MBBA Submission to Foreshore Management Plan

Hi All,
Attached is MMBA’s Response tp the Eastern Beaches Coastal Management Plan. It’s long! In general we feel the that the report is a significant step forward. Please send your views directly to Council via email or by making a submission. You can read the Report on the Council’s Your Say page.

The key points for focus:

– See the MBBA List of Outcomes in Section 2 of our submission below.
– The importance of on-the-ground work and funding for it (which has increased).
– The Plan is following the recommendations from the Coastal Hazards Adaptation Plan which is positive and important.
– Increasing native plants and decreasing weeds is necessary for a healthy buffer zone.
– The reserves are a transitional space that visiters and beach goers move through rather than a destination, so environmentally friendly, safe access paths are paramount.
– Whereever possible less invasive natural solutions to dune erosion issues are the preferred course of action.

Kind Regards,


The Marcus Beach Bushcare Association thanks the Noosa Council for the opportunity to comment in detail on the Eastern Beaches Foreshore Management Plan.

This submission is divided into three sections:

  1. Introduction
  2. Outcomes
  3. Community feedback received by the MBBA
  1. Introduction

The Eastern Beaches Foreshore Management Plan is a clear, concise and well-structured plan with excellent readability. In particular, the Snapshots on pp 4-11 give the reader a useful, informative overview of the Foreshore Reserves, together with the specific values and challenges for each section of the Reserve.

The Plan acknowledges and embraces the importance of the Eastern Beaches for recreational use, tourism and environmental activities, while highlighting that, as usage of the beaches increases, additional measures will be required to protect, manage and maintain the ecological health of the Foreshore Reserves.

The comprehensive reach of the Plan demonstrates a thorough scoping process.  The Plan incorporates community viewpoints, as well as local knowledge.  It has responded to specific community concerns in relation to encroachments and the coastal creeks, in particular Burgess Creek.

 The Plan considers the anticipated impacts of Climate Change and is consistent with the CHAP.

It is an excellent starting point as it clearly articulates the key issues and challenges.  While acknowledging that the Foreshore Management Plan is an overarching document, not an operational plan, the MBBA believes it would be strengthened by having a section on Outcomes as per the following section of this submission. 

By including outcomes in the Plan, there would be a basis for formulating more detailed operational plans with attendant KPIs.  It would provide a solid framework for directing operational activities and for assessing progress.

  • Outcomes

The Marcus Beach Bushcare Association believes that a management plan must provide a clear statement of specific, achievable, outcomes.  These outcomes drive planning and strategies, which then makes it possible to set goals and actions, and access whether or not the actions have achieved their goals in working towards the outcomes. 

We would therefore suggest that the Plan contains an articulated statement of Outcomes. The MBBA proposes the following (not in prioritised order):


  1. The western boundaries of the Coastal Reserves are regularly monitored to ensure that there are no property incursions into the Reserves, no weeds entering the park from adjacent properties, and any damage to the Reserves is quickly rectified.
  2. The eastern (seaward) boundaries of the Coastal Reserves are maintained by undertaking measures that allow the dunes to regenerate naturally, and by active restoration when required.
  3. The ecological health of the Coastal Reserve is improved, so that the biodiversity of native flora and fauna increases; the quality of coastal streams and their surrounding areas increases; erosion and other forms of degradation decrease.
  4. The Beach Access pathways and other Reserve infrastructure are designed and located to support the ecological health of the Foreshores Reserves, and to improve the visitor experience of the eastern beaches.
  5. An ongoing awareness and education campaign for Noosa residents and visitors that will increases the community’s understanding of the importance of protecting the dunes. Visitors appreciate the value of the Foreshore Reserves as a habitat, and as a place for people to enjoy without damaging the delicate balance of the ecosystem.
  6. The managed response by Council to natural disasters, critical incidents, and adverse weather events minimises their impact on the Foreshore Reserves and wildlife and minimises the risks to the public and the environment.
  • Comments and recommendations

Section 6: Climate change

The focus of the actions in the Plan in regard to climate change is monitoring and assessment. This is a first, necessary step. The Council needs to have a clear understanding of what climate change-driven environmental impacts will be over time so that it can formulate appropriate, cost-effective responses that ensure sound environmental outcomes. 

The protective value of the Foreshore Reserves has been noted in the Plan. This means keeping the Reserves well-vegetated and in healthy condition in order to minimise erosion. A monoculture or high weed load is undesirable in situations where weather conditions are likely to change rapidly. 

