MBCL SUBMISSION TO AMENDMENT L47 TO THE EXISTING KINGSTON PLANNING
SCHEME: EPSOM TRAINING FACILITY & SURROUNDING INDUSTRIAL AND MIX USE AREAS
DATE: 16 April 1999
DRAINAGE AND FLOODING
As stated in the report "A significant part of the policy area is currently flood prone". Records show that a severe storm event in l934 resulted in flooding to a depth of 2 metres on the eastern side of the Mordialloc railway line (1). A similar storm event in 1952 also flooded Epsom training track and reached to White Street. A recent 1996 study by the CSIRO Division of Atmospheric Research and Global Environmental Modelling Services reports that :
"the two present day storm surge events modelled (for Mordialloc using 1994 May and November storms) are not particularly rare, having return periods of several years", and
"The impact of a storm surge coinciding with increased run-off and hence higher river flow rates could be more severe", also
"An event such as the 1934 Mordialloc Creek floods which produced both extreme rain fall and storm surge could cause failure of the existing flood protection system under less extreme scenarios of sea level rise and lead to greater flooding"(2).
In view of the 1996 EPA Report Extreme events and the impact of climate change on Victoria's coastline, the 1988 Metropolitan Open Space Plan (Ministry for Planning and Environment) report into protection of flood plains offers constructive solutions to the present trend to fill and develop flood plains.
"Developments on these flood plains will be regulated to prevent hazardous situations during times of flood. Generally areas with potentially significant flood depths or velocities will be set aside for compatible uses such as public open space. The construction of new residential dwellings will continue to be prohibited on flood plains in new subdivisions"(3).
This sensible policy is worthy of adoption given the disastrous record of previous flooding in the Mordialloc Creek Catchment. Plans for even larger residential developments in the catchment will only exacerbate flooding in the lower reaches of the Creek and environs. The Australian Planner has pointed out however that:
"History has shown that timely decisions on insidious resource management problem of this nature are difficult to achieve and tend to wait for some form of crisis before concerted societal action occurs"(4).
The question then arises as to whether private insurance companies will continue to insure development on flood plains liable to flooding. Alternatively a consequence of increased storm events for bayside councils could be alterations to public liability insurance cover
DRAINAGE ON THE EPSOM SITE
Melbourne Water initially had serious concerns with the existing flood storage capacity and concerns regarding potential contaminant migration within the flood plain to Mordialloc Creek. Community fears appear justified when it is proposed that the waste/ stormwater from 428 houses on the Epsom site will enter a relatively small wetland area in close proximity to housing. It is also of concern that this 9.2 hectare retarding basin is supposed to provide the only public open space for this development.
Melbourne Water’s planned water quality treatment involves using sediment traps to prevent solids (leaves, litter, dog faeces) entering the wetlands. Stormwater, oil and waste water from car washing will run directly into a pond to remove nutrients and phosphorus. The water, after initial treatment will flow into other ponds before entering drains and finally, Mordialloc Creek.
The entire 9.2 HA retarding basin could at times of severe storm events be under water because of the overflow from the Woodlands Industrial Estate as well as stormwater on-site.
MOSQUITO CONTROL
"Wetland ponds have the potential for developing populations of mosquitoes which can transmit diseases and cause discomfort. Mosquito species use the wetlands and ponds as breeding grounds. Mosquito larvae is also found in pools formed by fallen and decaying vegetation, emerging macrophytes and along drainage channels"(5).
The close proximity of the polishing ponds to housing raises the question of effective mosquito control. Recent reports warn of mosquitoes carrying Ross River viruses, Japanese encephalitis and Murray Valley encephalitis (see reference list). Whoever ultimately becomes responsible for maintaining the wetlands will need to be vigilant in removing excessive weed growth, a potential breeding ground for mosquitoes.
If the wetlands become contaminated with weed killers such as glyphosate used in suburban gardens, then the frogs, which will be relied upon to control mosquito breeding, won't survive and the wetlands will indeed become a health hazard.
"Wetland systems offer a low technology approach to controlling pollution although they do require a large area of suitable land and if they are used, proponents must understand and accept the risk of failure and unsatisfactory performance…Care is required when it is proposed to use wetland filter systems to control the quality of urban runoff. Urban runoff is intermittent and of variable quality, containing pollutants such as sediment, organic matter, bacteria, nutrients, metals, pesticides and hydrocarbons. Urbanisation leads to a 7 to 10 fold increase in the export of pollutants from the land"(6).
FLORA AND FAUNA
Given the doubts raised about the successful relocation of regionally significant plants on the Epsom site, development should not proceed until the issue of protection of plants is resolved. It is disturbing to note within the proposal, that the effort to successfully relocate plants is subject to "available resources"(7).
The species under discussion are threatened at regional and possibly State level also. The best protection and chance of survival for these plants would be to relocate the water/wetland feature to the lowest point of the site, the centre, where the significant plants already exist. The fourth option therefore would be to explore an in-situ proposal in order to save the endangered plants.
An extension of time, until Spring, is essential to allow for a thorough
appraisal of the best method of conserving the significant species.
At present the question of responsibility for maintaining the wetland vegetation has not been resolved. It is essential, for example, that: "Weed control measures should be implemented once relocation has taken place and the monitoring for any future weed problems should be an on-going part of the Action Plan"(8).
Are Council resources available to adequately protect and maintain the area?
OPEN SPACE - PASSIVE RECREATION
It is ironic that at a time when the City of Kingston's Open Space Strategy is due for release, Epsom training track's private open space is to become a large residential site with only 9.2 HA of (wet) ‘open space’, in reality a drainage facility.
