BRISBANE REGION ENVIRONMENT COUNCIL



Submission to Logan City Greening Plan


This plan should be corrected prior to implementation in order to effectively protect remnant bushland habitat and stand up to the rigours of Planning and Environment Court and critical professional peer review with constructive and pro-active input.


Comments on Recommendations


Vision and goals donít explicitly refer to ESD

3.3.1.2 Doesn't mention links to development assessment systems.

Doesnít make explict what ecological values are to protected and enhanced.

5.1.1.2 Agreed

5.1.1.6 Agreed

51.2.3 Completely stop Department of Transport pushing ruddy great transport corridors through remnant bushlands.

5.1.2.4 Would support delegation trial

6.1.1.1 No mention of regional endangered, vulnerable, threatened ecosystems. With your maps obviously deficient there are data gaps for all vegetation not just "non woody stemmed flora".

6.1.3.2 LCC should firmly commit to produce an SOE in 1999 not look into it.

6.2.1.3. Professor Mike Liddle a world leader in the impacts of recreation in natural areas has concluded "that mountain biking is incompatible with nature conservation". Mountain bike and other high impact activity should b excluded from core or critical areas.

6.3.1.1 The planning scheme should also reflect environmental outcomes as per Environmental Protection Act, Nature Conservation Act and the Inter-Governmental Agreement on the Environment, not place all faith on the Integrated Planning Act !!!!

6.3.1.4. Point 4 - absolutely no subdivision in Rural Conservation Zone.

6.3.1.6 In general agree

6.3.1.9 This strategy is always fraught with complexities and should indicate that this option is availble but NOT give an "as of right" entitlement automatically. Unless the land earmarked is secured for conservation such swaps don't offer long term protection. The land must be protected by caveat on title in Conservation Zone and/or ceded to public or trustee ownership. Until the proper legislative framework is in place the development density bonus ar just a way to shoe horn higher density developments into "protected areas".

Public recreation zoning is never appropriate for remant bushlands. 75% of bushland in SEQ has been cleared. Remnant bushlands are not big treed parks. Nature conservation is an objective of public benefit in its own right !!!!!!

6.3.2.1. This section enshrines marginal practice rather than best practice by aiming for "minimum standards of environmental assessment.". This is an inappropriate response.

6.3.2.5. Proposed Local Law No. 8

To comprehensively assess remnant vegetation, a field officer needs skills in ecology, geomorphology, pedology and impact assessment in addition to botanical skills. To suggest that an aborist and botanist could to do the whole job is ludicrous.

6.4.1.2. Agreed

6.4.1.3. Agreed

6.4.1.4 Council can designate its own lands as "areas of interest" under NCA.

6.4.1.6 LCC should have as a target to sign at least 10 VCA in Logan every year of the plan.

 

General Comments on Logan City Greening Plan


 

This plan should be corrected prior to implementation in order to effectively protect remnant bushland habitat and stand up to the rigours of Planning and Environment Court and critical professional peer review with constructive and pro-active input.

This process should include community participation of technical advisory groups and reference groups, having active input into planning, implementation and review of management plans and be completely independent of council and development aspirations.

The reports failed to fulfil the aims and objectives of the brief and stated aims to provide biodiversity mapping and biodiversity imperatives. This is due to startling omissions and inadequate mapping scales such as all riparian ecosystems (rivers, creeks and their tributaries), and their vital ecological functions of habitat provision and refugia for diverse flora and fauna, and essential vegetated linkages to, either core or remnant, forest habitats.

By adopting the present course, it is difficult for council to implement policies or effectively manage programs and will lead to further clearing and fragmentation of remnant bushland for development. The mapping scale of remnant vegetation 1:100 000 is totally inadequate given that substantial portions of Logan City are highly urbanised with residential development, roads, shopping complexes, assorted business and industrial estates.

Consequently, there was no impact of remnant vegetation loss on fauna diversity, or structural indicators such as old growth values, health and condition of forest in terms of distinctive strata or fire regimes, or whether forests have a diverse or simple understorey.

