Environmental Submission writing kit for the Draft Logan Planning Scheme
due: deadline 5 pm Wednesday 30 April
Logan and Albert Conservation Association have 5 key concerns relating to the strategic planning that underlies the planning documents. We have explained the background behind each concern and make a recommendation for how those values - which are core values for our organisation - could be improved. Please read the following document to read all 5 points. The first 3 points are covered in the pdf document lower down the page. Regional biodiversity corridors and Priority Development Areas (PDAs) are the last 2 points added.
Do not include attachments (which would have to be digitally signed) unless you need to
Submissions must be properly-made for Council to consider your feedback. A properly made submission means:
• You must include the full name and address of each person making the submission
• Submissions must state the grounds for the submission and the facts or circumstances to support the grounds. See text in red below
Apart from email submissions (preferred) written submissions - posted letters or email attachments, but NOT emails, must be signed by each person making the submission
Submissions can also be made Via post to Logan City Council, PO Box 3226, Logan City DC, Qld 4114, but have to arrive by 5 pm Wednesday 30 April
Significant environmental concerns to comment on include
Koala mapping not included as statutory overlay in Draft Planning Scheme
Offsetting and the Council’s flawed Ecological Significance scoring
Limited locally significant flora and fauna mapping
Background information for each is provided to explain why Logan and Albert Conservation LACA and others are concerned.
1. Koala mappingnot included as statutory overlay in Draft Planning Scheme
Background: While out of date mapping of Koala habitat does appear in the Draft Planning Scheme, this is not legally supported mapping (ie not statutory) and therefore has little chance of being defended in a court challenge.
This is because, while the Draft Logan Planning Scheme (DLPS) must adhere to the State Government’s ‘Single State Planning Policy (SPP)’, there is no requirement in this for the Council to incorporate statutory Koala mapping in the planning scheme.
Therefore there is no legal support in the planning scheme for the protection of koalas in the DLPS. This again underscores how hollow the State Government’s concerns are for protecting the environment – where they say they will ‘protect’ but then provide legislation which is toothless. However, by putting a comment on this into your submission you help send a strong message to both Council and the State Government that the community wants stronger legal protection for Koalas and their habitat in Queensland.
2. Offsetting and the Council’s flawed Ecological Significance scoring
Background: So-called ‘offsetting’ is now a core part of State Government ‘environmental’ policy. It is emerging as their principle propaganda tool around environment issues in Qld. Yet it is a ‘sleight-of-hand’ process that results in a net loss of biodiversity each time it occurs. It is a way of soothing concern over development in critically sensitive areas by promising that something will be done in the future to balance (and somehow make acceptable) the loss of crucial wetlands, rainforest, reef etc. The State Government is now so chuffed about the righteousness of this idea that they are even pointing to the possibility of National Parks being ‘offset’ if a coal miner wants to take them out. The Federal Government supports this too. Five million tonnes of port dredge spoil dumped on the Great Barrier Reef will now be OK because Federal Minister Hunt has said this can offset by reducing the flows of sediment out of the Burdekin River – a vague promise into the future that will more than likely never happen in any real sense. ‘Environmental offsets’ can more accurately be called ‘environmental setbacks’.
Council has devised its own ‘offsets’ policy based on ecological scores for each property across the Logan landscape. To do this they have created an ‘ecological significance’ map which assigns ecological values to various ecosystems across Logan. The trouble is most of this was ‘desk top’ – based on mapped and recorded data that was already 7 or more years old. There is little inclusion of fauna and flora survey data and other knowledge that has been recorded for Logan since 2007. We have found significant flaws, deficiencies and anomalies in the Council’s ecological scoring, which will be directly used to calculate the ‘cost’ of an offset to a developer. As a result, there are potentially many high biodiversity areas in Logan that score very low (therefore cheap to offset) just because amazing new data since 2007 hasn’t been included. We cannot support the concept of offsetting and we certainly should not, by omission, give tacit approval to an offset policy that is based on flawed and deficient data.
3. Limited locally significant flora and fauna mapping
Background: Logan has responsibility for a number of rare and endangered plant and animal species that require attention through the Planning Scheme if they are to survive the next decade on our watch. So it is alarming that the Draft Planning Scheme has only mapped two ‘locally significant’ threatened plant species (Gossia gonoclada and Melaleuca irbyana), and one ecosystem type (vine forest) as worthy of special consideration under the new Planning Scheme, which will be operative possibly until the mid 2020s.
By then it may be too late to do anything about the vulnerable to extinction Persicaria elatior, a flowering plant that is now only recorded in tiny numbers in one site in Logan City and nowhere else in mainland Queensland. And it may be too late to provide tree hollow homes in old growth trees for the Powerful Owl, which helps control flying fox numbers. And the endangered Glossy Black Cockatoo may not find any of its special food trees left anywhere in Logan. And rapid clearing of essential habitat for the endangered Quoll will mean this very special marsupial may needlessly disappear from this part of Australia, on our watch. And of course there is the Koala.
Mapping the location of the essential habitat of these plants and animals across Logan adds another check on reckless clearing of sites critical to the survival of these species. It is not enough for the planning scheme to recognise only two plant species with special mapping - there are a number of other plants and animals that need ongoing layers of protection provided by statutory mapping in the Planning Scheme.
In your email submission, you could copy and paste the text in red below the background, or say the same things in your own words.
Make sure you include the second part - ‘My proposed change to the Draft Logan Planning Scheme’
It is important that you make a submission to protect the biodiversity of our region - the flora and fauna - endangered threatened rare and common that together with our waterways make SOUTH EAST QUEENSLAND the special ecological region that it is.