YOUR VOICE NEEDED NOW ON KEY ISSUES

The Urban Bushland Council has a long history of advocating for the protection of urban bushland. On this page you will find information about current consultation processes and information to assist you in writing your submission.

Our general advice for effective submission writing is to state your position at the start; comment under specific headings and give a strong concluding paragraph. It can also be helpful to personalise your story using one or more of these ideas:

• I am/we are active community conservation volunteer/s caring for my/our local bushland [NAME IT].  I am also aware of the importance of ecological linkages between our patches
• I have knowledge/understanding about our local environment and the interconnectedness of patches of neighborhood nature
• What is important to you…..   ( eg keeping what we still have…)
• What are you concerned about…  (eg impacts on hydrology  / removal of bushland with impacts on fauna  (inc insects, reptiles, birds, marsupials)

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DRAFT DERBAL YIRAGAN (SWAN) DJARLGARRO (CANNING) RIVER PROTECTION STRATEGY – CLOSED 9 OCTOBER 2024

UBC congratulates the Swan River Trust (SRT) and Department of Biodiversity, Conservation and Attractions (DBCA) teams for this easy to read, comprehensive assessment of threats and a foundational focus on how to respect and protect our Perth Rivers.

However we remain concerned about a number of matters including:

• need for legislative change to reflect the current management responsibilities
• the strategy deals with symptoms rather than causes
• goals are not SMART
• geographic focus is limited to water and foreshores of Swan and Canning
• Swan Estuary Management Park has been omitted
• Environmental vandalism

You can read an overview in the Urban Bush Telegraph, and download the UBC Submission, the full Strategy document and the framework at these links.

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BOARDWALK PROPOSAL – SOUTH TRIGG BEACH – CLOSES 31 JULY

Support the Friends of Trigg Beach protect their patch.

Say No (again) to an environmentally destroying boardwalk through the South Trigg Beach Class A Reserve 46248 Bush Forever Area 308 Sector 6 Trigg Bushland Reserve

The City of Stirling is asking for community comment on what it is calling “Feels Like Scarborough”.  There is a link to its “Pulse Survey” on its website:  www.stirling.wa.gov.au/FLS  by 31 July 2024. Please tell them that you support protection of the South Trigg Beach Reserve for future generations. This survey is open to non-residents of the City of Stirling.

Download their documents here and here. See press article here: Scarborough Beach to Trigg boardwalk back on the agenda as City of Stirling budgets $500k for report | PerthNow

For more information contact Friends of Trigg Beach friendsoftriggbeach@gmail.com

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ANKETELL ROAD UPGRADE (LEATH ROAD TO KWINANA FREEWAY)

This project has been referred via the WA EP Act (here) and the Federal EPBC Act (here).

UBC has requested that this project be assessed via a Public Environmental Review (EP Act) and/ or a Controlled Action (EPBC Act).

In due course we will have the opportunity to make comment on the proposals by Main Roads.

What is at threat?

This proposal will have a significant impact on nationally threatened species and ecological communities.

The ecological communities are:

1. Tuart Woodland and Forest of the Swan Coastal Plain ecological community
2. Banksia Woodland of the Swan Coastal Plain ecological community
3. Honeymyrtle shrubland on limestone ridges of the Swan Coastal Plain ecological community.

and the threatened species are black cockatoos and their habitat.

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PERTH AND PEEL URBAN GREENING STRATEGY: SURVEY CLOSED 7 JUNE 2024

UBC GUIDE available in WORD or as PDF

UBC’s response to focus questions here.

The State Government is developing an urban greening strategy to help make Perth and Peel greener, cooler and more liveable into the future. This strategy is expected to be finalised by the end of 2024. The Strategy will be developed based on the best available evidence and international best practices as well as acknowledging the work of local government and other existing urban greening initiatives. An URBAN GREENING SURVEY has been developed for community input.

Whilst the Urban Bushland Council (UBC) is pleased to see the WA Government focussing on ‘Urban Greening’ we are most concerned about specific aspects of the current plan and problematic omissions. The ecological and wellbeing benefits of ‘tree canopy’ and ‘ecological linkages’ cannot be created in isolation from our natural areas. Diminishing tree canopy, further clearing for housing developments, removal of mature trees on urban blocks, heat island effects, Polyphagus Shot Hole Borer, a drying climate and a long hot summer that doesn’t want to end are all reasons why we should contribute to the development of the ‘Perth & Peel Urban Greening Strategy’

As such, UBC calls on the WA State Government to set and regulate a 30% Tree Canopy Target by 2040.

