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

     -     The Plan fails to comprehensively assess sub-zones within the river such as lakes or urban areas or provide specific responses to zone issues.
     -     The current piecemeal approach is considered inadequate in scope nor properly consulted with key marine environmental reference or research groups.
     -     Proposed action
     -     Plan needs a defined scope as to whether it is referring to inland/upriver waterways or all river and coastal areas.
     -     Plan then needs to be revised to align its scope (e.g. If it is only addressing river, then it should delete coastal references).
     -     If it is addressing upriver and coastal issues, then it needs significant additional work rather than the current piecemeal approach to selective species and
           topics.
     -     Plan should comprehensively assess and profile each major region in the river to provide strategies and actions that are properly responsive to each
           region’s individual issues.
Actions not related to issues
     -    The first draft of the Plan (page 7) stated that the river was under pressure from many sources including recreational users and environmental impacts but
          did not attribute a single issue to commercial operators.
     -    The second draft similarly does not attribute a single issue or environmental impact from commercial operators however the report continues to
          inappropriately recommend Council taking control of commercial operators.
     -    The second draft similarly does not attribute a single issue or environmental impact to commercial operators, however the report continues to
          inappropriately recommend Council taking control of commercial operators.
     -    Action required by Council
     -    Council should ensure any actions are directly linked to clearly identified/and prioritised issues.
     -    It should not include vague political agendas in the plan if they are not causally linked to an actual issue that can be objectively assessed as causing
          negative impacts on the Noosa River.
Marine knowledge and experience
     -    Plan makes various references to marine safety and marine infrastructure however does not properly reference existing legislation, agency responsibilities,
          international regulations or do so with the input of appropriate marine qualifications.
     -    Many statements appear to be personal opinions and lack baseline data (eg. Boats regularly break free of their moorings and damage infrastructure) or
          understanding of marine regulations (eg. Duration for anchoring and marine pollution).
     -    Plan appears to be a desktop study and has no reference to baseline data for marine incidents.
     -    To our knowledge, Council staff / authors do not have any marine qualifications and/or on-river experience nor have they consulted with any industry
          members or marine experts.
     -    Actions required by Council
     -    Plan needs to be peer reviewed by marine industry experts.
     -    Plan needs to have input of State and Federal agencies before further considered by Council (noting it would be highly inappropriate for Council to approve
          a plan that recommends Council taking actions that would breach State and Federal laws (e.g. in relation to authority to enforce compliance).
     -    Plan needs to be edited to remove personal perceptions and unsupported anecdotes that have no baseline data.
     -    Plan needs to engage with industry in relation to marine infrastructure issues and strategies.
Implementation Plan
     -     To be effective, Objectives need to be specific, measurable and have a completion date.
     -     Most actions lack a completion date and are inappropriately vague which will make the plan fail and responsible officers unaccountable.
     -     Actions listed as for completion by 2030 need to have sub-actions with earlier completion dates so progress can be tracked on an annual basis.
     -     Actions required by Council
     -     Revise the Implementation Plan to provide more specific, measurable actions with clear completion dates that happen on at least an annual basis.
Users
     -     The report makes inappropriate and subjective distinctions between residents and visitors (e.g. Objective 2 Residents and Visitors are compliant ….”)
           without reference to any data or baseline data to infer either group causes different impacts or warrants different approaches.
     -     Council has no data that would enable them to differentiate between residents and visitors using the river. State and Federal marine regulations apply
           equally to all users.
     -     Action required by Council
     -     Remove inappropriate distinctions between residents and visitors.
 Message from the Mayor
     -     Accolades to environmental activists being the exclusive protectors of the river are inappropriately dismissive of the community and industry’s efforts over
           decades.
     -     The Mayor’s accolades for the Noosa Parks Association adds to a community perception of a conflict of interest given his relationship with NPA.
     -     Our members have operated continuously on the Noosa River for 70 years and are significant stakeholders who have contributed to the river system’s
           success and sustainability, yet are denied meaningful consultation and their feedback to draft 1 has been ignored.
     -     The broader community are significant contributors to the river system’s success and sustainability through their careful use, volunteerism and advocacy.
     -    Action required by Council
     -    Rewrite the Mayor’s Message to respect the many stakeholders that have contributed and continue to contribute as stewards of the river.
     -    Remove reference inferring that business owners have been actively engaged in this process as Council has had no active engagement with them.
Introduction (page 5)
     -    The document states “The Plan applies to Noosa’s freshwater creeks, wetlands, lakes, river estuary, coastal creeks and groundwater, and incorporates a
          whole of catchment approach to land based and on-river activities.
     -    The Plan also seeks to reduce diffuse pollution flowing from the land, to enhance the health of our coastal waters, beaches and reef.”
     -    This scope is not applied consistently throughout the document nor is adequate regard given to non-river borne pollution issues that are affecting Laguna
          Bay.
     -    Examples of weaknesses includes usage issues associated with adjacent coasts (eg. dune protection, camping, 4WDs on beach, camels, national park
          etc).
     -    No reference to usage and litter issues associated with Hastings Street / Main Beach being the most highly used zone.
     -    There is no reference to litter pollution strategies such as beach cleaning.
     -    There is no comprehensive review of species. Most coastal species are ignored however there is an unusually large focus on the occasional marine turtle
          visit to the North Shore.
     -    No regard is given to significant species changes such as reported reduction in sand and mud crabs in the river or matters such as growing whale
          migration through Laguna Bay.
     -    No reference to shark nets.
     -    No other reference to “reef’ in the report despite there being several in close proximity.
     -    Action required by Council
     -    Broaden the report to ensure it is comprehensive and addressing all known issues before prioritising strategies.
     -    Undertake public consultation on new strategies.
Errors (page 31)
     -    Spelling errors
     -    Action required
     -    Correct spelling errors with NICA and Sea Shepherd
Hincksia Blooms (page 37)
     -    Hincksia research referred to is 2006.
     -    Plan states Council “put in place a more proactive strategy should Hincksia blooms occur again” but the examples provided refer to a workshop and a
          sample collection program.
     -    Reference is made to a management strategy being developed in future however we believe sufficient time has passed for Council to have formed a view
          on what it will do if elevated nutrient levels are detected and/or another outbreak occurs.
     -    Actions required by Council
     -    Plan should reference more recent research if available.
     -    Plan should provide details on what Council will do in the event of another Hincksia outbreak.
Living on the river (page 45-46)


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