North West Alliance
PROPOSED Geelong GROWTH AREAS
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
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 https://yoursay.geelongaustralia.com.au/GGASA or by emailing GeelongGrowthAreas@geelongcity.vic.gov.au.
Alternately please send written feedback via post to:
Coordinator Strategic Planning
City of Greater Geelong
P.O. Box 104
Geelong VIC 3220
People can make a submission through the Victorian National Parks Association website at https://vnpa.org.au/action/ask-geelong-city-to-make-homes-for-wildlife-and-people/
Alliance Latest News Item
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 conservation framework aimed at managing impacts on Matters of National Environmental Significance (MNES) by avoiding, minimizing, mitigating, and offsetting them. Implementation documents, such as the draft Biodiversity...
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.
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.
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 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?
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 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
OVERVIEW OF THE STRATEGIC ASSESSMENT
• 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
NWGGA EPBC PLAN
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
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“It is that range of biodiversity that we must care for – the whole thing – rather than just one or two stars.”