Noosa Parks Association Report on SCRC
Rural Futures Background Study (RFBS)
October 2009
The Noosa Parks Association (NPA) welcomes this opportunity to provide input as the planning schemes of the previous local government areas of Maroochy, Caloundra and Noosa are combined. There are however, concerns within the NPA at the very limited public consultation process undertaken by the Sunshine Coast Regional Council (SCRC). We request consideration be given by the SCRC to a review of the public consultation process to allow genuine community engagement.
Executive summary
The Noosa Parks Association supports the SCRC vision of future planning for the region to be based on creating a more sustainable community. The concern is that during the standardisation of planning across the region, the Noosa Planning Scheme is weakened. The Noosa Planning Scheme has the wide support of the Noosa community, with its strict regulations on building height limits, vegetation management, signage, landscaping, and development limitations.
Recent amendments to the South East Queensland Regional Plan have permitted a range of new development activities on land in the Regional Landscape and Rural Production Area (RLRPA). The NPA has specific concerns with the SCRC Rural Futures Background Study 2009 (RFBS). This suggests the SCRC is also considering permitting new accommodation based community, recreational, sporting and tourism developments in the RLRPA.
The RFBS has indicated the SCRC intention to adopt the previous Noosa Council's Rural Precinct Plan for Ecotourism. The Noosa Parks Association has identified rural planning as a significant threat to the Noosa Planning Scheme; therefore we have provided the following report into SCRC Rural Futures Background Study 2009.
We Refer to:
SCRC-RFBS 8.2 Ecotourism Planning
"The previous Noosa Council commenced a planning project on ecotourism. It sought to advance the development of a Rural Precinct Plan to facilitate ecologically sustainable tourism in rural areas. The Rural Precinct Plan would allow for specific land use and subdivision controls that vary from generic regulations within the SEQ Regional Plan. This project is currently on hold pending further decisions on Rural Futures, but could quite easily be rolled out across the whole Sunshine Coast".
SCRC-RFBS 5.2.3 Rural Policy indicates plans to:
"Encourage the development of sustainable rural areas by supporting innovative planning approaches consistent with the Rural Precinct Guidelines".
SCRC-RFBS 5.3.2 Ru7 Growth Management Position Paper Policy proposes to:
"Identify areas (within Rural Precincts) suitable for larger tourist facilities that are environmentally, culturally, economically and socially sustainable and which complement the values of the Sunshine Coast".
NPA Comment:
The Association has previously recorded its objection to Noosa Council's Rural Precinct Plan for Ecotourism with the State Government, Noosa Council, and the SCRC. NPA concerns with the ecotourism strategy include:
· The scale of proposed activities to be defined as ecotourism.
· The incompatibility of large scale resort developments in areas of significant biodiversity or rural land use.
· The relaxation of the SEQ Plan's 100 Hectare subdivision restrictions on rural land deemed necessary to implement the Rural Precinct Plan for Ecotourism.
Due to the impact State planning policy has on Local Government planning, the NPA considers the SEQ Plan critical to the matter of rural land use policy.
SCRC-RFBS 5.2.2 SEQ Plan
Regulatory Provisions
The Regional Plan regulates subdivision and land use in the RLRPA through the Regulatory Provisions. This consists of restricting:
► Subdivision of rural land below 100 hectares, unless in a recognised rural precinct (discussed below);
The regulatory provisions seek to support diversification of rural economies by allowing a range of developments, including:
► Small to medium-scale tourist activities (accommodating less than 300 people)
► Small-scale industry and business activities;
► Community facilities (such as schools and churches) and
► Sport and recreation facilities.
Obviously such development is still subject to compliance with the relevant planning scheme.
5.2.2 Rural Precincts
Local authorities may determine that the Regulatory Provisions applicable to the RLRPA (explained above) need to be varied in order to achieve the desired outcomes for certain rural areas. This could be to protect or promote any rural activities. The Regional Plan provides for local authorities to create 'rural precincts', which could have subdivision and land use controls that differ from the generic Regional Plan provisions. These new provisions relating to these precincts must still uphold the principles and policies of the Regional Plan. "Possible rural precincts include Ecotourism"
"It's also become apparent that there has been a lack of industry development for the Sunshine Coast's tourism industry, and while efforts are being made to market the region as a destination there has been relatively little development or innovation in the industry".
NPA Comment:
Amendments to the SEQ Regional Regulatory Provisions regarding Material Change of Use on rural land fail to protect the RLRPA from inappropriate development. The new provisions exempt a range of development activities from being defined as urban uses of rural land that require the impact assessment they did previously. The NPA objected to these reclassifications as the previous provisions were considered acceptable. The State Governments expansive policies on urban and rural growth are simplistic and fail to avoid conflict over incompatible land use and also fail to provide the necessary services for such growth.
The NPA requests the range and scale of activities described above continue to be assessed as urban uses requiring public consultation and impact assessment under the local planning scheme.
