Author:  MBCL member - Name withheld

Date:  August 2007

Submission:  Submission to the Kingston Coastal Management Plan

 

 

Rebecca Cohen

Foreshore Coordinator

City of Kingston

 

Dear Ms Cohen,

 

Comments on Vision and Values Report - Kingston Coastal Management Plan

 

There is no closing date for comments stated on this report, and you indicated to us that it would be acceptable to receive our contribution about the end of August, so we assume that our comments will be accepted and considered.

This Vision and Values Report for the Kingston Coastal Management Plan covers a range of issues needed to develop a comprehensive management plan for the Kingston foreshore.  However, there are some additions, changes or deletions needed, or preferred by us, which we cover below.

General Comments:

We are particularly pleased with the proposed mapping of Ecological Vegetation Classes south of Mordialloc Creek, which is likely to find plants of interest, especially in the less disturbed area south of Patterson River.  (Ideally, over time, we would prefer mapping of Ecological Vegetation Classes undertaken for all natural areas to discover the ‘ecological bounty’ and potential biodiversity in Kingston, which would be consistent with the Kingston Biodiversity Strategy.)  And we are pleased that new foreshore planting is to be indigenous.

We are also pleased that heritage is to be recognised in the CMP, and that future development and commercial activity should be maintained at current levels.  We support increasing and improving Rakali habitat, and suggest that there may also be scope to improve habitat and habitat links for other fauna.

We also support all of the Key Messages throughout this report, except where indicated under specific comments below.

One of the actions in the Foreshore Vegetation Management Principles promotes ‘Encouraging planting of indigenous vegetation on private property’, which we wholeheartedly support, particularly where properties on dunes have displaced the original plant communities, including trees.  We suggest that this action be further embraced in the City of Kingston by adopting a cherished tradition in the United Kingdom where landholders reserve a portion of their land for native flora and fauna, or at least one corner or canopy tree.

This Vision and Values report makes several worthy statements, such as maintaining and restoring pre-European biological diversity, protecting the sensitive foreshore environment, recognising heritage features, etc.  Nevertheless, the focus of this report is on recreational, tourism and commercial opportunities or facilities, which is at variance with protecting the foreshore environment.  This is a conundrum.  One way of reconciling these two opposites, regarding the foreshore environment, is to ask if any proposed principle or action does harm to the natural foreshore environment; if so, is it really needed, or can it be modified or minimised to a level that does little or no harm.

We are very concerned that reference to the natural foreshore environment is missing or repeatedly ‘watered down’ as a lower priority.  We would like to see greater reference to, emphasis on, and acknowledgment of, the protection and rehabilitation of the natural foreshore environment, as a reminder that it exists and is worthy of protection.  And also because (1) such recognition and care is a focus and principle in the Victorian Coastal Strategy 2002; (2) a Melbourne 2030 policy states, “Protect coastal and foreshore environments…”, and (3) the Kingston Municipal Strategic Statement identifies the key challenges of ‘Foreshore enhancement’ and ‘Protecting and enhancing ecological value’.

We would also like to see greater reference to Aboriginal Heritage and Culture and any archaeological sites, and more emphasis on climate change factors.

The word ‘enhance’ in this document is ambiguous—it can mean different things to different people in different contexts.  For clarity, please define ‘enhance’ or give examples of enhancement where the word appears.

A thorough spelling and grammar check is needed to correct errors, duplication, repetition and unnecessary words.  Inappropriate apostrophes on pages 7 and 8 should be deleted and replaced with ‘a’ or ‘an’ or ‘the’ CHMP/RAP, because CHMPs and RAPs are documents not individuals.

Above:  Parkdale Foreshore – bay, beach, dunes, sandy path and coastal vegetation – adjacent to Beach Road and two storey housing.

 

Specific comments:

 

More detailed comments follow, with our additions or changes appearing in italics:

 

Introduction (page 1):

The introductory description in this Vision and Values Report needs to be more comprehensive, because it is not truly representative of the Kingston coast.  Anyone who had not actually seen the Kingston foreshore, might assume that this coastal environment is a beach playground for hordes of people, has no dunes and cliffs, has no native vegetation or land or marine wildlife, and has no history.  Please also include:

·        in particular, a statement such as, ‘The Kingston foreshore is home to a wide range of coastal flora and fauna that significantly contribute to the local flora and fauna biodiversity

·        reference to marine life

·        the geographic history and make-up of the Kingston coast

·          the Aboriginal and European cultural and built heritage along the foreshore

·          the recent impact of climate change.

