PBCA SUBMISSION ON NOOSA COUNCIL’S DRAFT COASTAL HAZARDS ADAPTATION PLAN. MARCH 2021.
Key recommendations. Council needs to:
· Set up specific programs to educate both visitors and residents of the vulnerability of beach areas to coastalhazards
· Establish a series of CoastSnap positions at various locations along the Noosa coast to monitor the shoreline and amount of sand on the beach; and encourage other “citizen science” projects to monitor coastal hazards
· Educate both visitors and residents on their responsibilities for coastal hazards management
· Appropriately fund dunal rehabilitation as a form of coastal hazard reduction
· Introduce better, and more consistent, enforcement against dunal encroachment
· Establish a policy on public beach infrastructure which also prohibits, or at least regulates, private beach infrastructure
· Develop a comprehensive information paper to address the issue of insurance responsibility and liability
· Regularly monitor the impact of increased visitor numbers to our coastal areas and report regularly on such impacts.
Introduction and overview
,The Peregian Beach Community Association (PBCA) represents the interests of residents of Peregian Beach and Marcus Beach and was founded on residents’ concerns for the future of Peregian Beach’s natural and built environment. Its members engage with issues affecting the Peregian Beach and Marcus Beach areas for the benefit of the community at large. The issue of coastal erosion and its potential impacts on both these locations is of particular concern to residents. As such, PBCA has reviewed Council’s DRAFT Coastal Hazards Adaptation Plan (CHAP) and we offer the following comments on Council’s approach to this issue.
PBCA is generally supportive of the thrust of the draft CHAP and the actions identified to combat the risks identified to our coastal environment. However, climate change and its ramifications are not the only coastal hazard. Population growth, increasing visitor numbers, and biodiversity and species loss are also real threats to our coast and these need urgent consideration when taking into account the additional threat of storms, sea rise erosion and inundation.
As it is now some four years since this process commenced, we urge Council to identify and agree on a number of actions that can be started immediately without waiting for the preparation of a further plan. The Community Adaptation Options Workshop held in December 2018 identified a number of initiatives and we cannot see why these could not be implemented immediately.
The CHAP presents a summary of the findings of various studies, as well as a set of preferred long- term adaptation outcomes and short-term actions for the areas of most concern within Noosa’s coastal zone. Much of the document reiterates findings from previous studies and strategies and is devoted to a description of the development of the plan. While we support these strategies, the CHAP lacks specifics in terms of detailed action plans and we would like to have seen more emphasis on specifics in this regard. We have made some suggestions, particularly in the areas of information and education, that should be included in the final document.
While we understand that the CHAP will inform a wider climate change adaptation program, we are strongly of the view that Council moves immediately to provide an appropriate level of funding for a range of short-term (but ongoing) initiatives. This includes funding and increased resources for dune rehabilitation and regeneration and an ongoing education and information program.
We don’t believe population growth and the human pressures on our coastal environment have been adequately addressed in this draft plan. At the very least, Council needs to adopt a long-term strategy of monitoring population pressures on our coast and reporting those impacts, if not on an annual basis, at least when the Noosa Plan comes up for review and update. With the possibility that Brisbane / South East Queensland will host the 2032 Olympic Games the human impact on our coastal environs, resulting from this event, will be enormous.
The 2011 Baker & McKenzie report on local council risks and liabilities in the face of climate change acknowledged that local government has an important role in providing leadership and education to assist residents and businesses to better understand and accept their responsibilities to address climate change.
While the question of insurance is not directly addressed in the draft CHAP, we strongly recommend that Council develops a comprehensive information sheet to address the complex (and sometimes contentious) issue of insurance responsibility and liability. As part of the adaptation strategy is information and education, we believe this issue needs to be addressed further to assuage any community concerns and to counter the spread of misinformation.
On a positive note, Noosa Council, as recognised, is at the forefront in taking action on climate change and we believe the CHAP provides an opportunity for Council to further promote the Shire’s credentials in this regard.
We acknowledge the science.
We recognise that, despite ongoing international efforts to reduce greenhouse gas emissions, climate change is likely to have significant effects on coastal environments across Australia.
