20th September 2006

Submission

West Yamba Draft LEP

From: The Clarence Environment Centre 31 Skinner Street South Grafton

Preamble

The Clarence Environment Centre acknowledges Council's stated Aims to protect land of high conservation value; and to provide sustainable development that balances protection of natural areas and waterways.

However, it should be noted that other aims appear to be in direct conflict with those above, particularly Aim 2e, provide housing for approximately 2,000 – 2,500 people in close proximity to existing urban area of Yamba.

To achieve this aim, West Yamba has been selected, but there is no indication in the Draft LEP that any alternative sites were ever considered for this massive increase in population.

In principle the Clarence Environment Centre considers that any future development should consider, and adopt, the recommendations of the Department of Land and Water Conservation's "Upper North Coast Catchment Blueprint" (February 2003), whose Management Targets, includes: "No net loss of native vegetation from 2002". This aim was also adopted by the Federal Government (in 2003?): Therefore, the Environment Centre considers all future developments be located on land that is already cleared of vegetation.

The Centre also considers major developments of this nature should;

  • be located adjacent to existing facilities, particularly medical, education, public transport, and retail outlets,

  • not be selected until a full risk assessment of potential climate change impacts has been undertaken,

  • not be undertaken until waste water treatment infrastructure is upgraded to best practice standards, incorporating reuse technology,

  • not be approved until a secure water supply is in place and operating,

  • not be located on prime agricultural land, and

  • not be located in areas that are subject to isolation due to flooding.


The West Yamba Proposal

Specific to the West Yamba proposal, we could find no reference in the document (provided to us by Council) as to the exact size of the land identified as 2c residential, but the provided map (Council file 02639) suggests it covers approximately 1.2 sq kms, or 1,210,000 sq mtrs.

Climate change considerations

As much of West Yamba lies no more than a metre above sea level, landfill is a stated requirement. Again, nowhere in the provided document did we find any specific information as to exactly what height this land must be filled.

Another factor that is conspicuously overlooked by the document is that of global warming and associated rises in sea levels. Nor did we find any reference to other climate change risks such as the predicted increase in extreme weather events, specifically, the increased occurrence and intensity of cyclones, and their associated floods and tidal surges.

Already recent flood events has seen residents blocking storm-water drains to prevent back-flow from the Clarence River threatening to inundate their properties. This problem has been exacerbated by land-filling that has already occurred for residential developments completed in the past decade.

With this situation predicted to worsen, how much fill will be required for West Yamba? Worst case scenarios suggest sea levels might rise by over a metre within the lifetime of today's school children. Raising of West Yamba's ground level by just two metres will require 240,000 truck loads of fill. Where from; by which routes; and to what environmental impact to the area from which the fill is sourced, are all questions that, again, are not identified in the LEP.

Water supply.

A major problem facing the entire Clarence Valley, is water. Currently, all approved developments are being allowed based on the assumed effectiveness of the as yet untried Regional Water Supply Project, specifically the Shannon Creek dam. The dam will not be completed before the end of 2008, and a best case scenario will not see it filled before 2011.

Scientists have predicted that climate change could see a reduction in rainfall on the North Coast from between 10 and 50 percent. CSIRO scientists have already observed that, in Western Australia, a drop in rainfall of 10 to 15% over the last 30 years has seen run-off into dams reduced by 50%. This has led to the well publicised dire water shortage in Perth.

The implications for an off-stream storage at Shannon Creek, if only the minimum predicted 10% drop in rainfall occurs, is clear. With the Nymboida River flows halved, it would likely result in the river being unable to provide enough water to fill the dam. This is a storage that is also predicted to leak excessively through the highly porous Jurassic sandstone upon which the dam is being built.

The precautionary principle must be invoked, and the worst case scenario taken into consideration. Therefore, the Clarence Environment Centre considers there should be an immediate embargo placed on all development until the success or otherwise of the proposed Shannon Creek dam is fully ascertained.

Sewerage works.

We note the LEP's aim to permit development only when adequate sewerage works is available. We also note that consent for development / subdivision must not be granted unless the Yamba Sewerage Treatment Plant has the licensed capacity to cater for the additional population.

We must point out that the swamp forest, an endangered ecological community, into which treated sewage is currently being discharged at Yamba, is dying, and that current high levels of faecal pollution of many of the valley's waterways has resulted in swimming bans at a number of locations. The community can hardly feel confident that the current licensing process is likely to be effective at any time in the foreseeable future.

The Clarence Environment Centre is deeply concerned at the current inadequate level of sewage treatment across the entire valley, and its ineffectiveness in preventing pollution of the valley's waterways. We urge Council to place the upgrade of all treatment works, incorporating reuse technology throughout the area, at the top of its list of priorities.

In summary.

The Clarence Environment Centre asks that the West Yamba LEP be rejected in its entirety, as it fails to meet most of the criteria listed above, specifically:

  • there is an inadequate level of medical facilities for an expected aging population,

  • public transport is likewise virtually non-existent,

  • no risk assessment of potential climate change impacts has been undertaken,

  • water treatment infrastructure is clearly inadequate to serve the current population, much less the greatly expanded population proposed,

  • in an area renowned for floods (and with climate change that problem is likely to increase), no all-weather access to Yamba is currently available, and none proposed in the LEP,

  • no secure water supply is currently in place.

Therefore the Clarence Environment Centre urges Council to;

  • halt all further major development until a secure water supply is assured,

  • deny approval for any future housing estate, or industrial development on low-lying floodplain,

  • ensure all sewerage treatment works are built to best practice standards across the entire valley, incorporating reuse technology, as a priority,

  • immediately undertake climate change risk assessment on all the above, in line with the Federal Government's published report: "Climate Change – Risk and Vulnerability",

  • deny approval to any development that adversely impacts on prime agricultural land, and

  • immediately identify suitable cleared land for future housing development. Suitable land has already been identified on high ground between Junction Hill and Mountain View, and there is patently plentiful high ground in the Southampton to Waterview Heights area. None could be considered prime agricultural land, and would otherwise meet the above desired criteria for development, once the water supply and sewerage problems are corrected.

Compiled by J. Edwards (Scientific Licence No 11209)