Friends of Nillumbik Inc.
                                                                         P.O. Box 258 Eltham 3095
                                                                      mail@friendsofnillumbik.org

Submission on draft Council Plan 2017-2021
31st May, 2017

General comments:
As is the case with all Council Plans which set out strategic objectives for the shire, there is much in the “Living in the Landscape” document which will clearly benefit our community. However, in one crucial area the draft Plan takes us backwards from all previous plans.  Below we have commented on strategies and priority actions which are of concern.  
Strategic Objective 1:
1.6.1:  What is the intention behind, “review council’s role in direct service provision….etc”?  Is it intended to reduce council’s involvement?  Is this flagging reduced services levels?  More detail needed.
Strategic Objective 2:
2.2.8:  We are very concerned about a possible take-over of most of Eltham Lower Park, by mini-railway infrastructure.  The park is a valuable environmental and recreational asset which must be carefully managed to ensure no one activity interferes with other users and doesn’t degrade environmental values.  We are not convinced the Masterplan needs to be reviewed.
Strategic Objective 3:
3.1: What is the meaning of “holistic approach to strategic planning”?  Nillumbik’s planning scheme has as its central concern the health and sustainability of its Green Wedge, and that’s how it should be.  The intention here needs to be clearly spelled out.  It suggests more than just making it “easier and clearer”.
3.1.2:  This item grossly underplays the significance of the Green Wedge Management Plan, and distorts the emphasis from, how to sustainably manage a natural resource of considerable importance, to, how to change it to suit the demands of a pressure group.  It downgrades the importance of the Green Wedge.
3.1.4:  Does a “shire-wide housing strategy” include areas outside the Urban Growth Boundary?  If it does then councillors need to be reminded that the RCZ3 zone in the Green Wedge discourages residential use and that needs to be respected.
3.3.3:  Housing for retirement living must be confined to within township boundaries in order to retain the purpose of green wedge areas.
3.6:  This strategy is commendable, however, none of the associated priority actions (3.6.1; 3.6.2; 3.6.3; 3.6.4) will effectively achieve the strategy’s goal. There needed to be a separate Strategy concerning implementing the Green Wedge Management Plan.
3.10.1:  This should have words added: “but not through Nillumbik!”
3.10.4:  A train station in this location would be likely to lead to a new residential sub-division on green wedge land between Allandale Road and Diamond Creek, including a shift in the Urban Growth Boundary.  These consequences should be avoided.
Strategic Objective 4:
4.1.4:  “planning outcomes that are positive and customer-centric”?  What does this mean?  There are always winners and losers in planning outcomes; how can it be otherwise?  This should be removed.
4.2.1:  New tourism accommodation should also be consistent with the Green Wedge Management Plan.
4.3:  Development trends in activity centres (particularly Eltham’s) are already creating angst among nearby residents.  Do we really want to accelerate development pressure further?  This item should be removed.
4.4:  A visionary plan for Precincts 3&4 must include extensive community consultation because of the sensitive nature of the former Shire Office site.  Its use will be carefully scrutinised.  Current site also has existing community use.
Strategic Objective 5:
5.4:  This needs some rational argument consistent with the needs of the municipality and the rates structure of the shire.  It’s well known that Nillumbik has structural issues related to having a small rate base.  This is unavoidable.  Should be removed.
5.4.2:  This needs further explanation.  To what end?
5.5.1:  Accelerated program of debt reduction – needs rational justification.  Why “accelerated”?
5.6.2:  Selling assets at the scale proposed is unsustainable and unnecessary.  Rating according to the rate cap is realistic and responsible.  This should be removed.
5.7.1:  The “Organisational Culture and Capability Strategy” needs explanation. This lacks transparency.
5.9.2:  This action will lead to unnecessary speculation about the viability of the existing shire boundaries.  It is destabilising and damaging.  What is the purpose?  Needed much more explanation.  This should be removed.
Strategic Resource Plan:   There is much that is both ideological and political in this section.  The key assumptions come from an acceptance that an anti-rates prejudice among some in the community ought to be pandered to, rather than countered.  Some in the community need better information about Nillumbik’s structural problems which are well known in local government circles, including the MAV.  This section lacks rational justification.
Backwards steps from previous council plans:
On pages 8-11 there’s a familiar introductory profile of the Shire of Nillumbik.  It says that we are (known as) the Green Wedge Shire with a community which:
 “….values and wants to protect the Green Wedge with its bushland environment, open spaces…etc”, (with) “..large areas of native vegetation on public and private land and sites of national, state and regional significance for their fauna”.  
But extraordinarily, that’s where any further mention of the Green Wedge ends!  In the all-important body of the draft Plan where there are 186 strategic indicators, strategies and priority actions, there is not one further mention of the Green Wedge despite it making up 91% of the shire’s area!  The subject of dozens of mentions in our planning scheme’s Municipal Strategic Statement, local policy and state policy, references to the Green Wedge have been removed from council’s most important 4 year, strategic document!
Natural environment inaction:
The introductory comments refer to the community’s desire to protect bushland and open spaces and there is a strategy (3.6) which includes biodiversity and natural resources protection; but the accompanying priority actions about an invasive species plan, a water management plan, sewerage advocacy and sustainability advice to landowners, while helpful, do not offer a broad or systematic program of actions to tackle habitat decline and threatened species, urgent problems identified in council’s Biodiversity Strategy. Despite mention of “our iconic environment” in the heading for Objective 3, the only mention of landscape we could find is in the Plan’s title, “Living in the Landscape” which implies that our iconic environment doesn’t need protecting because it’s to be used for “living-in” i.e. for rural residential purposes, contradicting the rural conservation zone which discourages this use.  Under this draft Plan the shire’s natural environment, no doubt, will continue to decline.