The SEQ Plan allowance for 300 person tourist accommodation land in the RLRPA suggests it is unnecessary to undertake the State Interest Review process to further the Rural Precinct Plan for Ecotourism.
SCRC- RFBS 4.4.3 Tourism and Recreation states:
"Ecotourism, agricultural tourism, food and wine tourism, and animal based tourism are major components of the Sunshine Coast tourism industry". 4.4.3 It then explains "There would seem to be considerable opportunity to expand and develop the hinterland's tourism industry and the range of tourism products provided. For instance there are relatively few certified ecotourism facilities and scope for more agricultural tourism and art and culture based tourism products".
"Neither top end (5 stars) nor budget accommodation is very well catered for at present." and "Development and promotion of a food and wine trail would seem an obvious priority.
NPA Comment:
It appears much of the SCRC rural tourism policy is not recognising what tourism products are already available or the impact on existing enterprises of creating new large scale tourism facilities in competition.
Presently the level of tourism activity in the hinterland is meeting market demand and is generally compatible with the surrounding rural community. The close proximity of the Hinterland's successful tourism precincts with the coastal accommodation strip enables significant day use by tourists without diminishing the character of the rural villages they are enjoying.
The higher level of services required to cater for 5 star resort facilities necessitate the development to be of a significant scale to be viable. Pushing large scale tourism facilities into the hinterland would diminish its character. Provision for Type 3 visitor accommodation in the Noosa Planning Scheme allows for increased development of low impact enterprises that maintain the rural amenity of the places they are suited to.
The Noosa Shire Council Rural Precinct Plan for Ecotourism targeted the relocation of conventional tourism into rural areas based on a change in definitions. E.g. Nature based to Ecotourism. Historically Noosa's tourism industry was built on preservation of the environment to attract visitors to enjoy the regions natural assets. This began decades before entrepreneurs coined the term "ecotourism".
SCRC-RFBS Principle 5.2 Rural Planning Policy 5.2.6
"Protect areas of good quality agricultural land from incompatible development and provide for the expansion of agricultural production".
SCRC-RFBS Program 5.2.7
"Identify strategic agricultural production areas consistent with the nature and diversity of the region's productive capacity and agricultural land uses".
NPA Comment:
Medium to large scale tourism precincts situated in agricultural areas are in direct conflict with the intended outcomes of Policy 5.2.6 and 5.2.7.
State planning policy identifies residential development in the RLRPA as incompatible with rural land use and is therefore prohibited. The large scale tourist facilities the SCRC are considering allowing, require similar service and infrastructure provision to residential developments and are arguably less compatible with rural industries such as forestry, resource extraction and commercial agriculture. Large scale tourist precincts will further fragment the agricultural use of land in the RLRPA.
With the competitive advantages identified in 3.1Rural Production, the Sunshine Coast Region only exploits a fraction of the agricultural potential crucial to the region's future sustainability. Unfortunately State and Local Government policies have promoted flexibility in planning that has encouraged the development industry to stockpile large parcels of formerly productive agricultural land in the coastal sub-regions. This planning strategy has driven land prices up making the Sunshine Coast's rural areas less affordable for agricultural investment.
SCRC-RFBS4.4.2 Other Rural Industries- Extractive Industries
"The expanding construction industry on the Sunshine Coast is reliant on extracted material, particularly rock, sand and gravel. Extractive industries are located in various locations across the Sunshine Coast. They are almost all located in rural areas, due to the need to be separated from residential areas due to potential impacts such as noise, vibration and dust."
NPA Comment:
Tourism developments present a similar need to be separated from extractive industries due to potential impacts such as noise, vibration and dust. An example of the problems caused by the local government approving a tourism development neighbouring a quarry is the current conflict between a Kin Kin quarry and the owner of the neighbouring health resort who is heading the local campaign to have the quarry stopped.
SCRC-RFBS Principle 5.3 Rural communities
Ensure rural communities benefit from regional growth, and participate fully in the planning and development of the region.
NPA Comment:
The Noosa Parks Association does not believe rural communities have been adequately informed by the previous Noosa Council or the SCRC about the extent of proposed changes to allowable rural land use. This is an example of why the public consultation period should be reviewed to enable thorough community engagement in these and other issues for the region.
Conclusion
Although the NPA generally supports the SCRC Rural Background Study as it does contain many statements on sustainability, it does appear expansion of the tourism industry has taken precedence and been the primary focus of Council and State planners. The NPA opposes any amendments to the Planning Scheme that would permit community, sport and recreation, and tourism facilities on rural land with more than 100 accommodated Guests. Rural land use planning by the SCRC should be directed towards:
· Protection of the significant environmental values of land in the Hinterland.
· Facilitating projects that promote the use of rural land for sustainable agriculture, local food production and carbon sequestration.
· Provision of unique low impact visitor experiences in regional areas without compromising their character.
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