Concerns with Brisbane 1997 Town Plan Amendments and New Strategic Plan


Town Clerk
Brisbane City Council
26 July 1997
Dear sir,
While we support the thrust of the strategic plan to preserve, enhance and protect the ecological systems of the city we have a number of overall concerns, these being:

We also believe a number of amendments to the town plan pose a threat to the protection of the cities ecological values and life systems, these being:

More details of our concerns with the new Strategic Plan:

2.1 IGAE Absent also missed environment in Paragraph 1

2.2 Principles of ESD not implemented in policy framework

2.3 We do not think that greenfield developments are to be encouraged. Dr Catteralls report clearly indicated this as the number one cause of bushland loss in SEQ. The definition of Green Space/Open space contains uses not compatible with maintenance of ecological integrity, it implies open ended human use. We need a higher level of protection. This definition of greenspace ignores the aforementioned paragraphs that stress the importance of life support systems. This is not empty rhetoric, we rely on these systems for the air we breathe and water we drink and the food we eat. If they are compromised these things may become difficult.

Paragraph 4 Ignores ecological processes such as the Air shed, water and materials cycling.
Paragraph 6 Transport Orientated development around public transport is to be encouraged where that does not compromise life support systems. Some rail corridors are in core habitat areas and should be exempt from TODs.
Paragraph 7 No Doh !!! Arterial roads are eating into and bi-secting core habitat areas, to then encourage industry along these roads adds insult to injury. We want to decrease the reliance of an ever-growing road network.

2.4 We don't understand what is meant by “mixed communities” Perhaps you could modify the last dot point to read

3.2 the need to protect the resistance resilience and robustness of ecosystems and ecological processes are absent Perhaps the council should add to this list “Ecologically Viable”.

3.2.1 Processes absent. Intergenerational equity absent ie conservation of natural resources.

3.2.1.1 add d) modification of existing transport infrastructure to minimise its adverse environmental impacts.

3.2.1.2 add f) enhance and maintain the city's groundwater resources for both people and nature.

3.2.1.4 ensure the efficient use of renewable resources while seeking to minimise the consumption of non-renewable resources through programs and policies ; add d) retrofitting and redesign of existing infrastructure.

3.2.1.5 add e) protection of areas of soils formation.

3.2.1.6 add to a) and investigation of containment options. The reliance solely on buffers means that hazardous industries will always be in or near green space areas.
Add d) waste minimisation initiatives.

3.2.1.7 modify to “securing, maintaining and enhancing the city's biodiversity through:” a) modify to “identifying, assessing and protecting the City’s significant natural and semi-natural environments and ecological processes.
b) modify “ensuring no development occurs in areas of critical habitat values.”
c) we have concerns about the ecological impacts of the current burning regimes.

3.2.4.4 b) & c) These principles, if applied in major natural areas could wreak havoc with their ecological integrity. We have seen important habitat trees destroyed in the name of public safety, in Toohey forest. Nature is not safe nor should it be. The current bushfire regimes may be causing unacceptable floristic shifts and damage to wildlife.

3.2.5 add...... and the integrity and health of ecological systems.

3.2.5.2 What is sustainable growth can it be achieved and is it desirable ? a) subject to risk assessment, environmental impacts assessment and monitoring. An industry code developed in accord with EPA and approved by the minister will provide clear guidleines and some legal protection for operators.

3.2.5.3 (b) Assess and map geological reserves of major importance There is such a need as to preserve forever examples of significant geological resources and structures. There is also a need to preserve intergenerational equity as well as intragenerational equity.

3.3.1 We need a moratorium on development at Parkinson and Willawong while the area is under investigation. This area contains discrete wetlands and some extremely significant old growth value forest featuring squirrel gliders and greater gliders. It forms an extremely important landbridge connecting Karawatha-Drewvale, Oxley wedge-Greenbank Army Training Area(National Estate). Flinders Peak(National Estate). This complex of ecosystems is one the most important large remnants in South East Queensland and constitutes core habitat.
Life systems : Water cycle, nutrient and materials cycling, atmospheric cycles, soil formation, habitat protection and protection of catchments for the integrity of the water cycle are important too.

3.3.1.2 a) This definition of green space confuses and mixes a number of uses which are incompatible with ecological integrity and health. Recreation is a landuse distinct from natural systems. While recreation can clearly be seen as open space it is not always “green” this section should be split into two a) conservation b) recreation see Town Plan 11.4.1 “Lands included in the (conservation) zone are principally ecological in character, having inherent or potential natural values, human activities being secondary to these values” Recreational and other similar open space should be common lands and not be subjected to land uses that seek to restrict wider public access( enclosure of the commons). Why are 5 values converted to three areas for planning purposes. No map of green space values or biodiversity is provided.
c) Corridor Values
Green space corridors suffer the same deficiencies as the green space areas. We need a seperate and protected ecological corridors system distinct from open space and recreation areas. This system may be accessible in some places and at some times to the public but most of it would not have such access. Work by Dr Caterall indicates the need for breeding areas to be undisturbed. Ecospace consists of ecological areas of core habitat, significant remnants and refugia and rehabilitation areas , which are, where possible linked by ecological corridors of various scales. Minimum Notional Widths of 100m Local(50.) 300m Inter suburb(125), >500m subregional(175), >2000m Regional(350) This width may vary upwards with respect to the overall length of the corridor.
While connectivity of core habitats areas is vital , small unconnected remnants are important as refugia and genetic reservoirs even if they are degraded.

3.3.1.1 Habitat Values The 2nd Paragraph fails to identify all the significant habitat areas as identified on page 38 fig 7.2 Brisbane SOE 1996. These areas must be identified in the text of the strategic plan. add also:
Seasonal habitats including migratory habitats;
Connectivity value either to other remnants within city and to adjoining core habitat areas outside the city;
areas of either high species diversity, genera diversity or habitat diversity;
areas of floristic diversity;
areas of regional significance, endangered threatened or vulnerable at a regional level;
Catchment Values: including ares for maintenance of water quality and environmental flows.
The council needs a policy document to support the green space definitions and intents.

3.3.1.4 Conversion of Future Urban must be subject to a rezoning process and have appropriate triggers for EIA. Add EIA to Paragraph 2 page 24.

3.3.3.2 a) & b) Some of this area is not suitable for industrial development because of potential damage to the river and Moreton bay. It will be at risk from flood events which may compromise their containment systems and release serious pollutants into the river and Moreton bay.

e)Heathwood: The southern edge of this area is highly significant ecologically and should be excluded from being a major industrial area.

3.3.6.2 Last paragraph. A complete list of areas of environmental value should be included here.

3.3.6.2 Road Hierarchy: While other parts of the plan talk about decreasing reliance on the use of roads and private vehicles, this section enshrines the construction and planning of a network of arterial roads. Because of the noise impacts of these roads they often go through and compromise large remnant bush land areas (I guess the trees don’t vote). To really undo the gordian knot of our transport system, we need to challenge this traditional road hierarchy not enshrine it.

Local area outline plans: We support the concept of and the need for outline plans in fast developing areas. However the first round of LAOP’s happened too quickly, with little supporting background information and yielded some unacceptable environmental outcomes. The decision to locate a District Sporting Facility within Karawatha forest is one example. These studies and future ones need better consultation, background studies and more thought. The Gateway LAOP, in particular, should have broad and meaningful public consultation with surrounding suburbs and stakeholders.

This is not the full extent of our concerns with the strategic plan and we look to forward to an opportunity to discuss our concerns in more detail. Yours Sincerely Michael Petter Convenor Brisbane Region Environment Centre


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