There were no maps indicating topography (contour, slope, aspect), which would have clearly shown catchment boundaries for creeks and watercourses and extent of vegetation, perennial water bodies of ecological significance, or the influence of soils and geology on vegetation. The use of aerial photographs clearly indicates all waterways are functioning as important ecological corridors.

This often results in narrow riparian and remnant bushland linkages acting as a conduit and habitat refuge for a diverse range of fauna including birds, arboreal mammals and ground mammals, reptiles and amphibians, insects.

Failure to indicate and acknowledge these features ensures dubious protection of ridgelines, escarpments and creek catchments leading to continual clearing that has resulted in erosion, sedimentation, poor environmental stream flow, high nutrients and weed invasions, and eventual cessation of stream flow in the long term leading to environmental degradation.

Even more alarming is the omission of mapping remnant vegetation along Logan River, creek systems and their tributaries indicating a poor attitude to waterways and their catchments. In reality, this precludes any rational discussion within the voluminous texts. Even a cursory examination of aerial photos highlights the presence of remnant vegetation along creek systems even in densely settled suburbs, grazing/agriculture areas, small acreage farms and industrial areas. This vitally important remnant vegetation linkage and corridor function has been omitted.

If the report is supposed to be remnant bushland then it should have been mapped and highlighted in a more realistic scale of 1:20 000. This scale would have enabled a more accurate location of remnant vegetation and used in conjunction with cadastral overlay (streets and property boundaries).

By choosing a broad scale of 1:100 000 for identifying remnant vegetation, there are problems with highlighting narrow riparian vegetation units or small remnants of conservation significance. This not only downgrades the importance of rainforest remnants but non-inclusion makes it virtually impossible to protect significant flora and fauna habitat or identify linkages to core habitat areas.

Map 3 of 9: The mapping scale ensures that mangrove and saline communities, ephemeral grasslands, sedgelands and wetlands are very poorly represented, despite their common presence along the Logan River and adjoining ecosystems. Riparian remnant rainforest communities and other small rainforest remnants are not mapped but reduced to 2 Brush box - Eucalypt Open Forest Complex (often with rainforest understorey).

Map 4 of 9: Remnant vegetation as classified by major community type has summarised all plant communities into only 4 units: Black sheoak and/or Wattle Forests & Scrubs, Eucalypt Forests, Mangrove & Saline Communities, and Melaleuca Forests. There is no correlation between major community type black she-oak and/or wattle forests and scrub classification that would apply to Logan City. This vegetation classification refers to brigalow, mulga, myall, gidgee etc; sometimes in association with she-oaks in Western Queensland, Western Australia, South Australia (arid and semi-arid zones). This does not include Logan City.

There is also no mention of rainforest despite the occurrence of rare and endangered species including Austromyrtus gonoclada (velvet-leaved myrtle), and several discreet and ecologically significant remnant sites including species mentioned in text p38 Volume 1 of 2 (1996).

There is no correlation between Map 5 and text (pp37-38) of the preferred food trees of the koala (forest red gum of alluvial and riparian corridors, grey gum, tallowwood, Queensland white mahogany, red mahogany and swamp mahogany (E. robusta: Carbrook Wetlands).

Map 5 of 9: Preferred Koala Habitat has not acknowledged any movement patterns and connections across Logan City by using misleading categories. There are no clear indications of preferred (should read Optimal) koala habitat along rivers, creeks and tributaries across Logan.

With the amount of documentation of preferred koala habitat being, along creeks, rivers, and more fertile soil types in Greenbank, Loganlea, Daisy Hill State Forest, forests in Rochedale, and connecting remnants in Carbrook-Cornubia to the Carbrook Wetlands). One has to seriously question the rationale for such blatant omissions.

