Coastal vulnerability: an alternative approach
Last month I had the pleasure listening to an old friend, Wolfgang Amadeus Mozart, at the Sydney Opera House. The occasion was one of his more serious operas, Idomeneo. The Director noted that the “wine-dark sea” of the Homeric legend courses through the heart of this opera. Manipulating the flawed humans of Crete is the God of the Sea, Neptune, whose anger grows through the opera. Mozart conjures up the sea’s power with two magnificent sea-storms (and a sea monster!) before calm is restored. Idomeneo’s aria “Far from the sea, I have the sea in my breast” expresses the turmoil Idomeneo is facing in enduring Neptune’s cruelty on people of Crete.
This performance reminded me once again of what we face from raging seas at present and more so in the future. There is some evidence that global wave climates are responding to a windier world excited by global warming. Over the last six months news of devastating storm surge inundation has come from places as far apart as South Africa, Black Sea, southern California and Maine. Dramatic images were seen of so-called “unprecedented” overwash of protective structures by giant waves overtopping sea walls and cascading down streets into properties. As such extreme events become more common we have to continually reassess what we are doing to make coastal communities less vulnerable to such events as well as to that “known-known”: sea level rise.
In Australia it is left to state governments working with local councils to communicate to citizens what risk they face in living in places exposed to certain natural hazards. Over the last two decades enormous efforts have been made by public and private entities to assess risk in coastal areas. My first foray was in assisting the preparation of the Australian Government’s report on “Climate Change Risks to Australia’s Coast, a first pass national assessment” (Dept. Climate Change, 2009). We employed somewhat primitive but nationally consistent tools to assess risk down to a local government scale. A broad picture emerged highlighting estuarine locations as facing problems at an economic scale exceeding those on the open coast. Subsequent examination of particular hazards in different states has expanded on this initial work, but there remain concerns as to how best to communicate increasing knowledge of risk and apply that knowledge in land use planning and management decision making.
The coastal reform process in NSW involved changes in legislation, planning policy, guidelines (Manual) and funding arrangements. One step was to define four coastal areas within the Coastal Zone: coastal wetlands and littoral rainforest area; coastal vulnerability area (CVA); coastal environment area; and coastal use area. All but the CVA were mapped as required under the then Coastal Management State Environmental Planning Policy (SEPP) 2018. That policy now forms Chapter 2 in the Resilience and Hazards SEPP 2021. However as of February 2024 only one CVA has been both certified and mapped, that of part of the Coffs Harbour Coastal Zone. Why is this so?
At the time the Coastal Management Act was being debated in 2016 the then NSW Government took the position that local councils must take responsibility for mapping the CVA within its Coastal Zone. They were to be guided by the Manual and relevant technical information on the seven coastal hazards listed in the Act. The CVA must be prepared by each council following consideration of a local planning proposal to amend the SEPP and then sent to relevant Ministers responsible for the Act and SEPP for certification and declaration of the CVA map. To many of us this was an odd decision given that state agencies had worked with councils in producing the agreed maps for the other three coastal areas in 2018. It was also well known that the state government previously led in the production of bushfire risk maps and on acid sulfate soils. Placing the burden on local councils to do all that was involved in the mapping the CVA immediately exposed them to political as well as technical difficulties. The result has been many councils prevaricating or asking the State Government to do the mapping.
To make matters worse it has been difficult for councils, planning panels, communities and developers to work with existing provisions in the SEPP such as section 2.12 whereby developments should not be granted unless the consent authority is satisfied that any development proposal is not likely to cause increased risk of any of the seven hazards on that land or other land within the broader Coastal Zone (see also Planning Circular PS 21-009). This direction places the onus on council staff in particular to have sufficient knowledge through other planning instruments, policies or studies of such risks. A specific CVA on the other hand with its provisions under both the Act s7 and SEPP Division 2.9 would provide more clarity around how consent authorities assess development on land clearly mapped and identified as a vulnerable area (i.e. a CVA).
I accept the general use of “vulnerability” as the quality of being hurt or attacked. It is the state of being open or predisposed to harm. The more nuanced use of the term involving a combination of factors including exposure and capacity to adapt is not helpful in communication in a planning context. Thus if we are to identify land that would fall under a CVA it would require consent authorities to be satisfied that any proposed development must (1) withstand current and projected future natural hazards; (2) not likely alter coastal processes to the detriment of the natural environment or other land; (3) not likely reduce public amenity or access to beach, foreshore etc. adjacent to the proposed development; and (4) incorporate measures to manage public safety from natural hazards. These are threshold tests that should be applied at the commencement of any assessment of a DA and are higher than the intentionally low threshold contained within the catchall SEPP s 2.12. The question is whether the NSW Government is prepared to map a CVA that recognises the existence of areas predisposed to impacts of natural hazards as defined in the Act.
Last year I read an Environmental Research Letter (18, 2023, 034001) published by the US EPA on vulnerable populations living on floodplains or close to the sea. It was written by Jim Titus well known for his work on sea level rise on the US east coast. What was of interest was the relatively straightforward elevation-distance method used to define areas subjected to hazards. He examined land below a certain threshold elevation (e.g. for 1m and 3m above mean higher water level) and determined population numbers of different demographics that fell into what he termed “hazard zones”. The idea I would like the NSW Government to explore is an extension of this elevation-distance method for the entire NSW coast. It would involve mapping all coastal lands that fall below a particular datum, let us say 5m AHD. This would cover all land potentially inundated up to 2m above present-day high-water level. To this would be added those areas known to be subject to erosion events that are above 5m AHD ( foredunes, cliffs etc.). Remembering that the Act permits overlaps of coastal management areas, so what this method does is to ensure all lands likely to be affected by flood and marine inundation fall within the orbit of the Coastal Act and SEPP.
There are many positives that flow from such a statewide initiative. First the onus of identifying CVAs is removed from local government so it will automatically and consistently apply across all coastal LGAs just as it does for the other three coastal management areas. Second, it allows councils to then use hazard studies to bring specific areas within this broad CVA information relevant to specific hazards into their planning instruments (LEPs, DCPs). Third, it makes it clear upfront where there are likely issues that must be addressed in planning as each CVA will identify lands that have risk characteristics. Fourth, a statewide CVA gives visibility to proponents of what they must consider if they are to satisfy consent authorities. Such a CVA should not be seen as a mechanism to say No to development but to ensure awareness up front of risk. In this way we will become more conscious of potential harm that may occur on such land and manage it accordingly.
Bruce Thom
Words by Prof Bruce Thom. Please respect the author’s thoughts and reference appropriately: (c) ACS, 2024. For correspondence about this blog post please email admin@australiancoastalsociety.org.au
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