According to Noosa’s 2019 Environment Strategy, regional climate projections indicate that Noosa can expect increased water temperatures, more intermittent water inflows, and more intense rainfall events leading to more severe erosion. Increased frequency and depth of tidal inundation of terrestrial areas not currently exposed to saline waters is expected as a result of sea level rise.
Council acknowledges – and we agree – that climate change poses a serious challenge to Noosa Shire and, ultimately, the planet. Responsibility for responding to the causes and risks associated with climate change is shared by many stakeholders and requires a collaborative approach. PBCA, representing a wide cross section of the Peregian Beach community, is therefore a key stakeholder. Ongoing communication and collaboration with the community is critical.
Given the evidence of climate change and the likely changes in coastal hazards risks caused by rising sea levels, the PBCA is strongly supportive of measures that might be taken to both identify and then respond to those risks.
We strongly support the guiding principle that adaptation responses are driven by scientific evidence, risk management principles and community consultation.
CoastSnap beach monitoring and citizen science
Citizen science can make a significant contribution to the management of our coastline. There is an opportunity here for Council to proactively support the establishment of, and ongoing support for, a number of “citizen science” projects. The most obvious initiative would be the establishment of a series of CoastSnap positions at various locations along the Noosa coast.
CoastSnap stations measure the shoreline and amount of sand on the beach by taking a photo with a smartphone and sharing it through an app or on social media. The information will add to a community database to map shoreline changes. Community beach monitoring can help how we manage our coastal environment. CoastSnap beach monitoring is utilised at a number of locations in Australia but to our knowledge there is only one CoastSnap location on the Sunshine Coast at Alexandra Headland, which falls within the Sunshine Coast Council area.
PBCA also acknowledges the work done by Dr Javier Leon in the field of geomorphology and, in particular, his interest in the study and management of coastal systems. PBCA encourages Council to explore the possibility of a long-term “citizen science” project led by Dr Leon that would contribute to our understanding of the impact of climate change and sea-level rise along our coast.
Planning scheme and insurance
Understandably, there is some concern from residents whose properties could be affected by sea level rises, coastal erosion and inundation.
We note that one of the proposed actions for the next five years is to review and update the Noosa Plan 2020 to ensure the erosion risks to development are appropriately planned for and considered in the design and siting of new development.
PBCA strongly supports the implementation and maintenance of planning controls for coastal development to limit the encroachment of buildings and structures into the vegetated dune areas to preserve natural coastal processes of erosion and sand accumulation. This includes building setbacks from the seaward boundary of lots through the Noosa Plan 2020, as well as State coastal building lines for some lots under the Coastal Protection and Management Act.
The CHAP acknowledges that these planning controls are supported by maintenance of existing vegetated dune areas by Council and local bush care groups to enhance these vital buffer areas including active management of weeds and pests, fencing and replanting.
If Council is serious, through the CHAP, in managing coastal erosion, then it has to take stricter enforcement measures. Private property owners need to be reminded of their obligations and advised that it is not only socially unacceptable but illegal to clear pathways from their properties to the beach.
We note that one of the proposed actions is to investigate the impact of illegal encroachment by private asset owners into publicly-owned dune areas on dune health and natural coastal processes. This has been an ongoing issue at Peregian Beach and Marcus Beach and other localities throughout the Eastern Beaches for many years and it is surprising that Council only now sees fit to investigate the impact of illegal encroachment.
As a general observation, PBCA notes that vegetation management is often ignored in the process of building development.
We are not sure that landholders are sufficiently aware that the Queensland Government State Planning Policy requires planning schemes to identify and manage risks associated with coastal hazards and demonstrate through the planning scheme that new developments will achieve an acceptable and tolerable level of risk for people and property. Given the sensitivity of this issue, particularly to private property owners, we suggest that Council embarks on an information / education campaign on this matter.
Council needs to better explain what its responsibilities are with respect to State planning requirements and that a failure to address these issues will have a negative impact on the values of private properties.
Governments, including councils, are obliged to take possible climate change impacts into consideration when making planning decisions.
