The opportunity to ‘Have Your Say’ on the Tweed Development Control Plan closes 5pm Friday!
We’ve attached the CEC submission document for your interest, and for copy and pasting all or parts of as your own submission which is allowed and we encourage.
Please do make a submission, it is quick and easy on the Council website (link here: www.yoursay), or forward the attached CEC submission expressing your own support for it (email to tsc@tweed.nsw.gov.au).
To the General Manager Tweed Shire Council,
Submission on the Draft Tweed Development Control Plan 2026.
Tweed Council is commended for the many proposed improvements to the Tweed Development Control Plan.
Please find below some further requests for inclusion in the Plan.
Part A Aims
The aims of the DCP should require higher standards of environmental protection and restoration due to Tweed’s internationally significant environment, scenic landscape, huge numbers of threatened species, and many irreplaceable endemic species.
The Cool Towns program for urban revegetation should also be included in the aims here as opportunities for this can occur across many areas of development.
Part B2 Preservation of Trees and Vegetation
Tree removal permit criteria
The draft tree removal permit process expands ‘eligibility’ for protection to:
a) Native trees: taller than 3 metres – (currently they must be at least 5m).
A new size criteria has been added for a 10cm diameter at standard 1.4m height, (which equates to an average age of 25 according to the TLC Tree Age Calculator).
b) Non native trees: greater than 40cm diameter which equates to an average age of 100, (currently they must be 80cm diameter which equates to an average age of 200 according to the TLC Tree Age Calculator).
I strongly support Council expanding consideration for protection to smaller native and non native urban trees but I believe these changes are still not sufficient to achieve our targets and that any native tree over 10 years old should be protected.
Tweed Shire is falling well short of reaching our urban tree canopy target of 35% by 2030, as recently reported in Council’s December meeting.
The 2023 tree audit showed a 28.8% urban canopy cover – only a 2% increase from 2014.
This clearly demonstrates that far greater efforts and more comprehensive planning controls are critical.
This is the key document to achieve these canopy targets. Ambition is required as these plans rarely get reviewed so need to be relevant into the future.
NSW Department Planning, Industry & Environment suggests tree protection for a large range of impacts on local ecosystem services including urban heat, pollination of plants, pest control, impacts to water, soil erosion, buffer to floods. habitat, food sources or corridors for all native fauna, etc, etc. https://www.environment.nsw.gov.au/sites/default/files/2024-02/managing-vegetation-with-a-development-control-plan-190623.pdf#page9
Such protection should also be provided for Tweed’s internationally significant environment.
The community also plays a role in implementing the permit system as they are often the ones to report unauthorised tree clearing. This can be a difficult duty due to neighbour relations and lack of transparency on whether a permit has been issued. A notice displayed on a front fence, eg two weeks before tree removal, could alleviate much anxiety around these sensitive issues and encourage reporting of unauthorised clearing.
Schedule 2 Vegetation Retention Value table B2.4
Unfortunately the Vegetation Retention Value table used to assess the tree removal permits has such exceptional criteria for a tree to qualify as of ‘high value’ that there is little protection available. An average, decent sized, even native, tree will not be saved unless there is something very special about it.
There should be greater protections for natives than non natives, but there is little difference in the Values table unless it’s a threatened species or otherwise special.
To meet the ‘high value’ size criteria of a 200sqm canopy it would take a slow growing tree decades, and about 300 years to meet the 80cm diameter criteria according to the TLC Tree Age Calculator.
The age of the tree should be a criteria in the values table eg Manly Council. 10 years would be considered a significant investment in most circles so a high value should be applied to trees of such an age in my opinion. 10 years is a whole childhood from toddler to teen; that’s a long time to be without a decent sized tree.
The table does not advise what the outcome will be for a moderate or low value tree but presumably they are removable. The draft compensatory planting guide is an improvement to offset this but still far less than a tree’s actual ecosystem value, and it takes many, many years to see the benefits.
The whole Values table should be reviewed to better align with the aims and targets of the Cool Towns program to expand canopy cover rather than still allowing so many trees to be removed.
Part C Subdivision and Infrastructure
2.3.1 Ecological Significance
This section could be strengthened, particularly for multi lot subdivisions, to give consideration to restoring original ecosystems of the area, to the extent possible, ie not just avoiding further impacts to what is often largely cleared areas.
2.6 Site Design: Landscaping
New subdivisions and infrastructure are fundamental to achieving the Cool Towns canopy cover targets. Council is to be commended for including targets in this section, but these targets should be demonstrated by the developer to achieve the Cool Towns targets at a minimum over the whole subdivision.
A higher proportion of the target should be expected to be achieved at these new sites than the Cool Towns targets, in recognition that it may be harder to achieve tree coverage in established urban areas.
This could be most easily achieved with even higher density planting on public land, eg parks and road reserves. Council could consider allowing more than the current one tree per 20m on a nature strip, widening nature strips to accommodate more trees and understorey, and insisting on urban forest style planting in more available spaces. Significant large trees such as Fig trees should also be planned for.
2.3.9 Stormwater
Stormwater systems should be designed to collect all litter from the drainage channels and be easily cleaned and maintained.
Part D Built Form
All sections in this part should include a requirement to achieve the CoolTowns canopy targets.
Part E4 Access and Parking
Shade awnings should be provided for car parking in large shopping malls.
Tree lined streets for shady parking and to cool pedestrian areas should be prioritised in CBDs and employment zones rather than prioritising shop front exposure.
Thank you for your consideration,
Name:
Address:
Date: 20.1.26
