1
February
2001
Assistant
Manager
Coastal Planning,
Queensland Environment Protection Agency
PO Box 155
Albert St
Brisbane Qld
4002
Public
Submission: Draft State Coastal Management Plan
Dear
Sir/Madam
This
submission has been prepared by the National Office of Surfrider
Foundation Australia, in order to express formal comment
to the [Queensland] Environment Protection Agency (EPA)
on the development of the State Coastal Management Plan (SCMP).
We understand that the SCMP is a fundamental tool to
best implement the [Queensland] Coastal
Protection and Management Act 1995 (CP & M Act).
Surfrider Foundation (SF or 'the Foundation') is a non-profit environmental
organisation dedicated to the protection and enhancement of
Australia's oceans, waves and beaches for all people through
Conservation, Activism, Research and Education (CARE).
The primary aim of the Foundation is to give surfers
a public voice and campaign to mitigate adverse pressures
being placed upon the coastal zone and marine environment.
The Foundation is supportive
of the initiative - by the Queensland Government - to provide
a comprehensive framework for the management of the state's
diverse range of coastal resources.
Further, it is encouraging that the EPA has embraced
a management philosophy based upon principles of Ecologically
Sustainable Development (ESD), with a focus on the long-term
sustainability of coastal resources.
Aligned
with the Foundation's active interest in coastal zone initiatives,
please find our detailed comments on the following pages.
We ask that the EPA absorbs the Foundation's recommendations
to ensure that the interests of our members and supporters
are appropriately integrated into the state's coastal planning
and management system.
If
you have any queries regarding this submission or correspondence,
please feel free to contact Mr. Greg Howell at the National
Office on 07 5534 2855.
Yours
for Clean Oceans
Greg
Howell
Executive Director
GENERAL
COMMENTS
Policy
Development
It
is pleasing to see that the EPA - and the State Plan - recognises
ESD and the important interplay of social and economic factors
in the development of holistic environmental plans.
This Plan ties together a web of legislation, policy
and plans that will enable more effective management of the
natural environment in the coastal zone. There is, however,
no expectation that the legislation, plans and policy linked
to what will be a statutory document, are required to submit
themselves to ESD or best practice. The Plan is only as strong
as its weakest link.
Surfrider
recommends the following:
·
That the Plan
require all legislation, plans and policy that aid the implementation
of the Plan, be reviewed and upgraded (if necessary) to comply
with best practice ‘environmental standards’.
·
The development
of a model / application to monitor the cumulative impact
of development over time. A system such as the Regional Cumulative
Assessment Program (RECAP) used by the California Coastal
Commission is recommended.
Ecologically
Sustainable Development and Ecological Sustainability
There
seems to be some confusion between the objectives of ESD and
the need to see the management of the coast coordinated in
an ‘ecologically sustainable’ manner. To adhere to the principles
as outlined in the [Commonwealth] National Strategy for Ecologically
Sustainable Development (1992) is one thing, and to have as
a vision for the coast ‘ecologically sustainable development’
is quite something else. As the DSCMP policy outlines, some
areas of the coast will not be developed at all – this cannot
be called ‘development’. Using the term ‘ESD’ when you intend
‘sustainable management’ or ‘ecologically sustainable management’
implies that in order to protect, preserve, enhance or value-add
to a piece of land, that land must be developed.
Reporting
Period
It
is the belief of the Foundation that a 7 year operation period
for the policy before it is reviewed is inadequate. Natural
Resource Management, and specifically coastal management in
Australia is going through a period of reinvention. With the
Federal Coastal Policy, which was written in 1995, about to
come under review as well as the development of the State
Regional Coastal Plans (RCP’s) over the next 8 years, the
policy will be tested from both sides of the political spectrum.
Surfrider
recommends the following:
·
The Qld Government
increase the frequency of reporting to ensure that the policy
is reviewed at least every 4 years for three periods and then
every 5 years.
·
That the Government
prepare an annual report commenting on the success or otherwise
of the Plan.
1.2 Purpose of the State
Coastal Plan
On
p.5 of the DSCMP it is written that “Any ‘retrofitting’ of
development to meet the principles and outcomes of this plan
will necessarily be an evolutionary process over time, acknowledging
past decisions, and dependent on appropriate resourcing.”
