2021-01-18 GC - Item 2 - Attachment 3 - Consultation Report River Plan Version 2 (2019-20)

Commercial                -    The Plan fails to acknowledge commercial operators, jetty leaseholders and marine businesses as key stakeholders in relation to “Working Together’
Boatman’s                      despite their economic significant, cultural and recreational importance and role as major employers.
Association               -    Council did not respond to any of the feedback provided by our Association on the 2018 draft plan.
                          -    Council has not sought to consult with any commercial operator or our Association in the intervening 1.5 years since the first draft.
                          -    Based on this experience, our Association disputes Council’s suggestion that it wants “genuine partnerships’ as suggested on page 56.
                          -    Page 56 second and fourth dot points state that there have been forums with local community and environment organisations and broad public consultation
                               through to 2019 however our association and members are unaware of any single event, activity or opportunity since the first draft closed in mid-2018.
                          -    Draft 2 of the plan is now being circulated for comments in a compressed timeframe and during the peak holiday period which indicates Council has no
                               appetite for genuine consultation or feedback on its plan.
                          -    We believe these decisions contradict and contravene the plan’s own Objective 1 (page 56) that the “Noosa community is genuinely engaged and involved
                               in the management of the Noosa River.”
                          -    We are strongly opposed to Council rushing the second draft through when it is about to enter caretaker mode when radical steps are proposed and major
                               flaws in the plan need to be addressed.
                          -    We strongly recommend Council extend the consultation until after the election.
                          -    The 3rd paragraph incorrectly states that the community feedback has initiated Council’s push to control recreational use of the river.
                          -    No data is provided to support what our Association considers to be a purely political ambition.
                          -    Our Association strongly opposes Council claiming any mandate or jurisdiction to restrict or control recreational users.
                          -    In contrast, we note however that there is a strong and concerted opposition to many aspects of Council’s river plan and political ambitions to cap tourism
                               and commercial capacity in the region.
                          -    Action required by Council
                          -    Amend plan to acknowledge commercial operators as a significant stakeholder group that has not been actively consulted with to date.
                          -    Provide a written response to the Noosa Commercial Boatman’s Association feedback to the 2018 draft plan as well as its response to this submission.
                          -    The Plan should recommend Council move away from its traditional adversarial model of operation and enter into a new, positive dialogue with commercial
                               leaseholders and marine businesses to support the positive management of the river.
                          -    Establish a River Management Committee to better advise the Mayor, Councillors and management on the long term planning and management of the
                               Noosa River.
                          -    Extend the draft plan’s consultation to after the election to ensure meaningful and adequate consultation.
                          -    Provide data to substantiate this statement or remove it.
                          -    Ensure all statements and strategies abide by existing State and Federal legislation rather than Council’s political ambitions.
                          -    Establish a River Management Committee and commit to active and open consultation with all stakeholders responsible for the river’s health.

                     DRAFT RIVER PLAN (document structure, content, approach etc.)
Private              It is an impressive document to me because of the focus on collaborative effort. The Draft Noosa River Plan is extensive without being unreasonable. It seems
                     possible to achieve the goals in the action plan.

Private              I would like to see access to the Noosa River Plan available on the council web site for everyone to be able to access. I cannot go to the council chambers for
                     viewing.

NICA                 NICA applauds the overall ambition, scope and initiatives of the River Plan and looks forward to participating and supporting Council in its implementation subject to
                     final approval and adoption. Nevertheless, NICA specifically notes the following as areas that may require additional clarity or consideration
                           -   The proposed water monitoring program remains undefined in scope, distribution and key measurement parameters. NICA looks forward to working with
                               Council to designing and implementing this program.
                           -   Management of riparian areas adjacent to the Noosa River system should ideally encompass "whole of catchment" principles including specific program
                               initiatives to identify, monitor, and where necessary, rehabilitate, key areas of seagrass, mangrove, saltmarsh and adjacent habitat. These works will
                               complement existing in-river and upstream initiatives undertaken in the BBF project.
                           -   The enhanced Council (and presumably other stakeholder) attention on compliance of existing regulations is welcome and overdue, though note these
                               measurements are only effective if enforced regularly and in combination with education programs to encourage behaviour change. NICA amongst other
                               organisations would design and implement community education programs in parallel with these initiatives in addition to notifying Council of absences in
                               compliance where necessary.
                           -   NICA notes the continuing lack of consideration of the Noosa River as part of an integrated transport solution linking to existing terrestrial networks. Whilst
                               NICA acknowledges it is not the role of Council to provide point-to-point on-water transport links, both the River Plan and Transport Strategy remain
                               silent on this issue. Thoughtful consideration of how Council can assist river-based commercial operators devise solutions to Noosa's chronic peak
                               transport issues including the use of Council infrastructure would be welcome.
                           -   NICA Notes under the "Working Together" section that Council intends to support community groups assisting in the implementation of various initiatives of
                               the proposed River Plan. Nevertheless, the Plan lacks clarity on which initiatives community groups can assist Council in implementing along with provision
                               of funding for same.
                           -   As the only community organisation directly committed to the sustainable use and conservation of the Noosa River Catchment, NICA looks forward to
                               working with Noosa Council across new and ongoing programs and initiatives of the River Plan to ensure its every success.

