|Manager Statutory Planning
Mornington Peninsula Shire Council
Private Bag 1000
ROSEBUD VIC 3939
RE: MARTHA COVE MARINA DEVELOPMENT-
TASSELL'S CREEK SAFETY BEACH
The Port Phillip Conservation Council (PPCC) Inc. is an
umbrella organisation representing fourteen conservation groups around
Port Phillip Bay. Individual membership is approximately 5000 persons.
PPCC Inc. has examined the current proposal for the above named development
and has considerable environmental, social and economic concerns regarding
the current development proposal. We write to seek your support for retention
of Tassell's Creek in its natural form, importantly as the last remaining
coastal open space and natural estuarine area on the Southern Peninsula.
Our most recent meeting passed the following unanimous
"PPCC Inc. is opposed to the construction of the proposed
groyne and breakwater at Tassell's Creek and the raising of ground level
within the development by up to 12.5 metres above A.H.D. Accordingly, we
request the Minister to refuse consent under the Coastal Management Act
(1995), and that the Mornington Peninsula Shire Council reject the proponent's
The current proposal will rely on an Environmental Effects
Statement (EES) completed in 1992, undertaken on a quite different development
proposal at Tassell's Creek, designed well over ten years ago. It also
relies on a 1992 Planning Scheme amendment, with a 1999 Planning Permit
issued as an adaptation of that 1992 amendment, at which time the current
proposal was not before the Mornington Peninsula Shire Council.
In the last ten years, with increasing urbanisation, the
Peninsula has lost significant open space - we now have less than 5% of
our original indigenous areas remaining. The 1992 EES reported that figure
at 14%. Our knowledge of the importance of natural coastal systems, estuaries
and wetlands in supporting species diversity and managing flood events
has also increased, along with our knowledge of the inevitable effects
of global warming.
The failure of previous development proposals for Tassell's
Creek over the years, and subsequent increasing urbanisation of the Peninsula
has paradoxically revealed that the Tassell's Creek coast and wetland is
a much more important resource than we thought it to be 10 years ago. It
is now a precious piece of open space, supporting remnant, albeit small,
indigenous colonies of flora and fauna. Significantly, one species, the
swamp skink is now listed as Threatened under the Flora and Fauna Guarantee
Act. As a natural waterway if rehabilitated and well managed Tassell's
Creek would provide significant habitat for the Swamp Skink and other indigenous
species not yet threatened. It could also provide the most effective protection
against future inevitable flood events.
Clearly the project is in fact fundamentally changed.
Some of our members were involved in the community opposition to the previous
proposal and have documentation which confirms that a very different proposal
underwent the Environmental Effects Study at that time. The following dot
points summarise some of our major areas of concern:
The natural foreshore area surrounding the site will
be extensively modified by the proposed development. Several boatsheds
and the Safety Beach Sailing Club and Clubhouse are proposed to be relocated
to another nearby foreshore location, thus imposing their deleterious effects
on another section of previously undeveloped coast. This will cause a loss
of amenity for all other beach users in the selected relocation area. Surrounding
foreshore is already compromised, is narrow and generally overdeveloped
and is in urgent need of revegetation, not further development. Port Phillip
Conservation Council Inc. is committed to a policy of removal of these
private, damaging structures from coastal Crown land. Consequently we request
that you refuse CMA consent for the relocation of these boatsheds and clubhouse.
These differences and alterations are major changes - and
cannot be described as "fundamentally unchanged" when compared with the
previous proposal now over 10 years old.
Tassell's Creek and a channel up to 4.5 metre deep and 220
metres seaward will be regularly dredged to create the Marina and waterway.
150 metres of prime public beach will be lost across the mouth of the newly
constructed channel and groynes.
Only one groyne was proposed in 1992 approximately 40 metres
shorter than current proposal. The additional breakwater (functional second
groyne) included in this proposal was not included in the 1992 proposal.
