FoN submission on the draft GWMP
Submission on the draft Green Wedge Management Plan, 2019
Friends of Nillumbik Inc. (FoN) is a grassroots not-for-profit, community volunteer group. We have around 1000 supporters who live and work in the Shire of Nillumbik. The purpose of our association is to support and promote the environmental and landscape values, neighbourhood character, orderly planning and good governance of the Shire of Nillumbik.
Friends of Nillumbik Inc. expected that the serious ongoing threats to our Green Wedge would be addressed in this review of the GWMP. Threats such as the compounding effects of Climate change, accelerating biodiversity/ecological losses and urban sprawl pressures. The GWMP draft, as presented on 25 June 2019, has the potential to seriously undermine the sustainability of Nillumbik’s Green Wedge. Its goals fail to adequately detail and prioritise the protection measures required to ameliorate known threats to the Green Wedge.
Friends of Nillumbik considers that the GWMP draft in its current form is not fit for purpose. The draft fails in its purpose as per the following points:
- Insufficient priority given to the ongoing protection of Biodiversity and Waterways
- Foreseeable dilution of GWMP Goals and Objectives
- Groundless desire for changes to the Planning scheme
- Responsible Leadership listed as a separate Goal
- Process decisions
- PROTECTION AS AN AFTER-THOUGHT
Any effective GWMP for our Shire must have at its core a strategy for protecting the very essence of why this was declared a Green Wedge Shire. The sprinkled references to “identifying and protecting areas of high biodiversity” (ONLY) found throughout the Plan, will undoubtedly guarantee a swift decline in biodiversity. “Islands” of splendid habitat are not viable. Where are the references to dedicated Wildlife Corridors traversing the Shire? Habitat & Bio links allowing bird, reptile and faunal movement from our bushland areas to our waterways? And the creation of Vegetation Protection Overlays (or ESO’s) with bold measures to “achieve a net gain in the quantity and quality of native vegetation”? (Refer Appendix 1: Plan Melbourne 2017 – 2050, see footnote)
Melbourne has lost 2000 hectares of tree cover in the past five years ……...there has also been a 2% decrease in greenery over that time (ref: Ass. Prof Joe Hurley, RMIT).
If Nillumbik Council is not actively writing their management plan to arrest this trend, then which Councils should? Only half of the Objectives in Goal 3 address the natural environment, and only a third of the Key Actions. Biodiversity protection and enhancement should have a dedicated Goal to ensure that it receives appropriate priority.
- DILUTION OF THE GWMP AT INCEPTION
The GWMP should be written as a separate and distinct document. Its initial independence from other Action and Development Plans/Strategies is crucial for its integrity. When it is then fed into the Shire Plan (Council Plan, MSS etc) its actions and goals will inevitably be compromised due to the constraints and competitions of the Council budget. A diluted GWMP at its inception does not show foresight, just a lack of priority.
- SEEKING TO CHANGE NILLUMBIKS PLANNING SCHEME
In several places the draft seeks to challenge and undermine State planning policy. This is outside the purpose of a GWMP and is likely to be counterproductive. The discussion about rezoning from RCZ to GWZ (page 40); changing land uses around the UGB (page 22 – 24); and ensuring all farmland is “protected” from ESOs (see A3.1 and A3.2) is a radical attack on fundamental planning provisions designed to protect our Green Wedge. Any time spent attempting to leverage the removal of RCZ to be replaced with GWZ; and the creation of clumsy “Buffer Zones”, “Micro-zones” and “The Right to Farm” will reduce a 10-year plan down to just a few compromised years. It is an overreach which seriously compromises the document. It should not be a Green Wedge “De-construction” Plan, it is a Green Wedge “Management” Plan. Council should work within its own brief. Tinkering around at the edges in an attempt to placate self-interested and ill-informed residents will only result in further angst. It is imperative that all economic opportunities and activities pursued be compatible with the current Planning Provisions and have a positive (or neutral) impact on the natural environment of our Shire. The stated Vision of the GWMP and its long-term success demands this.
- GWMP Goal 5: RESPONSIBLE LEADERSHIP
Friends of Nillumbik rejects this as a stand-alone Goal. Responsible leadership should guide all aspects of this Green Wedge Management Plan. Community engagement, conversations, education, awareness and implementation of key actions cannot proceed without strong leadership. Many of the Key Actions listed for Goals 3, 4 and 5 (p33, p39 and p41) are a radical departure from the “management” brief. They have the potential to divide our community which is not Responsible Leadership. To balance people & place; and promote cooperation, we urge that this GWMP respect the confines of the State Planning Policy rather than undermining these protective provisions which apply to all landowners in the Green Wedge. True Leadership would endeavour to convey this and bring divergent groups toward shared, middle ground. An innovative leadership action could be to advocate for further Government monies to better support our rural areas (possibly in the form of an annual Melbourne property levy). All of Melbourne benefits from our Green Wedges and we should all contribute to the preservation of them.
- PROCESS INCONSISTENCIES AND FAILURES
Many of our Supporters have expressed concern with the GWMP Process. Although initially striving for a transparent and arm’s length approach by convening a randomly chosen Panel, Council must now recognise that there have been anomalies along the way. Making the choice to accept ‘recommendations’ written outside the Panel process (by 5 Panel members) and formally accepting a Landowner’s group dossier before submissions were called for was a digression in process. The lack of scientific data informing the Plan and no input sought from relevant Agencies are very serious shortcomings. In addition, the reliance on an Urban Planner with no demonstrated experience with green wedges as the Draft’s author, and the unofficial involvement of Councillors during the process, leave questions to be answered. Concern has also been raised over the participate.nillumbik proforma experience. Do submitters actually understand that “Strongly Supporting” Goal 4 - A Prosperous Economy could demonstrate complicit support for a piggery or equine facility being developed in the paddock next to their house? Or “Support” for Key Move 5 “Environmental stocktakes” may actually be an unintended vote to allow land clearing. The Participate portal is skewed in favour of accepting the Draft and this deception should be acknowledged.
In conclusion, Friends of Nillumbik appreciates this opportunity to relay our concerns about the severe shortcomings of this GWMP draft. We represent a not insignificant component of Nillumbik’s residents. We are confident that this Council will seriously consider our feedback and make major changes to this draft Management Plan. Friends of Nillumbik supports the retention of the current GWMP which correctly prioritises environmental protection, in preference to the adoption of this draft. Eighty nine percent (89%) of submitted feedback to the “Bushfire Mitigation Strategy 2019-2023” expressed interest in the protection of our biodiversity (of that, 76% expressed a much higher level of concern for protection measures). Council’s published response to these concerns (OCM 30July 2019) was that they would be “addressed in the GWMP”. Friends of Nillumbik holds council to this promise.
Footnote: (Appendix 1), Plan Melbourne 2017-2050 which provides the desired planning outcomes for Green Wedges and peri-urban areas, has the directive to “Maintain and enhance the diversity of indigenous flora and fauna habitats and species, and achieve a Net Gain in the quantity and quality of native vegetation.” This draft plan does not provide enough emphasis on biodiversity protection, which should be the primary Objective of this Draft Plan.