An extension to comment on the draft Environmental Sustainability Strategy 2020-27 was granted till 9/3/20.
Representatives from the CPPA and TASNG have spent many hours reviewing the document and survey which unfortunately was not very easy to digest or navigate. The product of these deliberations is the basis for the CPPA submission.
If you have time to comment please feel free to endorse the considered review provided by the
community submissions prepared by Toronto Area Sustainable Neighbourhood Group and the
Lake Macquarie Sustainable Neighbourhood Alliance.
LMCC Draft Environmental Sustainability Strategy and Action Plan 2020-2027
On behalf of the Coal Point Progress Association (CPPA) thank you for the opportunity to comment on the draft Environmental Sustainability Strategy and Action Plan 2020-2027 and providing an opportunity to better understand the document at the community workshop attended on 26/2/20.
The CPPA was involved in the development of the response submitted by Toronto Area Sustainable Neighbourhood Group (TASNG) (Appendix 1) and so whole-heartedly endorses this submission. The following comments are made in addition to the TASNG submission.
The ESSAP is a crucial document to ensure the long-term health and maintenance of the unique environmental assets of our City. The connected bushland that still spans the City provides a point of difference to other urbanised centres and a considerable head-start on meeting UN Sustainability Development Goals. This sets our City apart from our urban neighbours, Newcastle, Central Coast and Sydney.
A Strategy that values the biodiversity, connectivity and environmental services provided by native vegetation would endeavour to reverse the loss of native vegetation cover which is currently embedded in the ESSAP at 57.5% and strive for 60% cover, a point at which the integrity of the ecosystem function and environmental services are sustainable and providing an economic contribution.
The projected loss of 70ha/year of native vegetation cover is not sustainable. At a point, below 60% vegetation cover, the integrity of the ecosystem function and environmental services provided becomes compromised and increasingly additional resources are needed to be expended to furnish the services that vegetation cover supplies by virtue of its existence. It is a false economy to deplete a resource in the short term without any regard for intergenerational equity and the escalating climate change impacts that are being experienced.
Within this context an economic model that is driven by value adding to the existing vegetation assets, using them to connect communities and encourage recreational endeavours through appropriate infrastructure, would proffer opportunities to drive an eco-tourism market that supports retention and protection of native vegetation for the social and economic health of the City.
It is unfortunate the structure of the document and survey has made the community consultation process difficult to share in any meaningful way. The CPPA has in the past endeavoured to provide community summaries on significant documents however the time required to process this document has overwhelmed even the most committed of community representatives.
Regards
Suzanne Pritchard
President- Secretary, Coal Point Progress Association
LMCC Draft Environmental Sustainability Strategy and Action Plan 2020-2027Submission by Toronto Area Sustainable Neighbourhood Group March 2020
General comments
Lake Macquarie City Council’s Environmental Sustainability Strategy and Action Plan 2020-2027 (ESSAP) is a very important Council document both for the community to evaluate and for Council to implement.
Council has widely articulated the importance of its Sustainability Policy. This policy has four ‘pillars’ - environment, social, economic and governance. ‘Under this policy Council commits to making an equitable contribution to all aspects of sustainability (environmental, social, economic and sustainable governance) for Council and the City.’ The ESSAP could elaborate on the meaning of ‘equitable’ and how the philosophical intent translates to actions.
This ESSAP focuses on the environment pillar and, as such, it provides a critical balance to the economic-centric view of the world held by some. Because of its wide ramifications, environmental sustainability in its broadest sense is arguably the most important issue for the community and therefore should be for Council. As such, this document must be robust and integrate with all other strategies across Council.
However, the ESSAP document is quite complex in content and presentation, as are many of Council’s strategic documents. Thus it requires a considerable investment of time to properly assess and respond to. This is especially true of the stated actions. Because of this, only a small proportion of the community will likely respond. A shorter summary of the themes, targets and actions is required. The current summary section reads more like an introduction.
The Toronto Area Sustainable Neighbourhood Group (TASNG) has chosen to put a submission together. We believe that the on-line survey is not helpful for gauging community response. This is also the case with other strategy surveys. The recent community workshop held at Charlestown was certainly useful and enabled those present to highlight key areas needing attention. However, we note that two workshops were cancelled because of insufficient interest. In order for Council to better engage with the community for this and other strategies we suggest that a meeting of some community members and Council be convened to consider alternative survey models.
We appreciate the complexity of issues surrounding the concepts of ‘sustainability’ and that the ESSAP aims to identify linkages with other Council strategies already commenced and planned. We keenly support Council’s lead in pursuing sustainability development goals (SDGs) and aligning with state, federal and international initiatives.
