What is the SEQ RP?
The South East Queensland Regional Plan is the major planning document put out by the Queensland Government Department of Infrastructure and Planning (DIP), which claims to address economic and population growth and climate change issues, and to protect the region from 'inappropriate urban development' (SEQ RP Foreword, p1); the Plan is effective until 2031.
Read the complete SEQ RP document.
Criticism of the SEQ RP:
However, the SEQ RP has come under a range of criticism from conservation groups for its failure to limit urban sprawl, to mitigate climate change, or to protect biodiversit;, the Plan's decisions may even be accelerating biodiversity decline.
Submissions have been made to the 2008 Review of the SEQ RP by conservation organisations such as GECKO, LACA, BREC, QCC and numerous others within the region, pointing out the serious flaws.
Anti-democratic processes of the SEQ RP:
Despite numerous submissions by individuals and conservation organisations over thirty years, as well as to the 2008 Review of the SEQ RP, and recognition of the environmental values in official documents pointing out the unsuitability of the Bahrs Scrub area for development, the 2009 Plan not only extended but fast-tracked the area for development. This total disregard for the concerns and desires of so many sectors in preference for the appeals of a few to profit financially from the land not only points to a very poor appreciation of the value of our nation's natural heritage and our local area's scenic amenity, but also indicates a very serious failure of the democratic processes at State level, inherent in the provision of community consultation on any public project or decision.
LCC representatives have made a case for development of Bahrs Scrub based on the premise that the development was mandated by the State Government. However, notwithstanding such legislation being voted on by both sides of the House, this submission calls attention to the democratic right of the community to express dissent with legislative decisions and to call for the overturning of same. Legislation is not, as Cr Black made out (Community Workshop, Oct 8/09), either immutable or set in stone, and is only as valid as the result of a subsequent election when laws and decisions may be reversed.
The Irresponsible, Out-dated Greenfield Concept:
The State Government has mandated 28 Infill and 42 Greenfield sites in Logan by 2031.
The SBS Alliance challenges the State Govt requirement of 42 Greenfield sites in Logan Shire at core level, as an ill-informed planning decision. SBS further challenges the requirement that the Bahrs Scrub area with its known high conservation values should be included for consideration as Greenfield.
a) Climate Change and biodiversity decline mismanagement:
The SEQ RP claims to 'manage our expanding population...and tackle the issues of today like...climate change' (Foreword, p1). However, by condoning and promoting the development of 'remnant broadhectare lands (p15), much of which is forested, the Plan actually contributes to urban sprawl, thereby mismanaging population expansion and actually contributing to dangerous climate change in the releasing of stored carbon to the atmosphere and destoying vital carbon absorption sinks through the loss of vegetation. The Plan makes some provision for the potential of protecting remnant vegetation, but does not recognise that true remnant vegetation is comparatively scant across the region in present times, and any regrowth must be allowed time to achieve remnant status.
In the modern era of State and Federal acknowledgement of greenhouse gas abatement issues, and the ‘rapid and serious decline of Australian biodiversity’, including the drastic decline of the SEQ koala, also acknowledged by the State Govt, the concept of Greenfield should not be entertained at all. At even a pragmatic level, the concept of Greenfield should not be entertained in such large proportions.
b) Overpopulation and urban sprawl:
Although the SEQ RP purports to promote ‘compact urban form’ (SEQ RP, p15), the requirement of one local authority alone to sacrifice 42 Greenfield sites reflects grave miscomprehension of the concept of compactness. Greenfield comprises spreading urbanisation into undeveloped areas.
With no previous or current policy to stem or cap the unsustainable growth, the SEQ region's population has been increasing at nationally unprecedented rates; currently at 2000 people per week, predictions calculate the doubling of the SEQ population in seventeen and a half years. While such growth may be looked upon favourably by some business sectors, dramatic expansion of human numbers is already severely damaging to the general public's lifestyle and devastating for the natural environment. It is precisely because of population expansion driving urban sprawl that the SEQ koala and many other iconic species are now considered by responsible conservation organisations to be in peril. Thus again, the SEQ RP provisions run contrary to its stated aims of 'protect[ing] our wonderful way of life' or 'continu[ing] to deliver the lifestyle for which we are famous' (SEQ RP, Foreword, p1).
Furthermore, Logan City Council’s allocation of these Infill and Greenfield targets constitutes the City's ‘share’ of the State’s burden of accommodating population increase. However, since the City is already heavily populated and plans major future cities within its boundaries, the City can feasibly be said to have already upheld its ‘share’ of the population increase burden. In addition, the State Govt insistence that coastal shires continue to compress further and further infrastructure within their confines panders to the general preference for coastal, single level residences among intra/interstate migrants. Such pandering serves as an incentive for population increase, and should not be entertained by responsible planning authorities with an eye to the grave results overpopulation poses for the future. Coastal shires should be considered full, even beyond their population carrying capacity.
c) No proximity to exisitng services:
Arguments of Bahrs Scrub’s proximity to the existing, rapidly expanding areas of Beenleigh and Yatala, put forward in the October Community Consultation session by LCC representatives, do not serve as inherent justification for targeting Bahrs Scrub for Greenfield. The BSP is not within walking distance to the transport hub of Beenleigh and major road infrastructure would need to be set in place in order to provide linking serivces for an increased local population, such as buses. The BSP does not fit the SEQ RP description of being 'surrounded by urban development or near existing or planned urban infrastructure services' (p15).
d) Bahrs Scrub does not fit the SEQ RP criteria for suitable development land:
Bahrs Scrub ultimately does not fit the SEQ RP definition of 'remnant broadhectare land' suitable for development.
Regardless of the gross error made by State Govt in mandating and fast-tracking development for the Precinct, closer inspection of the stated SEQ RP principles clearly reveals that Bahrs Scrub qualifies as land which is NOT suitable for development. The SEQ RP document distinctly recognises that land may be 'unsuitable for urban development for other reasons, including constraints such as flooding, land slope, scenic amenity,and the need to protect significant biodiversity values' (SEQ RP, p15). Comprising 70-80% steep slopes, numerous valuable waterways given to flooding, potential rare and threatened flora and fauna species and regional ecosystems, scenic amenity for local people, and significant tracts of remnant vegetation (also mentioned as a criterion for exemption by the SEQ RP (p15)), Bahrs Scrub does not qualify as land suitable for development.
e) Decision can still be reversed by Logan City Council:
Again, despite the claims by Logan City Council representatives and publications that the development of the BSP is a foregone conclusion, decreed by the State Govt, the SEQ RP clearly states that the ultimate development decision is at the discretion of the local authority.
'Local government planning schemes are the main instrument that will establish and refine the desired use of land and the preferred timing of development within the Urban Footprint.' (SEQ RP, p15)
Major constraints such as flora and fauna sensitivity, geological impediments such as steepness of slopes, social concerns such as loss of scenic amenity and overcrowding, or disruption, loss and contamination of important waterways that not only service biodiversity and drain the region, but are a major catchment for the nearby Albert River, make the Bahrs Scrub locality totally unsuitable for consideration as a Greenfield site.
Our State Govt and local Council must make the only decision that can serve the interests of the community, our natural heritage, as well as our responsibility to play a local role in mitigating dangerous climate change. Logan City Council and the Queensland Government must reverse the decison to develop the biodiversity hotspot of Bahrs Scrub, and instead preserve and regenerate the Precinct for all time.
[WRITE TO THE HON. MARGARET KEECH, MP]