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

               -     Is protecting land within the catchment a strategy that has been considered? Old school acquisition can address some of the identified issues. Although
                     best management practices can be helpful for reducing sediment and nutrient inputs, preserving land along the river and within the catchment (where
                     feasible) can be more effective.
          For the bit about dams, it is hard to tell if flood control and/water quantity management are an issue.
               -     We are finding in the US the decisions made long ago about where and when to store water are biting us on the arse now that the precipitation patterns are
                     changing.
          The septic tank situation also sounds a bit dreary. 41% percent are non-compliant.
               -     In Florida, local governments are now requiring many homeowners and businesses to convert septic to sewer (at the homeowners expense) because there
                     have been so many problems with algal blooms.
          Maybe I missed it but I don’t have good sense about whether the rivers have high levels of hardening which can impact nutrient loads.
               -     It would also be nice to see some map that overlays the various priorities to see if there are hotspots in which you can really make a difference.
          Overall this is pretty much in line with other plans I have seen.

Private   Overall comments
              -     This draft Plan is not good enough – for the 2020s, for a sophisticated, modern, highly qualified, Australian community like Noosa, for the complex socio-
                    ecological system that is the Noosa River, and which is the core of a ‘world class’ Biosphere Reserve.
              -     While producing this Plan would tick the Council’s box of “produce a new Noosa River Plan”, this draft does not do justice to the current Council’s efforts to
                    operate as a high-quality, professional administration. If anything, this Plan would demonstrate only that Noosa Council lacks the capacity to plan and
                    establish an adequate management scheme for the Noosa River.
              -     Implementing this Plan will see flurries of ad hoc activity, but will not produce the substantive results and outcomes that are required for the future
                    conservation and sustainable use of the Noosa River and catchment.
              -     In my view, the draft Plan should not be ratified in this Council’s term; it should go back to the drawing board and its basic flaws should be rectified.
          More specific comments
              -     LACK OF GENUINE COLLABORATIVE APPROACH
              -     LACK OF COHERENT LOGICAL STRUCTURE
              -     LACK OF RIGOUR AND SUBSTANCE

          LACK OF GENUINE COLLABORATIVE APPROACH
             -   The overall Noosa river management scheme should be designed and established as a complete Co-Management Program, in which all the main
                 stakeholder organisations are properly engaged and participating, in all the components of the program: planning, resourcing, governance, coordinated
                 implementation and monitoring & evaluation of the (river management) scheme.
             -   It is difficult to understand why after 6 years, Noosa Council have not been able to establish an adequate mechanism to work with the other agencies
                 involved and produce a plan together for co-management of the Noosa River.
             -   It is not good enough to suggest, as this draft does, that Council can govern or deliver an adequate river management program by itself; it does not have
                 the authorities or capacities that will be required. The management scheme cannot be governed and managed by Council alone, working separately from
                 (i) agencies (QG) with direct responsibility and authority over various aspects of the river system’s well-being and use; or from (ii) the other LGAs with
                 jurisdictions overlapping with Noosa’s.
             -   Why was this Council not even able or willing to form at the outset of the process a suitably qualified external advisory group to guide the preparation of a
                 new Noosa River Plan. It would have been so easy and constructively useful to have done so.
             -   The draft section WORKING TOGETHER is weak, too vague and wordy to be of value. It contains no clear strong specifications of whose or what work will
                 be “done together”. Significantly this section comes before the start of the IMPLEMENTATION section, confirming the impression that “working together” is
                 merely a vague motherhood idea. The IMPLEMENTATION section makes it clear in the first paragraph who owns this plan and who intends to be the
                 governing body with authority over all aspects of the river’s and catchment’s management:
             -   “The River Plan heralds a new era of catchment management in Noosa, and it is Council’s primary role to coordinate and implement the programs and
                 initiatives outlined within the Action Plan.”
             -   (It is perhaps indicative that the author(s) could not resist inserting “and implement…” in this hubristic statement).
             -   It is disappointing that even the introductory Message from the Mayor makes no reference to the Noosa River as the ecological core of the regional
                 biosphere, and thus misses the opportunity to place the management of the Noosa River clearly within the context of the Noosa Biosphere Reserve
                 program. For me this exemplifies the mis-placed Council-centricity of this Plan, for which there does not seem to be an adequate reason.
             -   A related issue further negates the value of this being (only) Noosa Council’s plan for the river’s management: the catchment boundary and Shire boundary
                 are not aligned; significant parts of the Noosa river catchment are in the contiguous Gympie Regional LGA; a significant portion of Noosa Shire is in the
                 Mary River catchment rather than Noosa’s; and the southern edge of the Noosa river system, Lake Weyba, is shared with the Sunshine Coast Regional
                 Council area. Similarly, although the Message makes passing reference to the fact that “much of the river resides in the Cooloola section of the National
                 Park”, it does not take the opportunity to explain that this means that any Noosa River management strategy needs to be based on collaborative
                 governance between 3 LGAs plus the State Government agencies with authorities over National Parks, waterways and coastal marine resources.
             -   These factors make the title of this draft Plan a lie: “The Noosa River Plan – Whole of catchment management”; adding this cliché to the title of the plan will
                 not make it happen if there is no genuine collaborative basis to the management scheme.

          LACK OF COHERENT LOGICAL STRUCTURE
             -   This draft Plan is very weak in terms of logical structure and specification of meaningful SMART actions and planned Results; it is a “shopping list” style of
                 action plan with no clear strategic logic. There is no logical hierarchy of objectives providing the plan with a strong core framework. There are simply 2 sets
                 of 3 Objectives, none written as SMART statements. Similarly there are no baselines, targets, milestones specified for any of the objectives, which further
                 reduces their value.
             -   The core Management Plan – draft 2 is as follows; there is no logical framework structure and no rigour or substance in the specified objectives:

                     River Health and Biodiversity – Not further specified as an Objective
                              Objective 1.        Water quality is improved through whole of catchment management and
                                                  sustainable land use management on land and in riparian areas
                              Objective 2.        Aquatic biodiversity is improved, preserved and enhanced in diverse instream,
                                                  riparian and wetland habitats
                              Objective 3.        Pollution sources are identified, and discharge into the river is effectively
                                                  managed to reduce impacts on waterways, wetlands and coasts.
                     Sustainable Use and Enjoyment – Not further specified as an Objective
                              Objective 1.        Recreational and commercial use of the Noosa River waterways and foreshores is
                                                  undertaken in a way that protects ecosystem health, respects the rivers carrying
                                                  capacity and environment values, and prioritises visual amenity and public safety.
                              Objective 2.        Recreational and commercial fishing is undertaken in a sustainable way so there
                                                  is no long-term decline in fish abundance and diversity.
                              Objective 3.        River mouth and foreshores are preserved and protected to ensure the natural
                                                  form, processes and function of the river are not impacted.
                     Working Together – NOT an objective


               -    The lack of any logical structure and SMART wording makes this draft Plan rather meaningless, in the same way as its predecessor. The lack of clear,
                    rigorous objectives means that success or Recreational and commercial use of the River is to be….. managed? in some vague ways;
               -    Recreational and commercial fishing is to be “undertaken in a sustainable way”;
               -    The river mouth and foreshores are to be “preserved and protected” somehow.
               -    The objectives statements are vague and wordy rather than rigorously SMART. All of them need re-writing as SMART “single level” objectives.
               -    For example, “Water quality is improved through whole of catchment management and sustainable land use management on land and in riparian areas” is
                    a (wordy and vague) two-level objective statement: the higher level objective is to “improve water quality” (more specifications should be provided); in


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