With respect to SGSs, it is not clear what is meant by ‘percentage of our targets mapped to the four pillars...’ nor the value in presenting these statistics. Perhaps the ESSAP could start with the SDGs as the end-goal and the framework to be used, and then the objectives, targets and actions built around them. For example, how is ‘no poverty’ being addressed unless residents have affordable housing, a significant issue for Lake Macquarie LGA? Page 7 could be better placed further back in the document.
Interestingly the document does not include a definition of ‘sustainability’, though there are several possible definitions and Council’s four-pillar Sustainability Policy are referenced. Perhaps something like the following could be used or expanded on: ‘the quality of not being harmful to the environment or depleting natural resources, and thereby supporting long-term ecological balance’ or ‘the capacity for the biosphere and human civilisation to coexist’.
We note that Council has employed a Circular Economy Leader and trust that this will allow Council to better put sustainability measures in place. However, we also note that ambitious sustainability goals can be at odds with Council’s consistent messages about economic development and desire for ambitious population growth targets. It would be useful if the ESSAP provided commentary on the importance of the environment within the four-pillar sustainability policy.
We suggest that the aspirations of the ESSAP should be bolder in line with the urgency of climate change and alignment with SDG timelines. Lake Macquarie LGA is part of the larger Hunter Central Coast region and NSW. Therefore some commentary on collaboration to achieve aspirations, particularly around issues such as large-scale renewables, transport, circular economy and biodiversity, would be relevant in this document.
Perhaps section on ‘Targets’ should be logically placed after the ‘Themes’. It’s important to get the context right before the targets are presented because the targets will determine the efficacy of the actions and vice versa.
There are a number of references in the targets to 2007 and 2019 ‘baseline’ years but no further elaboration. The ESSAP needs to provide figures for these years and sources of information in order for us to interpret the value of the targets presented.
We anticipate that both Council and Councillors will embrace the sentiments expressed in page 6. On page 11, we note that ‘Diverse economy’ and ‘Connected Communities’ are not recognised in the theme of “Protecting and enhancing our natural landscapes”. In addition, without ‘Responsible Consumption and Production’, our ‘Unique Landscapes’ will be impacted.
There are too many actions listed. They are mostly not measurable and therefore it is difficult to see how they relate to the stated targets. This is a pity because in their own right they are interesting and important. In their current presentation, the actions are related to ‘issues’ which have not previously been elaborated on and focus on inter-strategy interactions. This is confusing and the vast majority of residents will just ‘glaze over’ them. There is too much to absorb and in a timely manner. Surely, the actions should be related to achieving the targets? We suggest that there should to be an additional section within the document labelled ‘Action and Delivery Plans’ or similar that is simpler and shorter and shows how the [smaller] number of actions will lead to each target being met.
We have focussed our feedback on the targets (pp. 18-19). We have elected not to comment separately on the individual actions but generally concur with comments made by Charlestown Sustainable Neighbourhood Group and the Sustainable Neighbourhood Alliance.
Strategic Theme 1: Protecting and enhancing our natural landscapes
1.1 Maintain at least 57.5% native vegetation cover in the City.
How was this figure arrived at? Currently we understand that this figure (for remnant native vegetation) is 58.5% (37588 ha) as mapped in 2018 with an average rate of clearing of 70 ha per year. What is the current and expected future rate of clearing and what is the definition of ‘clearing’, i.e. complete and/or partial? According to a 2018 Council report on biodiversity 2050, the percent native vegetation cover is expected to decline to about 51%. Based on Council’s Environment Enhancement 2023 statement calling for a 25% reduction in the rate of land clearing, shouldn’t we expect closer to 50 ha per year? How does 57.% fit with Council’s suggested 40% greenfield development target? The physical distribution of land clearing throughout the LGA is also important, with most of the projected green fill sites being in west ward and parts of the north ward.
1.2 Improve the condition of 30% of public land with high conservation value compared to 2007.
What is the % of total LGA area that is public land with high conservation value? Why is this phrased as relative to 2007 base line? To what degree will such land be improved. Why is 30% chosen? Is this to line up with the existing State of the Environment reports? How much improvement has already occurred since 2007?
1.3 No net loss in connectivity of ecological communities from 2007 baseline.
We support this target. However, why is the 2007 baseline chosen? There should be a focus on the health of the connection as well as the presence of a connection.
1.4 5% increase in area of the City (land and water) with conservation status compared to 2007 baseline
We support the thrust of this target. However, why 5% and why relative to 2007? What has been the change between 2007 and 2019 in land with conservation status? The Ecosystem Enhancement 2023 recommendation is 20% increase in area of public and/or private land with conservation status (excluding the lake).
1.5 20% increase in lake and waterway health compared to 2007 baseline
Why 20% and why relative to 2007? What has been the change between 2007 and 2019 in lake waterway health? Surely water quality is much better in 2020?
1.6 Achieve a ‘100% Water Cycle City’ state
We support this target.
1.7 90% of residents place a high value on the health of the natural environment (beaches, lake and bushland) of Lake Macquarie
We support this target.