We recognise, however, that the question of legal liability is contentious. In view of the sensitivity of the issue we recommend that as part of its communication plan Council takes steps to inform residents of the issues surrounding legal liability and the obligation on councils to take action. Council cannot sit back and do nothing. To do nothing would expose Council to litigation from any resident whose property was adversely impacted by the effects of climate change. Council could be sued for approving developments when the risk of harm was foreseeable; Council could face litigation for failing to include protective standards in planning schemes; Council could face claims for failing to maintain or build infrastructure or conduct coastal mitigation works; and it could certainly face claims for compensation if it failed to provide information on climate risks.
Given the potential for a misinformation and scare campaign, Council should prepare a detailed information paper outlining the legal liabilities that Council has and its obligations with respect to the development of planning schemes.
The Noosa tourism economy
As recognised in the CHAP, the natural character of Noosa’s coastline is a key attractor and point of difference for the local economy. The draft CHAP has rightly recognised that Noosa’s environment and, in particular, its beaches and foreshore are a major drawcard for visitors. Any threat to this environment is likely to have economic consequences. While we recognise the importance of tourism and visitors to the local economy, we also have to recognise that increased visitor numbers can contribute to the degradation of our coastal foreshores. Increased tourism puts pressure on the very environment we seek to protect.
These pressures should be acknowledged in the development of future tourism strategies. We believe the tourism sector needs to acknowledge the threats of increased visitor numbers on the environment and develop strategies to deal with this threat. The visitor sector needs to be targeted with an ongoing education / information programme. Given the long-term nature of the CHAP we urge Council to regularly monitor the impact of increased visitor numbers to our coastal areas and report regularly on such impacts.
Community engagement and consultation
PBCA is strongly committed to meaningful involvement by the community in the planning process. The work of many PBCA members demonstrates not only a commitment to the preservation of our coastal and dunal system but has built up an important reservoir of knowledge and experience of the coastal environment over the years.
We are pleased that as a result of community engagement and consultation, the CHAP recognises the high intrinsic value to the community of our natural and scenic amenity assets, and the strong preference for nature-based solutions that fit with the look and feel of Noosa, and that minimise imposts to natural environments.
CHAP is of considerable interest to the Peregian Beach Community Association given that our membership is drawn from residents of Peregian Beach and Marcus Beach. It is important that community engagement and consultation is maintained on an ongoing basis over the 80-year duration of the CHAP.
Education and information
In addition to the locality specific outcomes and actions, there are a range of actions that are applicable to all or most localities within the coastal zone:
· Improve the awareness and understanding of coastal hazard risks and adaptation measures amongst the Noosa community and other stakeholders.
· Ensure coastal hazard information is publicly available and understandable.
· Engage local business owners and operators in understanding what coastal hazard risk information may mean for them and how they may contribute to achieving Noosa’s adaptation outcomes.
PBCA is of the view that education and information are two of the most critical elements of any adaptation strategy.
While we recognise that due to the current COVID-19 environment opportunities for traditional workshops and presentations might be limited, these should still be utilised where practical, given appropriate health considerations.
As well as traditional communication mediums it is recommended that information is presented at park access points to the beach. For example, permanent visual displays should be erected at Victory Park, Peregian Park and Trespassers Park as well as other locations along the Eastern Beaches.
Signage should provide a broad spectrum of education about the impact of climate change as well as information on the importance of healthy dune systems. Many national parks have information displays about local flora, fauna and topography and a similar approach could be taken in providing information on climate change and the actions proposed to combat the effects of rising sea levels.
The information could be tailored to reflect locality specific issues and remedies. Information on the dunal system at Access 47 (Trespassers Park) is a good example of an education initiative.
Council should also consider permanent and semi-permanent displays at appropriate Council assets such as, for example, the Peregian Beach Community House. Educational and promotional material will need to be updated over the 80-year time frame to keep the community informed of climate changes, changes to the environment, and developments in Council’s approach to the problem.
Given that the Eastern Beaches communities would be amongst some of the main residential areas affected, this would be a logical approach.
Given that the CHAP is a long-term plan, then long-term communication strategies need to be developed and regularly updated.