What is a Coastal Management Plan? (page 1)

 

Key message.  Under ‘Purpose’, for clarity, please give broad examples of coastal values, e.g. natural environment, wildlife habitat, amenity, relaxation, recreation, etc.

Page 2, 1st para.  Protection of and impacts on the natural environment is missing in the CMP provision.  Please include such reference: ‘protection of the natural environment’ and ‘impact of infrastructure and activities on the natural environment’.

1.3       Study Area (page 2)

Please state whether the study area includes beaches to the high tide mark.

2.1.1   Coast Management Act 1995 (page 5)

1st objective.  If this is not a direct quote, please list conservation first, before recreation.

2.1.2   Crown Land Reserves Act 1978 (page 6)

1st para.  Apart from a ‘variety of public purposes’, Crown land also provides important flora and fauna habitat and plant propagation resources, and this should be stated.

Key Messages - Crown Land

Please clarify what ‘unreserved Crown land’ means, in reference to land adjacent to the Mordialloc Sailing Club.

2.1.5 Aboriginal Heritage Act 2006 (page 7)

1st para.  If this is not a direct quote, please state ‘proposed activities’.

4th dot point.  Please state, ‘’Description of the proposed activity’.

2.2.3 Landscape Setting Types for the Victorian Coast (page 11)

2nd para.  For clarity, please include ‘south of Mordialloc Creek, to read: ‘Nepean Highway and waters edge south of Mordialloc Creek’.

Quote.  The quoted statement, “… landscape is uninspiring… residential development close to the beach, minimal foreshore planting… uninteresting nature of the shore line and Nepean Highway” is representative of an out-dated reality and perception.  Given the general overall improvements in infrastructure and revegetation since publication (1998), and a shift towards greater appreciation of this coastline, the CMP should counter this misleading statement with up-to-date information.

1st dot point.  Please add ‘and foreshore’, to read: ‘Avoid overshadowing of the beach and foreshore with structures.

Key Messages - Landscape Setting

·        The CMP should correct the impression given in the quote mentioned above that there are no worthy coastal values (south of Mordialloc Creek).

·        Please change ‘protect’ to ‘ensure’, and add ‘strategic’, to read: ‘The CMP should aim to ensure access to the coast and enhance strategic views to and from the foreshore.

2.2.4 Boating Coastal Action Plan (page 11)

2nd dot point.  Mordialloc Creek and Pompei’s Landing are missing in the facilities listed.  Please add, ‘and Creek’ and ‘Pompei’s Landing’, to read: ‘With six regional boating facilities… Mordialloc Pier and Creek… Scouts and Guides; and Pompei’s Landing’.

2.5.1 Municipal Strategic Statement - Foreshore (page 16)

Objectives.  Protection of the foreshore environment should be the first objective listed because a healthy and attractive foreshore with indigenous vegetation is essential for flora and fauna habitat and is a major reason people wish to visit.  So please list Objective 2 first, and Objective 1 second.  Then a greater priority is given to this Objective, ‘To protect and, where possible, restore the integrity of natural ecosystems and coastal processes, and to minimise adverse environmental impacts on the coastal and marine environments.’

Key Messages (MSS - Foreshore)

Again, please list this statement first, ‘Encourage environmentally sensitive practices; and’.

Public Park and Recreation Zone

Again, please list this statement first, ‘To protect and conserve areas of significance where appropriate’.

Last para.  It is clearly stated that a permit is required for foreshore constructions, works or subdivision.  We would like the CMP to state this firmly and emphatically because a permit has not always been sought, eg. for removal of indigenous vegetation (2006) and installation of BBQs and seats (2007) in Peter Scullin Reserve, Mordialloc; and covered extension to Parkdale Kiosk (2007).

Heritage Overlay (page 18)

Heritage overlays are in place to preserve existing heritage features.  However, heritage features can be compromised by new installations that are out of character.  Reference should be included in the CMP to ensuring new infrastructure or buildings are in character with existing heritage.  For example, the new BBQs and platform seats in Peter Scullin Reserve are quite out of character with the existing heritage buildings, and diminish views to and from the rotunda.

Table 1 - Kingston Foreshore Heritage Citations (page 19)

Please include the Aboriginal midden at Parkdale (referred to on page 33 of this Vision and Values report).