Strategic Theme 2: Supporting Resilient Communities
2.1 Natural disaster risk reduction strategies in place for 100% of the City’s extreme and high risks.
We support this target. However, the recent bushfire and climate change impacts have demonstrated that much of the LGA is now considered high risk and risk assessments need to be updated. There is also opportunity to engage citizen helpers in times of storms and bushfires to support other personnel.
2.2 Climate change risk reduction strategies in place for 100% of the City’s extreme and high risks
We support this target, but refer above.
2.3 100% of known contaminated public land assessed for risk to human health and prioritised for risk mitigation measures.
We support this target. However, what is the figure for known contaminated private land? For example at Eraring and Vales Point Power stations?
2.4 Air quality emissions in the City meet the National Environment Protection (Ambient Air Quality) Measure
We support this target. Air quality monitoring should be installed across the lake and targets set for each. The environmental risks from the ash dams and air pollution from Eraring and Vales Point Power Stations need to be properly assessed and Council need to keep lobbying state government to do this.
2.5 70% of residents believe they have the information and resources needed to prepare, respond and recover from adverse events
We support the thrust of this target but why 70% is chosen should be clarified? Should it be ‘households’?
In addition, Council needs to consider how climate change and lack of vegetation cover impact on the ‘heat island effect’ in our urban centres and how this can be partly mitigated through an urban revegetation policy.
Strategic Theme 3. Creating a sustainable city and communities
3.1 57% reduction in City-wide per capita and total Council greenhouse gas emissions from 2007 baseline.
We support this target, but how is the figure of 57% arrived at and why is this relative to the 2007 baseline? What is the 2007 baseline line compared with 2019? There should also be emphasis given to reducing consumption and demand for energy resources, as well as energy efficiency.
3.2 12% reduction in City-wide per capita and total Council drinking water consumption from 2007 baseline.
We support the thrust of this target and note a small increase in per cent reduction on Sustainability Engagement 2023. Is ‘drinking’ water the same as ‘potable’ water? However, we would like to see a more ambitious target, closer to 30%, given the recent drought and climate change impacts. Continued education is the key to reducing daily water consumption thereby reducing the need for potential infrastructure spend by Hunter Water on a dam or desalination plant.
3.3 Increase active transport (walking and other) to 15% of total trips (Transport for NSW Household Travel Survey - Data by LGA).
We support this target. It is a rather complex area that is currently being pursued under the Active Transport strategy, including rolling out appropriate infrastructure. Both strategies can work closely together to achieve both the health benefits and assessment of the likely to impact on reducing air pollution, greenhouse gases and energy consumption. Achieving this target will also require continued communication with State government to improve links to public transport.
3.4 80% of residents report taking positive actions to source renewable energy and/or conserve water and/or undertake active transport trips.
Whilst we support the thrust of this target, we would like to know why ‘and/or’ is used and what is defined as a ‘positive action’. The three activities cannot be directly compared either due to the metrics needed or lack of quantification or both. What is the goal of this target and how will it be monitored? This target should be expanded to include businesses.
Strategy Theme 4. Responsible consumption and production.
4.1 30% reduction in the per capita ecological footprint of the City from 2007 baseline.
We are not clear what is meant by this target and how it can be measured. Ecological footprint is a ‘resource accounting tool’ and not an accurate measurement. This is the same ‘higher level target’ as indicated in Council’s Sustainable Environment 2023 statement, however there is no reference to 2007 baseline there. Why is there again reference to 2007 baseline? How much have we already progressed from that baseline?
4.2 To divert 75% of waste from properties serviced by Council (residential and commercial) away from landfill
We support this target. However, there is an issue (perceived or actual) with how much waste is actually recycled and not sent to land fill. This needs to be addressed to give the public confidence in the system.
4.3 To divert 90% of construction and demolition waste generated and managed by Council operations away from landfill
We support this target.
4.4 100% of Council tender specifications include recycled products, where a functionally and economically viable alternative to new materials is available.
We support this target. This figure should be expanded to include reused and sustainably sourced products. How are ‘functionally and economically viable alternatives’ assessed, and by whom?
4.5 Increase the number of businesses in the region involved in Circular Economy manufacturing, design, reuse, repair and recycling of materials by 20% from 2019 baseline
We support this target. How will it be implemented? Why is a 2019 baseline used here? Is it because there was no earlier baseline? More effort needs to go into publicity and creating jobs in the circular economy.
4.6 90% of residents believe it is important for residents of Lake Macquarie to reduce their resource consumption.
We support this target in principal. However, we believe that it is insufficient for residents to just ‘believe’. The wording should be expanded to include a target for residents ‘reporting’ reduction in resource consumption. This is an important and complex issue and at the heart of increasing community understanding of the need for a ‘circular economy’. Dealing with over and inappropriate consumption is the key to a sustainable environment.