We do not know which species are most likely to withstand higher temperatures and different weather patterns. Therefore, having a healthy, biodiverse habitat will enable a better chance of adaptation to the new conditions. Some native species will become more dominant, while others may be unable to adapt to emerging conditions.

Containing groundcover weeds such as Asparagus Fern and Gloriosa Lily that slow down or prevent the germination of native species is a key priority. 

The MBBA notes the additional resources allocated in MA 7.2 but urges the Council to make on-the-ground work on the Foreshore Reserves a high priority.

The recent excessive rain high tides and winds have highlighted how quickly the topography of the dunes can change. It has also highlighted the weakness in the beach access paths that can become impassable and a lack of clear measures to manage these access issues which are likely to become an increasing problem. 

MA 6.5. The MBBA welcomes the proposed S25,000 for emergency bush regeneration following emergency events. It is a good initiative that, if allocated wisely, will save money, and have positive environmental outcomes, as the case study suggests.

Additional Actions: 

  1.   Seek funding from State and Federal government to future-proof the Foreshore Reserves by improving their ecological health.

  2. Establish a contingency plan for all beach accesses to manage adverse weather events that cause inundation or that restrict access to public access points.
  3. Prioritise remediation works on Beach Access paths which are high-traffic paths that are known to flood or become inaccessible in extreme weather events.
  4.  Redirect the public to those pathways identified as principal access points using appropriate signage and barriers to ensure public safety, and to minimise damage to the dunes.
  5. Implement measures to deter the public from walking along the edge of dunes when the dunes are damaged by adverse weather events and have vertical sheared edges. 

Refer to Sections 8 and 12 for further comments and additional actions pertinent to Climate Change. See also the Appendix examples of current beach accesses and their infrastructure

Section 7: Ecology

As an environmental group, the MBBA contends that Section 6 Climate Change and Section 7 Ecology are the key sections of the Coastal Management Plan. All other sections essentially contain actions to support Sections 6 & 7 while at the same time catering for the many ways in which our community and tourists interact with and enjoy the Eastern Beaches. 

The MBBA notes that the Council has undertaken the detailed mapping of the Foreshore Reserves and in doing so has identified four previously unidentified Regional Ecosystems. This more detailed knowledge of the Reserves will inform weeding work schedules, restoration and regeneration processes.

MA 7.2 The MBBA welcomes the proposed $225,200 per annum to update and implement the ecological restoration plans for all EBFRs.  It stresses that the focus needs to be firmly on the attendant work on the ground.  If there is no follow through action, the hard work and cost of doing an ecological plan is a waste of time and of ratepayer money.

The MBBA notes that even without extensive mapping and assessment it is clear from a simple visual survey that there are large areas of the Coastal Reserves that are in very poor ecological health. As pointed out in the previous section there is a serious problem of introduced weeds outcompeting the native species in the Reserves. Not only does this lead to less biodiversity in the flora it also has detrimental flow-on effects on the native fauna. 

Although total restoration would be the ultimate solution, this is not a realistic goal as the level of neglect over the years has been such that the cost would be prohibitive.

In order to increase the overall health of the habitat in the Foreshore Reserves, the Council will need to be very clear about its objectives, with targeted and achievable actions

 Section 7 Ecology must address this reality by including Management Actions that are very specific and that drive on-ground action. The MBBA therefore recommends the inclusion of the following Management Actions:

Additional Actions: 

  1. Target five invasive weeds that are widespread and are reducing the regeneration and seed germination of native flora. The five would include Singapore Daisy, Asparagus Fern, Gloriosa Lily and Brazilian Pepper.
  2. Work with Bushcare groups, field experts, government bodies, council staff and contract workers to develop containment and reduction strategies for each weed as well as procedural guidelines.
  3. Conduct an annual sweep of all the Foreshore Reserves targeting weedy saplings such as Brazilian Pepper and isolated outbreaks of weeds such as Mother-in-Laws Tongues. This could be undertaken with the assistance Bushcare groups at some sites.
  4. Pro-actively identify, monitor, document and remove emerging new weeds that have the potential to outcompete native.
  5. Engage the community with an awareness campaign focused around a specific weed species that includes opportunities for people to have some hands-on experience in the bush.

Section 8: Social values

Cultural values

The MBBA endorses the idea of indigenous stewardship and the proposed action in MA 8.1 & 8.2. 