2.6.8. Coastal Vegetation of Kingston - Key Messages (page 26)

1st dot point.  Please add ‘and ensure protection of’, to read: (The Kingston CMP:) ‘Needs to be sensitive to these vegetation types, and ensure protection; and’.

2.6.9 Foreshore Vegetation Management Principles - Consultation Outcomes (page 26)

Point 2.  We believe the statement ‘(except in recognised formal park areas)’ should be removed from the stated principle, ‘All new foreshore plantings will be indigenous (except in recognised formal park areas), and from both the Foreshore Vegetation Management Principles and the CMP.  This statement is inconsistent with the principles of protecting and restoring indigenous vegetation in various Kingston documents, including (1) the Key Message ‘Ensure new foreshore plantings are indigenous…’ on page 27 of this report; (2) the draft Biodiversity Strategy; and because (3) indigenous vegetation must be retained for habitat value in formal parks, and introduced vegetation displaces native flora and fauna habitat.

Point 3.  In the CMP, please add ‘remnant vegetation and’, to read: ‘Council recognises the value of existing indigenous remnant vegetation and plantings, and they will be managed to reach a balance between the natural environment, recreation and amenity.

Dot point 3.  In principle, we support the action of ‘Encouraging planting of indigenous vegetation on private property’, particularly where properties on dunes have displaced the original plant communities, including trees.  But, encouraging this action should not be used as an offset or substitute for lack of the full range of revegetation on the foreshore.  In the CMP, please add a statement to this effect.

2.6.11 Natural Resource Area Management Plans (page 28)

We enthusiastically support the first clause for remnant and significant vegetation, to: ‘Maintain and restore pre-European biological diversity through the protection, maintenance and restoration of ecological processes, indigenous flora and fauna communities, habitats and gene pools.’  This is absolutely vital for the preservation of local plant species and local fauna species that depend upon these plant species, and also as a propagation resource.

Aspendale to Carrum  (page 29)

Management actions, 1st dot point.  Mapping the Ecological Vegetation Classes is a very worthy action, but the mapping should cover all indigenous vegetation because it has intrinsic value.   Restricting mapping to vegetation that is deemed high quality could miss out plants that may be of value or not obviously present because of plant life cycles, disturbance, seasons or climate.

Table 3 - Kingston SOE Report 1996 - Summary of Key Findings (page 31)

·        Note: since 1996, biodiversity has further reduced along the Kingston foreshore because of loss of trees and large shrubs and lack of a Council replacement strategy.

·        Any new SOE report should include solid fuel heaters under air quality.

Key Messages - SOE (page 31)

Under current conditions, the CMP should include the following:

·        Amend the Kingston Foreshore Vegetation Management Principles to allow revegetation with the full range of the Ecological Vegetation Classes that would include upper storey level trees and shrubs.  An interesting point is made in Table 7, from one person at the Community Consultation Workshop, that trees should be replaced because ‘they are used by boaters for navigation’

·        Include and address the issue of solid fuel heaters as a contributor to poor air quality for humans and wildlife alike.  Solid fuel heaters emit particles that contribute to smog but also emit dangerous invisible particles that are absorbed into the lungs of people and creatures and cause life-threatening respiratory conditions in susceptible individuals.  In winter, on still evenings, the air quality along some areas of the Kingston foreshore is very poor because of fuel in many solid fuel heaters being of the wrong type or incorrectly burnt.

2.6.14 Patterson River Foreshore Aquatic Safety Signage Audit (page 33)

1st dot point.  For clarity, please add ‘residential development’ to read, “The Waterfront” residential development.

Key Messages - Patterson River

Please add ‘and consistent’, to read: ‘… encourage good and consistent signage…’.

2.6.15 Foreshore Aboriginal and Cultural Heritage Study (page 33)

3rd paragraph.  For clarity, please add ‘in 2000’, to read: ‘This site was revisited during the survey in 2000’.

5th dot point.  Please add ‘including a scar tree’, to read: ‘Areas along Mordialloc Creek that contain remnant vegetation including a scar tree’.

Key Messages - Aboriginal Study (page 33)

1st dot point.  Please add ‘Aboriginal’, to read: ‘There is little evidence of significant Aboriginal Archaeological Heritage remaining in the Kingston foreshore area.

Please rephrase this negative statement, because it downplays aboriginal heritage on the Kingston foreshore and implies none exists.  Please put reference to Aboriginal archaeological heritage in the positive, to read: ‘There are some signs of Aboriginal archaeological subsurface deposits in three known locations, two on the Kingston foreshore, and one along Mordialloc Creek’.

