and by embedding principles of the circular economy and maximising resource recovery. 

•Provide support to adapt to climate change, particularly in key risk areas such as water security, infrastructure resilience and coastal management to address storm surges and sea level rise. 

•Support environmentally sustainable development that is responsive to natural hazards. 

•Retain and protect local biodiversity through effective management of environmental assets and ecological communities.

(All of these aspirations are commendable – however strong planning instruments need to be created with the teeth required to effectively bring  real, genuine outcomes described here)

Productive and Connected 

•Foster the growth of knowledge-based and education industries within the Southern Cross University. 

•Capitalise on opportunities associated with the new Tweed Valley Hospital. 

•Deliver new employment and business park opportunities at Kingscliff, Pottsville, Tweed Heads south and South Murwillumbah, and encourage the development of airport related and tech business in the Cobaki release area. (The industrial centre on the coast at Pottsville has been contentious. A lot more work and community consultation is needed and must be a consideration in this planning report)

•Identify emerging trends affecting work in the Tweed and develop a robust, contemporary and enabling policy framework to foster employment growth. 

•Encourage employment and mixed use clustering.

Housing and Place 

•Enhance housing diversity by increasing housing density in the centres and encouraging a range of housing products. 

•Deliver housing across the LGA to meet impending growth out of South East Queensland. 

•Prioritise the delivery of affordable housing to support workers in key service industries.

( it is critical that these aims for housing also deliver on the aims for sustainability & ecosystem support that are so often referred to in this report)

Smart, Connected and Accessible (Infrastructure) 

•Foster stronger alignment and integration with the Southern Gateway Economic Cluster in South East Queensland and the Northern Rivers subregion. 

•Collaborate with South East Queensland on the Gold Coast Airport precinct masterplan. 

•Identify barriers to economic growth and essential infrastructure delivery between South East Queensland and Northern NSW.