Council Meeting

 Wednesday, 17 July 2019  at  6:30pm


Additional Attachments


Item                 Name                                                                        Page No.

Director Environment & Planning

C07/19-149      Adoption of Biodiversity Strategy 2019

Attachment 1    Cumberland Biodiversity Strategy 2019 - Amended Summary of Public Submissions................................ 7

Attachment 2    Amended Cumberland Biodiversity Strategy 2019..... 19        

REPORT C07/19-149

Attachment 1

Cumberland Biodiversity Strategy 2019 - Amended Summary of Public Submissions

Council Meeting

 17 July 2019

Biodiversity Strategy 2019 - Summary of Submissions


In total, 4 submissions were received during the public exhibition period. Each of the 4 individual submissions contained numerous comments and suggestions. The following table summarises all comments and suggestions received.



Comments / Suggestions

Council response

Changes to Strategy

Submission 1

Dear Council, well done on the Draft Cumberland Biodiversity Strategy 2019. The strategy provides a high level insight into what is needed to support the development of sustainability initiatives. My recommendations:


1. Locate and build partners in the community (particularly the majority Arabic and Chinese speaking) communities who care about the environment. See this resource and common myths for working with multicultural communities:


2. Local parks are places where you might have a planting of endangered species which were listed in the plan. We could trial a site next at the cnr of O'Neill St and Elizabeth Street Guildford and have a "adopt" a park with some nests for powerful owls, and provide some flowering trees (not just she oaks) for the local birds to eat etc... If there was some communication, a series of local groups may be interested in getting involved and supporting the restoration of local biodiversity. Activities could include having a night walk in a local park etc to see wildlife.



3. Encourage people to plant street trees and support the NSW Department of Planning to increase the catchment of trees in our LGA. This could be a tangible indicator.


1.    Council agrees with your comment to build partnerships with the community, paying attention to non-English speaking communities. Council recognises it has one of the most diverse communities in NSW. Council has and will continue to focus on engaging with its diverse community to build resilience as part of Key Focus Area 1 ‘Community Awareness and Engagement’.



2.    Council has a proactive bush regeneration program across our local government area. Some actions include plantings of native vegetation, weed, rubbish removal, installation of bird boxes. Council has in the past delivered guided walks along Prospect Creek and has organised for a bird spotting walk in late June. In addition, Council also supports local bushcare groups working along Prospect Creek and Duck River. These are being actioned in Key Focus Area 1.1 and 2.1.


3.    Council is exploring opportunities to increase the green cover in our area. Some ongoing initiatives include Council’s annual ‘Free Plants Giveaway’ program where Council aims to give away 2000 plants and shrubs to residents annually. In addition, Council participates in the annual National Tree Day and Schools Tree Day where approximate 3000 plants are planted.



No changes required

Submission 2

General Comments

The MDRRC strongly believes that this draft strategy should be rejected and that significant additional work should be carried out on its development to bring it to an acceptable standard.



Noted and acknowledged. This is a high level document providing strategic direction for biodiversity management. The aim of this document is to communicate biodiversity issues in a clear and concise manner to our community. This Strategy is supported by background analysis.

See comments below.






Long history of environmental, biodiversity and sustainability strategies and plans were not incorporated meaningfully into the biodiversity strategy. Past strategies should have been reviewed to incorporate learnings into the strategy.

As Council is a newly amalgamated Council, a holistic Biodiversity Strategy is required to cover the whole of Cumberland. Previous plans were site specific rather than Council wide.

Additional comment added to section 4 ‘Action Plan’ to stipulate that project planning includes review of past strategies and apply learnings where applicable.

The draft strategy bizarrely includes areas of focus which have nothing to do with biodiversity management, including a photograph of community vegetable gardens, actions relating to water harvesting and water sensitive urban design and examples of litter clean up programs as “biodiversity management.

Council acknowledges that a wide range of initiatives are required to help biodiversity. These programs either support biodiversity outcomes through education and engagement with the community or encourage direct action, such as bee hives in community gardens and litter reduction programs. KFA’s 1, 2 and 3 have actions that together will help manage biodiversity.

Amend captions in photos to explain biodiversity benefits, including role of community gardens.

Key Focus Areas have appeared in previous strategies and failed to turn around decline in biodiversity.








This is Cumberland Council’s first Biodiversity Strategy. The Strategy maps out the high diversity areas and highlights priority areas where management actions will deliver the highest biodiversity outcomes. The Key Focus Areas (KFAs) were developed with the help of the community, including Council’s Aboriginal and Torres Strait Island Committees, residents and community groups. KFAs are identified priority areas that are developed through the strategy development process. They guide program and activity development.

