The Director General
NSW Government
Crown Lands Division
GPO Box 15
Sydney NSW 2001
Tweed Coast Holiday Parks Reserve Trust (TCHPRT) and Land and Property Management Authority (LPMA
Bogangar, Cabarita South Precinct Plan
Introduction/Summary
The Tweed Coast has been under constant threat of wave and wind erosion for millennia, but the rate of sea level rise and extreme storm events seem to have increased exponentially in recent times, due to increased atmospheric pollution. The current erosion situation at Kingscliff should give the Council pause to reflect on the wisdom of building on coastal foreshore dunes.
The Tweed Coast has also been under constant attack/exploitation from the 1950’s to the naughties and today. Drainage of wetlands, clearing, poisoning, mowing and frequent burning of heaths and bushland, the removal of littoral rainforests for beach sand mining, unrelenting urbanisation, the dumping of rubbish etc., the list goes on. There comes a time when ENOUGH IS ENOUGH; a time to conserve the few remaining stands of natural vegetation.
The natural environment on either side of the coast road south of Bogangar is still one of significant conservation value. In particular the locale around the site of Bogangar Primary School is significant in many ways. In the context of an eroding coastline and an uncertain and accelerating future, the prudent and precautionary – indeed wise – strategy would demand the permanent conservation of the subject Crown Lands for obvious environmental reasons. Predicted rates of erosion may well be exceeded, as is already happening at Kingscliff, costing local and state government’s lots of money. Natural coastal heath and bushland is a fast disappearing asset which is necessary for North-South, East-West, and upland/coastal migration of bird and bat species (especially).
The wisest and most responsible use of these scarce coastal land resources is to maximise their integrity and assist the natural regenerative processes through conservation, consolidation and rehabilitation.
Rather than developing this Crown Land (i.e. the public’s), it should be permanently conserved for habitat, recreational and educational purposes. The existing and future residents of Bogangar and especially the neighbouring school population will need these resources in the future even more than we need them today.
Poor land use decisions at Jack Evans Boat Harbour and at Boyd’s Bay concerning the closure of camping facilities, the trend at Fingal and Kingscliff towards semi-permanent cabins, the aggressive beach erosion at Kingscliff, the decision to opt for resort style accommodation at South Kingscliff rather than camping facilities, have all combined to produce a dramatic decline of camping facilities in the northern part of the shire. The net effect seems to be an unreasonable demand to appropriate and privatise unsuitable, vulnerable and regenerating foreshore dune land at South Bogangar to help maintain the provision of camping grounds due to the closures in the north.
Ecological Considerations
Proposed caravan park site – 8.4ha
The two small populations of the Endangered Ecological Community (EEC) Coastal Cypress Pine in the NSW North Coast Bioregion are of particular significance. The EEC is poorly represented in Tweed Shire with only small fragmented populations remaining. The entire population occurring on the site is to be removed.
Sections of the site, particularly in the north, which are currently dominated by Coastal Banksia, Banksia integrifolia with an emerging understorey of rainforest species in time will progress to littoral rainforest. Littoral rainforest in the NSW North Coast and Sydney Basin and South East Corner Bioregion is a state and federal listed EEC. The proposal will remove 80% of this vegetation community.
The endangered Pink Nodding Orchid, Geodorum densiflorum has been recorded at several locations within the site. Seedlings of the nationally and state listed vulnerable Stinking Cryptocarya, Cryptocarya foetida have been recorded in the north of the site. These species were not recorded in the preliminary environmental assessment (Boyd’s Bay Environmental Services 2011).
The site is dominated by Coast Banksia which is an important food tree for over wintering birds and bats. The large number of mature and flowering trees on the site would provide for numerous species of fauna including Threatened Species such as Grey-headed Flying Fox and Common Blossom Bat. The use of Coast Banksia in nearby locations such as Koala Beach, Salt and Casuarina has been monitored on an annual basis and recorded the use of the trees by these threatened species.
