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.
"• 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.
BREC COMMENTS ON CHAPTER 5
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
OR
• 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!
The following are not ranked in any order:
NATURAL HERITAGE NOMINATIONS: