Submission

GWC submissions to VCAT,  State and local government and agencies

 

 

Environment Victoria response to UGB proposal & EPBC impact assessment

RESPONSE TO URBAN GROWTH BOUNDARY PROPOSALS AND EPBC IMPACT ASSESSMENT

 (DELIVERING MELBOURNE’S NEWEST SUSTAINABLE COMMUNITIES )

Environment Victoria is the state’s peak non-government, not-for-profit environmental body. With over 120 member groups and thousands of individual members and supporters, Environment Victoria has been representing the voice of the Victorian community on the environment for 40 years.

This is Environment Victoria’s response to the Urban Growth Boundary Review Report, the proposals for the Outer Metropolitan Ring Freeway and Tarneit Rail-link, and the Strategic Impact Assessment Report for the EPBC Act, which have all been released for public consultation in June-July.

Environment Victoria reiterates points made in previous submission

In our initial submission to the state government’s Melbourne@5million announcement, Environment Victoria emphasised the threat to highly significant remnants of endangered ecosystems and threatened species habitat posed by the UGB expansion. There is still an opportunity to establish a visionary conservation network about Melbourne’s urban fringe, which is based on protecting the existing green wedges.

We also emphasised the importance of achieving sustainable, consolidated urban development, and of focussing transport investment into rail and public transport instead of building new freeways. We urged Government to make better use of existing growth corridors by implementing modest increases in housing density, and not to expand the urban growth boundary for at least another 5 years as recommended by the Melbourne 2030 audit.

Environment Victoria’s concerns and recommendations outlined previously apply also to the urban growth boundary proposals and EPBC strategic assessment now released for public comment.

SPECIFIC RESPONSES TO URBAN GROWTH BOUNDARY PROPOSALS AND EPBC STRATEGIC ASSESSMENT

to read the complete submission download the pdf attached to this page.

 

For further information regarding this submission or Environment Victoria’s work, please contact Victoria McKenzie-McHarg, Safe Climate and Sustainable Transport Campaigner at victoria@envict.org.au or on 03 9341 8112.

SUBMISSION on proposed Urban Growth Boundary Changes – Melbourne@5 Million

We wish to object to ANY changes to the current Urban Growth Boundary (UGB).

 
Areas for investigation the Government has identified have NO STRATEGIC BASIS and are based on flawed policy and beliefs. The majority of these areas are inappropriate for urban development as were many of areas on the outskirts of Melbourne that were devastated this month by bushfires. Numerous consultation and community submissions (including from the Green Wedges Coalition) over recent years have provided the Government with more than enough information to understand the benefits and needs of the Green Wedges, suggesting that this current exercise is merely a political move to grab more land for developers and that any “consultation” will be nothing more than lip-service.
 
The Calder Highway to Sunbury was not supposed to be a growth corridor and the Green Wedges Coalition and SMVGWD had guarantees from Ministers Delahunty, Hulls and Madden that this would not eventuate. Now Minister Madden is breaking his word on this specific issue and on his undertaking not to undermine any of the gains achieved by his predecessors.
 
Hume City Council strategy plans to ensure the rural outlook surrounding Sunbury is maintained, and recent studies have shown that there is ample in-fill and greenfield land within the current Sunbury UGB to cope with predicted growth for the next 30 years. As recently as last November the Government said the Urban Growth Boundary around Sunbury would not move and that further urban development around Diggers Rest would not be permitted[1]…
 
Yet this new State Government proposal to expand the UGB in large areas to the West and North of Melbourne effectively closes the gap between Craigieburn and Werribee, creating one monster urban jungle. Much of the western plains grasslands and other environmentally significant areas are contained in these areas where urban development has been proposed. Many significant Aboriginal and European Cultural sites also exist in these areas…though for how much longer? The residents of the north-west and west of Melbourne DO NOT want to live in an urban jungle. 
 