Both the Open Space Strategy and Residential Strategies report that there is an aging population in this section of the City of Kingston. That being so, there is a need to provide areas for passive recreation within easy walking distance for elderly or disabled residents. The grassy woodland on the north east corner of the site (on the White Street/Boundary Road corner) could provide a pleasant area for passive recreation.
With the retention of the River Red Gums and the removal of approximately 16 house sites this could overcome, or compensate slightly for the loss of 45 HA of open space. Mounding around the fence line to restrict noise from both major arterial roads would enable this to become a practical addition to a housing development severely lacking in a passive recreation area.
Without this area included in open space provisions of the development, the open space/drainage contribution of 9.2 HA is insufficient to compensate for the loss of 45 HA of open space which, whilst being privately owned, was a ‘green’ breathing space with open vistas and sky-scapes as a relief from the encroaching built environment.
OPEN SPACE - ACTIVE RECREATION
Whilst there might appear to be a demand from a minority of the 385 sporting clubs in the City of Kingston for space for more noise generating activities such as football and soccer at senior levels, the Melbourne Open Space Plan and Kingston's Open Space Strategy surveys reveal that :
"On the whole the city is well endowed with sports facilities" and that overall only a "minority of residents" in Metropolitan Melbourne (which includes the City of Kingston) use active sport facilities (9). The majority of those surveyed expressed a preference for passive activities which involved the whole family. These were outdoor and nature activities, bushwalking and cycling.
Given that there is a sports oval, the Ben Kavanagh Reserve in McDonald Street, 500 metres from the Doug Denyer Reserve, an oval should not be constructed on the Epsom site because of the constraints of noise, lighting and lack of car parking space. The Sandbelt Open Space Report states that such facilities should "be isolated from abutting residential areas"(10). Therefore a large sporting oval abutting the residential area on the Epsom site should be re-located and the remaining space on the Doug Denyer Reserve utilised for bocce, netball or other sports unlikely to draw large vociferous crowds.
The sports oval shown on the ULC plan, built on the Reserve and extending onto the residential site, therefore should not be considered because of the lack of car parking space, crowd noise from sporting events, noise from amplified announcements, possible amplified musical events and lighting for night time events, all of which will be detrimental to the environmental amenity of the area.
BUFFERS / NOISE CONTROL
It is obvious from the ULC Subdivision Concept Plan that by siting 21 houses along Boundary Road and 10 houses on White Street the residents will be subjected to intolerable noise levels from traffic. Acoustic fencing, mounding, double glazing and removal of wall vents in the houses will be required in an attempt to overcome excessive traffic noise levels.
Aircraft noise will affect housing in the northern section of the development whilst industrial noise from factories in Lamana Street adjoining the Epsom site, will encroach across the narrow section of the retarding basin to the houses on the south-west corner of the site. The noise emanating from the factories "includes air compressors, refrigeration equipment and fans located at the rear of properties. General activities such as hammering, spraying and telephone bells, are audible at 10 metres from the rear of these properties". The consultants report states:
"It is likely that these activities would result in SEPP N-1 limits
being exceeded especially in the evening period after 6.00 PM…A 5O metres
landscape buffer between the rear of properties in Lamana Street and any
residential development would be desirable"(11).
Factory owners to the north, south and west of the Epsom site are justifiably concerned that complaints from the newcomers, the residents protesting about noise and lighting will exert pressure for these factories to be relocated. Perhaps council could be required to compensate factory owners who are forced out of the area.
CONCLUSION
The removal of 21 housing sites on Boundary Road and 10 to 16 on White Street to allow for landscaping of the area as a buffer against traffic noise would be a principled decision. To do otherwise is to unnecessarily subject home owners to intolerable traffic noise which will increase in future as more residential developments are approved in the Braeside and Aspendale areas.
The profit motive should not override the very real concerns for the well
being of future home owners on this site and the open space entitlement of
Mordialloc residents.
AUTHOR: M. Rimington, Secretary MBCL.
END-NOTES
(1) McInnes, K. & Hubbert, G. (1996) p.12
(2) ibid., p. 64
(3) Ministry for Planning & Environment (1988) p. 35
(4) Schneider, S.H. (1989) p. 146
(5) Cullen, P. (1989) p. 41
(6) ibid., p. 40
(7) Hill, J. (1999) p. 4
(8) ibid., p. 5
(9) Ministry for Planning & Environment (1988) p. 16
(10) Melbourne Parks and Waterways (1994)
(11) Marshall Day Acoustics (1999) p. 3
REFERENCE LIST
Author unspecified (1998) "Ross River fever warning" in, The Age, Dec. 19.
Author unspecified (1999) "Beware the old girls out late, warns mossie man" in, The Age, May 15.
Cullen, P. (1989) "Prospects and limitations on the use of wetlands for treating effluents and run-off waters" in, Wetlands, their ecology, function, restoration and management: Proceedings of the Applied Ecology and Conservation Seminar Series: Wildlife Reserves, La Trobe University, Oct-Dec.
Hill, A. (1999) The mapping of native vegetation and an Action Plan for its relocation at the Epsom Subdivision, Mordialloc, Victoria, Biosis Research, Port Melbourne, April.
Lodge, J. (1996) "Ross River fears" in, Mordialloc-Chelsea News, date unknown.
MacInnes, K. & Hubbert, G. (1996) Extreme events and the impact of climate change on Victoria's coastline: Report to EPA and Melbourne Water, Environment Protection Authority / State Government of Victoria, June.
Marshall Day Acoustics (1999) Epsom Development Site Noise Assessment, April.
Melbourne Parks and Waterways (1994) Sandbelt Open Space Project Development Plan, Melbourne Parks and Waterways, May.
Ministry for Planning & Environment (1988) Melbourne’s Open Space: The Metropolitan Open Space Plan.
Schneider, S.H. (1989) Global Warming: Are we entering the Greenhouse Century?, Sierra Club Books, San Francisco.