UBC GUIDE now available in WORD or as PDF

THUS FAR:
27/3 – Briefing by DPLH for member groups and wider community.
Thanks to Nicholas Dufty, Department of Planning, Lands and Heritage (DPLH) for his briefing of community conservation network members – including responding to many questions around scope and primacy of the PPUGS as well as anticipated influence of the strategy on the impacts of residential, industry and infrastructure development across Perth and Peel on canopy and natural areas. Recordings from this session are available on YouTube

10/4 –  Information session on benefits of canopy cover, nature nearby & having your voice heard….
UBC in collaboration with WA Tree Canopy Advocates (WATCA), Wetlands Conservation Society (WCS), Wildflower Society of WA (WSWA), Birdlife WA (BWA) and other organisations held an information session to hear from advocates of the importance of urban greening.

The recording is now available https://youtu.be/qe7_CPbVQWs

We have now completed OUR GUIDE to help you complete the survey about the ‘Perth & Peel Urban Greening Strategy’.  You can find it HERE as a Word document that you can copy and paste from. It is important that the government is reminded of the importance of retaining and managing well our natural areas.

You might also like to read the excellent report by Ecovision or visit Environment House’s guide or visit WATCA’s guide

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APPEAL UPDATE – CLEARING PERMIT 10068/1 – PERTH SURF PARK, JANDAKOT

Stop the Waves of Destruction – Update 2 February 2024

We continue to campaign to stop the Perth Surf Park in Jandakot and save an endangered banksia woodland. This is our last chance to save an endangered banksia woodland from a surf park in Jandakot. The Minister for Environment will make his decision within 2 or 3 weeks on whether to grant a clearing permit for the proposal.

Write your MLA TODAY!

If the surf park is built in Jandakot – an endangered Banksia Woodland, critical foraging habit for black cockatoos and a Conservation Category Wetland will be destroyed. Unbelievably, the site was chosen by the WA Labor State Government! Our public asset must be conserved. It should not be destroyed for a private, commercial venture. This beautiful banksia woodland is worth far more to the community than a surf park.
Please send an urgent message to your MLA asking them to MOVE the SURF PARK. Stop the waves of destruction. Now!

Here’s some Background Information on the project.

Here’s a timeline of recent actions

• 5th February – UBC requests a reconsideration of decision by DCCEEW (Federal government) that surf park proposal is not a controlled action
• 7th February – UBC rebutted DWER’s response to public appeals
• 7th February – UBC requests that the Federal Minister for Environment step in and save the banksia woodland and wetland
• Ongoing – Online Letter Campaign to MLAs – Stop the Waves of Destruction
• Ongoing – Sign the online petition Appeal Against Clearing Permit posted by Heidi Hardisty and supported by UBC. https://chng.it/7VJ9Y4CjZC
• By February 23rd – Write Letter to Minister for the Environment – Ask to move the surf park and save the site. Minister.Whitby@dpc.wa.gov.au
• By end of February – Minister to hand down decision on whether to grant a clearing permit

The Appeal

A clearing permit has been conditionally granted (subject to appeal) for the proposal to build the Perth Surf Park at Lot 800 and Lot 9001 Prinsep Road, and Lot 801 Knock Way, Jandakot. This includes the development and operation of an open water surfing lagoon, accommodation, food and beverage venues, function centre and events space.

The proposal will clear endangered Banksia Woodland, critical foraging habit for the Carnaby’s Black-cockatoos and a Conservation Category Wetland. The Urban Bushland Council deems this an unacceptable loss, asking that the clearing permit not be granted, and that the Minister for the Environment step in and find an alternative site for the surf park.

The Appeals Convenor Committee is currently investigating public appeals against the project. The investigation ends February 7th. The Minister is expected to hand down his decision on whether to grant a clearing permit soon after that.

It is urgent you write your MLA now. You can click on the link and use the online letter template or send your own message. It’s not ok to destroy nature for a surf park!

