Nature-Based Tourism Grant and the Unanswered Permission Clarification
In Defence of Ediblescapes
Issue Five: Nature-Based Tourism Grant and the Unanswered Permission Clarification
Correcting the record about the grant application
The City has identified the following matter as one of the grounds supporting its decision not to renew Ediblescapes’ licence:
“Submission of an application for the City’s Natural-based Tourism Grant while indicating that all required permissions had been obtained when they had not. Recreational Services requested additional information regarding the proposal; however, this information was not provided before the application proceeded.”
Ediblescapes believes this description omits important documented context.
Ediblescapes did not ignore Recreation Services’ communication. We responded on the same day, clarified the proposed sequence of activities, stated that visitor infrastructure would depend upon permissions being in place and directly asked Recreation Services whether we were permitted to submit a formal project proposal.
That question was not answered.
Ediblescapes sought guidance before applying
On 3 June 2025, Ediblescapes wrote to Recreation Services explaining its intention to apply for the City’s Nature-Based Tourism Program.
The accompanying document described a proposal to develop Ediblescapes as a regenerative, climate-conscious visitor and learning experience within the existing garden footprint.
It included interpretive visitor activities, education about agroecology and community food systems, and a proposed plant-based cultural cooking component.\
Ediblescapes expressly requested:
- feedback from Recreation Services to ensure alignment with City planning;
- consideration of a letter of support; and
- confirmation that the proposed activities were consistent with the permitted use of the existing site.
This correspondence demonstrates that Ediblescapes was actively seeking confirmation and guidance from the City before submitting the grant application. It was not presenting every proposed physical element as already approved.
Recreation Services’ response
On 4 June 2025 at 8:20 am, Recreation Services advised that, before undertaking improvements or works on City-owned premises, Ediblescapes would need to submit a Recreation Services Project Proposal.
The requested supporting documents included:
- professional drawings or plans;
- a location map and details of vehicular access;
- a site plan;
- written quotations or a quantity-surveyor estimate;
- a project budget, including contingency and evidence of funding; and
- evidence of public liability insurance.
The email also stated:
“Work must not commence until we provide written consent as landlord.”
Ediblescapes understood this direction to concern proposed improvements or physical works. It did not understand it to prohibit submission of a grant application whose initial phase centred on capacity-building, community engagement and media development.
Ediblescapes responded on the same day
At 8:01 pm on 4 June 2025, Ediblescapes replied to Recreation Services.
The response explained that the first phase of the proposed Nature-Based Tourism project was intended for capacity-building, including:
- workshops for the Ediblescapes core team;
- community-engagement activities; and
- development of digital, video and social-media content promoting Ediblescapes as a climate-conscious visitor experience.
Ediblescapes also clarified that visitor infrastructure was not planned during this initial phase:
“The delivery of visitor infrastructure, such as the outdoor cultural cooking equipment, is not planned until after this first capacity-building phase—likely in the period from July to September 2026, once readiness and permissions are in place.”
The response further explained that, if permanent infrastructure could not be supported, Ediblescapes was prepared to:
“adjust the delivery timeline and/or modify the visitor experience to include mobile cooking equipment and improved storage systems, all within our approved garden footprint.”
At the time, Ediblescapes understood that it was continuing under a verbally described provisional or probationary status. No written guidance had explained whether an organisation under this status was eligible to submit an infrastructure-related Project Proposal.
For that reason, Ediblescapes directly asked:
“Could you please confirm whether Ediblescapes is permitted to submit a project proposal during the current provisional period?”
The email concluded:
“Please let me know if a meeting or additional documentation would be helpful at this stage.”
This response was sent 26 days before the Nature-Based Tourism Grant application was submitted on 30 June 2025.
The clarification was not answered
Recreation Services did not reply to the 4 June 2025 email.
Consequently, Ediblescapes received no answer to its direct question about whether it could submit a Project Proposal during the provisional period. Recreation Services also did not identify what further information, if any, was required for the capacity-building components of the proposed grant project.
Based on the correspondence available to Ediblescapes, there was no further communication from Recreation Services concerning this matter for more than a year. It was subsequently raised retrospectively as a ground supporting the decision not to renew the licence.
The statement that requested information “was not provided before the application proceeded” therefore requires context.
Ediblescapes did not submit professional construction drawings and the other supporting documents because it had clarified that infrastructure would not be delivered during the initial capacity-building phase and would depend upon readiness and permissions being in place.
Ediblescapes asked whether it was eligible to commence the formal Project Proposal process but received no answer.
A grant application was not permission to commence works
Ediblescapes did not treat submission or approval of the Nature-Based Tourism Grant application as landlord consent to undertake physical works.
The grant application allowed a proposed visitor and educational experience to be assessed and developed. Any physical component requiring separate landlord or regulatory approval would still require that approval before proceeding.
No new permanent visitor infrastructure was constructed under the Nature-Based Tourism project.
As the project developed, its delivery remained within the existing garden footprint and centred on capacity-building, interpretive learning resources, community engagement, media, storytelling and portable community food activities.
The permission statement requires context
The City’s statement says that Ediblescapes indicated that all required permissions had been obtained.
Any such indication must be interpreted alongside the information and documents provided with the application, including Ediblescapes’ existing Deed of Licence and the contemporaneous correspondence with Recreation Services.
Ediblescapes held a current Deed permitting community-based ecologically sustainable food production, organic-food production and distribution, workshops and community events. This provided the existing operational basis for many of the proposed educational and community activities.
However, Ediblescapes did not claim in its correspondence that separate approval for future physical infrastructure had already been granted. On the contrary, the written record expressly stated that infrastructure would proceed only “once readiness and permissions are in place.”
The contemporaneous correspondence therefore does not support an interpretation that Ediblescapes intended to conceal an absence of infrastructure approval or knowingly proceed with unauthorised works.
Ediblescapes’ position
Ediblescapes accepts that a clearer written distinction should have been established between:
- permission to submit and be assessed for a grant;
- activities already permitted under the existing Deed of Licence; and
- separate landlord or regulatory approval required before physical works could commence.
However, we dispute any implication that Ediblescapes ignored Recreation Services, concealed the proposal or knowingly proceeded as though approval for physical infrastructure had already been obtained.
The documented record demonstrates that Ediblescapes:
- informed Recreation Services of the intended application before submitting it;
- requested confirmation that the proposed activities aligned with the permitted use;
- responded to Recreation Services on the same day;
- distinguished the initial capacity-building phase from later infrastructure;
- expressly stated that infrastructure depended upon readiness and permissions;
- offered to modify the visitor experience if permanent infrastructure could not be supported;
- directly asked whether it could submit a formal Project Proposal;
- invited a meeting or a request for additional documentation; and
- received no response to these questions.
A fair assessment must consider this complete exchange—not only the fact that construction documents were not subsequently submitted.
The constructive way forward is a clear and responsive process distinguishing grant eligibility, permitted activities and approval for physical works. When a community organisation asks the responsible City service for procedural clarification, that question should be answered before the absence of further documentation is later treated as evidence of non-compliance.
This statement is offered respectfully to establish the documented sequence and support a fair, proportionate and evidence-based conversation.
Supporting records
3–4 June 2025 — Email exchange between Ediblescapes and Recreation Services
Includes Ediblescapes’ notification of its intended application, Recreation Services’ Project Proposal requirements and Ediblescapes’ same-day clarification and request for guidance.
3 June 2025 — Clarification of Ediblescapes’ 2025–2026 Plans and Nature-Based Tourism Project Proposal
The document provided to Recreation Services before the grant application, requesting feedback, confirmation of alignment and support.
