In order to secure grant funding via the NSW Government Coastal & Estuary Management Program to implement actions, a certified CMP required.
Eurobodalla Council are requesting submissions to the draft Estuaries Coastal Management Program for Moruya River, Mummaga Lake and Wagonga Inlet with the closing date for submissions being Wednesday 5 January 2022, 4.30pm
When asked in the meeting as to why this was being prepared and exhibited you will recall the Director responded to the effect ‘ it was to enable the securing of grant funding to carry out the identified works’
Clr Phil Constable moved that the community be given 56 days, and not 28 days as recommended by staff, to enable the community to make informed submissions, given the complexity of the issue and the ramifications that will impact the community and more specifically adjacent and affected land owners.
Clr Pat McGinlay also raised his concerns around the nexus between Mummaga Lake and the proposed developments on land that is directly involved as a catchment to the lake and interfaces with Mummaga. Given Council's recent decision to sell this land it is immediately apparent that the impact of such a development on Mummaga Lake has not been factored.
While works have been completed in the catchments of Mummuga Lake there is no formal estuary plan which considers current land use within the catchments.
It is understood that estuarine CMP's are not mandatory. If this is the case then why is Council moving to put considerable effort into preparing one for Moruya River, Mummaga Lake and Wagonga Inlet?
When asked in the Ordinary meeting of October 26th 2021 as to why these estuarine plans were being prepared and exhibited the Director of Planning responded to the effect ‘it was to enable the securing of grant funding to carry out the identified works’
Council is responsible for preparing Coastal Management Programs (CMPs) in accordance with the requirements of the Coastal Management Act 2016 and the Coastal Management Manual.
While Council say "This is advantageous to Council as a gazetted CMP unlocks funding opportunities via the NSW Government’s Coast and Estuary Grants funding stream" there is another bonus, in that, "Further, a gazetted CMP will provide a degree of exemption from liability to local councils under Section 733 of The Local Government Act 1993."
Opinion : The grants enable Council to employ staff to carry out works. It is a bit of a merry go round where staff are employed to write grant applications to secure funds so that other staff can then spend those funds. Rarely does the grants funding filter out to the private sector. The grants are a cycle to employ people to write Plans that receive funds to put in place actions. When that one is finished the next is lined up ready to do it all over again. And if we are lucky we get thrown grants we didn't even ask for. Like a Juggernaut the Council trundles on and every year gets
The Council agenda of Oct 25th 2021 informs us that:
"A certified CMP enables Council to have access up to 2:1 funding allocated under the NSW Coastal Management Program Fund to carry out the actions identified in a certified CMP. It also contributes to Action 3.1.1 of Council’s Delivery Program 2017-21 to manage coastal use and hazards."
Bottom line is that without a certified CMP Council can't apply for a grant.
In a comment prepared by Ian Hitchcock, Eurobodalla Regional Coordinator, NSW Coastal Alliance, on the Draft Eurobodalla Estuary Coastal Management Program (ECMP) covering Moruya River, Mummuga Lake and Wagonga Inlet he offers;
"Coastal Management Programs (CMP’s) are an integral part of the NSW Coastal Management Act. The programs are intended to protect the natural environment in NSW Coastal Zones and to identify and introduce mitigation solutions for areas of the built environment assessed as vulnerable to sea level rise and other coastal hazards.
A Eurobodalla Coastal Management Program has been in preparation for some years, but has been held up by resistance from community groups in Lower Surfside, near Batemans Bay.
Despite promises made by the local member and other Government Ministers, the Surfside community has been denied mitigation to protect against the ongoing erosion caused by bridge construction and other government works (sea walls) on the southern side of the estuary. The NSW Government has shown a reluctance to protect low-lying coastal communities, even when their own infrastructure activities have caused the underlying problems.
Council has now placed another CMP on exhibition. This time it is an “Estuary” CMP that covers only the Moruya River, Mummuga Lake (Dalmeny) and Wagonga Inlet (Narooma).
Commenced in 2018, the preparation of this program has been drawn out and removed from CEMAC, Council’s coastal management advisory committee. The validity of its separation from the main Eurobodalla CMP has been under question for some time.
Now that the draft report has been released, it might be described as “money for old rope”. Most of the environmental issues identified by the consultants relate to the natural environment and go back a decade or more. Council’s coastal management staff should already have an in-depth knowledge of each and every one of the issues identified.
The author of this response has strong concerns about the consultants understanding and solution to the Myuna / Attunga foreshore management in Dalmeny. The threat of “compliance activities, including fines” against the foreshore residents in this area will do nothing to gain community support for Council’s misguided rehabilitation program. This issue will be covered in a separate paper.
Of immediate concern to the communities of Moruya, Dalmeny and Narooma, especially those with properties in low lying areas, is the exclusion of coastal vulnerability assessments, and related mitigation planning, from the ECMP.
The consultants claim that vulnerability assessments could not be made in the absence of mapping as specified in the 2018 Coastal Management SEPP. The consultants also state that Council intends addressing estuarine coastal hazards as part of their flood studies.
They go on to state that “Coastal vulnerability will not be a key focus for the proposed CMP but may be incorporated in a more rigorous manner at a later date.”
These revelations should ring alarm bells with all affected ratepayers. Council has had over two years to produce the required mapping, and the consultants are now recommending implementation of the CMP by a committee of public servants with NO COMMUNITY REPRESENTATION.
Once this “incomplete” Estuary CMP is endorsed by the responsible Minister, these unelected committee members and council bureaucrats will be in a position to incorporate coastal vulnerability assessments into the CMP without public scrutiny.
Owners, unfortunate enough to have their properties assessed as vulnerable to coastal hazards, will face development restrictions and could find their properties uninsurable against inundation and other coastal hazards. Few mortgagees will offer finance on properties that are deemed to be uninsurable.
Affected residents must be given the opportunity to comment on the proposed vulnerability assessments and solutions before the CMP is submitted to the Minister and set in concrete. Elected councillors should ensure that the release of this CMP is deferred until the vulnerability and mitigation issues have been addressed and included in the proposal. The recommendation that the CMP is implemented by a committee, without community representation, should be rejected out of hand.
The ideological public servants responsible for the development and delivery of the latest NSW Coastal Management Act have to date shown little or no regard for the property rights of coastal residents."