Green Wedge Management Plan:
In the draft council Plan the Green Wedge Management Plan receives scant attention (see priority actions 3.1.2) Here, it’s regarded merely as a potential problem for landowners.  This dismissive treatment fails to recognise its significance.
Nillumbik’s Green Wedge Management Plan (2010-2011) derives from State Government planning policies and strategies:  
“Its preparation is guided by the Department of Sustainability and Environment practice note: ‘Preparing a Green Wedge Management Plan’, August 2005.  The concept of green wedges as rural landscapes and natural areas separating corridors of urban development is a long standing metropolitan planning commitment.  This commitment has been endorsed and promoted by the Victorian State Government policy document ‘Melbourne 2030’ and, subsequently, by ‘Melbourne @ 5million’ which confirms these policy directions.  In this context the Nillumbik Green Wedge is a resource to be protected and managed on behalf of the whole metropolitan community because of its environment, and its recreational, agricultural, economic and social values”. (page 11, GWMP volume 1)  
In 2007 an Audit Expert Group made the following recommendation in respect of green wedges:
“the state government gives higher priority to enhancing the contribution of green wedges to the sustainability and liveability of Melbourne.  Mean by which this can be achieved include:
•    Implementing the green wedge management plans, ensure that controls on the land recognise the inherent differences in the nature and capability of land within each green wedge”.  (page 13, GWMP volume 1)
The Nillumbik Green Wedge Management Plan 2010-2011 contains 29 strategies covering infrastructure, recreation, settlement, agriculture, tourism, business development, cultural heritage, transport, biodiversity, strengthening communities and landscape.  It has 109 recommended actions including 50 high priority actions.  It is not, by any means, a radical “green” document: For example, it calls for economic development in townships; increased business opportunities and tourism-related accommodation in the Green Wedge; the growth of locally based food production; an Active Ageing Strategy, among many others.  The failure to make this landmark strategic plan a central part of council’s draft Plan is very worrying and must be rectified.
The importance of the Green Wedge Management Plan is based on Nillumbik’s Planning Scheme:  “The main council planning document applying to the Nillumbik Green Wedge is the Nillumbik Planning Scheme which incorporates the Municipal Strategic Statement (MSS).  The MSS sets out the broad strategy for the Nillumbik Green Wedge and Nillumbik as a whole.  The Nillumbik MSS states that:  ‘…in defining the boundaries of the shire, the Local Government Board recognised the strong rural and conservation focus shared by the communities of interest in this particular region of Melbourne’.  In keeping with this statement the Nillumbik Planning Scheme states that the shire has a role as metropolitan cultural, nature conservation and recreation resource that will continue to be recognised throughout the state:
All future land use and development will enhance the aesthetic qualities of the urban and rural environment responding in particular to the character defined by landform, landscapes and vegetation cover.  The energies of the Nillumbik Shire Council will be directed to enhancing the environmental conditions that enrich the area and promoting development which meets present needs without compromising the future wellbeing of the shire. In this way, the Shire of Nillumbik will achieve an environmentally, socially and economically sustainable future (MSS, Planning Scheme, and page 14, GWMP volume 1)
To realise these well-established goals from Nillumbik’s Municipal Strategic Statement it’s necessary to implement the Green Wedge Management Plan.  Instead the draft council Plan has effectively shelved it.  It must be re-included into the Plan.

Greg Johnson (on behalf of Friends of Nillumbik Inc.)
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