Our
understanding is that the RCP’s are going to be developed
over the next 8-10 years.
Will the State Plan have
authority until RCP’s are completed ?
Surfrider
is aware of the difficulties involved in ‘retrofitting’ policy.
However, we are of the belief that if some of the current
‘land management’ practices are continued, many sensitive
environmental areas may be threatened before legislation to
protect them can be enforced.
Surfrider
recommends the following:
·
Any plan to
delay the ‘retrofitting’ needs to be complemented with a strong
environmental education policy.
·
Current development
applications and project proposals need to be catalogued and
categorised. Any projects that affect areas of significant
environmental value need to be flagged and reviewed in the
light of current legislation in order to reflect ‘best practice’
and ESD.
1.3 Coastal Management
in the Queensland context.
The
Plan recognises that there are an assortment of activities
that can contribute contaminants to coastal waters. Industry
and primary agriculture discharges can have significant impact
of the quality of coastal water. It is important that the
Plan recommend that these industries embark on an intensive
program of upgrading and sourcing the use of alternatives
to some of the harmful chemicals and other contaminants that
are currently discharged into our waterways.
Chapter 2 – Direction
‘How Queensland’s coast is to be managed’
General
Comments
Surfrider
has a number of issues with the exclusive currency that the
Plan places in the findings of the State
of the Environment Queensland 1999. The current system
measures only predetermined variables within the Condition-Pressure-Response
(CPR) system. To restrict the Plan to these variables means
that it will be beset by similar pitfalls to the State of
the Environment Report. The CPR system is not capable of introducing
or recommending proactive environmental gains, nor does it
provide a suitable means of measuring the effectiveness of
policy or education on the quality of the environment. Measuring
the effectiveness of policy and education programs (impact
on humans rather than human impact on the environment) for
coastal management should be core business for the Coastal
Plan.
Surfrider
recommends that:
·
The Plan include
‘monitoring and evaluation’ of programs as a Core Issue.
Implementation
of the State Coastal Plan
On
p.14, it is written: “In addition, there are numerous other
actions and activities undertaken by community groups and
industry bodies in the coastal zone that contribute positively
to coastal management outcomes… It is encouraged that such
groups and bodies also reflect the outcomes, principles and
policies of the State Coastal Plan.”
As
one of many non-government community groups that work for
the protection of the marine and coastal environment, Surfrider
is aware of the difficulty of tracking and coordinating the
work done in the non-government sector.
Surfrider
recommends:
·
That the final
Plan introduces as policy, a system to track and coordinate
the work done by the non-government sector towards conserving,
maintaining and protecting the marine and coastal environment
and that this information be available to resource managers
and to the general public to enable a more informed decision-making
framework / process.
2.1 Coastal use and development
2.1.6 Extractive industry
Surfrider
Foundation is opposed to sand-mining for commercial purposes.
We encourage the Qld Government to review its policy on sand-mining
and urge both the State and Federal Government to ban all
mining that may affect the Qld coastline.
2.1.9 Tourism and recreational
activities
Surfrider
recognises that the beach has replaced the bush as Australia’s
national icon. Tourism, both local and international, is a
major source of income for Qld. In developing the Plan, Surfrider
believes the Government has an opportunity to promote tourism
and ecological sustainability.
Surfrider
recommends the following:
·
That any new
tourist or recreational developments be designed to industry
‘best practice’ standards. We encourage on-site waste-water
treatment and re-use strategies.
2.2 Physical coastal processes
2.2.1 Erosion prone areas,
2.2.2 Shoreline erosion management, 2.2.4 Offshore structures
Surfrider
applauds the Government’s decision to keep, where practicable,
erosion prone areas development-free areas. Surfrider recognises
that there are numerous areas of the Qld coast that are currently
being eroded by both natural and human-induced causes. We
encourage the Government to accept the right of a beach to
exist for itself – as part of an ecosystem, rather than exclusively
for human use. Experience around the world indicates that
the construction of seawalls inevitable leads to the destruction
of beaches.
Surfrider
recommends the following:
·
That the Government
recognises the environmental right of beaches to exist.
·
That the Government
recognise the right of the public to beach access.
·
That the Government
make a commitment to use soft-nourishment options for beach
preservation.
·
The Government
undertake extensive public / community consultation before
any significant coastal engineering works are initiated.
