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The Central Coast Council has recently placed its Draft Tree and Vegetation Management Chapter XXX on exhibition for public comment.

While the draft chapter generally requires landowners to obtain a Permit from Council to remove or prune a tree, the draft also describes Exemptions to avoid having to obtain a Council Permit.

The Draft Chapter and Submission details are available through the following link: https://www.yourvoiceourcoast.com/draft-development-control-plan-xx-tree-and-vegetation-management.

Under the proposed chapter, trees may be removed without a Permit if Council is “satisfied” that they are dead or are assessed as posing a risk to persons or property and are not required as habitat for native fauna. Evidence of these assessments is required to be kept by the landowner for 6 months after the removal.

Under the current draft the required evidence may be provided by an arborist with “Trade (AQF3)” qualifications.


  • AQF3 training does not cover tree species, diseases, assessment or reporting. This is covered in AQF5 training.
  • Therefore tradesmen with AQF3 qualifications do not have the knowledge to assess if…”vegetation is dying or dead and is not required as the habitat of native animals”
  • As most tree-removers hold AQF3 qualifications, there is a risk of unreliable evidence from sources with only this qualification.
  • Since tree-removers are paid to remove trees, they have a clear “Conflict of interest” if they are authorized to condemn trees.

Make a submission by 5.00pm on Monday 28th January 2019

It is recommended that your submission makes a comment similar to the following:

“Council can only maintain the tree canopy on the Central Coast if it carefully controls removal processes. If removal without a Permit is to be authorized under certain circumstances, Council must choose to be “satisfied” by evidence provided only by those who are properly qualified to assess and report on trees and who are also independent of any removal company. An AQF3 arborist is not qualified to make risk assessments of trees or to report on their condition.

I ask that Council amends the draft plan as follows:

In clause 3.1, amend “Notes” to read:

“Notes: In relation to 3.1 a ii and 3.1 a iii above, Council will be “satisfied” by evidence that is:

  • Provided by Council’s own AQF5 qualified Arborist; or
  • Provided by an AQF5 qualified Arborist or Ecological Consultant who is independent of any tree-removal entity.

In either case, removal must not occur prior to Council determination. Evidence must:

  1. Be submitted to Council prior to removal
  2. Be written and include photographs identifying the tree species and condition;
  3. Include evidence that the tree is dead or dying and that failure is imminent
  4. Include evidence that the vegetation is not required as the habitat of native animals;

In CL 3.2:

  • Delete Items “b, c, d and i”.
  • Amend “Notes” as follows:
    • Remove the words “Trade (AQF3) or” and
    • After the words “Consulting (AQF5) Arborist” add “or Ecological Consultant who is independent of any tree-removal entity,”

Appropriate Council staffing, Procedures, Forms and Records must be developed to enable these changes to be fully effective.”

You may also wish to comment on other improvements required in the draft chapter, for example:

  • Council should align this Chapter with the Community Strategic Plan and its vision for “an urban forest policy” and the greening of the Central Coast
  • Council should quickly develop a comprehensive and current Central Coast “Heritage and Significant Tree Register”
  • Council should recognise the value of non-native trees. In some areas maples, jacarandas and other large exotics provide the only canopy. These trees need to be retained while more natives are introduced.
  • In order to defray costs, Council should require the payment of a substantial tree removal application fee and substantial fines for contravention of policy
  • Council should require the planting of replacement trees as part of any permit and monitor compliance
  • Council should list reasons for removal that would be considered inadequate eg.:
    1. leaf drop (into gutters and downpipes - pools, lawns and the like);
    2. to increase natural light;
    3. to improve street lighting of private property;
    4. to enhance views;
    5. to reduce shade created by a tree;
    6. to reduce fruit, resin or bird droppings on cars;
    7. minor lifting of driveways and paths by tree roots;
    8. to erect a fence;
    9. bushfire hazard control which has not been verified by council;
    10. potential damage to sewer mains unless supported by written expert advice and only where reasonable alternatives are not feasible (e.g. relocation or encasement of main).
  • In the exhibition announcement, Council has invited community “feedback” on proposed exemptions. It has not defined what it considers to be “reasonable requirements” for tree preservation and maintaining the amenity of our suburbs”.

Please use your own words to make your submission unique. Identical submissions will not be counted by Council. Please also ask for a receipt for your submission.

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Contact details

CALL 02 4349 4756

FAX 02 4349 4755

PO Box 149 Ourimbah NSW 2258

The Manor, Central Coast Campus
University of Newcaste
Brush Road Ourimbah


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