The removal of Coast Banksia at development sites has required compensation packages including large scale plantings and restoration of on site or nearby locations. The significance of Coast Banksia has not been recognised in the preliminary environmental assessment (Boyd’s Bay Environmental Services 2011). The report dismisses the habitat as providing “minor ranging and feeding opportunities”. In addition the report states that this vegetation type is well represented in Cudgen Nature Reserve and Hastings Point environmental parks. Extensive stands of Banksia woodland are limited in Cudgen Nature Reserve (approximately 7ha) and in the Hastings Point area.
The proposed site is located in an important coastal corridor as identified in DECCW and NRCMA Climate Change Corridors mapping. The corridor provides a north south linkage for the movement of flora and fauna. The 2011 report recognises that the proposal will impact on connectivity.
The proposed caravan park is a gross overdevelopment of a significant coastal environment. The footprint of the park covers 90 percent of the site and does not include Asset Protection Zones (APZs) for protection against wildfire. APZs of up to 50m in width on the north, east and west of the site would be a requirement of consent. This would require additional removal of vegetation on adjacent Crown Land if the current proposal was approved.
The issues of coastal erosion and climate change have not been fully taken into account. Transportable buildings are not the answer to threat from coastal erosion and rising sea levels. Currently large amounts of resources are being poured into Kingscliff Caravan Park where coastal erosion has exceeded the 2050 predicted erosion line.
Proposed residential – 5.1ha
The majority of the vegetation on the site is coastal heath land (3.2ha) with a stand of coastal woodland dominated by Pink Bloodwood in the north east (0.4ha) and a stand of open forest dominated by Broad-leaved Paperbark (0.3ha) in the south west. The vegetation communities are classified as high/very high conservation significance in the Tweed Vegetation Management Strategy (2007). The open forest dominated by Broad-leaved Paperbark could potentially be classified as the EEC Swamp Sclerophyll Forest on Coastal Floodplains of the NSW North Coast, Sydney Basin and South East Corner Bioregions.
The coastal woodlands and open forest are considered inadequately reserved in the Tweed (TVMP 2007). Although coastal heath land is considered adequately reserved regionally there are only small fragments remaining on the Tweed Coast in close proximity to the coast at Pottsville, Fingal and the proposed development site. The heath land is floristically highly diverse. The preliminary assessment (Planit 2010) relies on CRA (2002) and TVMP (2004) recommendations for conservation status.
The vegetation particularly the heath land provides habitat for a range of insectivorous birds and bats.
The site is within the coastal corridor as identified in DECCW and NRCMA Climate Change Corridor’s mapping and provides part of the link from the coast to Cudgen Nature Reserve to the west.
The documentation does not show the boundaries of the proposed residential development and required APZ’s on the north and south of the site. Vegetation to be retained is more likely to be the coastal woodland in the north, with the development concentrated in the south and central locations.
Planit (2010) suggests that compensatory rehabilitation be undertaken on the site and environmental offsets be considered on adjacent or nearby Crown Land. Comparable coastal heath land is difficult to establish without substantial expertise and commitment as was evidenced with the translocation of soil and propagules from the heath community which existed on the adjacent school site prior to clearing.
Time has come – indeed is well past – when we must stop the mining of coastal sand dunes for inappropriate development. A consistent effort should be made now, and continued indefinitely into the future, to bolster and rehabilitate these sites, to provide better protection, better habitat and better visual landscape amenity along our valuable and eroding coastline.
The erosion, urbanisation and sand mining of the past 50 years need to be balanced with the conservation and rehabilitation of coastal Crown Lands. This is our destiny as responsible stewards for future generations.
Conclusions:
To keep on exploiting finite natural resources especially when those resources represent profound protection against coastal erosion and which provide valuable habitat and visual landscape amenity along a coastline which has been, is being, transformed into a fragile urban interface with the South Pacific Ocean, is a foolish, irresponsible and unsustainable strategy. The Department responsible for Crown Land and Tweed Shire need to find less sensitive land which may be suitable for exploitation.
Yours sincerely,
Mr. P. (Hop.e) Hopkins
Coordinator
Caldera Environment Centre
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To go to the Cabarita Beach/Bogangar Residents Association website, click this link:
http://www.cabaritabeach.org
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