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]

Development planning for Bahrs Scrub occurs in the modern context of anthropogenic climate change acknowledgement and awareness, biodiversity decline, and a burgeoning world and national population. Social, economic and environmental implications of the above are numerous, diverse and far-reaching; however a unifying thread is the global recognition that past human practices cannot continue without drawing the Earth, its resources, landscapes, and life forms, including the human species, to cataclysm.

Whether individuals and politicl parties choose to accept or reject the legitimacy of the majority of climate scientists who warn that there is an enormous and fatal risk that human activities are casuing rapid climate change, since 2007, the majority opinion of the world's nations is to address this risk. Consequently, nations will implement - or have already implemented - sweeping changes to legislation in relation to bringing down greenhouse gases and emissions reductions targets, albeit some more meaningful than others.

Despite the failure of world leaders at the United Nations COP 15 at Copenhagen in December 2009 to achieve consensus on a binding emissions reductions target, and despite our own government's difficulties in establishing a meaningful legislative approach to addressing the risks posed by climate scientists by introducing either an Emissions Trading Scheme, Carbon Price or other overarching system to effectively bring down greenhouse emissions, there is little doubt that some form of climate change legislation will be set in place for Australia in the near future. Even if Australia fails to implement climate change legislation, the requirements set in place for international interaction by many other countries in regard to their own climate change legislation will have ultimately a significant impact on the Australian economy and way of life.

So, regardless of whether we believe in anothropogenic climate change or not, regardless of whether the Labor Government ETS Scheme is passed or whether the Opposition version, or the Australian Greens' version is implemented, some form of legislation will soon come into place regarding emissions reductions.

For this reason, any project that causes a rise in greenhouse emissions will become extremely expensive. Conversely, any project that contributes to reducing greenhouse emissions will become lucrative.

The conservation of Bahrs Scrub forest will be a valuable asset for Australia, the State and Logan City under pending climate change legislation.

Allowing the destruction of Bahrs Scrub forest will result in very high greenhouse emissions mitigation costs to the Council and the developer; this signiicant cost will be passed on to the ratepayer and the consumer. Allowing this destruction would be a very short-sighted decision by LCC, which still has the opportunity to exercise good judgement and foresight, and recognise that the moral and monetary costs involved in developing Bahrs Scrub are much too high.

LETTER

The decision to develop Bahrs Scrub can still be reversed by Logan City Council!

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 Greenfiield 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 potential biodiversity hotspot of Bahrs Scrub, and instead preserve and regenerate the Precinct for all time.

Logan City Council Community Information so far:

On October 9, 2009, the Logan City Council presented to the local community and interested parties an outline of the Local Development Area Plan for the Bahrs Scrub Precinct.

Cr Sean Black, speaking on behalf of the LCC, claimed that Council had decided to go ahead with development of Bahrs Scrub 'sooner rather than later, in consultation with landowners'. Cr Black also stated that development of the Bahrs Scrub Precinct (BSP) was mandated by the South East Queensland Regional Plan.

LCC staff informed the community that the BSP was to accommodate 7000 -11000 residents over the next 15-20 years; with 15 dwellings per hectare minimum mandated by the State Government to 'create a modern, diverse lifestyle'. Unlike other areas, the Bahrs Scrub Local Development Area (LDA) has a minimum density requirement.

The community meeting was told that the State Government has decreed that development of the BSP must occur before 2031, and has in fact been fast-tracked for development within the next five years. In order to accommodate the unprecedented population growth of the South East Queensland region which the State Government deems must be shared by all coastal Councils,  LCC is required to supply 28 infill and 42 greenfileld sites for development; the Bahrs Scrub Precinct is planned to be one of those 42 greenfield sites.