Key points:

• The building of the surf park in Jandakot will result in the destruction of an endangered Banksia Woodland, vital foraging habitat for our endangered Carnaby’s Black-cockatoos, and a Conservation Category Wetland.
• The surf park is a commercial venture for mainly private benefit. The beautiful banksia woodland is worth far more to the community if left intact.
• A clearing permit for the project must not be granted by the Minister for Environment. The clearing of this public asset would cause permanent and serious environmental harm to nature and is seriously at variance with a number of Clearing Principles under the WA Environmental Protection Act.
• The clearing will have “significant residual impacts” on Matters of National Environmental Significance under the federal Environment Protection and Biodiversity Conservation Act.
• There are grave concerns about the enormous quantities of water that will be used to operate the surf park when Perth is already suffering from water shortages.
• The offsets proposed are completely inadequate to compensate for the significant and cumulative environmental impacts of the proposal. There will be a net loss to the area of nearly 6 hectares of native vegetation.
• Jandakot cannot afford to lose any more green space as the community is undergoing a barrage of development – against their wishes and best interests. The Glen Iris Golf course has been closed for housing and rural residential lots will be turned into concrete urban blocks.
• Save this endangered Banksia Woodland and Conservation Category Wetland. Make a conservation park for the benefit of all.

UBC requested that the clearing permit not be granted. Download UBC’s guidance for your appeal

UBC’s guiding points have been developed with the assistance of Heidi Hardisty (UBC), Margaret Owen OAM (UBC) and Dr Megan Jaceglav (The Beeliar Group).

Photo by John Blakey

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SUBMISSIONS CLOSED – SUBDIVISION OF LOT 123 MORTIMER ROAD CASUARINA

UBC has published its guiding points for YOUR submission  for the protection of this extremely high quality patch of Banksia woodlands. 

Lot 123 Mortimer Road Casuarina (Lot 123) is 45 hectares (ha) in size, and is proposed to be subdivided into two lots; one conservation lot of 7.9 hectares (ha) and a balance lot for residential development. Lot 123 contains excellent quality Banksia woodland vegetation, threatened fauna habitat, and a conservation category wetland. The Level of Assessment was set at Referral Information with Additional Information (2 weeks public review). The additional information published for public review is required for the EPA assessment:

• of the potential impact on Flora and Vegetation
• of the potential impact on Terrestrial Fauna
• of the potential impact on Inland Waters
• to align with the Commonwealth accredited process.

Public submissions are to be received by the EPA by 4 December 2023. You can find the link to the EPA’s page here.

Images with kind permission of  Cate Tauss from her independent assessment of the flora, vegetation and wetlands of Lot 123 Mortimer Road, Casuarina in Western Australia for the City of Kwinana (2021)

SUBMISSION ADVICE

UBC’s guiding points have been developed with the assistance of  Mary Gray OAM (UBC), Cate Tauss (Tauss and Associates Biodiversity Consultants) and Christine Burtenshaw (City of Kwinana). In summary UBC recommends:

• Subdivision of Lot 123 Mortimer Road Casuarina to allow for urban development with clearing of ~38 ha of high quality native vegetation is totally environmentally unacceptable under each of the EPA significant factors and Matters of National Environmental Significance (MNES) as detailed above and should not be permitted. It is not developable land. It is therefore strongly recommended that the proposal in all variations be rejected.
• Further, as the owner wants to sell the land, it is strongly recommended that all of Lot 123 Mortimer Road be acquired by the WAPC and then transferred to the Crown and added to the conservation estate as an ‘A’ class reserve for the purpose of conservation of nature.
• Also, that it be vested in and managed by the City of Kwinana. Notably, this is consistent with the WA Native Vegetation Policy, and also with the UN Biodiversity Agreement (December 2022) to protect at least 30% of native vegetation, and with the highest priority for protecting highly biodiverse ecosystems such as this.

We have also received this submission advice – follow the link here.  It contains information on the background to the consultation process plus a summation of environmental significance to assist with submissions and have been asked to distribute the information and referral portals links to our community Groups. Lot 123 is a regional ecological asset worthy of retention and protection through the State and Federal Government planning process.

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SUBMISSIONS CLOSED – MAIDA VALE URBAN PRECINCT

METROPOLITAN REGION SCHEME (MRS) AMENDMENT 1344/57 MAIDA VALE URBAN PRECINCT

This amendment proposes to rezone approximately 177.53 ha of land in Maida Vale (City of Kalamunda) from the ‘Rural’ zone to the ‘Urban Deferred’ zone in the MRS. The proposed ‘Urban Deferred’ zone will facilitate future residential and areas of public open space. Following the lifting of ‘Urban Deferment’, a local scheme amendment, detailed structure planning and subdivision approval  will occur under the Planning and Development Act 2005. The ERD may be downloaded from the Department of Planning, Lands and Heritage (DPLH) website either here  or at their consultation hub here