There will be significant additional adverse environmental and management
consequences attached to the current groyne proposal, compared with those
considered in 1992. Even the proponents' consultants are unsure of the
long-term effects on the existing regime, especially the small remaining
beach to the north of the proposed groynes. PPCC Inc. is appalled that
the proponent can arbitrarily decide that a longer breakwater and an additional
groyne could be included in this proposal without any further environmental
assessments. Further studies must be undertaken to attempt to quantify
the undoubted long-term effects.
Mornington Peninsula Shire Council intends to sell a parcel
of coastal land to the proponent for inclusion in the development. PPCC
Inc is opposed to any further private acquisition of coastal land. Private
ownership of coastal land causes conflicts with public users of coastal
land, and has caused untold damage to our coastal areas and is most usually
an inevitable expense to government in the long term.
The proposed groyne is 220 metres long, and approximately
4 metres high RL. Its width at the crest is 10 metres and at RL 0.00 is
approximately 22.5 metres. This is unacceptably physically and visually
intrusive, detracting from the current scenery provided by the natural
cove and backdrop of Mt. Martha cliffs. Residents on the slopes of Mt.
Martha will suffer this constant intrusion into their lives.
The 1992 proposal had much less extensive inland waterways.
The 'cascading canals' of the current proposal were not part of the 1992
proposal or EES.
The extensive banking around even the most inland of the
canals is unique to the new proposal. Embankments of up to 12.5 metres
AHD on flat land were not part of the previous proposal. This introduces
adverse social and environmental consequences for residents outside the
development who will be forced to live near a 'walled' development.
The 1992 EES concludes that a view from a residence is fortuitous
and should not be considered as intrinsic to a residence. However the EES
goes to great lengths to discuss the importance of viewlines for motorists
using the nearby freeway, concluding that although the then proposed development
would not adversely affect motorists views looking towards Mt. Martha Cove,
it was important to retain a sense of open space and rural landscape for
motorists. It seems incongruous that motorists rural views were considered
more important than those of permanent residents of Safety Beach.
Stormwater management arrangements, ongoing maintenance and
costs for those dwellings and streets outside the development affected
by the 12.5 metre high embankments is not adequately addressed in the current
proposal. Disturbance to viewlines for residents abutting the embankments
is not addressed at all.
The entire area is a recognised flood plain, and the local
vegetation has evolved to accommodate flood events. The area will inevitably
flood again as it has in the past, but natural systems to deal with flood
events have been altered/removed.
Has the developer undertaken a study on the impact this development
will have on changes to a future flood event, and can the impact of proposed
changes be accurately predicted?
Construction of the 'levees' will alter the impact and effect
of a flood in the area. It is highly likely that insurers will deny flood
damage to residents once alerted to the predisposing conditions that have
been created by the developer.
If the proposal were to proceed, residents should expect
the developer to provide an indemnity to protect residences affected by
floods arising from changes to natural watercourses, and any mismanagement
of artificial waterways (inland canals and harbour) which may contribute
to or augment a flood event.
Our most up to date science warns of the unpredictable nature
of future weather events, but the certainty of rising water levels. The
current proposal provides for the construction of hundreds of dwellings
on flat or 'remade' land, even on concrete slabs. The prospect of future
flooding for these properties is very real.
The current developer intends to remove ALL remaining vegetation
from the site. The previous EES reported low numbers of significant terrestrial
and avian species, but did concede that observations may have been undertaken
at times when particular species would not have been expected in the area.
It would seem logical, especially 10 years hence, with remaining indigenous
flora and fauna having declined further on the Peninsula that a more timely
and effortful report would be more appropriate and useful. Significantly,
the EES does concede that the threatened Swamp Skink was found on the site,
and speculated that the Glossy Grass Skink and Latham's Snipe, both of
conservation significance may well use the area.
The current Environmental plan seems to be little more than
a site management plan, and is in draft form only. A recent fauna study
under taken by Biosis Pty. Ltd. was on display at the Developer's information
day, however the attending consultant readily admitted that there had been
no study of aquatic or avian species.
