The General Manager
Eurobodalla Shire Council
PO Box 99 15 June 2005
MORUYA NSW 2537

DRAFT EUROBODALLA RURAL LOCAL ENVIRONMENTAL PLAN 1987
(AMENDMENT No 38) Ref No 04.8207

Our Association strongly supports the aim of the proposed amendment "to protect a threatened ecological community and to retain separation between the settlements of Broulee and Moruya". However we do not see how the rezoning to 7(f1) will "afford greater protection than is available under the current land use zone arrangements" for those areas that are now zoned 6(a) Public Open Space.

While the 7(f 1) is an improvement on Rural 1(a) it still allows far too many land uses both with and without consent to be really called an Environmental Protection zone. On the other hand the 6(a) Public Open Space Zone has much stricter limits on the type of developments that are allowed and, apart from the name, seems much more likely to achieve the aim of the rezoning providing that the recreational opportunities really are compatible with the natural environment.

To quote from the objectives of the 6(a) zone -

a) to identify land which is owned by Council or the Crown and which has been set aside for use by the public as open space… This complies with the community's wish that the land remain as Community Land and be managed to conserve the forest, dunes and undeveloped nature of the area.

b) to ensure that a range of recreational opportunities is provided that is compatible with the natural environment…… The area can be managed to facilitate sustainable recreational opportunities while at the same time affording better protection to the threatened vegetation and fauna habitats. The proposed pedestrian-cycleway is just one such use.

We note that the proposed conservation zones at Barlings Beach are also suggested to be zoned 6(a) and many sensitive coastal areas were zoned 6(a) prior to their inclusion in the Eurobodalla National Park. Obviously none of these areas are or were intended for intensive recreational uses such as playing fields.

It seems that 6(a) zoning would give better protection to the land, especially if a Plan of Management for the Community Land addresses the problems of the proliferation of four-wheel drive tracks (particularly near the foredunes), illegal rubbish dumping and too frequent burning (including arson). A cynical person might say that the 7(f 1) zoning is mainly to leave Council's options open to reclassify most of the land as operational and subdivide it into large lots for sale.

The section of land adjoining Broulee Road that is under investigation for future recreational use could also be zoned 6(a) at the same time. Because it has not been burnt as often as most of the remaining coastal forest the understorey here is in much better condition at present. There is a much greater diversity of species and the Sheoaks (Allocasuarina littoralis) have not been killed by fire. It is a favourite feeding area for the threatened Glossy Black Cockatoos. It is very important that the whole of this section be preserved intact at least until the understorey to the south has had time to regenerate.

Image 1   Image 2

Image 1: On the western side of the northern power line easement - diverse understorey in the section of land near Broulee Road not included in the draft LEP. The Sheoaks are used by Glossy Black Cockatoos - March 2005

Image 2: On the eastern side of the power line easement - burnt understorey with Sheoaks killed by fire. Bracken, Burrawangs and Blady Grass are the main plants - all three benefit from fire. - March 2005

CONCLUSION
The proposed 7(f 1) zoning is an improvement on Rural 1(a) but we are not convinced that it is an improvement on 6(a). Ideally we would like to see the land between Broulee and Moruya airport zoned 7(f 2) Environment Protection (Coastal Lands Acquisition Zone) and acquired by the state government as an extension of Broulee Nature Reserve.

Jenny Edwards
Secretary