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BREC Submission to BCC City Plan 1999

June 4th 1999

The BCC City Plan is one the first Town Plans under the Integrated Planning Act. The City Plan contains a number of good features to protect biodiversity, wetlands, waterways, air quality, water quality and promote energy conservation. With most of these things however the real test is in the details of what the plan has to say. While these comments focus largely on the negative aspects of some of this detail, we do recognise that there is a lot of progressive parts to this plan. The plans main handicap is the State Integrated Planning Act. Other BREC documents on the City Plan and IPA can be found at:
BREC Media Release on City Plan
Integrated Planning Act
IPA Desired Environmental Outcomes

General Comments

Most of the codes and assessment tables allow for adjacent uses to be "Code assessable" which is unacceptable.

Some adjacent uses in addition to the ones proposed in the Environmental Impact Assessment policy and the Industrial Amenity and Performance Code must be included. Urban or Rural subdivisions adjacent to wetlands can have severe adverse effects on them.

The City Plan is difficult to use and is in places circular in its references ie assessment tables point you to codes to determine the exact level of assessment required the codes then in turn tell you to refer back to the assessment tables for that information.

The Desired Environmental Outcomes's(DEO's) in Chapter Two contain some contradictory objectives with no guidance of how to resolve these contradictions.

The performance indicators are simplistic and wont reveal if the BCC is meetings its DEO's. We suggest that a list of already available indicators be compiled from existing corporate reporting, Environmental Management Information System and the State Of Environment resources. From this list a set of 30-40 key environment indicators could be compiled. Furthermore we suggest that these performance indicators are incorporated into the BCC corporate plan.

Environmental Protection Area: This is misnamed it should be called low density rural residential.

Chapter 2 The Vision

The Vision section should include

"Brisbane is a City which understands, avoids or minimises its total adverse environmental impacts on the city and surrounding region"


"2.2.1 Desired Environmental Outcome

Brisbane’s land use pattern and built environment promote its unique character and encourage a sustainable network of Residential Areas, Centres, employment and transport links." (BCC City Plan 1999 Chapter 2)

Add "Will minimise land take and cumlative environmental impacts."

"2.2.3 Citywide strategies to achieve the DEO

Supporting the preferred pattern of urban settlement established by the Regional Framework for Growth Management for South East Queensland

Through…" (BCC City Plan 1999 Chapter 2)

The RFGM process has not produced a sustainable pattern of urban settlement. The RFGM has failed to address cumlative environmental impacts or the control of rural residental urban spread. Slavish following of this plan can only lead to an unsustainable outcome.

ADD ensuring that the pattern of urban settlement established by the RFGM is ecologically sustainable and in the absence of scientific data on thresholds, applies the precautionary principle.

see also 800,000 more people in SEQ - BREC Report on New Population Planning Figures
BREC Submission to SEQ2001 Institutional Review

"• transport - planning for effective transport/land use interaction." (BCC City Plan 1999 Chapter 2)

The plan should talk about desirable transport/land use interactions not just effective ones. We should avoid new transport corridors in "undeveloped" areas to restrict "ribbon development". We should avoid approving or supporting settlements that require transport corridors to violate greenspace areas (eg Springfield, Mango Hill).

"• transport networks - the design and landscaping of major Movement Networks to minimise impacts on adjacent areas" (BCC City Plan 1999 Chapter 2)

add "or greenspace values" see also March 99 Newsletter Inner Northern Anti Freeway Coalition

"2.4.1 Desired Environmental Outcome

The City’s environmental quality and natural assets are protected so that they contribute effectively to ecological sustainability and biodiversity.

2.4.2 Performance indicators

Bushland and wetland protection

• Proportion of wetlands protected in accordance with the Wetland Code" (BCC City Plan 1999 Chapter 2)

All wetlands should be covered by the Wetlands Code see also general comments on performance indicators.


Waterways Code

The general exemption in section 1.0 of this code is unacceptable. The code should apply to all waterways corridors

Waterways corridors in general should not be disturbed. If some reason these was a community need to disturb a corridors the criteria in the Water Resources Act applying to Vegetation removal in watercourses should apply.

Extractives Code

We object to most development in these areas being "Code Assessable". Anything goes in an extractive zone ?

Industrial Amenity and Performance Code

Open space provisions should be as high as residential areas to promote safety and health.

We support the cumulative air pollution assessments in this code but they fail to refer to cumulative soil loading from deposition of air pollutants. It should also refer to the capacity of the receiving airshed to cope with additional pollutants.

The Stormwater Code is supported

Subdivision Code

All subdivsion,rural or urban, has negative impacts on the ecological sustainability of the city. The creation of 4ha allotments is of sufficient impact to warrant impact assessment.

Rural residential subdivisions where more than 100ha is to be subdivided should be impact assessable.

Structure Planning Code

Needs to have clearer guidelines regarding minimisation of cumulative negative impacts. We do not regard this code as having sufficient details are to void the need for further impact assessment.

We are not sure if the road networks envisaged in this code are either affordable or sustainable in the long term.

Parks Code

Subdivison within conservation areas should be impact assessable.

Wetland Code

"1.0 Application

This Code will be considered in assessing development on land in or adjoining Wetlands indicated on the Planning Scheme Maps.

P3 Development provides effectively for replacement, enhancement or rehabilitation of Wetlands cleared, destroyed or damaged as a result of the development

A3.1 Where part or a whole of a Wetland of low ecological value is to be cleared or destroyed for development: • provide for ecological enhancement of another Wetland site, where there is environmental benefit such as:

- a greater area of Wetland in the same catchment or sub-catchment will be established, rehabilitated or enhanced to compensate for any Wetland loss

- Wetland functions can be transferred.

