20th September 1999

Office of Planning
Department of Infrastructure
PO Box 576 Geelong
Vic 3220

Dear Sir/Madam,

Re: Amendment R243 of Greater Geelong Planning Scheme

Watersports Complex Proposal

We are writing to object to the International Watersports Complex proposal for Belmont Common. The Geelong Community Forum is an independent community advocacy group which focuses upon raising debate around issues of environmental sustainability and issues of social justice and equity. There is no reciprocal membership arrangement between the Friends of the Belmont Common and our organisation, however, we would like to indicate our wholehearted support for the views of the Friends of the Belmont Common.

The members of the Friends of the Belmont include some of Geelong’s most eminent conservationists and field naturalists who have generously contributed their decades of experience to campaigning against this complex on behalf of the wider community. From the outset we would like this fact alone to be recognised as a significant opportunity cost. These are the same people who would otherwise be contributing their valuable time and energy to tree planting, educational activities and general community development. It is a shocking waste of time, resources and emotional energy for these people to have to fight against this ill conceived project which has already been rejected by previous generations twice in the past half century.

We believe that a permanent moratorium should be placed upon this development and all commercial developments on the Belmont Common and flood plains along the Barwon river. Furthermore we would ask that the funding made available for this project be redirected into a proposal raised by members of the Geelong Environment Council to create the most interesting and environmentally friendly golf course in Australia, and also the construction of a new bridge from Fellmongers Road to properly link the east and west of Geelong.

 

Specific Concerns

Flora and Fauna Guarantee Act

We would like to draw your attention to the provisions of the Flora and Fauna Guarantee Act 1988, Schedule 3, which relates to ‘potentially threatening processes’ to flora and/ fauna.

Sch. 3. amended by GG27.5.92 p1258

"Alteration to the natural flow regimes of rivers and streams"

• Cutting a channel through the Belmont Common will affect both the natural flow of the river out to Barwon Heads, and also its course during flooding. Post flooding it can be anticipated that stagnant water and rubbish will be trapped either side of the embankments where it will be unable to flow away.

• Digging of the channel may lead to a lowering of the water levels which sustain the Jerringot Wetlands.

• The report by consultants Sinclair, Knight and Mertz states that "In the long term, there is a risk that the old river course could become partially blocked to the point where the river reroutes itself along the new alignment" (SKM, 71).

Sch. 3. amended by GG 8.6.95 p.1391

"Input of toxic substances into Victorian rivers and streams due to human activities."

• The Belmont Common is known to be the site of a disused rubbish tip potentially containing high levels of toxic material and heavy metals. The consultants predicted that zinc would be released into river at levels 450 times higher than those allowed by the Environmental Protection Authority guidelines (SKM 53).

• In recent years the water surrounding the nearby Balliang Sanctuary has become thick with toxic and anoxic blue green algae. It is not unreasonable to predict that the stagnant channel would similarly become an enormous breeding pond for such algae which would not only impact upon wildlife, especially oxygen starved fish, but also make it impossible to run events on the course during a bloom.

• No fewer than eight species of animal are listed as threatened under Schedule 2 Appendix 5a of the Fora and Fauna Guarantee Act 1988 have been confirmed at the proposed site and would suffer significant impact if the proposal were to proceed.

 

Flora and Fauna Guarantee Act 1988 listed animal species:

Birds

Great Egret (Egretta alba)
Orange Bellied Parrot (Neophema chrysogaster)
Little Egret (Egretta garzetta)
Baillon's Crake (Porzana pusilla)
Brolga (at Reedy Lake)

Fish

Australian Mudfish Galaxias sp
Australian Greyling

Mammals

Common Bentwing Bat

Amphibians

Growling grass frog (Littoria raniformis)

This list continues to grow in two ways:

1) Threatened plants and animals are returning to the Common as the plantings made by the Golf club and the Geelong Field Naturalists mature and are extended.

2) Each year more species are added to the list as habitat is destroyed and their viability becomes more threatened.

There is an opportunity here to halt the destructive processes and work with the community to provide extra habitat rather than less.

Loss of Trees

• The loss of 6,000 trees rates a special mention. Those trees were planted by the community and no doubt contribute significantly to lower carbon monoxide and other pollution levels from the adjacent freeway.

 

Wind Studies

• We question the positioning of the wind study site, a sheltered oval removed from the location of the proposed course.