Visitors to the Noosa Shire – particularly those visiting the Eastern Beaches – often unwittingly contribute to the degradation of our dunal areas through inappropriate use and activities (e.g., occupying and playing on the dunes). Visitors should be a key target audience in any education and information campaign. We strongly recommend that accommodation houses are included in any target audience with specific messages targeted at visitors concerning inappropriate use of the foreshore areas. Council should encourage accommodation houses to include relevant information
on threats to our coastal environment as part of any booking information to visitors. Educating visitors would hopefully not only reduce inappropriate behaviour but leave visitors with a better understanding of the pristine areas that they come here to visit and enjoy.
Identifying assets of importance and their risks
By prioritising assets, Council is able to commit resources accordingly, based on likely asset life, desired function, and vulnerability to coastal hazards.
Protection of Peregian Park is critical. The park is an essential feature of Peregian Beach providing not only recreational and economic benefits to the local community, but also benefits to the many visitors to the village. Peregian Park is an integral part of the local economy and its social environment.
As well as public infrastructure such as the skate park, playground facilities, toilet block, park seating and the surf club, Peregian Park is also the venue for many activities including the popular Peregian Originals monthly musical event, week-end markets, community gatherings and Christmas carols.
Foreshore work that aims to prevent inundation of the Park is deemed a priority.
The risk to the asset/value is determined by combining the likelihood of the event (coastal hazard) with the expected consequence (impacts) of the event on that particular asset/value (e.g., infrastructure asset, recreational facility). Part of Council’s asset management should have a replacement or upgrade strategy that recognises the potential threat.
PBCA recommends that Council budget papers and associated asset management plans clearly identify replacement schedules and projected costs on an annual basis and that this information forms part of Council’s communication program.
Redesign and relocation of key recreational and infrastructure assets
We note that across the coastal areas there are numerous recreational and service infrastructure assets that will increasingly be under threat from erosion over time.
We note that the main assets at risk by mid-late century (2070-2100) in Peregian Beach are:
· Natural assets (e.g. beaches and vegetated dunes);
· Beach accesses;
· Peregian Park and the various community and visitor recreation assets it contains (picnic tables, skate park,footpaths);
· The Victory Park carpark and amenities block;
· and the backyards of a small number of residential lots at the very southern end of Peregian Beach.
· The Peregian Beach Surf Lifesaving Club is itself not expected to be directly impacted during a major erosion event, however operations could be impacted due to damage to the park and beach accesses.
We recommend that as part of Council’s asset replacement program, forward estimates should budget for the replacement of the surf club building that is built to withstand any threat from coastal erosion.
PBCA advocates dune revegetation and management as a major strategy in managing coastal hazards. PBCA itself will continue to be active in this work through its very active bush care group. While we are strongly supportive of the concept of community stewardship and believes this plays an important role, the community cannot shoulder the burden and responsibility without increased support from Council. This has to be a shared responsibility. This strategy includes revegetation and maintenance of at-risk dune and foreshore areas, including weed and pest control and fencing.
Appropriate fencing needs to be intensified and, as mentioned previously, this needs to be conducted with education programs discouraging locals and visitors from defacing and destroying signs and fencing.
Revegetation and dune management is a very low-cost action but will require increased funding commitments to community organisations including bush care groups. Increased funding should commence immediately and be included in the current budget cycle.
We agree with the planned action to expand native vegetation coverage to support frontal dune stabilisation. Council should develop a detailed forward plan that identifies specific areas to be revegetated and rehabilitated. Recent initiatives by the Sunshine Coast Council at Shelley Beach are a good example of what can be done.
We acknowledge that beach accesses may need to be redesigned to deter foot traffic across nearby dunes. Access paths should be fenced on both side of the path to indicate the right path to the beach and to discourage pedestrian traffic from deviating across bush areas.
As indicated elsewhere in our submission we support the installation of signage designed to increase beach user understanding of the importance of healthy dune systems. Signage (sympathetic to the surroundings) along Beach Access 47 (supported by access to print material) is a very successful initiative (See attachment B). Interpretive signage re weed species should also form part of any signage policy.
The recent trend away from planting natives in new home gardens, and the removal of natives, to be replaced by introduced species can have adverse impacts on existing and emerging native vegetation. Planting of native species, especially in areas in close proximity to the coastal buffer zone, should be encouraged.
March 2021. PBCA.