Submission to the Department of Environment, Land, Water & Planning from Anne Heath Mennell
I am writing as an individual who has been a resident of the Western Port ward of Bass Coast Shire for nearly twenty years. My particular concern is the part of the pilot project which involves actual and proposed sites on the eastern shores of Western Port. Some of these encroach on land currently part of the Holden Proving Ground.
As you will know, that site is for sale and there is a strong community alliance, supported by the Bass Coast Shire Council, working to preserve the site. It is a unique tract of coastal forest which has been protected from encroachment for the past sixty years and is irreplaceable. It provides habitat for many species of flora and wildlife, some of which are endangered. There is potential for the site to form part of a wildlife corridor and to link with other remnant landscapes as a larger nature reserve. Allowing sand-mining on even a part of this site would be environmental vandalism in the extreme.
In the 19th century, the treed hills of South Gippsland were felled and the wood shipped across Western Port to build Melbourne. In the 20th century, the sea grass meadows of Western Port were cleared almost to extinction and also shipped to Melbourne to be used for insulation, I believe. There have been sand and gravel quarries in this region for many years and there remain many leases which were granted a long time ago and have not yet been exploited. Where these are in areas of relatively low environmental value eg cleared land which can be rehabilitated post extraction, there would be little objection. However, I do think that it is past time to stop stripping this area of its non-renewable resources.
In the Overview document it states:
‘The project will trial the establishment of SERAs that will define the locations of strategic state resources while considering other existing land uses, environmental assets and community interests.’ (my emphasis).
I interpret that to mean that the project will give equal weight to each of those factors and will be trying to balance the needs of each where they might be in competition. In reality, the project appears to elevate the importance of extractive resources at the expense of the natural environment and other key planning considerations.
The Overview also states,
‘The Victorian Government is committed to helping secure access to critical materials to build our future homes and infrastructure affordably.’
Demand for quarry materials is expected to continue rising and there is a need to source them close to where they will be used to keep construction and transport costs down in order to improve affordability and sustainability.
Whilst these are important objectives, it implies that existing processes are inadequate and need improving to ‘secure access to these critical materials’. The number of existing mining leases in the West and South Gippsland region, both active and already approved, suggests that a secure pipeline of critical materials already exists. The report suggests that the current processes are too long, costly and uncertain and that biodiversity requirements are key constraints, involving very high upfront costs to the extractive industry. The proposals in the report seem to favour extraction at the expense of any other land use and remove any opportunity for community involvement.
The Overview also states:
‘The Victorian Government is inviting feedback on the methodology used to inform the SERA pilot project, the SERA boundaries in the two pilot locations, and the planning controls drafted to implement them.’
The stated aim of the report is to ensure greater certainty for the extractive industry. It aims to achieve that by designating areas as SERAs and reducing the need to justify why quarrying is appropriate at particular sites. Effectively, the report prioritises the needs of extractive industries at the expense of any other activities including environmental, community and local government interests and use by other industries and food production. It demonstrates the wide coverage of a potential SERA (and State Resource Overlays) in South Gippsland. The area involved includes a nature conservation reserve and a natural environment that seems to have been given little or no consideration. What defines a ‘suitable location’ should be clarified in terms of the ecological, landscape, habitat and vegetation values of each proposed area. Detailed analysis and proper consideration of sensitive environments need to be undertaken before any decisions are made.
My comments on boundaries relate only to the Gippsland pilot locations.
The marked SERA investigation area and extractive industry interest areas, if approved, would end any possibility of creating wildlife corridors and linkages of existing small reserves, from north to south of the eastern shoreline of Western Port. The area proposed to be ‘carved out’ for quarrying is enormous and appears to include part, if not all, of the Holden Proving Ground site. It would be a desecration to turn this site into a quarry. Remediation would be impossible. Designation of all these areas as SERAs is a land grab of amazing proportions. Sourcing resources close to where they will be used to keep costs (to the industry?) down and to improve affordability and sustainability is laudable but at what cost to irreplaceable environments? There is an argument for using nearby sites where appropriate and suitable but to protect highly sensitive, valuable and unique sites surely it is worth sourcing some resources from further afield and paying the price.
Demand for building materials will certainly continue to rise in the future but new materials and construction methods are being developed all the time. Surely it would be prudent to explore some of these options, including using recycled materials, to reduce the need to excavate non-renewable resources and devastate landscapes, ecosystems and habitats which are already under pressure.
The project appears to elevate the importance of extractive resources at the expense of the natural environment, landholders such as farmers and traditional owners, other activities such as tourism and other key planning considerations. Areas with high biodiversity value have been included within the proposed SERA boundary as they apparently do not necessarily ‘restrict or impinge’ on quarry operations.
There will no longer be any requirement for public notification and participation so local communities will not be included in the planning process. Local Government input would be severely restricted. Coverage of the proposed overlay would not only apply to existing resource sites, but also to future expansion and buffer zones.
This prioritises planning for extraction sites above all other potential uses and weakens existing planning processes which provide some protection for sensitive sites. This is a retrograde step which should not be allowed to happen.
Planning controls should continue to be robust, comprehensive, consultative and transparent. The extractive industry should be planning ahead to allow time for necessary resources to come on line after thorough consideration of each proposal. Where proposals are in competition with other uses there should be a process of assessment which could result in re-negotiation, compromise or trade-offs to minimise conflict.
In October 2019 Bass Coast was declared a Distinctive Area and Landscape under the Planning and Environment Act 1987, offering increased protection to the coastal environment. The environment is the economy for Bass Coast and it is an important visitor destination for travellers from interstate, internationally and locally. Western Port is a Ramsar wetland, part of a UN Biosphere and contains three small marine National Parks. The eastern coastline of Western Port is very fragile and inland, the remnant vegetation is vulnerable. The State Government is putting protections in place for some of these sites and yet other parts of the government seem to be trying to remove or weaken these protections for the same sites.
The Legislative Council Environment and Planning Committee of State Parliament is currently undertaking an inquiry into the decline of Victoria’s ecosystems and measures to restore habitats and populations of threatened and endangered species. It is seeking public submissions. Some of those ecosystems, habitats and endangered species are within the South Gippsland SERA boundary and the extractive industry interest areas. These competing imperatives need to be reconciled via a considered, coordinated and transparent planning process
Anne Heath Mennell
54 Bayview Avenue, Tenby Point, VIC 3984.