Eurobodalla Councillors received an open letter over the weekend from the Dalmeny Matters group ahead of their voting on the draft Draft Estuaries Coastal Management Plan at Tuesday's Council Meeting. The group wrote: "We hope you have a moment this weekend to consider requiring stronger actions for Mummaga Lake under the draft ECMP you will be asked to vote on at Tuesday's Council Meeting. Last year, we discovered that this Draft Estuary Management Plan had failed to take into account the 100 Ha development planned for Dalmeny in the lake catchment area.
However NO CHANGE has been made to the Draft in response to submission about the incorrect population forecasts.
The Draft states that the Development Control Plan will ensure that runoff will be managed onsite and not impact the lake
But the Revised Risk Assessment does NOT support this statement:
“it is rare that development can have a positive or neutral impact when a previously undisturbed part of the catchment is developed, unless a system of offsets is somehow adopted." (revised risk assessment, pg 8, appendix D) No 'system of offsets' is proposed for the Lake Catchment. We hope you will consider asking for stronger actions to protect Mummaga Lake before adopting this plan. We are not trying to take away from the important work this plan achieves. Mummaga Lake is extremely important to Dalmeny and we hope you will act cautiously in regard to its protection. The Councillors were also provided the following to assist them in their own research, and to ask questions of Council staff around the timing of the Draft in its relation to the vote that was made to sell the Dalmeny land in what has been considered by many as a cunning sunt of manipulated timing designed to ensure the sale of the land with Councillors basically left in the dark over the possible consequences to adjacent waterways. Mummaga Lake Left Behind: Draft Estuaries Coastal Management Plan 22/10/22
The Draft Plan makes clear that Mummaga Lake:
Is not presently well understood in regards to water quality and the impacts from runoff
That development in estuarine catchments is linked to the “destruction of important ecosystems” (revised risk assessment, pg 14, appendix D)
And that “it is rare that development can have a positive or neutral impact when a previously undisturbed part of the catchment is developed, unless a system of offsets is somehow adopted." (revised risk assessment, pg 8, appendix D)
The Draft Plan recommends that “future urban development in and around all estuaries needs to be approached with care to ensure that appropriate measures are taken to prevent the decline of water quality.” (pg 34 ECMP final draft)
When discussing the proposed development in Dalmeny, a new section has been added, assuring us that the Development Control Plan will address all issues and ensure that all runoff is managed onsite so as not to impact water quality. (pg 27 ECMP final draft)
This is in stark contrast to the Revised Risk Assessment appendix, written prior to Council’s hasty revision of the Draft Plan after the community pointed out the omission of the proposed Dalmeny Development.
This Risk Assessment states that development most likely will have significant effects “unless a system of offsets is somehow adopted”...(revised risk assessment, pg 8, appendix D)
However NO ‘system of offsets’ is included as an action, or detailed in any way.
Generally offsets work by protecting, restoring and managing another area to achieve biodiversity outcomes. Could this be achieved for Mummaga Lake? What area of an equivalent size and importance could be protected and restored? It seems likely that this is not being considered.
No Environmental Protection Plan?
The Moruya River and Wagonga Inlet each have funding allocated for an action to Restore Wetlands and Implement an Environmental Protection Plan
Why is Mummaga Lake not receiving the same protection? Was this not considered a requirement because of Council’s error in failing to include the proposed catchment development in the Draft Plan?
No Land Identified for Protection?
The ECMP aims to achieve objectives of the CM Act:
● To facilitate ecologically sustainable development in the coastal zone and promote sustainable land use planning decision-making. (pg 13 ECMP final draft)
● To facilitate the identification of land in the coastal zone for acquisition by public or local authorities in order to promote the protection, enhancement, maintenance and restoration of the environment of the coastal zone. (pg 13 ECMP final draft)
However no land is currently identified for public acquisition in the ECMP.
Given that an overarching concern identified is population growth and the effect of development on estuary systems, why are the actions related to planning, development and land acquisition so non-specific and weak?
Authority may lie with State Government legislation and Council planning instruments, but that does not prevent this ECMP from making stronger recommendations which may actually succeed in protecting our waterways from badly managed or inappropriate development.
Dalmeny Matters believes that the public acquisition and protection of the land in the catchment zone of Mummaga Lake is the only real way to protect the lake ecosystem.
The downplaying of the risks associated with the proposed development, which are not even supported by the Risk Assessment attached to the draft ECMP, is unhelpful and irresponsible.
We urge Councillors to consider delaying the approval of the ECMP, and recommending that actions to actually “protect and enhance natural coastal processes and coastal environmental values including natural character, scenic value, biological diversity and ecosystem integrity and resilience” for Mummaga Lake are detailed.