The proportion of greenfield sites is significantly high despite the urgent requirement of the present era to stem urban sprawl for protection of Australia's fast disappearing biodiversity and to avoid the worst ravages of anthropogenic climate change.The Qld Government itself acknowledges in the South East Queensland Regional Plan (SEQ RP)  the importance of 'Compact Settlement' (Part D8) when defining the Urban Footprint; furthermore, the SEQ RP clearly states that areas within the Urban Footprint which offer 'constraints such as flooding, land slope, scenic amenity, and the need to protect significant biodiveristy values' will be 'unsuitable' for development (see SEQ RP, page 15 ).

Council officers also made much of the public assurance that development of the BSP would be, “ A new and modern community in a sustainable setting” (BSLDA Mission Statement, LCC, 2009); however, this statement is a contradiction in terms, when the physical constraints of the BSP such as steepness of large areas, the QLd Dept of Infrastructure and Planning (DIP) density requirements, existing Gold Coast City Council (GCCC) steep slopes  codes, visual amenity guides, social amenity considerations, and, most critically, potential loss of,or damage to,one of Queensland - and Australia's - biodiversity hotspots.

Neither Council nor the State Government DIP appears to be appreciate or acknowledge that Bahrs Scrub, a potential biodiversity hotspot and a steep region with numerous waterways, presents a series of grave constraints to development, which will either cost LCC (and subsequently the ratepayers) considerable expenditure on comprehensive flora, fauna, hydrological and geomorphological mapping to determine what local residents and concerned conservationists already know, or which will be ignored, with the result that extremely valuable flora and fauna may be lost forever to developer greed and public complacency.

Bahrs Scrub and neighboring residents, highly qualified professionals within the Qld EPA, and conservation-minded indviduals and groups, such as the Save Bahrs Scrub Alliance have long been aware of the stunning biodiversity values of the BSP, which is home to unique rainforest plants as well as rare and threatened plant species, and also serves as vital habitat for a wide range of fauna, including the koala, sugar glider and platypus. These groups and individuals also have a long history of informing governing authorities about the values of Bahrs Scrub; however, decades of submissions, reports and entreaties have fallen on deaf ears, leaving the potential conservation values of Bahrs Scrub officially unrecognised. This lack of official acknowledgement of the flora and fauna of Bahrs Scrub has enabled the Qld Government, the GCCC, and now the LCC to expand the development zonings for the area, and have left Bahrs Scrub unprotected by state and national envrionmental protection laws.

The Bahrs Scrub Precinct has already lost and is losing forest habitat to old, Gold Coast City Council development approvals which never acknowledged remnant vegetation, koala populations or rare and endangered flora in the area, let alone issues such as climate change. Present and completed clearing practices demonstrate no signs of understanding sustainability principles. Furthermore, LCC has no clear or meaningful definition of the word despite numerous public roundtables, committees and regular meetings with conservation groups of the area identified under the banner of 'sustainability'.

 The Council's community workshop in October, 2009 presented the Bahrs Scrub Local Development Area as a fait accompli, citing the stages of the community consultation process as moving from Planning Scheme Amendment to Development Assessment to Construction, as though the ultimate fate of Bahrs Scrub as a densely developed area the size of neighboring Beenleigh were already decided and community feelings were irrelevant.

'Sustainable' development of Bahrs Scrub is a convenient term that belies the impossibility of ensuring the needs of both the infrastructure of whole townships (as a developed Bahrs Scrub would be), and undisturbed and even regenerated natural spaces to accommodate vital and fragile ecosytems are met. Comments from Council officers on October 9/09, such as,'We’ll have to do our homework there' (re regrowth and remnant status of BSP forest and re flooding) or, 'A bushfire threat exists but will go if we cut down trees'  inspire even less confidence in the authority's ability to comprehend an appropriate vision of sustainability for the area let alone implement one.

Urban sprawl and development has no place in a potential biodiversity hotspot.

 Please act now to Save Bahrs Scrub! 

