Dear Dr Kennedy, 

Application for a Planning Permit Ref. No. PO2/ 0535 Rye Foreshore Reserve: BMX Bike & Skating Facility 

Port Phillip Conservation Council Inc., a federation of 15 conservation organizations around Port Phillip, notes your Council’s receipt of the above application for a "permanent skate boarding, inline skating and BMX bike skating facility" on the Rye foreshore near the Ranger’s office. 

Port Phillip Conservation Council Inc. objects to the above Planning Application for the reasons below: 

Water Dependence: The proposed facilities are in no way coast or water dependent. They will function just as well on other inland sites. It has been the well-accepted policy of State Governments over many decades that the very narrow essentially fixed area of coastal reserve land around Port Phillip should be left in its natural condition as far as possible, with the exception of limited development that is water dependent. It is a well-established planning principle in Victoria that coastal land should be free of avoidable intrusions. The proposal appears to be inconsistent with the Victorian Coastal Strategy. It is an appalling state of affairs that such an incompatible development is to be foisted on the distinctive and highly regarded Foreshore Reserve on the basis that "Council can find nowhere else to put it". That is tantamount to treating the Foreshore Reserve as a dumping ground of last resort. 

Removal of Indigenous Trees: Removal of indigenous trees is required to place the facility among the remaining trees. Removal of indigenous vegetation on foreshore land is a particularly critical matter. Coastal vegetation protects dunes against erosion. Gradual and unwanted spread of sand by the wind has been facilitated already at Rye foreshore by earlier removal of vegetation. Windborne sand was a major reason why a similar proposal was rejected at Frankston, as Frankston City Council realized that grains of sand constantly being blown into the metal bearings of skateboards was a major reason for preferring a much more sheltered inland site for their facility. 

Concrete Cover: PPCC Inc. understands that the proposal involves over 1000 square metres of concrete being placed on the foreshore. That is an ugly and incompatible treatment for any part of the edge of the metropolis’s major natural feature, Port Phillip Bay. 
Deterioration and Removal: As has been all too common for developments in the corrosive and abrasive coastal environment, there appears to be no commitment for future maintenance against the harsh deteriorating influences of sun, salt and wind-blown sand. The result is that the usual steady deterioration and neglect can be expected. Past experience has shown that enthusiasms like skateboarding have usually been ephemeral. Nevertheless the Shire, notwithstanding its proclaimed commitment to sustainable development, appears to have not required a bond to be lodged to provide for the inevitable ultimate demolition and sound disposal of the works, and for the restoration of the site. 
 
Introduction of Unwanted Noise onto the Foreshore Reserve: Users of the Foreshore Reserve are entitled to expect that the main sounds they will hear there will be those of waves on the shore, and the wind. The harsh metallic and mechanical noise produced by skateboards on concrete is an unwarranted intrusion onto the Foreshore Reserve and its relaxing and pleasant acoustic environment. 

A Central rather than a Peripheral Site is Needed: Using a site on the very edge of the municipality is a very poor way to maximize the accessibility of a facility. Surely Council should aim at a site that caters for users coming from 360° of the compass rather than a mere 180° as is the case with the proposed site. 

Adjacent Excess: The site is near an area of foreshore where at various stages a large conglomeration of other intrusive developments has been imposed. Those have included the very large area of foreshore taken over for car and boat trailer parking at the Rye Boat Ramp, and many other structures in that area. The load of intrusive development has become excessive. Other land, less highly regarded than the foreshore, should be used for the skateboard proposal. 

Pre-emption of Plan: The Shire is preparing a Coast Action Plan (CAP), whose outcome should be awaited before a structure that is evidently inconsistent with it is imposed on the coast. It seriously devalues the status and credibility of such a Plan if attempts are made to intrude items likely to be unacceptable in such a Plan before the Plan comes to fruition. At the very least a decision should not be made in the absence of a Coast Action Plan unless an Environment Effects Statement has been produced that satisfactorily demonstrates that the facility could be accepted. 

Yours sincerely, 

Geoffrey Goode 
President 
Port Phillip Conservation Council Inc. 

 
cc.  Hon. Sherryl Garbutt MLA; Minister for Conservation and Environment; Mr Victor Perton MLA; 
      Mr Martin Dixon MLA; Hon. Ron Bowden MLC: Hon. Ken Smith MLC; 
      Mornington Peninsula Shire councillors 
      Mr Nick Wimbush, Central Coastal Board