AERIAL IMAGE – EXTRACTS: Pages 1075-1076
360 Environmental – part of SLR (2023) WA Planning Commission Metropolitan Region Scheme Amendment 1344/57 – Maida Vale Urban Precinct Environmental Assessment Assessment No: 217 Environmental Assessment

The Urban Bushland Council is concerned that this amendment will result in the removal of habitat trees, shrubs and grasses including as an ecological linkage for our iconic black cockatoos.  In addition, removal of trees increases the heat island effect, contributes to climate change and removes the aesthetic value of having nature in our suburbs. It contradicts the Native vegetation policy for Western Australia  to have a net gain in native vegetation – not an ongoing deficit.  The current vegetation also contributes significantly to the The 3-30-300 Rule for Healthier and Greener Cities : NBSI where everyone has:

• 3 medium-large trees within sight of their home
• 30% canopy cover in their suburb and
• a park or green space within 300m.

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SUBMISSIONS CLOSED – CLIMATE CHANGE BILL  

The State Government has committed to introducing climate change legislation to contribute to national and global goals for decarbonisation, provide certainty for business, and attract the investment required for the transition to net zero emissions by 2050. Their explanatory paper is here.

Our changing climate has been of great concern for UBC and member groups and supporter. One of the biggest disappointments in the proposed bill is the delay by 20 years in reaching net zero emission targets – i.e. 2 decades later than the rest of the nation. We have an opportunity to remind the WA State Government of their responsibilities. 

The State Government’s Explanatory Paper indicates that the legislation will ensure accountability and transparency for government:

• establishing WA’s long-term target of net zero emissions by 2050
• provide statutory requirements to set interim emission reduction targets
• provide statutory requirements to develop policies to reduce emissions and enhance climate resilience.
• require the Minister for Climate Action to set a 2030 target for State Government emissions as soon as practicable after the Act comes into operation
• require the Minister for Climate Action to report annually to Parliament on WA’s net emissions and progress against the emission reduction targets.

Extract from response of ‘The Australian Institute’

Weak WA Climate Bill a Blow to National Emissions Target, September 20, 2023

Details about the WA Government’s proposed climate change bill demonstrate that it is an inadequate and inappropriate response to the state’s rising energy emissions, and deal a major blow to the Federal Government’s 43% emissions target.

Key points:

• Despite the urgency of climate action, the proposed bill fails to require the WA Government to set a 2030 target in line with other states and the Commonwealth.
• The proposed bill also will do nothing to prevent more enormous new export gas projects, including Woodside’s North West Shelf extension, which would result in almost 400 million tonnes of emissions in WA, and 4.3 billion tonnes globally.
• The explanatory paper for the proposed bill contains no measures to rein in the rapidly rising emissions of the gas industry, despite gas industry emissions making up almost the entire increase in WA’s energy emissions since 2005 and endangering Australia’s national emissions targets.
• Official data shows that WA’s energy emissions have increased by 53% since 2005, driven by increased gas exports.
• LNG emissions have increased by 26 million tonnes per year (400%) since 2005 and appear to account for almost the entire 26.8 million tonnes increase in energy emissions.
• Fugitive emissions, mainly from the gas industry, are up an incredible 128% since 2005.

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SUBMISSION CLOSED  – ROCKINGHAM INDUSTRIAL ZONE

7 day call for public comment – Rockingham Industry Zone Undeveloped Land Derived Proposal Application 

You may be aware of this proposal area as ‘H2Perth’ – when Woodside Energy Technologies Pty Ltd proposed to construct and operate a domestic and export scale hydrogen and ammonia production facility, located approximately 40 km south of Perth in the Cities of Rockingham and Kwinana.  In June 2023 UBC responded that ‘H2Perth’ should be assessed at the level of Public Environmental Review (PER) due to many things including its importance as ecological linkages and the presence of Tuarts.   Download our submission here.

The new ‘proponent’ is the State Government via DevelopmentWA and the proposal is for industrial lot subdivision. 

The new proposal is a derived proposal, authorised by the Rockingham Industrial Zone Strategic Environmental Assessment, Ministerial Statement 863 (EPA report number 1390) and would consist of the development and subdivision of undeveloped land in the Rockingham Industrial Zone into 13 superlots, with roads, easements and services. The proposal would include the total disturbance of up to 269 hectares for industrial lots within the Rockingham Industrial Zone Strategic Environmental Assessment. 