2.2.3 Coastal hazards
The RCP’s
are going to be developed over the better part of the coming
decade. How much of the coast has already been mapped and
high risk erosion areas declared? What will happen in the
regions where RCP’s are not yet developed? What assurances
do we have that no inappropriate developments will take place
in the interim?
2.3 Public access to the
coast
Surfrider
recognises and supports in principle the right of the public
to access the coast. However, in attempting to legislate for
public access, certain issues have not been taken into consideration.
Surfrider recommends that:
·
The Government
restrict or ban all vehicle use on beaches during nesting
times for shorebirds and turtles.
(There
is no mention of this in Section 2.7 Conserving nature)
2.4 Water quality
Traditional
methods of sewerage and stormwater management can often have
negative environmental impacts. For quite some time now, the
community has called on the Government to embrace new technology
and upgrade all treatment plants and discharge outlets – these
are our ‘established environmental values’.
Surfrider
urges the Government to respond with a comprehensive waste
water management policy. The EPA, through statutory measures
should encourage much more than end of pipe solutions. The
Plan has the potential to be very powerful instrument for
the protection of our marine and coastal environment. It can
also be a proactive piece of legislation, not just a document
that responds to current practice.
2.5 Cultural Heritage
Surfrider
Foundation recommends that:
·
Indigenous
and non-Indigenous cultural heritage be treated as separate
and distinct entities.
2.8 Coordinated management
Fundamental
to the prescription for effective coastal management is the
importance of having adequately trained or experienced people
as the decision-makers. Surfrider recommends that:
·
The Plan have
specifications built into it that require periodic ‘training
/ management needs’ assessments of coastal managers, and that
there be regular seminars, conferences and educational programs
to ensure that there is a continual upskilling of coastal
resource managers.
The
Principles should be expanded to include the above recommendation.
Surfrider
is stoked that the Government is attempting to coordinate
this area of resource management. We are encouraged by Principle
8B:
“All
levels of government, non-government agencies and the community
participate in coastal planning in an open and cooperative
way.”
In
order to ensure this, Surfrider recommends that:
·
The Government
establish a reporting and communication framework to encourage
open and frequent dialogue between itself and all community
and non-government groups working in the coastal zone.
2.9 Research and Information
One
of the fundamental principles of Agenda 21 is the need to
involve the community in the decision-making process. Core
to achieving this is the need to encourage the public to become
involved in community groups. The National Oceans Policy embraces
the concept of ‘environmental stewardship’, as will the revised
National Coastal Policy. Simply put, without people, there
would be no need to monitor the environment. The plan is built
around monitoring human impact on the environment, but there
is no mention of any strategy to monitor and evaluate the
impact that environmental education, facilitation or community
participation programs are having on people or their behaviour.
Surely this is core business for the development and review
of the Plan? The
fact that there are few indicators in Schedule 2 to report
on such activities is testimony to this.
Surfrider
recommends that Section 2.9 of the Plan be expanded to include
as a core Principle:
·
The development
of a system to monitor and evaluate the effectiveness of environmental
education, facilitation and community participation.
Further
to the above, Surfrider recommends that:
·
The Plan be
expanded to include a database to monitor the work that is
being done in the marine and coastal environment by all groups.
2.9.3 Monitoring
The
California Coastal Commission recently introduced a program
called the Regional Cumulative Assessment Program (RECAP).
RECAP provides a framework for monitoring the cumulative effect
of development and development proposals over time. It allows
the decision-making Authority to weigh up the cumulative effects
of development in one particular area over a period of time
as part of the decision-making process.
Surfrider
recommends that:
·
Section 2.9.3
of the Draft Plan be expanded to include a systematic framework
for monitoring developments and plans over time.
Schedule
2: Proposed performance indicators
General
Comments
As
previously mentioned, Surfrider recommends that the Plan be
reported on annually. The CPR system for identifying environmental
indicators has many strengths, however, for some activities,
Surfrider believes there needs to be more comprehensive environmental
reporting. Key areas are aquaculture, offshore structures
and vehicle use on beaches.
On
behalf of the Surfrider Foundation Australia, we recommend
these comments to the Government and look forward to your
response. If you have any questions or would like to pursue
further discussions, please contact the National Office on
07 5534 2855 during business hours.
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