• We also question why wind studies were not conducted during the windiest times of the year, namely the equinoctial periods of March and September, rather than simply during the off-season. For correct predictions, there should have been wind studies done for each month of the year. Wind has been one of the limiting factors of the Carrum course; it would be ironic and wasteful if this error were to be repeated twice in the same state.

• We have reason to believe that in high winds the reflection from the ends of the course could lead to standing waves of up to several metres. Waves of that height could snap an eight in half as has been known to happen on the Hopkins River in Warrnambool and also at Lake Colac. Mathematical models of predicted wind conditions should have been included in the consultants’ report.

Visual Amenity

• With banks over 4.5m high and 80 metres wide on a high slope no amount of landscape gardening is ever going to hide either from the freeway or from the ground, what will be an appalling visual eyesore which is totally out of keeping with the surrounding area. In addition, the width of the course is triple that of the existing river, and of course, in a dead straight line producing a visual impact which will be tremendously sterile.

Water Licensing

• The proponents of the course have not yet managed to gain a water permit from the appropriate authority. There is no guarantee that a water permit will be granted due to water shortages which have already led to restrictions. The water requirements of the broader community should be considered ahead of this course.

The Value of Public Open Space

• The Belmont Common is public parkland and as such is well utilised by the community for many recreational and leisure activities. It is the Green Heart of Geelong, of similar importance to our region as Corio Bay and the Bay front surroundings. It must be preserved for these reasons, and for the use of the Geelong community, for visitors to our city, and tourists, now, and for future generations.

 

• We believe that the excision of 64 ha of public open space contravenes the City’s own Environment Management and Open Space Strategies (1998). It is also out of keeping with two important community charters - namely the Parklands Principles and the Parklands Code. Under the latter two documents, for example, the City would be required to substitute a similar area of land for that which is lost. There is nowhere else in Geelong where this could happen.

• We adamantly reject the argument of the proponents that this proposal ‘increases’ the accessibility of public open space by getting rid of the golf course. This is nonsense as people will need to walk the length of the course to access the existing river banks which are among the most scenic areas on the Common.

• As population pressures increase in Geelong we need a place where people can go for passive recreational pursuits such as walking along the river. The removal of this space could negatively impact upon the psychological health of a large proportion of the community.

• The value of public open space has not been addressed in a formal social impact analysis.

Safety

• The small access bridge to the centre island of the course does not take into account safety issues such as access for fire trucks or ambulances.

• In addition, similar islands in Geelong, such as in the Balliang Sanctuary are off-limits to the public because of snake investation, in particular, by the aggressive tiger snake.

• The gradient of the banks could be hazardous to people who attempt to walk down to water level.

Costings

• The cost estimates for this course are up to twenty million dollars lower than for comparable courses elsewhere in the country. Why would anyone choose to schedule an international event on a cut-price course?

• There has not been a formal Cost-Benefit Analysis of the proposal which fully costs out 2nd and 3rd order flow-on effects against the lost opportunity costs of the land as it is currently being used, or could be used in the future. This includes the 30,000 casual and long-term patrons of the community golf course which will be closed down.

 

• There have been no realistic estimates of spectator numbers, the costs of car-parking, fixed structures, ongoing maintenance costs, the refurbishment of wetlands, the loss of the proposed bridge from Fellows Road and the cost of re-routing the road and bridge around the complex.

• In addition, the City is spending large sums of rate payer money on public relations exercises. We are not satisfied with the figures supplied to our organisation about the cost to the community and will undertake further investigations into these ancillary expenses in time for the panel hearings.

Conclusion

We don’t believe that the push for this project is from the grass roots rowing fraternity, but appears to be initiated by the City of Greater Geelong and vested business interests. The real losers will be regional biodiversity, and the Geelong Community who will face increased water restrictions, decades worth of maintenance costs and the loss of more important uses for the money.

In the two public meetings which have taken place in Geelong so far with 600 and then 900 people in attendance, objections to the course have been overwhelming. It speaks for itself that the City of Greater Geelong has refused to call its own public meetings on this issue. We ask the relevant planning authorities to put the community ahead of the narrow interests of one lobby group and reject the Watersports Complex Proposal.

Written by Serena O’Meley and Stuart McCallum
on behalf of the Geelong Community Forum, Inc.

 

Submitted by Stuart McCallum