It is out for 7 DAYS of PUBLIC COMMENT regarding whether it should be assessed. And if so, what level of assessment. We urge you to request a PUBLIC ENVIRONMENTAL REVIEW (PER) level of assessment.  You have 500 word limit.  It is best to respond under the EPA’s relevant ‘Environmental Principles & Factors’ similar to our last call for a PER for this area 

UBC in most concerned that the proposal is relying on environmental information collected and analysed 14 years ago (fauna) and 25 years ago (flora and vegetation). The current 2023 proposal under consideration has relied on PGV Environmental 2013 plans for ‘Environmental Management’ and ‘Construction Environmental Management’ that have in turn relied on: 

• Flora and Vegetation Surveys completed in 1998 (Trudgen and Weston) and 2006 (ATA)  
• Fauna Survey completed in 2009 (Coffey). 

In addition, UBC is concerned about the: 

• clearing &/or disturbance of Threatened Ecological Communities (TECs) 
• impacts on habitat for endangered fauna (and other fauna) 
• removal of critical ecological linkages. 

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SUBMISSIONS CLOSED – ROE 8 / 9 CORRIDOR

Metropolitan Region Scheme (MRS) Major Amendment 1404/41 Roe 8 Remainder and Roe 9

You can find  UBC’s submission here.

The ‘Cockburn Community Wildlife Corridor Inc’ (CCWC) continues to support the Roe 8/9 land being developed as a connected green corridor “Wetlands to Waves”. This could be created by rezoning all the corridor as Parks & Recreation (P&R) and including it within the Beeliar Regional Park. In addition, the wider community /public understandably believes that the Roe 8/9 Corridor has been conserved for conservation and recreation.

However, the draft MRS includes significant urban infill.  Furthermore, it does not reflect community wishes already submitted during the earlier consultation in January when the UBC joined others and called on the WA government to adopt a visionary approach to the Cockburn Green Corridor that will:

• Conserve and protect all existing native vegetation along the corridor, including the areas currently reserved for intersections.
• Restore ecosystems along the corridor to create viable ecological connectivity.

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SUBMISSIONS CLOSED – PUBLIC OPEN SPACE

Draft Operational Policy 2.3: Planning for Public Open Space (POS) – details here 

Public Open Space (POS) provides many essential benefits including enhancing local neighbourhoods, people’s lifestyles and improving health outcomes. POS takes many forms and serves a range of functions but are typically identified as a park. The Western Australian Planning Commission is advertising the draft new planning policy on public open space, intended to replace Development Control Policy 2.3 – Public Open Space in Residential Areas.

Public Open Space is also critical for many issues of concern to bushland/ wetlands/ coastal groups including ecological linkages/ greenways and reducing heat island effect. UBC will be making a submission and we encourage you to also send your own comments into the WA Government and remind them why Public Open Space is important for you, your neighbourhood, and the environment. You can find a copy of our Draft submission here.  Submissions closed 22^nd September

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APPEAL PERIOD CLOSED – FOREST MANAGEMENT PLAN

You can find UBC’s Appeal here.

The EPA has recommended the proposed Forest Management Plan (FMP) 2024-2033 be approved subject to conditions relating to reporting, as well as the recommendation of an independent scientific review of prescribed burning.  The EPA’s report to the Minister for Environment is now open for a three-week public appeal period, closing 25 September 2023. Appeals are lodged at the Appeals Convenor’s website via this link.

A positive is the recommendation for “An independent review under the Environmental Protection Act 1986 would call on the expertise of independent scientists to consider prescribed burning approaches and implementation”. There are however concerns regarding other aspects including the misnomer of ‘ecological thinning

The UBC continues to be highly concerned about the proposal to thin any of our natural areas and thin up to 8,000 ha of forest every year – being 1,500 ha more than the average area logged per year over the past 10 years. We are concerned because we believe there will be:

• Significant detrimental impacts on plant communities and individual species; fauna communities and individual species; soil compaction; hydrology; surface water; and fungi
• Spread of weeds and diseases including Dieback and Marri Canker. It is disturbing that at least 242,100 ha is infested with Dieback and that >40% of southwest flora species are considered vulnerable to Dieback in the FMP area; and
• Forests are naturally self-thinning, and this ‘imposed thinning’ should be allowed to happen. Therefore, thinning should not be permitted. This should be explicit in the FMP.

UBC supports the WA Forest Alliance in its position on ecological thinning. 

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SUBMISSIONS CLOSED – GREATER BRIXTON STREET WETLANDS

Submissions closed on on 28 August, 2023. You can read our dedicated campaign page here.  The UBC final submission is here.

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PREVIOUS SUBMISSIONS

You can read our past submissions in our Resources section here.