Noosa Design Principles

MA 8.3-8.5 

The MBBA sees an opportunity to build structures that, in addition to having an aesthetic and functional value, are designed and located so that they have a protective value for the Foreshore Reserves. When considering infrastructure of any kind in the Foreshore Reserves, the disturbance to vegetation must be the first consideration and be minimised. The value of the infrastructure as an amenity and as a protective measure for the health of the dunes must justify any disturbance caused by building it.

Section 9: Partnerships

The MBBA welcomes the Council’s commitment to develop, support and drive more community-based partnerships and initiatives. Climate Change awareness, particularly amongst the younger generation has sparked a wider interest in the environment. The MBBA believes that there is a largely untapped pool of residents, young and old, who would be willing to participate in environmental activities. 

Section 10: Community education

The Plan recognises the importance of “ongoing community education and targeted communication between Council visitors and neighbours” in protecting the Foreshore Reserves. It points to the complexity of reaching different audiences and the need to target the messages.

MA 10.1-10.5

Developing the appropriate communication programs, designing the material, determining effective forms of delivering the message(s), costing the exercise, and determining means to ensure that the material reaches its targets takes specialised expertise that involves a cost which has not been factored in. There are also ongoing labour and material costs in delivering, updating and maintaining communications, materials and systems.

The MBBA is concerned that the actions for Section 10 Community education do not have a funding allocation and that the sole responsibility lies with environmental services. While this sounds fine in theory, in reality, if it is undertaken properly, it diverts valuable resources from on-ground core work. The most likely outcome for these actions will be that they are low down on the list of priorities, resulting in them either not being done or being done in a piecemeal way, reducing their effectiveness. 

The MBBA recommends that the Council takes a whole of region approach to providing information and community education on Natural Areas and Reserves. We can see considerable cost value in terms of resources used in formulating strategies, message delivery, and developing educational material if a Foreshore Reserves community education and awareness campaign is conceptualised as something that can be rolled out, with appropriate adjustments, for other reserves. 

For example, standardised signage could provide uniformity across Reserves and be designed in a way that promotes a “Noosa feel.” Visitor information, both digital and paper-based can have a similar design with eye-catching elements (e.g. colour, logos layout).

Additional Actions: 

  1. Develop and implement a comprehensive, multifaceted communications strategy on the value, protection, and visitor experiences of the Foreshore Reserves at a pilot project to inform communications on other Nature Reserves and public spaces in the Noosa region. (The strategy for the Foreshore Reserves will encompass Management Actions 10.1-10.5.) 
  2. Create a template from this pilot project that can be adapted for all Nature Reserves in the Noosa Region. (Additional Actions 1&2 to be funded as a pilot project.)

Section 11: Encroachments

MA 11.1-11.3

The MBBA endorses all the actions in this section. 

The MBBA welcomes resources directed at dealing with this issue. There is clear articulation in this Plan of how encroachments have detrimental impacts on the Coastal Reserves. This is not always understood by Reserve neighbours and the public.

Refer also to the Additional Actions under MA10.1-10.5

Section 12: Public access and recreation

MA 12.1 to 12.8

The MBBA endorses all the actions in this section. 

The MBBA supports the work being done to review existing beach accesses and infrastructure as part of the secured design grant. We note that a strong emphasis on beach access points is in line with the way the public interacts with the Foreshore Reserves. 

While the review work is important and necessary, disappointingly, MA 12.1 to 12.5 do not result in any on-the-ground work being done to address the problems identified in the Plan.

Most of the recreational activities occur on the beachfront, not within the body of the Reserves. For the majority of beach visitors, both locals and tourists, the Foreshore Reserves are literally a pathway to a destination. (This pattern of behaviour is also evident in the illegal private pathways that intersect the Coastal Reserves.)

We believe that a useful way to conceptualise the Foreshore Reserves is as a transitional space rather than a destination, with eastern (ocean) and western (land) boundaries. This aligns with a sound ecological approach as, from the perspective of preserving habitat and wildlife, the less traffic through the bushland by humans, feral animals and dogs, the better. 

In ecological terms, boundaries have a critical influence on the surrounding habitat, which is another reason why the Plan needs to focus on them. See MA 11.1-11.3 While the Plan maintains that the public access paths are in relatively good condition, the impact of increased path use has had detrimental effects on the foredunes, particularly in periods of dune depletion. 