2.6.16 Exploring Leisure Needs in M2030 Activity Centres (page 34)

Mordialloc, 2nd dot point.  Please rephrase this statement, to read: ‘That the Peter Scullin Reserve serve as the Activity Centre’s town park and that this is reflected in the Master Plan’.

The impact of additional infrastructure on the natural environment at Mordialloc must be carefully considered, so that flora and fauna habitat and overall amenity are not adversely affected.

Key Messages - M2030

Please add, ‘but be mindful of and minimise any impact on the sensitive natural foreshore environment, including flora and fauna habitat, and overall amenity’.

2.6.17 Survey for Rakali, Hydromys Chrysogaster, within the City of Kingston (page 34)

1st dot point.  Suggest fencing native vegetation would prevent dog walking in these areas.

3rd dot point.  Suggest any basalt rock rakali habitat is screened by appropriate native vegetation.

Page 35, 3rd dot point.  For clarity, add ‘along Mordialloc Creek and Patterson River’, to read: ‘Revegetate riparian areas along Mordialloc Creek and Patterson River…’.

Community Profile

3.5 Age Structure, 2nd para (page 39), and 3.6 Persons Born Overseas, 2nd para (page40)

Delete ‘Airport’, because Moorabbin Airport does not contain housing.

3.10 SEIFA Index of Relative Socio-Economic Disadvantage (Suburbs) (page 42)

2nd para, under Table 4.  In terms of available time for foreshore visits, there is no valid reason to single out this low socio-economic group compared to any other, so there may be an assumption made about available time.  If this statement remains, for clarity, please state whether people of low socio-economic status are likely to spend more or less time at the foreshore, rather than ‘…likely to impact upon their available time to spend at the foreshore…’.

3.11 Summary (page 42)

1st dot point.  For clarity, please include ‘population’, to read: ‘Have a high average population density in comparison with the remainder of the municipality.’

Last para.  Please add the word ‘these’, to read: ‘…though these will be…’.

4.1 Boat Ramps and Moorings (page 43)

Last para.  Please delete ‘Road’ and add ‘at Pompei’s Landing and Governor Road near Chute Street’, to read: ‘…watercraft upstream of Nepean Highway Bridge at Pompei’s Landing and Governor Road near Chute Street…’.

4.4 Piers (page 45).

1st para.  Please add ‘at the pier’, to read: ‘Berthing at the pier is possible…’.

4.5 Car Parks (page 45)

2nd para.  Please add ‘at Aspendale’, to read: ‘Gnotuk Avenue car park access at Aspendale may…’.  And please add ‘at Mentone’, to read: ‘Mundy Street and Dixon Street car parks at Mentone have…’.

Regarding the statement, ‘Car park expenditure exceeds revenue for the foreshore area…’, this blunt statement may lead to the expectation that revenue from foreshore parking should cover all foreshore expenditure.  Care must be taken that a mindset is avoided where all open spaces are seen as revenue raising opportunities rather than natural values or amenities that should be funded through rates.

5.2 Kingston City Council (page 48)

Last para.  Please add ‘and in consultation with’, to read: ‘on behalf and in consultation with the Crown.’.

5.3 Parks Victoria (page 49)

1st para.  Please change ‘facilitates’ to ‘facilities’.

2nd para.  Please change ‘that’ to ‘land’, to read: ‘some of this land, including land seaward…’.

5.4 Melbourne Water (page 49)

The statement, ‘Melbourne Water is responsible for’ is thrice repeated.  Suggest, ‘Melbourne Water is responsible for’ followed by dot points:

·        maintaining the levy banks…

·        dredging…

·        maintenance of four stormwater…

5.5 Central Coastal Board (page 50)

Please state what the Victorian Coastal Council is and what it does.

5.6 Kingston Foreshore Reference Group

Please change ‘advice’ to ‘input’ because the KFRG is an advisory body to Council but its members have input into information gathering and recommendations.  Please add the word ‘on’, to read: ‘…provide input to Council on management of the foreshore…’

5.7 Community Groups

1st para.  Please change ‘friends’ to ‘Friends’ and ‘environmental groups’ to ‘environment groups’.