Noosa Parks          Version 2 is a considerable improvement to version 1. At least it now has a recognisable logic. And it is a good enough attempt to bear the Noosa Council logo,
Association          which V1 was not.
                          -    However it lacks a strong stretch strategic vision, choosing instead one that is the status quo: “Our vision is that the Noosa River is recognised as the
                               healthiest and most biodiverse system in South East Queensland”. This failure of vision causes the rest of the plan to unravel toward a rather timid list of
                               actions.
                          -    Disappointingly, there is more than a little Noosa Council preening about its prior track record in Noosa River planning and protection, but no
                               acknowledgement of Noosa Council’s track record in being the principal destroyer of the Noosa River estuary’s ecological flows, marine habitat, and
                               biodiversity.
                          -    Perhaps unsurprisingly, at the action end of Version 2, there is little more than vague rhetoric on lower estuary restoration.
                          -    Using river health and biodiversity, sustainable use, and working together as major themes makes The V2 superior to V1. Sticking to these themes in the
                               same order in each section of the plan would improve it further. And using them to structure the risk assessment matrices would lead to more credible
                               matrices than those in V2, which appear to have been reverse engineered from the action list.
                          -    Despite the above misgivings, Noosa Parks Association congratulates and thanks Noosa Council for producing Noosa River Plan V2. It’s the first Noosa
                               River Plan ever produced by Noosa Council that NPA has been able to endorse.

Noosa North Shore    With regard to the Oyster Reef Habitat section we find the opening paragraph very misleading and inaccurate.
Association (NNSA)        -   It is stated …”In the Noosa River system oyster reefs that were once plentiful, became commercially and functionally extinct by the 1940s as a result of
                              intensive dredging of oyster lease areas and the removal of live oyster beds and the underlying bedrock (Thurston 2015). As a consequence, large areas
                              of intertidal and subtidal ‘hard substrates’ required for oyster spat to settle, grow and form reefs, were lost.
                          -   There is ample empire evidence and consensus amongst expert scientists that this is a false statement. We have to remember that back around the turn of
                              the 20th century, there were essentially 2 types of oyster stocks – oyster banks and dredge oysters. The oyster banks reported in Hansard indicate that
                              they were in 50 acre lease sites in shallow tidal areas such as Lake Weyba, whereas dredge oysters were found in isolated areas where solid formations
                              such as rocks and hard river bottom is found. The actual ‘size’ of naturally formed oysters in the river was not immense as portrayed by Council’s selective
                              excerpts from Dr. Thurstan’s report.
                          -   The facts are that the rock oyster industry in southern Queensland peaked in 1891 producing around 21,000 sacks (at 90 kg per sack = around 1890
                              tonnes; Smith 1981; Lergessner 2006; Diggles 2013). Smith (1981) noted that around 80% of the production at this time was generated by oyster banks,
                              while dredge oysters comprised only about 20% of the harvest after the dredge sections were damaged by the floods of 1887, 1889 and 1890. Even
                              though production dwindled from that time onwards, during the decade 1901-10 the industry reached its peak for the number of men employed, banks and
                              sections leased, and boats licensed (Smith 1981). For example, the total number of dredge sections in Queensland reached an all-time high in 1904 with
                              64 leased, but from then on there was a gradual decline.


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