For example sediment and nutrient filtration functions, flood mitigation functions - there is ecological gain


• establish a new Wetland of increased function value

A3.2 Deposit a performance bond to ensure that Wetland environments are protected and rehabilitated in accordance with the approved rehabilitation strategy

A3.3 The proposal must not disturb any vegetation" (BCC City Plan 1999 Chapter 5)

These provisions envisage the continued destruction natural wetlands, which BREC does not support. A sediment basin and concrete water channels for flood control can only replace a very small part of a wetlands ecological function.

The code only applies to mapped wetlands even though its talks about the importance of billabongs, which are largely unmapped.

Strategic Natural Heritage Sites

Highest priorities for protection, should be chosen on the impending threats to those areas and their significance to Brisbane. The first five sites are seen as priorities. Other areas are also immediately threatened. Moreton Island is a case of simple area designation change to ensure it’s given the status we all attribute to it - Conservation!

  1. Parkinson/Larapinta/Heathwood: Brisbane South's main green/biodiversity artery. Needs consolidating into one core area under Conservation Area status. see also Save the Brisbane's Gilder Forest at Parkinson
  2. Bulimba Creek Corridor: Brisbane’s most viable creek corridor linkage to the river. Needs a review so environmentally constrained sites are designated appropriately.
  3. Kuraby Bushlands: Acquiring strategic lands will ensure linkage of those above. se also Latest Version Kuraby Ecological Protection Report
  4. Boondall (West): Under review. Should Conservation and incorporated into Boondall Wetlands Park.
  5. Wakerley/Ransom: Wetlands and bushlands. Ramsar sites, high ecological values. Emerging Community lands inappropriate usage. Should be Environmental Protection Area and Conservation.

The following are not ranked in any order:

  1. Moreton Island: A National Park and must be Conservation Area.
  2. Deagon Wetlands and corridors: Threats: Sport & Recreation and Rural Res.
  3. Lota Creek Catchment Linkage: A viable link between Tingalpa and Bulimba creeks. Links Bayside Parklands to main greenspace inland. Bayside-Tingalpa Reservoir: EP is not enough protection. Suggestion: Conservation or Parkland (with added DOEs) over "Natural Area Corridors" within the Environmental Protection Area lands. Land for Wildlife and VCA’s would also assist. High biodiversity values should be recognised.
  4. Mt Gravatt/Toohey Forest: Management Plan not reflected in draft. Heritage is taken off and Parkland area is on Mt Gravatt. Must be Conservation, on Natural Heritage register/map. Toohey Forest needs better environmental protection with a property management plan for Griffith University that can be reflected in City Plan.
  5. Enoggera Military Camp: Bushlands need a special upgraded area designation to Conservation.
  6. Tingalpa Wetlands & Creek Corridor linkages: The use of Conservation for actual wetlands and viable buffers; Environmental Protection Area for private lands abutting these areas.
  7. Mt Elphinstone: Ridges should be at least Environmental Protection Area. High landscape/cultural significance
  8. Moggill-Anstead: Wider Environmental Protection Area to buffer Emerging Communities land from bushlands abutting the Brisbane River.
  9. Wacol: Development threats to significant populations of Macropods. Institutional developments and State land disposal is in contravention of Local Area Plan.
  10. Lake Manchester: Interim protection for land transferred from Ipswich to protect Brisbane’s Water resources and the significant conservation values. This would be pending incorporation in a future City Plan revision.
  11. Mt Cootha: Natural Heritage Map revision to cover all of the area.
  12. Pinjarra Hills: Waterway should be adequately buffered. Parkland Area (with DOE’s added to this area status to make it affective for protecting riverfrontage)
  13. Airport Precinct & associated wetlands: No environmental assessment on precinct. Mangroves and four other regionally significant ecosystems under threat. Upgrade in Area status and on Waterways mapping. (Conservation/parkland). see also Jul 98 Submission to Draft Airport Master Plan
  14. Boggy Creek Corridor: Threats to mangroves and riparian zone and impinging on flood regulation line. Draft: Future Industry & Parkland. Should be Conservation. see also Pinkenba Ecological Protection Report -Boggy Ck to Kedron Brook Habitat Corridor
  15. Bay Islands: e.g. Green, St Helena and Mud Islands. Should go to Conservation.
  16. Salvin Creek Corridor linkage: Lands in Emerging Communities in Draft CP, are designated "Natural Area Corridors" in District Open Space Study. Also refer Ch 4: local plans 1.0 and 4.0. This is a water corridor link from major bushland node to major creek corridor. Emerging Community in Draft. Should be Conservation or Parkland and protected by a strengthened Waterways Code.
  17. Gateway Ports: Draft City Plan has missed saltmarsh communities, a protected marine plant (should be flagged under Wetlands code). Areas threatened: Bulwar Island, Myrtletown and parts of Pinkenbar. Should be on Wetlands Map. There needs to be an effective network of conservation reserves through out this area both south and north of the river. see also Gateway Ports Plan - Gateway to disaster
  18. Karawatha to Greenbank Corridor: Secure Karawatha/Greenbank corridor and add to Parkinson core area. Draft: Low Density Residential & Emerging Community. Corridor should be in Conservation.
  19. Karawatha: Low density residential area. Should be Conservation.
  20. Cedar Creek: Ridges and waterways under threat. Draft: Emerging Community. Should be Environmental Protection Area.
  21. Lota Bushland & tributary: Area of significance and corridor linkage. Waterway corridor should be given upgraded Area status. Council llands in this area should be put into the Conservation Area.


  • Enogerra Bushlands
  • Heathwood/Larapinta/Parkinson Bushlands
  • Mt Gravatt
  • "All" of Mount Cootha


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