Additional Actions: 

  1. Identify the high-priority Beach Access paths. Fast-track the work on these paths and allocate funds.  Use a set of criteria that includes foot traffic volume, the physical condition, the safety of the path, the location in relation to waterways and vulnerable vegetation, steep slopes and other geographic features. A key selection criterion could be the suitability for becoming an emergency access point. 
  2. Implement low-cost improvements to all  access paths that will improve accessibility and protect the foredunes as a priority (See Marcus Beach case Study)

Section13: Incidents and disaster management

MBBA stresses the importance of knowing whom to contact in case of a disaster or critical incident, particularly during out-of-office hours.

For example, in the case of a major crisis such as the 2019 fires, the Council’s disaster response team would be the first responders, not necessarily environmental services. 

It is critical that various departments within Council, as well as the general public, know the appropriate point of contact in the case of a critical incident or disaster, particularly out-of-office hours.

The Council’s response to the polystyrene washing up on the beaches was delayed because it happened on a Friday afternoon. 

Section14: Coastal Creeks and stormwater

The MBBA has always recognised the importance of coastal creeks and from its inception has been actively involved in maintaining the health of riparian areas and monitoring water quality. We therefore in general support the actions of the Council in this area with minor changes. 

While Burgess Creek has management issues that are unique, it is important that all coastal creeks are resourced to restore riparian areas and improve water quality. This is why Coastal Connect, in which the MBBA was one of the lead organisations, has focused its efforts on rehabilitating three coastal creeks as part of its grant. 

A recent report compiled by MBBA collating historical data on the water monitoring of Peregian, Marcus and Castaways Creeks shows that these creeks rate poorly on some indicators of water quality.

The MBBA notes that the movement of the mouth of coastal creeks is normal creek behaviour and that wherever possible it is better to leave nature to its own devices rather than engineer responses that often prove costly and unsatisfactory.

The MBBA also recommends that closer attention be paid to stormwater and drain outlets as this with the anticipated increase in rainfall and adverse weather events predicted as a result of Climate change there is a greater potential for habitat damage and erosion from deluges.

  1. Amendment: “Prioritise, plan, schedule and implement the management of coastal mouth alignment and erosion” where necessary. 
    1. Amendment: “Work with Unity Water, the State Government and community members to restore bushland and improve water quality at Burgess Creek” and all other coastal creeks in the Foreshore Reserves

Additional Actions: 

  1. Conduct a twelve-monthly check and do the necessary maintenance on all stormwater discharge sites on the Foreshore Reserves.
  2.  Survey all the infrastructure that is associated with coastal creeks where a creek intersects with hard surfaces such as David Low Way. Document and attend to their condition.
  3.  Identify and earmark for improvements the poorly designed culverts and drainage systems so that when they are replaced or upgraded the design of new infrastructures supports environmental principles rather than being detrimental to the adjoining ecosystems.

See Appendix for examples of creek movement, poorly designed culvert infrastructure and storm water drainage erosion.

Section 15. Foreshore tenure and gazettal

The MBBA understands that the differing tenure and classification of the land that makes up the Foreshore Reserves adds an additional layer of bureaucracy to the overall management of the vegetated coastal strip along Noosa’s eastern beaches.  

The best way to ensure that the short to medium-term effects of climate change are minimised and property is protected is to have a buffer of healthy native vegetation that withstands the onslaught of waves and inclement weather. The classification of the foreshore reserves and adjoining areas need to be aligned with this. 

While nobody is suggesting that the bush in the Reserves be converted to grassed areas – the experiences in the northern communities in NSW demonstrate how little protection turf affords – one assumes that an area classified as a recreational reserve could in theory become a park.

The MBBA believes that in the interests of better management of and in order to preserve the vegetated coastal strip, the Council must deal with the issues of tenure, reserve purposes and land management plans as a matter of priority. The process is likely to be complex and lengthy, so immediate action with a budget allocation is recommended.

Additional Actions: 

  1. Seek to have all land that makes up the Coastal Reserves as defined in this document, including unallocated state land and undescribed land, gazetted as Nature Reserves.
  2. Where this is not possible secure long-term management plans between local and state governments that guarantee the long-term retention natural vegetation and “Nature Reserve-like” status. 
  • Community feedback received by the MBBA

The MBBA has also received written and verbal feedback directly from community members who would like their opinions noted.