No changes required.




Strategy poorly communicates reasons to protect biodiversity and focuses on human centric rationale for protection.

Community Consultation has been poor.

Council discusses the need to protect biodiversity for both the community (section 1.1) as well as for the natural environment (section 2.1). As part of the development of the strategy, Council held workshops with Council’s Aboriginal and Torres Strait Islander Committee, residents and environmental groups. All active members of these groups, including members of the MDRRC were invited to participate.

Added additional objective in Key Focus Area 1 as follows ‘Create opportunities for effective collaboration with our community’




Key Focus Area 2

KFA 2.1 This is broadly supported, but should be reworded to include targets. The current Council bush regeneration programs are inadequate, and bushland in the LGA continues to degrade. This KFA, as worded could result in ongoing degradation.


Noted and acknowledged. As part of KFA 2.4, Council will develop baseline data for biodiversity health as projects require.


Amended KFA 2.4 to include targets and now reads as follows ‘Develop baseline data and targets for biodiversity health’.


KFA 2.2 is broadly supported, but it should be reworded to be stronger than just "identify opportunities".

Noted and acknowledged. Council will continue to investigate and implement biodiversity improvement initiatives, dependent on Council priorities and available funding.

Amended KFA 2.2 to ‘Identify and progress opportunities that improve biodiversity connectivity for priority areas’

KFA 2.3 is broadly supported but should be worded to be stronger than just "explore" and also should be expanded to include regional initiatives, collaboration with state and federal agencies, and non-government organisations.

Council agrees with this comment. A key objective of KFA 2 is to ‘Improve condition and connectivity of priority areas in line with regional strategic plans’.

Amend KFA 2.3 to read ‘Explore and collaborate on suitable opportunities with neighbouring Councils and regional organisations’.

KFA 2.4 broadly supported, but it is surprising that it is worded around "develop" when there are already many environmental baselines in the LGA from existing and past plans and strategies.

Noted and acknowledge. Although there have been past environmental baselines, due to amalgamation, Council has the challenge of developing consistent baselines across the newly amalgamated Council. This will be explored in KFA 2.4.

No changes required.

Key Focus Area 1

This should be changed to “Community Awareness, Engagement and Action”


KFA 1.1 is generally supported. However, instead of initiatives, which are episodic and ephemeral, an ongoing environmental education program should be implemented, not only to raise awareness, but to change behaviours and to support action.

Noted and acknowledged. Environmental education programs will be considered under KFA 1.1.



Added ‘Action’ to KFA 1, it now reads ‘Community awareness, engagement and action’.



KFA 1.2 is supported, but wording stronger than to "explore opportunities" is needed.

Noted and acknowledged.

Amended KFA 1.2 to ‘Explore and progress engagement opportunities with the Aboriginal community in biodiversity management’

Suggested additional KFA:

KFA 1.3

"Create and resource a Community Environment Reference Group, reporting to the General Manager, to advise and engage with Council on environmental issues and to review the implementation of this strategy and related plans."


Noted and acknowledged. This will be considered under KFA 3.3


No change required.




Suggested additional KFA:

KFA 1.4

"Expand the existing Bushcare Program, with the aim of having community Bushcare groups in all Council owned or managed bushland areas."

Council agrees that bushcare programs form an important component of Council’s bushland management program. Council will continue to explore opportunities to expand its existing support of bushcare groups throughout Cumberland in KFA 2.1

No change required.


Section 1.3

The strategy states: The Draft Strategy aims to balance the needs and preferences of the community with Council’s capabilities and resources.

This is a worrying sentence. Firstly, the strategy should be about managing biodiversity and why would a balance between the community preferences and needs (which aren't actually articulated in the document) and Council resources and capability even be a consideration?

The Draft Biodiversity Strategy acknowledges that there is a need to manage Council’s biodiversity, specifically in sections 1.3 and 2.1. Council recognises it has multiple commitments and is required to balance priorities within its capabilities and resources.

No change required.





Section 1.3.3

There is little to indicate that this is a community focused strategy, so this premise is disputed.


Council has developed the biodiversity vision, key focus areas and actions with the help of residents and community groups in workshops. This document also aims to deliver the community vision as reflected in the Community Strategic Plan 2017-27. In addition, KFA 1 is focused on raising community awareness and engagement with the community to value biodiversity.

No change required.