2nd para.  To provide a more comprehensive impression, we suggest all groups or, at least, categories of groups operating on the foreshore are listed, for example: ‘The groups are Life Saving Clubs, Yacht and Motor Boat Clubs, Friends groups’, etc, or list them individually.

5.8 Existing Lease Agreements (page 51)

2nd para.  The CMP is not a person so cannot, itself, have any understanding.  Suggest, ‘This list provides sources of income generation…  that will help assessment in a coordinated manner’.

6.4 Stakeholder Consultation Outcomes (page 55)

The list of stakeholders seems incomplete, because we believe that representatives from the Mentone Village Committee and AWARE (animal rescue group) were also present.

Table 6 – Stakeholder Consultation Issues (page 56)

Please make some additions and remove some ambiguities as follows:

·        Themes.  Suggest themes are listed in order of importance or alphabetically.  Our preference is for Climate Change first, Flora and Fauna second, and so on.

·        Water Quality.  State the full name in brackets after the acronym ‘WSUD’.

·        Flora & Fauna.  Please list these comments that are missing in Table 6:

·        one person said marine biodiversity is an issue

·        another said education is needed on the difference between the native eleven-armed seastar and the Pacific seastar pest

·        another said restore Ecological Vegetation Classes

·        another requested to get public to appreciate the foreshore.

·        Accessibility (page 57).  Add (at Bonbeach) after Harding Ave.

·        Graffiti and Vandalism.  One person mentioned tree vandalism, which is missing and should be listed in Table 6.

·        Litter (page 58).  In addition to dog litter bins, another person mentioned dog ‘mess’ on the beach and paths, which seems to be missing and should be included in Table 6.

·        Boating & Boating Infrastructure (page 59).  Please state the location in brackets after ‘Retain Boat Trolley access across beach (at ?)’.

·        Signage (page 60).  Please add (Aspendale) after John Watkins Reserve.

6.5 Community Consultation Outcomes (page 62)

1st para.  Please add ‘the’, to read: ‘… was to provide the community…’.

Table 7 – Community Consultation Issues (page 62)

Please make some additions and remove some ambiguities as follows:

·        Themes.  Again, suggest themes are listed in order of importance or alphabetically.  Our preference is for Climate Change first, Flora and Fauna second, and so on

·        Some identical statements appear under different headings.  Is that correct?

·        Dredging (page 63), 2nd dot point.  ‘Mordialloc’ may be incorrect because dredged material is usually deposited on North Aspendale beach

·        Dredging, 4th dot point.  Please add ‘North Aspendale’, to read: ‘…litter on North Aspendale beach…’

·        Development.  One person requested, ‘No more foreshore taken, not one square metre, buildings should go up not out’.  This request was recorded but is missing and should be listed in Table 7

·        Commercial Activities & Tourism (page 63), 6th dot point.  One person suggested a ferry from Mordialloc pier to the city.  So, is ‘…ferry service from Portsea to City…’ recorded correctly?  If so, does it indicate a ferry service along the Kingston coast?

·        Recreation & Events, bike path.  One person requested, ‘Don’t want tracks concreted’ which is missing in Table 7

·        Community Facilities (page 66).  One person suggested that ‘Life Saving Clubs should be community centres as well’.  Another person said that ‘Mordialloc LSC is a disgrace; it’s old, has rats, needs renovating’.  Both the statements are missing and should be included in Table 7

·        Heritage and Protection, 3rd dot point.  This person may mean the Mordialloc rotunda that is on the foreshore reserve not on the pier.  Is ‘Protect the rotunda at the end of the pier.’ recorded correctly?  If so, state which pier in brackets.

Visions (page 67).  Please change heading to Community Visions

·        Page 68.  Delete one of the duplicated ‘Stop pollution in the waterways…’.

7 Existing Values and Threats

Control of foxes and rats have been mentioned in this report, but not the problem of domestic cats that roam day and night marauding wildlife in foreshore areas, parks and residential gardens.  Cat owners are either ignorant of or turn a blind eye to their pet’s slaughter of our unique wildlife.  Please add a reference about the need to limit the cat population through licensing or other strategies, encourage owners to keep their cat contained (especially at night), or ban cats near the foreshore or bush areas.

In addition, foxes are quite numerous along the foreshore, Mordialloc Creek, the railway reserve, etc.  Foxes also kill native animals, and their dens undermine and destroy vegetation, so greater control of foxes is also needed.

Page 70, three Kingston coastal environments.  Please add general references to the geographic history and make up of the Kingston foreshore, its Natural Heritage, and Aboriginal and European Cultural Heritage.

