Following the workshop with the Envionmental Defenders Office (EDO) on May 7 I have compiled this guide to help people to make an effective submission to the Draft Plan. The notes that were used at the EDO workshop are available here.
This guide includes information taken from the EDO guide to making submissions. Please make reference to the Draft Plan as you compile your submission. When you are ready please feel free to make use of the template submission example here.
The Draft Plan is produced by the NSW Department of Planning and the Environment. It is a proposed blueprint for the next twenty years of development in the region. It will guide local Councils as they grow and change. Now is the time for us to comment on the Plan and to influence the outcome.
The NSW Department of Industry, Resources and Energy also influences the Plan. They have an interest in making sure that any potential mineral resources remain available to be exploited.
The Nambucca Shire Council has a Local Environment Plan that is produced in consultation with State government bodies to guide development within the shire.
The thing to note is that these three bodies (and probably others) often have conflicting priorities. This is very evident in the Valla area. The Industry Department wants to keep Valla available for mining. The Council has earmarked the eastern side of Mt England as an urban growth area. This is a direct conflict of land use. The Council has also allowed land on the western side to be sub-divided into smaller parcels which also creates land use conflicts with mining.
On top of this there is Aboriginal Heritage areas, koala habitat, acid sulphate soils, farmland of regional significance, and established farms and residences.
Personise your submission. If you use a pro-forma submission ensure you add to it to personalise it.
Talk about how the Plan will affect:
- your family
- the environment
- the local economy
- existing industry
If you submit on behalf of a group it is also worthwhile to have the individual members of the group to also make their own individual submissions.
It is not enough to say what you don't want. It will be much more constructive to say what you do want. For example, as well as saying that you do not want Valla to become a mining area, make sure you say what you do want for Valla. You may want to see the protection of farmland and safeguard it from industrialisation. You may want to ensure that Deep Creek and it tributaries are protected from logging and industrial pollution.
Decision makers will take a good idea from one person over a bad idea from many people. I say this to reinforce the need to have many personal, individual submissions.
"Keep submissions on-topic. Give insights into analysis or experiences from elsewhere that make your case. Point to innovative ideas. Make your submission short and punchy. Get the reader engaged early. Be objective ond outcome focussed. Have a civilised and interesting conversation. Include a summary at the top of your submission. Use headings within your submission to structure your argument. Use clear language. One idea per paragraph. Put your idea in the first sentence, then explain it in the rest of the paragraph. Think about your strategy. What will motivate people?" - Tom Grosskopf, Director Metropolitan Branch, Regional Operations, Office of Environment and Heritage.
A good submission should:
- Introduce yourself or your group, acknowledge the opportunity to make a submission and note any relevant work you or your group has done.
- Outline your key concerns and focus your discussion on these. It is not necessary to address the whole proposal - choose the parts that are most relevant to you.
- If possible, make recommendations. Make strong clear statements, e.g. ‘the proposal should be amended to include a requirement that…’
- Use evidence or case studies or stories to support your arguments and recommendations. Give specific examples that draw on your knowledge and experience. If you can, collect other stories that support your argument from others in the community. You can also draw on the work of others, for example scientific publications, government documents, or the work of other organisations.
- Don’t forget to set out the aspects of the proposal that you think are good. There may be other stakeholders who want to get rid of things you think are positive so it is important to point out what you support.
If you are a member of a group, you should write a submission on behalf of that group, but each member should also write their own submission as well. You may choose to endorse another group’s submission. This counts as a separate submission.
If your arguments are backed by good quality research they will carry more weight than personal opinion or heresay.
There are a number of documents you may wish to peruse if you are interested. If you can suggest more please email me a link.
Hexagon Resources says they won't mine if there is no social licence.
Our aim is to prevent mining from becoming established in Valla. The reason for this is that what goes on on top of the land, the farming, fishing, and tourism, is sustainable, employs more people, and is far more valuable than any sort of mining.
The Draft Plan does not properly address factors such as climate change, fauna (such as koala habitat), or coastal erosion.
If you want to add pictures to back up your evidence then include them in an Annexure.
Mining does not create many jobs. The majority of jobs and job growth in the area are in tourism and primary production.
Regional cities are not the only places where people are living. Stress that Valla is a great place to live. Developing mining in the area is inappropriate.
I provide a template submission example here. Remember, this is just an example. Feel free to modify it to make it reflect your concerns and your situation. Remove stuff and add stuff as you see fit.
I have compiled this quick guide to making an online submission. It covers the mechanics of submission online.
Alternatively, you can print your submission and mail it to:
Director Regions, Northern, Locked Bag 9022 - Grafton NSW 2460