Section 2.1

The section should include description of the intrinsic values and rights of biodiversity, not just the values that support humans.

The section should include additional threats that relate to:

-light pollution (that can affect nocturnal animal behaviour and survivability);

-motion pollution, which impacts especially on wetland and migratory bird feeding behaviour and intertidal organisms' feeding behaviour;

-noise pollution;

-fragmentation from recreational use such as bike paths, unrestricted recreational access;

- domestic cats and dogs; and

- inappropriate fire regimes.

Noted and acknowledged. Section 2.1 emphasises the importance of the three levels of biodiversity, in addition, the supporting Biodiversity Background Study further explores the importance of biodiversity. In addition, Eco Logical Australia has reviewed the threatening processes relevant to Cumberland Council in supporting Biodiversity Background Study.








Additional section called ‘Threats and Challenges’ added to the report, including light pollution and fragmentation.












Section 2.2

It is surprising that such a basic description of biodiversity principles has been included, especially without any identification of constraints or opportunities relating to the specific conditions in Cumberland.

This document identifies opportunities to improve biodiversity under the heading of ‘Biodiversity Principles’. Council aims to manage biodiversity by adhering to these principles (Habitat, wildlife corridors, green infrastructure and the biodiversity hierarchy).

Constraints will be added in section 2.1 under ‘Threats and Challenges’. Opportunities appear in section 4 ‘Action Plan’ and mapped out in Priority Areas map on page 21.

Section 2.2.2

This section should look at the need to utilise street and parkscapes, and backyards to increase habitat and connectivity. It should also consider horticultural species selection by Council. Council currently uses a number of known weed species in its landscaping or species that have little or no biodiversity value.

Habitat and connectivity is further detailed in Council’s Background Study. A recommended species list also appears in the Appendix A of the Background Study. Connectivity is addressed in KFA 2. Connectivity opportunities are highlighted in the Priority Areas map on page 21.

No change required.




Section 2.2.4

With only 2.6% of natural areas left, Council should aim for development to be biodiversity positive, not just biodiversity neutral. This should be made explicit and detailed in this section.

Council agrees with this comment. As per s2.2.4, Council preference is to apply the biodiversity mitigation hierarchy and avoid biodiversity loss wherever possible.

No change required.

Section 3

This section utterly fails to recognise any of the aquatic biodiversity in the LGA.


Council’s commitment to managing aquatic biodiversity is demonstrated through our membership of The Parramatta River Catchment Group (PRCG) whose three area of focus are biodiversity, estuary management and water/stormwater management. Section 1.3.2 recognises that Council has responsibility under the Central City District Plan goal C3 to ‘Protect and improve the health and enjoyment of the District’s waterways’.


Added additional paragraph to acknowledged the important role of aquatic biodiversity under section 3 ‘Biodiversity in Cumberland’.


Added additional Action under KFA 2: Support delivery of Parramatta River Catchment Group’s ‘Parramatta River Masterplan’.

Table 4

This table is not comprehensive, and also contains irrelevant information.

-Monitoring of plant give away programs in other jurisdictions has shown that they have little value. Plants are not planted or maintained.

-The stated Habitat Stepping Stones monitoring measure is meaningless from a biodiversity impact perspective.

-Workshops and events - apart from the native beehive program, none of these are relevant to native biodiversity.

-Litter Programs - this program is not going to deliver biodiversity outcomes.

-Clean up Australia Day - this program is not going to deliver biodiversity outcomes.

-Children’s Sustainability Hub - it should be clarified how this program will contribute to biodiversity.

-This list only mentions one grant funded project and misses out on a large number of grants that the previous Councils were given for biodiversity works, few of which have been maintained.


Council acknowledges that a wide range of initiatives are required to help biodiversity. These programs either support biodiversity outcomes through education and engagement with the community or encourage direct action, such as planting native species and cleaning up the local environment. KFA’s 1, 2 and 3 have actions that together will help manage biodiversity.










No change required.

















Section 4

The vision is inadequate and meaningless.

This section highlights the inadequacy of the structure of this strategy. The strategy as written has a meaningless vision, poor objectives, no targets and a lack of measurable actions and outcomes. There is little in this document that could meaningfully drive an integrated management regime to maintain or improve the biodiversity of the LGA.

Noted and acknowledge. The vision is written to be aspirational and reflect the desires of the local community as developed in Council workshop sessions with residents and community groups. The first half of the Strategy (Sections 1 and 2) describes the need for biodiversity management whilst the second half (section 3 and 4) explain the current biodiversity context and actions. Section 4 notes that the biodiversity strategy will be reviewed annually to identify actions taken, lessons learnt and measureable changes.

