ESC Rural Lands Strategy Proposal – Suggested Points for writing Submissions

Eurobodalla Shire Council is proposing very significant planning changes under their new Rural Lands Strategy Planning Proposal

If we don’t object to these changes the conservation values and long term future of this beautiful area will be compromised. 

There are more than 650 pages of maps and documents involved. 

The exhibition period from 9 May 2018 to 22nd June 2018 seems inadequate.

You can read or download the documents and maps from or hard copies are available at Council’s offices and the three libraries.

If you value our local environment, please write a submission to Council by 22nd June.

Email or snail mail to

The General Manager, PO Box 99, Moruya 2537

Your letter can be as brief as you want to make it – maybe only focussing on 1 or 2 of the suggested talking points below or do your own thing –see the last page here


1. Damage to conservation values and the tourism industry

The largest employer by far in Eurobodalla is tourism and recreation. This industry is based on the beauty, natural values and stunning landscape of the Nature Coast .

The council must protect the natural resources that underpin this industry.

2 Rezoning proposals will have a negative effect on the Shire’s biodiversity. 

The outcomes will affect thousands of hectares identified by experts and State Agencies such as the Office of Environment and Heritage as having High Environmental Values – called High Conservation Values (HCV) in the LEP.

Around 90% of these HCV will be zoned primary production which will allow land clearing and many additional land uses. The Proposal will significantly reduce environmental protections.

Many of the areas are currently covered with intact native vegetation; some are heavily forested with large old growth trees.

If the proposed plan is adopted the result will be more fragmentation of the Shire’s environmentally important bushlands, a loss of habitat and connecting corridors, and a greater impact on threatened species and ecosystems.

3. Reduction in lot sizes will increase land clearing, and reduce habitat for native species.

The Proposal includes a range of permissible lot sizes from a few at 1000 ha down to a majority of smaller lots, many as small as 2ha.

With this sort of subdivision comes land clearing for housing, roads, fences and bushfire protection.

Land clearing is one of the biggest contributors to climate change and endangering native wildlife..

4 Additional land uses – almost anything goes

. (see Vol 1 of the Proposal, Appendix 1, pages1-3 )

The Proposal wants to add many additional land uses for large lot residential (R5) and environmental living (E4) zones. For primary production zones RU1 (larger lots) and RU4 (smaller lots) the Proposal wants open land use. That means you can apply to have any sort of development as long as it is not one of the few prohibited uses. Development proposals for all these zones will need approval but it isn’t often anything is refused, especially for environmental reasons.

5 Council is ignoring expert advice

The consultant hired by Council and the government’s own experts have opposed some of the changes in the Proposal.

State agencies including the Rural Fire Service, the South East Local Land Services and the Department of Heritage and Environment have pointed out that many of the changes are inconsistent with both their advice and Directions from the Minister for Planning.

For example:

South East Local Land Services said in their submission that while broad scale clearing of native vegetation needs approval at the state level, clearing for subdivision, especially on parcels less than 100 ha, generally does not. They wanted subdivision and changes to lot sizes considered in relation to the cumulative impacts of clearing. This has not happened.

Office of Environment and Heritage, Sth East Region is damning in their assessment of the draft Proposal. Like Local Land Services, OEH pointed out that there should be no increased grazing of coastal wetlands (zoned E2). They also said that a number of HCV blocks are still subject to increased subdivision and dwelling entitlement to which the Department objects.

They strongly opposed the removal of the Terrestrial Biodiversity Overlays and associated Clause 6.6. They said, “The use of overlays is essential in identifying areas warranting thorough assessment.. OEH supports the use of the Natural Resource Sensitivity – Biodiversity maps in the current format which define the areas to which the clause applies including i) Extant native vegetation ii) Endangered Ecological Communities and iii) Biocorridors.”

6. The effects of climate change have not been considered

Australia is already experiencing drier conditions, more heatwaves, and spikes in rainfall that can lead to more flash flooding. These circumstances are now confirmed by Australia’s peak scientific bodies such as CSIRO

Land clearing, especially for grazing more methane-emitting cattle, will increase greenhouse emissions.

Retaining intact native vegetation will mitigate the effects of climate change as vegetation provides carbon storage.

7. Concerns about water supply

Current proposals for State Forests will result in much more clear-felling and denser regrowth. This has the effect of increasing sedimentation of streams and reducing water yield once the forests start to regrow. These forests are a major part of Eurobodalla’s catchments.

The Planning Proposal will add to these problems

Creek run off from increased grazing and cleared land will reduce the quality of the Shire’s water supply

The Department of Primary Industry – Water does not think Council has given enough consideration to provision of adequate water supplies as small rural subdivisions will place greater demands on water resources.


Don’t be overwhelmed by the size and complexity of the documents and maps you can just read parts of them (see below)

To help with the jargon —

RU1 zone is Primary Production larger lots, RU4 is Primary Production smaller lots, R5 is large lot residential, E4 is Environmental Living and E2 is Environmental Conservation.

B1, B2, B4, B5 are various Business zones and IN is for industrial zones. On the maps you will also see R2 and R3 Residential Zones which are not proposed to be changed.

You could just focus on some of the pages in Volume 1. (all page numbers are as they appear in the document)

Vol 1 – Appendix 1, Pages 1-10 sets out all the rural land uses that are currently allowed with consent and many of the extra land uses that are proposed to be added. Many of the land uses listed in the tables can hardly be called primary production=farming!

Vol 1 – Appendix 2 pages 28-34 tries to justify having “open land use” tables and grazing in E2 Environmental Conservation zone (wetlands and other endangered ecosystems)

Vol 1 – Appendix 5 deals with how lots are proposed to be zoned, their lot sizes and how many new dwellings will be likely. The tables on pages 45-47 may help you locate your area. Some of the environmental, social and economic impacts are on pages 59-61.

Vol 1 – Appendix 7 pages 67-71 deals with removing the Terrestrial Biodiversity Map (overlays) and relevant Clause from the LEP thus weakening environmental protection

Vol 3 has maps where you can look up your local area. There is an index to the maps then each one has an aerial photo of the vegetation, the areas outlined, and then a page that compares old zoning and lot sizes with what is being proposed. Just because land is proposed to be zoned rural does not mean it will stay vegetated or be used for primary production.


This entry was posted in 2018, Planning & Law - Eurobodalla, Publications, Rural Lands Strategy Planning Proposal, Submissions. Bookmark the permalink.