Turtle Care

“An audit of all lights along eastern beaches is needed.  This could be a community task if an audit form was created.” 

By email

Dogs and the reserves

The following is verbal feedback from MBBA Bushcarers and others who work in the Foreshore Reserves.

Dog faeces

Our Bushcarers find working at the entrances of dog friendly beaches extremely unpleasant as they are weeding and kneeling in close contact with dog faeces. Some understandably will not work in these areas. The contractors working on the Coastal Connect site at Marcus Beach have also commented on this problem. 

 The Bushcare coordinator at Marcus Beach had to remove the copious amount of dog faeces prior from an area where school children were coming to plant.  This is a health hazard to which the Council would not want to expose children to.  

From an environmental viewpoint dog faeces provide fertilizer for weeds, something we have observed over the years.

Out-of-control dogs and irresponsible owners

Our Bushcarers also comment on the number of dogs that are permitted to run on the dunes and into the reserves. Not only does this destabilise the fragile foredunes, it also frightens wildlife. There are instances where bush wallabies have been mauled by dogs.

In addition, there is a blatant disregard for keeping dogs confined to the dog zones and for keeping dogs on the leash in areas where dogs are permitted only if they are on a leash.

Whilst none of the above is the responsibility of Bushcarers, they and other environmentally aware beachgoers do from time to time talk to dog owners about this. Some owners understand while others are either dismissive or rude. This is definitely an area where Council needs to step up and take more responsibility.

Foreshore incursions at Marcus Beach


Council should be able to print out plans showing all the residential blocks that adjoin PUBLIC LAND where Native reserves and public spaces are in place. Sadly, our fight is with non-caring people. Some with others very selfish agendas. These plans should then all be inspected for existing infringements such as —

. Poaching of the public land (official Boundaries) 

. Destruction of native Fauna and Flora (e.g. Removal of trees in the reserve to create 

uninterrupted ocean views or simply add cleared public land to theirs). 

. Building unauthorised wooden or other man-made walkways 

. Fences extended from their freehold properties into the reserve to stop public passage past the front of their property. 

Lack of seemingly any prompt intervention by Council on infringements merely prompts like minded others to take the law into their own hands. We are seeing this right now on a regular basis as more new breaches occur. 

. Advise all residents in this situation of what the Council is planning.

.Encourage residents to report on damage to flora and fauna, dumping of rubbish and unattended dogs and cats roaming as feral. 


The various landcare groups could possibly provide volunteers to help council to compile the infringement map showing which properties have been registered .

The landcare groups have experienced people who could identify flora and fauna irregularities inside their own boundaries and in the public reserve. 

The end result would be…

. Identifying who are the offenders and details of the offence 

. Notifying the offenders and the consequences of their infringements 

. A detailed document accompanying all rate notices clearly communicating their responsibilities.

This should include ALL their responsibilities, especially including the laws that apply to cat and dog owners. (cats, not just feral) are plundering the birds and other wildlife without any consequences. 

. Sale of property should be forbidden until the owners have fixed the infringements. .Vendors of any type, Real estate agents should be made aware that ALL possible buyers will be responsible for restitution if the vendors have failed to get a clearance from the Council. 

Hand delivered to MBBA

“I would like to see an end date or time limit on reinstating the natural reserve and replanting of native species to its former (glory)state, at the owner’s cost.  I also would like to see very substantial fines for breaching the Noosa foreshore plan and for encroaching on the Nature Reserve as well.”

By email

Footpaths and universal access

 “Regarding the entrance point at the Marcus Beach car park pathway (Access 47). 

 This is now a very well-used pathway, and also the southern entry point for the dog access area to the north. It can get very congested if a car parks in this location, with dogs coming and going, and getting hosed after their beach sojourn.  It would be good to put in a pram ramp, as we are seeing more families with young children (and old dogs!) in prams.”  

By email and verbally

“A couple of designated disability parking spots close to the pathway entrance would be welcomed by our older citizens who have difficulty walking.”

By email

Beach Access 45
At times during school holidays, good surf conditions and public holidays the beach access is overused.  The state of the paths from the track down to the beach is being constantly extended and the dunes damaged.  Currently cars park almost to the top of the hill on the eastern side of the road from the access point and also on the western side.

To restrict access, all that is needed is to extend the metal barrier on the eastern side of the road, from just south of the access point to part of the way up the hill.”

By email

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