No change required.

Submission 3

KEY FOCUS AREA 1: Community Awareness and Engagement


We welcome any initiatives to increase awareness of our native flora and fauna and their value, particularly in schools and local media.


The Aboriginal community must be engaged in biodiversity management, to share a great wealth of expertise, knowledge and history for our area.


Encourage a focus on connecting the network of volunteers.


Council agrees with these comments. The Strategy will be addressing education through KFA 1.1 and indigenous engagement through KFA 1.2. Council will be supporting bushcare groups and volunteers in KFA 2.1.

No changes required.

KEY FOCUS AREA 2: Habitat connectivity and condition


Motivation is also needed to remove exotic weed species which can easily spread into bushland.


Connectivity and the value of significant tree canopy and habitat in our neighbourhoods must be made clear, with regulations around removal and replanting strengthened and stringently monitored.


Council seriously needs more Tree Preservation Officers to help preserve and identify significant trees.


Respect for waterways and native areas must be encouraged. (e.g. fines for dumping of rubbish, damage and weeds spread by vehicles, vandalism, etc).

Council agrees with these comments. Council has an active bush regeneration team focused on weed removal and will continue with this program under KFA 2.1.

Council acknowledges the importance of tree canopy cover. Council is exploring opportunities to strengthen regulations regarding removal and replacement in our planning instruments. This is being addressed under KFA 3.1.

Council agrees that Tree Management Officers play an important role in Council and will continue to monitor this area in KFA 3.3.

Council’s Waste and Resource Recovery Strategy 2018-23 addresses illegal dumping and littering under KFA 4.

Added Council’s Waste and Resource Recovery Strategy’ as a key influencing document under section 1.3.3 Local Planning Context.



KEY FOCUS AREA 3: Planning and innovation


These are all very welcome steps, in particular KFA 3.1 Embed biodiversity considerations into strategic plans and controls.


KFA 3.2 and KFA 3.3 are likewise integral for planning and innovation, to save waterways from pollution by run-off, and to allow improved and consistent biodiversity management strategies to take effect in the longer-term.


The aim to incorporate the biodiversity strategy into all aspects of development of a new Local Environment Plan for Cumberland is most welcome.


Noted and acknowledged.

No change required.



Pages 12 and 13 map biodiversity in the area, what is not so clear is the occurrence of any native species at all. We are concerned that the vast areas without any green or orange dots could be misinterpreted as not having endangered species, so therefore holding abundant healthy native communities. To give an accurate picture for general public display, perhaps the maps could be overlayed to show what is actually in those blank spaces: industry, detached housing…


It is very gratifying to note that the Duck River corridor is shown as a District Priority.

The threatened species that appear on the ‘Threatened species’ map are all native species.

Council acknowledges your concern about the empty spaces in the map. The aim of this map was to graphically show locations of threatened species in a clear and simple map. Council believes that additional overlays would clutter the map.

This Strategy formalises Duck River as a priority corridor and reinforces it as strategic corridor in line with The Central City District Plan’s Green Grid.

Clarify the species map by changing the map title to ‘Native Threatened Species.



Bushcare Volunteers: Monitoring and Follow-up: We suggest ‘Bushcare groups monitor sites they work on’ be amended to ‘Bushcare groups and council teams monitor sites they work on’


Bush Regeneration: ‘Council undertakes bush regeneration activities throughout the LGA - Ongoing.

Monitoring and Follow-up: Ongoing – targeted.’

It is not currently at all clear where this is actually ‘On-going’. We suggest amending ’On-going’ to ‘On-going and expanding’.

Council agrees with these comments and KFA 2.1 focuses on bush regeneration programs.

Amend Table 4: Bushcare Volunteers Monitoring comment to ‘Bushcare groups and Council monitor sites they work on’.


Amend Bush regeneration description to include expansion of bush regeneration sites in line with Council priorities and funding.

Submission 4

I hope Council will amend both documents – the Cumberland Biodiversity Strategy 2019 and its Draft Operational Plan 2019-20 – and clarify that Council will not distribute beehives to unit residents.

Noted and acknowledged.

Council will not distribute beehives to dwellings with a balcony.

Amended Table 4 by removing ‘balcony’ and updated the Native Beehive Program to reflect this change.





REPORT C07/19-149

Attachment 2

Amended Cumberland Biodiversity Strategy 2019

Council Meeting

 17 July 2019