Select Page

North West Alliance



The North West Alliance is a coalition of organisations and local community members with serious concerns that the environmental values of the Northern and Western Geelong Growth Areas and the Geelong Strategic Assessment are not being given their due importance.

Submission writing workshops

Alliance members on the Sustainable Hour

A big thank you to The Sustainable Hour crew for allowing North West Alliance members Cameron Steele and Lachie Chomley on to their show. It was fantastic to be able to talk about the concerns the Alliance regarding the impact of the growth areas for Geelong on biodiversity values. Our contribution is at the 38 minute mark and we talk about the upcoming submission writing event.


Submissions due this Monday 5pm
25th September 2023


Geelong and Melbourne are bursting at the seams. Our towns and cities are looking for ways to accommodate our growing communities.

The City of Greater Geelong wants to build new housing estates. The plans include clearing important habitat for endangered plants and animals. Some habitats will be conserved, but most bulldozed.

Farmlands that were once grasslands are set to become Geelong’s newest suburbs. Amazingly, endangered creatures like Striped Legless Lizards and Golden Sun Moths still live in these changing landscapes.

The challenge is finding room for everyone without destroying the remnant grasslands and their critters.

We have until 5pm Monday 25 September 2023 to share our concerns.

Please provide feedback on the draft Geelong Growth Areas Strategic Assessment by completing the online submission form at or by emailing

Alternately please send written feedback via post to:

Coordinator Strategic Planning

City of Greater Geelong

Wadawurrung Country

P.O. Box 104

Geelong VIC 3220


People can make a submission through the Victorian National Parks Association website at


More information

0413 757 173

Or watch this submission writing workshop including a presentation from a growling grassfrog expert.


Alliance Latest News Item

Briefer on the Geelong Strategic Assessment

Farmland set to become Geelong’s newest growth areas is home to threatened animals like Striped Legless Lizards and Golden Sun Moth, and grassland communities that are close to extinction. Development will push up against important waterways like the Moorabool River and Cowies Creek, degrading water quality and putting pressure on endangered Growling Grass Frogs and native fish. The Geelong Strategic Assessment is supposed to set out how nature will be protected in thedevelopment of Northern...

read more

What is needed

We understand the need for sustainable urban design based on sound planning principles. Strategic assessments are, at least on paper, a good idea, taking a whole-of-landscape approach to the conservation of natural values. But the process to date has left us with little confidence in the Geelong Strategic Assessment. The ‘strategic’ component of this development process currently
lacks important detail. Nature is seemingly being relegated to second place to offset-driven development. Communications from the City of Greater Geelong have raised many more questions than they have provided answers.


Greater security for biodiversity and less emphasis on developer-friendly offsetting.

The current EPBC Plan appears to rely heavily on offsetting. In the Northern Geelong Growth Area, a ratio of less than 1:6 of protected habitat to cleared known habitat for Matters of National Environmental Significance is proposed. This fails to appropriately consider the avoid and minimise conditions for native vegetation removal. The vast amounts of offsetting needed may not be available, affordable or appropriate.

Grasslands are not like forests. Leave a forest alone and it gets better. Leave a grassland alone and it gets worse. Grasslands require regular biomass removal forever, not just for ten years. Weed issues will also likely require considerable ongoing inputs. These perpetual management requirements demand a system that allows for perpetual funding.

Keeping it local

Where offsetting must occur, offsets must be kept local (within 20 km)



Upfront purchase and management of conservation areas

Offsets should be purchased within three years to create new or better biolinks or expand areas of high biodiversity. This may involve paying a premium above current land values. An alternative is to pay landowners to place a covenant on their land.

No detail has been provided of when conservation area land will be acquired. Land for conservation needs to be purchased upfront to minimise costs as land value increases, and to reduce substantial future management costs as well.


The immediate implementation of an interim management strategy

Biodiversity values are in decline across the GSA area, yet City of Greater Geelong is making little effort to ensure biodiversity values are being maintained. This failure to act in a strong, integrated manner, and to actively support current land holders with incentives, will lead to long-term loss of conservation values and greater management costs.

River health

Actions that allow for improved health of the Moorabool River and Cowies Creek, including minimum 200 m conservation buffers and no floodplain development

There is serious potential for significant impacts on the Moorabool River and Cowies Creek. We understand that the extent of the floodplain for the Moorabool River at the western edge of the Western Geelong Growth Area is yet to be determined and will not be determined until after the Biodiversity Conservation Strategy – one of the key documents of the Geelong Strategic Assessment – is finalised, in effect leaving no opportunity for appropriately informed public comment to protect a landscape that will be profoundly impacted by development.

Conservation buffers along waterways need to be a minimum 200 m. Choke points that compromise ecological function must be avoided. Flows from septic tanks must not compromise water quality. Additionally, treated wastewater should not be discharged into the Moorabool River due to the risk of bioaccumulation of emerging contaminants, such as pharmaceutical compounds.

Additional concerns include the potential failure to identity ephemeral water bodies, and the lack of acknowledge the impacts of quarry-related structures on fish populations in the Moorabool.

Cultural heritage

No PSP gazetted until all survey and other actions associated with an appropriate Cultural Heritage Management Plan are implemented

No mention has been made of cultural heritage. Have agreements been made with the Wadawurrung? Without a Cultural Heritage Management Plan, many conservation management measures cannot be undertaken, e.g. those causing soil disturbance, to the detriment of biodiversity. Cultural Heritage Plans must be completed before any PSP process gets to public engagement.

