This Association (FoN) strongly objects to sections of Council’s submission which reflect the narrow views of two local lobby groups which gained political influence following the 2016 local government elections.

The equestrian lobby and the PALS (Pro-Active Land owners) group have both pushed hard to remove measures which would protect the shire’s rural environment.  This position is not supported by the broader community.  The Wayfarer Consulting survey (August 2018) with 688 responses, showed that Nillumbik residents overwhelmingly wanted the natural environment of the Green Wedge to be protected, including biodiversity, plants and animals.  1

The influence of these two groups can be seen in three sections:  the “Context to Council’s submission” (page 1); the reference to “red tape” (page 3) and “Improving the Relevant Planning Provisions” (page 5).

For ‘horses’ to be included in a list of ‘principle agricultural products of Nillumbik’ (page 1) where the DELWP project is focussed on protecting food production, is no more than irrelevant special pleading. Horses are not a food product.

Under the Rural Conservation Zone in Nillumbik, agriculture needs a planning permit so that natural resources, habitat and biodiversity can be protected through conditions of permit.  To regard this as, ‘unreasonable red tape’, and a ‘significant burden or hindrance for landowners’ (page 3 and 5) reveals the PALS/equestrian push for less regulation for landowners, but at the expense of healthy biodiversity.  The suggestion to, “micro-zone agricultural land to a more facilitative zone” or, “modify the RCZ to better distinguish and

accommodate agricultural activity..” etc (page 5) would lead to a patchwork of different land uses and zone controls and the certainty of eroded environmental values in the long term.

Council’s radical ambition to deregulate unspecified parts of Nillumbik’s Green Wedge in the interests of agriculture, lacks any strategic policy basis, and is without any evidence of broad community support.  Both State and Local planning policies (MSS) support the regulatory management of land use for environment protection, and the existing Green Wedge Management Plan (GWMP – currently under “review”) is strong in support of sensible regulation, environment protection and existing rural zones – but after revision? We don’t know.  Council is talking with only one part of the community. The submission exemplifies a serious failure of process and governance.  

The submission refers to the GWMP Community Panel (pages 1-2) implying that its recommendations supported Council’s position on prioritising agriculture over environment regulation.  This is a misrepresentation and far from the truth.  For example, the Panel fully endorsed the existing GWMP; blamed domestic stock grazing in privately-owned bushland for diminishing biodiversity; wanted a broad land management plan to regularly review biodiversity values and guide landholders – particularly with climate change upon us; and wanted to conserve and enhance bush and rural landscapes. 2   The Panel also made clear its support for Nillumbik’s role as the Green Wedge shire: “Nillumbik’s role in protecting biodiversity and natural landscape must be supported.” This is exactly why Nillumbik’s Rural Conservation Zone must be retained and Council’s radical plan for “micro-zoning” and “modifying” the RCZ, must be seen for what it is.  Bowing to those with a partisan interest.

During the contentious Council debate on this submission, a senior officer, despite the well-known legislative hurdles to be overcome for re-zonings in the Green Wedge, publicly assured councillors that many farming properties zoned RCZ would be able to be micro-zoned to the Green Wedge Zone.  Enough councillors were persuaded.

Friends of Nillumbik Inc supported the identification of agricultural land in Nillumbik as ‘significant’, with its Rural Conservation Zoning.  If the land fails to achieve ‘significance’ status then we expect DELWP’s promise in “Frequently Asked Questions” (Fact Sheet) to be followed up: i.e. For green wedge land with a ‘range of other important values’, existing planning controls that apply “will remain in place and not be weakened…. we plan to come back to the community (to discuss) how we can strengthen planning controls for these areas” (DELWP)

We are happy to discuss any of these matters.

1.  Community Engagement Report, Key Findings, MosaicLab, p6-7

2. GWMP Review Community Panel – Recommendations, 17th Nov. 2018