Dear Editor,
In the January 18 edition of The Beagle, Reading between the lines reveals little substance you commented on Cate Faehrmann’s report “Concreting Our Coast: The developer onslaught destroying our coastal villages and environment”, which puts forward a set of principles to prevent inappropriate coastal development.
Your comments on the recommendations are mostly negative and, in some instances, disappointingly ill-informed. As locals concerned about coastal development in general and the development in Tuross Head next to Coila Lake foreshore in particular, we would very much appreciate the opportunity to have our response to your comments published.
First, you draw attention to the housing shortage in Eurobodalla Shire Council and criticise the Report for not offering guidance on this (saying "What the media release doesn't tell us is where the wave of new residents to the South East will live".)
Clearly, that is not the purpose of the Report and is not within its scope. We agree that we need more housing, particularly affordable housing. But that does not mean that releasing 72 housing blocks, some on floodprone, boggy land near Coila Lake, bordering Endangered Ecological Communities (EECs) is a good way of addressing the issue - particularly as these blocks are being advertised as prestige blocks and are likely to cost well over $400,000 each.
Regarding the developments at Tuross Head and Dalmeny, you state that “appropriate studies have been, or will be, carried out to constrain any activity within protected areas.” This is not the case.
(actually I responded to the proposed Framework Principles to Save our Coast that offers:
1. PROTECT COASTAL ENVIRONMENTS By prohibiting roads and developments that impact ecologically sensitive environments including Threatened Species Habitat and Endangered Ecological Communities and adding ecologically sensitive land to the protected area network] by saying:
"For Tuross Head and Dalmeny: Appropriate studies have been, or will be, carried out to constrain any activity within protected areas. Eurobodalla employs a system of Biodiversity offsets that allow for development in one area whilst committing to an equal area of protection.” )
The ‘zombie’ development at Coila was approved in 1984, when no Environmental Impact Statement (EIS) was required. The current developer is not required under law by either Council or the NSW government to carry out any such assessment.
Further, with no requirement for an EIS, the Council and developer have no idea what
species, endangered or otherwise currently call this place home and are likely to be displaced once bulldozers and trucks begin work.
Friends of Coila have observed and recorded birds using this land over a number of years. There is one critically endangered species – the Far Eastern Curlew. This bird is at an extremely high risk of extinction in the wild. There are at least 9 endangered or vulnerable bird species meaning they’re in danger of extinction or likely to become endangered in the foreseeable future.
You also mention Council’s ‘offset’ system which ‘allows for development in one area whilst
committing to an equal area of protection.’ We would like to know what you, or the Council
staff member who informed you of this, means by ‘equal’?
The land to be subdivided near Coila Wetlands contains Endangered Ecological Communities (EECs). EEC’s can be defined as groups of vegetation which are becoming scarce and threatened with extinction.
We’d also like to know how the various plant and animal species threatened by a development in or near an EEC will be transferred to their new homes in this ‘equal’ area?
Proponents of this ‘system’ demonstrate a complete lack of understanding of the complexity
and fragility of EEC’s. A recent government report concerning biodiversity offsets
established that they are ineffectual in practice. The Sydney Morning Herald’s Laura Chung
had a piece published on this on 24 November 2022 entitled, ‘Fundamentally broken’:
Biodiversity offset scheme needs overhaul, government report finds.
Regarding climate change, you say that "Council considers this already". Unfortunately,
Council is using outdated information and fails to consider the State of the Climate report by
the CSIRO and Bureau of Meteorology (http://www.bom.gov.au/state-of-the-climate/), which
for south east NSW predicts more drastic increases in extreme rainfall events, flash flooding, bushfires and extreme sea level events.
On the issue of providing adequate infrastructure and services, you respond to the Framework 3. ENSURE INFRASTRUCTURE AND SERVICES ARE IN PLACE The Government must place requirements for adequate infrastructure and services before new housing developments can be built saying that "Council has this in hand". We beg to differ.
Where are the safe emergency centres for residents in the event of adverse weather events, such as floods and bushfires? Those of us who were in Tuross during the 2019-2020 bushfires appreciated the efforts made by management and staff at the Tuross Head Country Club to look after those who evacuated our homes. But what plans does Council have for providing safe community spaces catering to an increasing population as we experience more frequent and severe floods and bushfires?
Cate Faehrmann’s report recommends developers be obliged to use independent ecological assessors.
(ED NOTE: The report clearly states 4. MAKE ECOLOGICAL ASSESSMENTS TRANSPARENT AND INDEPENDENT By making developers use independent ecological assessors provided by the department instead of being able to shop around for experts that enable development).
Your comment on this is that the result may be challenges from assessors who are left off the list of approved independent assessors saying "By enforcing independent ecological assessors provided by the department the challenge will be that those not recommended by "the department" can challenge why they are not listed and why they are denied due regard. Let's see how this one plays out".
Is that a good enough reason for leaving environmental matters in the hands of the developers? As you comment elsewhere, developers have considerable ‘skin in the game’ and are unlikely to seek assessors who produce reports which limit development.
You also considered where future developments should occur, suggesting urban infill and
building higher as the alternative to development in Eurobodalla. The Gold Coast is an
extreme example of this. We’d rather not see Tuross Head or other parts of Eurobodalla using urban infill, but would like Council to consider purchasing already cleared land for urban expansion and adopting affordable housing rather than facilitating wealthy developers to subdivide and build for those wealthy enough to purchase homes by Coila Lake.
Our coastline is under threat from several so-called zombie developments like the one at
Coila.
(ED NOTE: The “Concreting Our Coast: The developer onslaught destroying our coastal villages and environment” report recommends 8. END ZOMBIE DEVELOPMENT APPROVALS By forcing existing Development Approvals over 5 years old to be reassessed through the planning system with inappropriate approvals forced to redesign, take a land swap or receive compensation where appropriate).
You comment that this will result in extensive and exceedingly expensive litigation. This may well be true. But we would like to know what dollar value you would place on our coastal communities, on the precious, fragile ecosystems around us, on the fauna and flora that live alongside us and rely on our protection and finally, on the tourists who visit precisely to spend time experiencing all this?
Yours sincerely,
Friends of Coila