Strong Governance

Strong governance provisions for oversight, protection and compliance

We require assurances that good governance frameworks will be in place. How will monitoring be undertaken in a manner that ensures appropriate ecosystem values are being captured? What targets are going to be set? How will compliance be ensured? The CaLP Act is effectively toothless.

Will areas to be conserved be required to be restored to their previous quality? Who will be held to account for loss of biodiversity?

Restoration targets

Targets that encourage restoration, not simply business-as-usual management

We have heard nothing about restoration. Is there any intention to try to reverse the declining conservation values of this landscape, or is further loss of nature through offsetting the only conservation outcome?

Much of the land is being dismissed as ‘degraded’, ignoring the fact that, despite the high presence of exotic species, these are nevertheless grassy ecosystems with important biodiversity and ecological values. This emphasis on ‘degraded’ also ignores the fact that with time, patience and good management these communities can be moved towards more natural native grassland ecosystems.


Proper adherence to the FFG Act

Section 4B of Victoria’s Fauna and Flora Guarantee Act requires matters of biodiversity significance to be given their due weight by government authorities. The City of Greater Geelong appears to be abrogating its responsibilities in this matter.


Biolinks to strengthen biodiversity values within and beyond the growth areas

We are told determination of biolinks will occur during the PSP process. This runs counter to the intentions of a strategic assessment: to do planning for biodiversity early to avoid inevitable land use conflict later. Biolinks have to be put in place at the whole of landscape scale, that is one of the objectives of the Geelong Strategic Assessment.

Biolinks need to be wide to allow proper functionality, and wider still if they passive recreation, bike paths and so on. Biolinks need to link both inside and outside the Northern and Western Geelong Growth Areas.

Better data

Better baseline data to make this strategic assessment more truly strategic

Substantial areas have not been subject to fauna and flora surveys. These areas must be surveyed because it is likely they have good conservation values.

There is a significant chance that small but important areas of grassland have been overlooked across the Growth Areas. It is well known that big is not necessarily better when it comes to grassy ecosystems. It is important to consider that small patches can be protected, and that restoration works can work out from these remnant cores to create larger robust areas of good quality grassland.

Some significant species and communities have been overlooked in the survey process, e.g. Plains Wanderer, and Seasonal Herbaceous Wetlands. The determination of which species to survey for is based on the recorded presence of existing flora, but there are almost no survey records for flora in the surrounding areas – not because of lack of biodiversity values, but because it is farming land that has never been surveyed.

No methodology has been provided for how data has been aggregated. Surveys focus on Matters of National Environmental Significance, not state and local significance. For biolinks to be effective, they need to link to areas of conservation significance beyond the Northern and Western Geelong Growth Areas. However, no data is presented to suggest where such biodiversity values might lie.


Detailed response to these concerns and more engagement from City of Greater Geelong prior to the proposed June 2023 release of the GSA documents for public consultation.

We have asked for but have yet to receive responses to many of the concerns group members raised with the EPBC team through this process. We require detailed responses to those concerns and the ones we have raised with them since. We require more engagement from the City of Greater Geelong prior to the proposed June 2023 release of the GSA documents for public consultation.

Proposed approach to retention of conservation values within the Northern Geelong Growth Area

Proposed approach to retention of conservation values within the Western Geelong Growth Area


• The City of Greater Geelong identified two key areas for urban growth = the Northern and Western Geelong Growth Areas

• In August 2020, the City finalised the Northern and Western Geelong Growth Areas Framework Plan (the Framework Plan)

• In January 2022, the City signed an agreement with the Commonwealth Government to undertake a strategic assessment under the EPBC Act (Environment Protection and Biodiversity Conservation Act 1999)

The strategic assessment is suppose to:

Provide Commonwealth biodiversity approval

Support State planning processes



Objective of the EPBC Plan:

Provide for the protection of matters of national environmental significance while supporting the delivery of the Northern and Western Geelong Growth Areas

Framework Plan and its objectives

The EPBC Plan:

• Establishes six outcomes to be achieved over 30 years
• Describes the development that will occur in the Growth Areas. E.g. urban and commercial,
industrial, supporting infrastructure
• Provides commitments to protect Commonwealth biodiversity values. These include:
o Establishing conservation areas within the Growth Areas (e.g. Cowies Creek)
o Measures to protect downstream locations (e.g. Lake Connewarre)
o Biodiversity offsets outside the Growth Areas
• Includes an implementation framework to ensure the Plan is successful

Alliance News

Briefer on the Geelong Strategic Assessment

Farmland set to become Geelong’s newest growth areas is home to threatened animals like Striped Legless Lizards and Golden Sun Moth, and grassland communities that are close to extinction. Development will push up against important waterways like the Moorabool River...

read more

Draft EPBC report now open for public exhibition

The draft Environment Protection and Biodiversity Conservation (EPBC) Plan is now out for public consultation. It outlines various measures and commitments for dealing with the impacts on biodiversity values in the areas designated for development. It incorporates a...

read more

Alliance News

Our Alliance

Get in touch with us

9 + 4 =

“It is that range of biodiversity that we must care for – the whole thing – rather than just one or two stars.”

- Sir David Attenborough