Environmental Assessment must come first: Proposed dog off-leash areas at Palm Beach (north) and Mona Vale Beach (south).

At the Council meeting on 27 April 2021, Council resolved to commence public exhibition for the trial parameters as described in the feasibility report for establishing dog off-leash areas at Palm Beach (north) and Mona Vale Beach (south).

The Palm Beach Protection Group’s key and fundamental issue with the resolution is that the feasibility report has raised a number of environmental concerns. This includes risks and environmental impacts communicated by key NSW Government agencies.

Given the requirements of relevant legislation, including the Environmental Planning and Assessment Act, these environmental considerations need be investigated ahead of developing any proposed off-leash dog trial parameters, and before engaging with the community.

Indeed, it is noted that the report to Council recommends community engagement should be undertaken after environmental assessments have been completed and reported to Council. The Palm Beach Protection Group notes however that the current community consultation was accelerated ahead of assessments of environmental considerations, following agitation by the pro-dog activist group, Pittwater Unleashed.

This approach is similar to the failed off-leash dog trial at Station Beach where community consultation was also sought ahead of environmental assessment in an attempt to stymie critical analysis. In this instance, the Council failed to examine and consider to the fullest extent possible all matters affecting or likely to affect the environment by reason of the off-leash dog activity.

The Palm Beach Protection Group is encouraging people who care about our beaches to vote ‘No’ and not support the proposal for Palm Beach (north) and Mona Vale Beach (south). Beaches are flourishing ecosystems with unique environmental sensitivities. Please register your Non-Support by visiting Council’s comment page. In the comments section, please mention that a decision over a future trial must commence after the environmental process is completed. Please note, Council has set up the comment form on two tabs, one for each beach, so please ensure you vote on each tab. Comments close soon on 6 June 2021.

Click here: Proposed Dog Off-Leash Concept Plan

Click here: Council’s comment page

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In addition to the fundamental issue named above, we note the following concerns, omissions and issues with the proposal:

(1)   Environmental Risks

There are serious environmental concerns with the proposed trial area location, given its close proximity to the Barrenjoey Headland National Park.

NSW National Parks and Wildlife Services (NPWS) correspondence to Council dated 25 March 2021 has indicated that NPWS would prefer to see the proposed area brought further south so the northern end of the off-leash area aligns with the northern end of the Governor Philip car park. NPWS has flagged concern that due to the secluded nature of the northern area, dog walkers may be tempted to let their dogs continue further north into the biodiverse habitats protected within the area. NPWS has also asked Council to be cognisant of the NPWS’s future pest control program within the national park and its potential risk to domestic dogs. Finally, NPWS has also requested Council to advise how dogs will be managed given the potential risks of interaction between the semi-permanent wild seal population which occupies the rock shelves at Barrenjoey Headland, noting that the animals view one another as a threat. Consideration of these issues could cause the proposed boundaries to be moved.

Other important environmental considerations include potential direct impacts to sand dunes erosion, dune vegetation, migratory and non-migratory birds, associated natural fauna habitats, water quality and aquatic ecology.

(2)   Proposed Boundaries

There is no detail provided by Council in relation to the areas between the car park and the proposed off-leash area. Does this mean that dog walkers are free to unleash their dogs from the Governor Phillip car park, which can then roam freely into the adjacent unprotected national park?

(3)   Proposed Times

Experience has shown from the previous Station Beach trial that many dog owners do not respect the permitted access times, visiting the beach at all-hours. We consider compliance will be an issue here again.

(4)   Pollution

Experience from the Station Beach trial saw a marked increase in dog pollution on the beach and in the water. It was noted that many dog walkers believed that the tide will wash away dog pollution. We noted that beach users avoided swimming in areas that dogs have occupied. We consider that Palm Beach, being such an iconic beach, should not be subject to this kind of pollution. We consider compliance will be an issue here again.

(5)   Fencing

As the proposed western boundary bookends the national park, fencing or other permanent controls will have to be installed to ensure that dogs do not enter the park. This also applies to the pathways from the car park to the beach. This will be costly and unsightly.

(6)   Signage

Signage at the designated boundary areas will need to be prominent. This will partially deface what is an iconic beach. The experience at Station Beach, showed that many dog owners ignored signage, which highlighted permitted times, days and boundaries. We anticipate that signage will be ignored again.

(7)   Compliance

Given the secluded nature of the proposed trial areas, effectively managing compliance of complacent dog owners operating outside permitted areas and times, will be more difficult for Council Rangers and will likely heighten possible environmental damage.

(8)   Conflict between dogs and beach users

If the proposed area is moved south as the NSW National Parks and Wildlife Services recommends, then this would bring dogs into close proximity to the North Palm Beach SLSC patrolled area. Given that dogs are likely to roam beyond the designated area, this will likely lead to conflict with families and other users of the beach around the patrolled area.

(9)   Palm Beach already has extensive dog walking areas

Palm Beach already provides extensive dog walking areas without a justifiable need to extend dog activity to Palm Beach (north). Governor Phillip Park is actively used as a dog walking area. The recently opened pedestrian pathway from Governor Phillip Park, Beach Road to Ocean Road through to Palm Beach (south), is attracting significant dog walkers on a daily basis. This has provided a long stretch solution for dog walkers without impacting the environmentally sensitive beach area and which avoids conflict with other beach users.