Ten years ago, the then proponents described the Tassell's
Creek wetlands as "of local significance" - being unable to find
direct evidence that the EES had described the area as less than 'regional
significance' for "water oriented birds". With increased development in
the region in the last 10 years it seems highly likely that the area would
now be regionally significant as a wetland. This should be tested.
The previous proponent described the then proposal as
"... a much enlarged marine habitat and wetland/woodland ecosystem". The
current proposal does not incorporate a much enlarged wetland/woodland
ecosystem. Significantly the EES did not agree with the proponent on this
point, and stated that the number and diversity of marine species and water
birds can be expected to increase at the expense of the terrestrial and
freshwater species. PPCC Inc. suggests that the projected increase in marine
birds would include a large proportion of scavenging seagulls whose opportunistic
feeding habits attract them to marina developments.
The current proposal provides limited detail regarding the
proposed management of Tassell's Creek flow downstream of the proposed
development. It seems that redirection to the Bay via underground pipe
may be undertaken as fresh water flow into the inland canals is considered
undesirable. This means that natural downstream movement of fish and other
aquatic species within the creek system will be effectively terminated
at the development. Likewise, any marine species which relies on estuarine
habitat for feeding/spawning will not be able to access Tassell's Creek.
Local knowledge indicates that salmon spawn in the creek, and whiting breed
at its mouth. There does not seem to be adequate information available
on longterm effect on these natural events as a result of the proposed
Aquatic food sources for bird life and larger fish species
provided by these natural processes will also be consequently detrimentally
The new proposal has reduced public open space compared with
the previous proposal. The 1992 EES suggested that an oval or similar amount
of open space should be provided as part of the open space planning. The
current proponent readily admits that the proposal will have less open
space than that proposed over ten years ago.
A recent proposal for housing development on the Esplanade
at the Mt. Martha quarry site would compound traffic volumes on Marine
Dve/ Esplanade. Rather than continuing to consider proposals in isolation,
Planners should consider the two developments in tandem with regard to
their potential environmental and social impact on the area.
The current proposal confirms that over 8000 car trips per
day would be generated by the development. This does not include the additional
traffic generated by the marina and motel/restaurant. Since the previous
proposal, traffic levels on Marine Drive, and the Esplanade to Mornington
have increased significantly along with the explosion in tourism in the
region. Traffic studies in the current proposal rely on data up to 20 years.
Our membership believes that sustainable economic benefits
are obtainable in the ongoing employment opportunities for restoration
and maintenance of the natural estuarine and wetland area, the future promotion
of the area as a significant wetland for migratory birds and a scenic marine
and coastal area for the enjoyment of all. Recent leisure studies
have found that bird watching is the second most commonly undertaken leisure
activity. We are experiencing the start of a renewed community interest
in our environment and its unique inhabitants. It would be an outrage to
destroy some of the last remaining areas of our unique region to construct
an outmoded development for the dubious pleasure of the few.
The social benefits derived from preserving open space
have been confirmed in recent press articles and community action, which
has emphasised the fact that urban dwellers require open space, and that
in many areas opportunities for enjoying open space are limited or require
extensive travel. Tassell's Creek is the last remaining piece of
coastal/estuarine open space on the southern Peninsula, and forms a natural
'open space barrier' between the increasingly urbanised Mt. Martha and
Dromana. It presents an outstanding opportunity to commence an urban biosphere
regeneration project, rather than a tired old 1990s housing development,
of no intrinsic value to the wider community. Housing developments do not
have an exclusive claim on community health and wealth generation.
The current proposal and its underpinning approvals is
borne of a time when we were somewhat more ignorant of the environmental
and social consequences of our planning decisions, many examples of which
still exist to our shame. As you have recently supported the Mornington
Peninsula Shire Council in its proposal for the first global urban Biosphere,
your support for retention of the natural systems at Tassell's Creek, would
publicly confirm your commitment to the first urban biosphere.
Miss Olwen Bawden
Port Phillip Conservation Council Inc
26th July 2002