The koala habitat map fails to indicate the extent of distribution of preferred koala food trees including Eucalyptus tereticornis (forest red gum), E. microcorys (tallowwood), E. propinqua (grey gum), E. tindaliae (Queensland white mahogany), E. resinifera (red mahogany), E. robusta (swamp mahogany), E. seeana, E. racemosa and several other stringybarks. Four of these species are widely acknowledged by DOE and also Dr. Pahl as the most important and preferred food trees for koalas, and confirmed during my surveys with Dr. Pahl and for Carbrook Wetlands Study

Instead, the map suggests that Logan koalas only exist in forests adjoining the Redlands by default. There is no preferred koala habitat mapped in west Logan, including Greenbank Military Reserve, despite scientific evidence refuting these claims.

This has serious consequences for koalas, kangaroos and wallabies which need large areas of connecting and contiguous bushland for their long term survival; thereby making this a regional issue beyond Logan City boundaries. Important linkages include from Greenbank to Karawatha: Bulimba Creek bushland remnants in Brisbane, and Native Dog Creek, Serpentine Creek linkages from Carbrook Wetlands to conservation areas in the Redlands.

Map 6 of 9 (Classified by Ecological Significance) and 7 of 9 (Classified by Level of Planning Protection) are also very misleading with large areas of eastern Logan remnant bushland recognised as having regionally significant natural areas; but in reality, they are not well protected.

Consider Portion 238, which is in private hands, currently under the cloud of development and beyond the reach of public ownership and utilisation due to an over-inflated land valuation. The question remains of where is collected green levy money being allocated if not to acquire core forest habitat and regional ecosystems of concern?

These issues should include secure zoning tenure as conservation reserves of ecological significance beyond the reach of development pressure. This should include remnant and discreet rainforests in Kimberley estate, riparian areas at Murray's Road, Usher Park, Parkview Estate adjoining Portion 238, along California Creek and remnant patches in Carbrook/Cornubia.

These startling omissions severely downgrade the importance of areas recognised as being nationally and regionally significant (Carbrook Wetlands, and escarpment from West Mount Cotton to Rochedale: including Portion 238, Venman's National Park and Daisy Hill State Forest).

There is no indication of linkage from remnant riparian, mangrove and forest red gum communities to remnant and core forest habitat; thus supporting the notion of bushland alienation and continued fragmentation as the norm rather than an act of vandalism that severs important ecosystems.

The preferred width of corridors could have been on a priority ranking based upon proximity to core bushland habitat, adjoining land uses, size of current buffer zone and corridor, type of fauna observed or anticipated based upon NatureSearch and Queensland Museum fauna surveys. The optimal corridor widths for inter-regional linkages should be 1500 - 3000 metres (1.5 - 3 kilometres).

Corridors should be 100 metres either side of watercourse and excluding 10% "park/ bushland contribution". They should be 500 metres in floodplains and ephemeral wetlands eg. Slacks Creek/Scrubby Creek confluence at Loganlea, Carbrook Wetlands and adjoining areas of mangrove and saline communities. The 1974 flood levels indicate the floodplains and wetlands.

The conclusion has little acknowledgment of the aspirations of the National Heritage Trust that creeks and waterways are the arteries of green for maintaining remnant vegetation. In this case the arteries have been amputated, severed and stripped of their major function of maintaining environmental flows and providing corridors for flora and fauna movement.

It is worth considering the summation by David Bellamy that "Wetlands are among the most endangered systems on earth. They are the lungs, kidneys and the ovaries of this living planet upon which we all depend. They must be saved."

Some of the key recommendations should be to recognise, encourage implementation of Carbrook-Cornubia Development Control Plan, and highlight areas of ecological significance worthy of linkage to Conservation A and B and thereby ensure real protection.

It would be a sad legacy of Logan City remnant bushland and the only fauna mentioned (koala), if they succumb to the chaotic road networks associated with poor urban planning and development constantly creeping across the shire.

Yours for Nature

 

Dave Gasteen Field Officer

Michael Petter Coordinator