Wooli is a coastal village south east of Grafton. The old part of the village is on a long, narrow sandy spit between the Wooli Wooli River and the sea. It is under threat from severe storms and sea level rise as a result of climate change.
The Draft CZMP proposes beach nourishment sourcing sand from within Yuraygir National Park.
The Clarence Valley Conservation Coalition (CVCC) believes this Management Plan cannot be approved in its current form as it recommends an option that is prohibited under the Coastal Policy.
There are other options that are not explored or fully costed in the Draft CZMP. These include sand-pumping.
Another major concern is that beach nourishment is only a stop-gap measure. With sea level rise and shoreline recession serious planning should commence for long-term solutions such as re-location of critical public infrastructure and planned retreat from the Wooli Spit.
The CVCC's submission to Clarence Valley Council is printed below:
Submission on Wooli
Beach Draft Coastal Zone Management Plan
The Clarence
Valley Conservation Coalition Inc (CVCC) urges Clarence Valley Council to
reject the draft Wooli Beach Coastal Zone Management Plan (CZMP) in its current
form. It should not be adopted without
amendment for the following reasons:
1. The Plan is inconsistent with the
Coastal Policy
The
guidelines for preparing a CZMP state:
“1. Consider
the objectives of the Coastal Protection Act 1979 and the goals, objectives and
principles of the NSW Coastal Policy 1997.”
Obviously a
prerequisite for this plan is consistency
with the legislative and policy framework established by the Act and the
Coastal Policy. This consistency
does not exist. In fact, its key
recommendation (a beach nourishment scheme with sand sourced from within
Yuraygir National Park) is a clear contravention of action 5.2.9 of the Coastal
Policy which prohibits sand extraction from coastal national parks. On this point alone, this draft CZMP in its
current form should be rejected.
The CVCC is
astounded that a plan that flouts the current legal and policy framework
governing coastal management could be placed on exhibition.
2. The Plan does not offer a long-term
solution to the coastal erosion hazard at Wooli.
While the plan acknowledges the long history of coastal recession on Wooli Beach and that the village’s population and infrastructure are at significant ongoing risk, it does not offer a long term solution. Instead it seems to be suggesting waiting a further decade before serious planning work is taken to address the risk. This ostrich-like attitude may comfort current residents and protect current councillors from their lobbying but it disregards one of the key objects of the Coastal Protection Act. This object is “to encourage and promote plans and strategies for adaptation in response to coastal climate change impacts, including projected sea level rise”.
While the plan acknowledges the long history of coastal recession on Wooli Beach and that the village’s population and infrastructure are at significant ongoing risk, it does not offer a long term solution. Instead it seems to be suggesting waiting a further decade before serious planning work is taken to address the risk. This ostrich-like attitude may comfort current residents and protect current councillors from their lobbying but it disregards one of the key objects of the Coastal Protection Act. This object is “to encourage and promote plans and strategies for adaptation in response to coastal climate change impacts, including projected sea level rise”.
The plan
implies that in the long term some serious planned retreat will be required by
2050 as 50% of the houses and the critical public infrastructure of the water
tower, public school and marine rescue building will be at risk. This process should start sooner rather than
later and be more thoroughly canvassed in this draft document.
3. The costs are under-estimated and benefits
are primarily of a private nature
The costing
for the proposed beach nourishment scheme given in Table 1 of the plan is based
on the least expensive and non-permissible option of extracting sand from
Yuraygir National Park. The least
expensive permissible option should have
been fully costed if the beach nourishment scheme is to be recommended by
the plan for the consideration of the Council and the Minister.
The CVCC
notes that (based on the information in Table 1) 94% of the assets to be
protected by the works are private assets.
While the plan states that funding for the BNS will be apportioned in
consideration of the benefits it provides to both public and private lands, it
would be extremely fanciful to believe that private landowners will be willing
to contribute 94% of the $2.1 million required for each nourishment
campaign. It is far more likely that
taxpayers will be footing the majority of the costs. The Clarence Valley community will gain only
marginal benefit from the works. Is this a suitable use of public funds –
whether or not these funds come from Council or the State Government or a
combination of the two?
The CVCC
further points out that the issue of coastal erosion/recession will increase
along our coastline with sea level rise and the other effects of climate change
including the predicted more frequent strong storms. Obviously all levels of government will find
it increasingly difficult to meet the expectations of those living in at-risk
coastal communities. Council needs to
bear this in mind when considering this Draft CZMP.
4. The potential environmental impacts of
the sand extraction works are dismissed
The plan
dismisses concerns regarding the potential environmental impacts of the works
it proposes. Based on information from a
report completed in 1989, it claims the area in Yuraygir National Park
identified for sand extraction was mined and is degraded. The area marked on Fig. H3 appears to lie
very close to a popular picnic area and walking track at Wilsons Headland and
is well outside the area covered by the mining lease in the 1970s. The area is vegetated and is certainly not
degraded. It can be assumed therefore that the environmental impacts of this
option are much greater than the plan acknowledges.
Much more
detail should have been provided on the other options for sourcing the sand for
beach nourishment – for example: from south of the training wall, Wooli River
and marine sources.
5. Lessons from other beach nourishment schemes
If Council
is committed to beach nourishment, even though it is only likely to be a
short-term stop-gap measure to placate current community members, then it
should heed the evidence of similar
schemes in
Australia. The only ones that work
involve sand pumping bypasses around the barriers to the northerly progression
of sand. This has been proven to work in
the southern Gold Coast and is proving effective at Coffs Harbour to reduce the
coastal erosion hazard at Park Beach.
In the case
of Wooli, this would involve sand pumping from the vicinity of Jones Beach
around the training walls at the mouth of the Wooli Wooli River. It should be noted that there are specific
provisions in the Marine Estate Management Act 2014 which allow for sand
extraction from marine parks for conservation and risk management purposes, and
no prohibition is contained within the Coastal Policy. So, unlike the preferred option given in the
draft CZMP, no legislative or policy barriers exist for this alternative.
Conclusion
The CVCC
regrets that Council has progressed no further in the management of this
section of the coast than it had in 2010.
The current draft plan is a short-term document which does not deal with
the reality of the situation facing Wooli and provides false hope to its
community.