From Mentone to Mordialloc Creek.  Please add a reference to an Aboriginal midden at Parkdale.

Patterson River.  Please add a reference to the clump of mangroves.

7.1 Coastal Character and Amenity (page 71)

2nd para.  Please include the following:

·        Add a reference to the original inhabitants, such as: ‘For example, the original Aboriginal inhabitants once roamed the Kingston foreshore and surrounds.  They contributed to the sustainable maintenance of the indigenous flora and fauna and left traces of their presence in the form of middens and scar trees.

·        Add ‘by early settler fisherman and’, to read: ‘And the boating village character of Mordialloc dates back to when the area was used by early settler fishermen, for boat building and as a safe mooring’.

7.3 Coastal Processes and Infrastructure (page 72)

Regarding the impact of human induced changes on coastal processes, coastal erosion and dredging are important to name.  However, the CMP should list all known relevant impacts, including biodiversity levels, flora and fauna survival, pollution and litter, etc.

7.4 Recreational and Community Uses (page 72)

3rd para.  Please add the word ‘be’, to read: ‘…should be allowed for…’.

7.5 Environmental and Sensitive Areas (page 73)

2nd para.  We wholeheartedly support retention of the biodiversity of the foreshore, keeping activity away from sensitive areas, and enhancing habitat corridors.  However, the CMP should state the need for habitat corridors across activity hubs and open spaces.  For habitat corridors to be effective, they need to somehow span activity hubs and open spaces so that flora can reproduce under appropriate conditions, and insects, birds and other animals can move between areas to feed, seek shelter or mate.

3rd para.  Certainly, some coastal views and vistas should be protected at intervals along the coast.  However, coastal views and vistas along 100% of the foreshore are quite unnecessary and, if promoted, are likely to contribute to a substantial reduction in biodiversity and flora and fauna habitat; reduce shade and wind shelter for humans and flora and fauna; and increase wind damage, blown sand and erosion.

Last para.  We welcome reference to consideration of climate change issues, but the CMP should list all known issues relevant to a coastal environment.  Some climate change factors and issues are: reducing greenhouse emissions; reducing consumption; more arid conditions; species extinction and dislocation; habitat fragmentation; increased pest species; pollination problems; more acidic oceans; sea level rise, storm surges and inundation; reducing stormwater run-off and increasing permeable surfaces; saving and/or recycling water, etc.  (For example, all Council premises should have dual flush toilets to save water and make more water available for open spaces.)

7.7 Access and Connectivity (page 74)

Key message

Please add, ‘whilst maintaining secure habitat areas’, to read: ‘The foreshore must be a publicly accessible space, with strong connectivity to activity centres and community facilities, whilst maintaining secure habitat areas’.

Last para.  Reasons should be given for excluding a cycle path in the southern section.  It is illogical that a foreshore cycle path is considered inappropriate for the southern section but highly appropriate for the northern section of the Kingston foreshore.  In reality, a cycle path anywhere on the Kingston foreshore is highly inappropriate and damaging because of the loss of flora and fauna habitat and soft walking tracks, and an increase in the built environment.  If it is acceptable for the cycle path to run inland in the southern section, then the cycle path could equally run inland in the northern section.  We understand that DSE have no requirement for the proposed cycle path to run within the foreshore reserve north of Mordialloc Creek.

Last para.  We certainly agree that communication between agencies sometimes does not happen.  Recent examples are: Kingston officers did not seek permits before removal of indigenous vegetation (2006) and installation of BBQs and seats (2007) in Peter Scullin Reserve, Mordialloc; and a covered extension to Parkdale Kiosk (2007).

8 Future Vision (page 75)

1st para.  Please add ‘the needs of the sensitive foreshore environment’, to read: ‘… take into account the needs of the sensitive foreshore environment, and aspirations…’.

Key message - Future Vision

Please add ‘the natural features of’, to read: ‘To protect and enhance the Kingston foreshore through recognising the natural features of its three distinctive coastal environments…’.

9 Next Steps (page 76)

Last para.  Reviewing the CMP every three years seems excessive in both time and cost because each review would take some months and would involve much staff time.  We suggest a review every five years would be appropriate.

We appreciate the opportunity to comment on this Vision and Values Report for the Kingston Coastal Management Plan, and we hope our contributions are useful.

Yours sincerely,

 

Name withheld.

 

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