As it stands, the Bahrs Scrub Precinct provides valuable refuge for a stunning variety of plants and animals, some of which have survived nowhere else on the planet. Bahrs Scrub forest and non-forest vegetation also serves humankind by acting as a vital carbon sink as considerable amounts of carbon is stored in trees and plants. When modern development practices decimate a landscape by wiping out vegetation, crucial habitat is also lost and with it the intricate array of species within an ecosystem; planet heating carbon dioxide is also released into the atmosphere when vegetation is destroyed, turning a valuable carbon sink into an emissions source modern civilization can no longer afford.

Australia, the continent likely to be hardest hit by global climate change, is still destroying vegetation at an alarming and irresponsible rate. In Logan City, urbanization is a primary cause of this unsustainable loss of natural habitat as authorities take little meaningful action either to cap population or to stem the sprawling construction of housing and industry to serve this alarming growth.

Since the precise effects of climate change at local level are difficult to predict and will occur over varying time frames, the exact future of Bahrs Scrub flora and fauna is unknown. However, general trends towards a drier continent, with greater risk of fire and drought and inevitable loss of habitat will spell disaster throughout the natural environment, including the special setting of Bahrs Scrub. Climate change will advantage a few species of plants and creatures over others, leading to the loss of the great biodiversity of the Precinct, which has managed to survive the past centuries of development as one of the last remnants of the uncommon vegetation that once predominated throughout the Albert and Pimpama River Valleys. Since climate change will have drastic effects on regional ecosystems, immediate and rigorous protection of what still thrives is warranted.

Predictions for the effects of climate change on ecosystems   make the outlook grim for Bahrs Scrub, the Border Ranges and any small reserve. Studies are already showing the retreat of moisture-providing cloud to higher altitudes, thus affecting tall forests and limiting the re-colonisation of tree species at lower altitudes. Secondary foliage is also being impacted upon by loss of moisture, and fauna such as bird species are either relocating or failing to breed.

Temperature and humidity studies are required for vegetation within the Bahrs Scrub Precinct, the canopy and perimeters require re-afforestation and gullies and niches require retrofitting for water retention to aid the survival of precious fauna in order to withstand the oncoming effects of climate change.

Warnings from scientists and conservationists for decades about the catastrophic risk of global warming and climate change have at last been legitimized by government bodies around the world, including our own. Action on climate change, whether preventative or adaptative, is required in virtually every facet of modern life, none more significant than the practices associated with the spread of urbanization.

While the Australian Government’s present focus is on increasing the nation’s population through high immigration intake and domestic birth incentives, pressure on the fragile ecosystems of this continent from urban sprawl and development, particularly in coastal regions, remains extremely high. Old-fashioned practices such as clear-felling all forest for site preparation, and perspectives which are still attuned to the era of unlimited expansion predominate in the greater majority of development instances, and in policy, legislation and decision-making.

Governments, developers and consumers are still failing to accommodate meaningful climate change action into practice, despite the global consensus demonstrated by United Nations COPs, including Copenhagen 2009, and the rhetoric of public information disseminated by all levels of Australian government, including Logan City Council. While paying lip service to concepts such as ‘sustainability’, ‘carbon storage’, ‘emissions reductions’, and even ‘climate emergency’, the Qld Government and LCC are failing in practice to implement tangible changes immediately required in order to prevent catastrophic climate change, thereby honouring our region’s shared commitment to this global obligation to save the planet. By failing to immediately curtail severely destructive development practices, the state and local authorities are also derelict in their elected duty to protect the natural environment and give local biodiversity a fighting chance against the inevitable and largely unpredictable ravages of climate change.

This is the era when individuals, businesses and governments should be doing our utmost to preserve and regenerate ecosystems of all varieties, especially biodiversity hotspots. Destruction of vegetation in the present time of awareness of the massive impacts of human activity is not merely immoral as we neglect our duty to preserve the lifeforms that share this planet, but dangerous for our own survival, as we speed the processes that are driving climate change. The decision to develop the biodiversity hotspot that is the Bahrs Scrub Precinct is reprehensible and must be reversed. The flora and fauna conservation values of Bahrs Scrub warrant the preservation and regeneration of this precious area within Logan City Council.