060610hg attach 1 - city of joondalup · attachment 1 page 2 c:\documents and...

$: 060610hg attach 1 - City of Joondalup · Attachment 1 Page 2 C:\Documents and Settings\gilliank\Local Settings\Temporary Internet Files\OLK3\060610hg attach 1.doc$
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Attachment 2 Page 1 SUBMISSION TO WESTERN AUSTRALIAN PLANNING COMMISSION –

DRAFT GUIDELINE FOR THE DETERMINATION OF WETLAND BUFFER REQUIREMENTS


NO DOCUMENT REFERENCE

TECHNICAL COMMENTS

1 Size and complexity of document

The draft document is comprehensive, highly explanatory and relatively easy to follow. As a result, the 72 page document is substantial in volume. This may dissuade the user from properly utilising the information provided and it is suggested that the size of the document be significantly reduced to facilitate ease and effectiveness of use.

2 Responsibility and skills for

assessment under the Guideline It is stated in the Introduction that “the guideline has been developed to assist landowners, developers, planners and architects to identify an appropriate buffer between wetlands and land uses…”, and that “it should be used where a change in land use or development is proposed in the immediate vicinity of a wetland where these may conflict with the established wetland management objective”. It is, however, unclear who would be required to undertake an assessment of the adequacy of a wetland buffer. If the intention is that local government officers are held responsible for assessments. Should this be the case, this would place additional resource burdens on the City, particularly given the potential length of the assessment process. In addition, applications are likely to vary in their details and level of expertise depending on whether or not an environmental consultant is employed to prepare or supplement the application, placing more responsibility on assessing officers.

In view of the above points, it is suggested that it is critical to desired outcomes that steps 1 & 2 of the assessment process are undertaken by DoE or EPA officers. The assessment process could take a significant amount of time which is an additional cost to Councils in terms of resources.

3 Cross-referencing to other texts A number of references are made to supporting texts and documents in terms of explanations and legislation. Given that access to these documents may not be readily available to the applicant/consultant or the assessor, it would be preferred if all necessary information was included in the body of the document.

4 Step 1 and Application Note 1 –

Acknowledge existence of wetland Regarding Step 1, it is noted that wetlands catchments are difficult to identify on the WALIS site, particularly if the site is cleared or urbanised. It is suggested that the dataset should be made easier to use.

5 Step 2 and Application Note 2 – Identify wetland attributes, wetland management category and establish

Regarding Step 2, management objectives for wetlands are difficult to locate on the WALIS site. It is suggested that a complete list of all wetlands and their attributes be compiled by the Department of Environment (DoE) or Environmental Protection Authority (EPA) and made available to all local

Attachment 2 Page 2 SUBMISSION TO WESTERN AUSTRALIAN PLANNING COMMISSION –

DRAFT GUIDELINE FOR THE DETERMINATION OF WETLAND BUFFER REQUIREMENTS


NO DOCUMENT REFERENCE

TECHNICAL COMMENTS

management objective

governments and applicants/consultants.

6 Step 4 and Application Note 4 – Identify threatening processes

Regarding Step 4, it is suggested that a “threats to wetlands list” be provided to local governments and applicants/consultants by the DoE or EPA, or be made available on their websites.

7 Step 7 and Application Note 7 – Apply separation requirement to proposal and assess its ability to achieve management objective

With regard to making a case for an alternative separation requirement to meet the management objectives of a wetland, as set out in Step 7, it is considered that this should occur at the beginning of the assessment process and clearance provided by the DoE or EPA prior to an application being submitted to local government.