It is time the government responded to the communities’ questions:
1.      Can we sustain such growth in some areas due to water availability and other environmental constraints?
2.      Can we sustain such growth when current infrastructure cannot cope with existing population demands, specifically public transport, roads, electricity, gas and water supply?
3.      Why isn’t there a population policy for Melbourne that limits growth? (Melbournians do not want to lose the character and open spaces of their city to become a huge metropolis like Sydney).
4.      Why do we have to keep making submissions about what we value about the green wedges, what needs to be protected and how best to go about providing controls and protection – do you not read or listen? All previous SCS submissions and Green Wedges Coalition submissions to your government have made clear statements on all these issues, specifically that, “THE UGB MUST REMAIN FIXED – AT LEAST UNTIL 2030”.
5.      How can Melbourne Airport maintain it’s “Curfew free” status if urban development is allowed to expand in the Sunbury Green Wedge, specifically around Sunbury and Diggers Rest where Overlays currently exist?
6.      Does this Government value Melbourne Airport’s “Curfew free” status?
7.      Will the Government give meaning to its environmental and heritage policies by keeping the UGB where it is and ensuring it stays there for at least the next 30 years?
8.      History shows us that strong housing growth as we have seen in Melbourne over the last 5 years DOES NOT equal strong economic growth. Too many other factors influence the economic health of the State. Indeed, the housing boom, fuelled by people being encouraged by financial institutions to spend more than they could afford on housing, has contributed largely to the current Global Financial Crisis in its heartland USA and it seems in Australia. Why then does the Government continue to use this rational for justifying continued encouragement of population and housing growth?
9.      What is the justification for providing vast new green field land at the expense of the green wedges, with no consideration of the ecological footprint, environmental and heritage significance and no genuine attempts at sustainable housing or development by controlling densities, etc?
 
 
This is a brief submission as it appears fruitless to continue to make comprehensive detailed submissions that the Government consistently ignores.
 
The one point that the State Government needs to accept is that the Urban Growth Boundary should not move in ANY areas and a population cap should be urgently applied.
 
Increased densities and other mechanisms can and should be adopted to cope with any predicted growth.
 
 
Yours faithfully,

 
Arnie Azaris
President, Sunbury Maribyrnong Valley Green Wedge Defenders,
(SMVGWD belongs to the Green Wedges Coalition)
 
Attached: Letter from Minister Madden to GWC dated 18.8.2008
                 Letter from Minister Madden to David O’Connor dated 11.11.2008


[1] Letters from Minister Madden regarding no additional growth for Sunbury and Diggers Rest

 

SUBMISSION TO GROWTH AREAS AUTHORITY: URBAN GROWTH BOUNDARY REVIEW

Dedicated to Jenni Bundy, Secretary of the Green Wedges Protection Group
Who died in the Nillumbik green wedge bushland she worked so long and lovingly to defend  

1. Background 
 
 The 1968-71 metropolitan planning process officially established nine Green Wedges as non-urban zones between Melbourne's main urban development corridors. It outlined acceptable non-urban uses, including recreation, flora and fauna conservation, landscape protection, resource utilization and farming. The protection of public land and of public open space - including Crown and public authority land - is integral to the first two of these uses, but not necessarily to the others.
 
These non-urban zones, together with metropolitan parks and other fringe areas of special significance play a vital role in protecting areas which are critical for Melbourne's future as a livable city. They have been further protected by legislative and planning provisions introduced as part of Melbourne 2030, which added a further three green wedges and an Urban Growth Boundary. The outer boundaries of the municipal councils with green wedges were thereby defined as the boundary of the Greater Metropolitan Area.  
 
The Green Wedges were to be Melbourne's breathing spaces, to separate the urban development designed to be confined to the transport corridors. But while development spread out along the transport corridors, there was increasing pressure on municipal councils to permit the development of the Green Wedges for residential and industrial uses. Hence in May 2002, representatives of the main environment or Green Wedge defender groups in each of Melbourne's nine green wedges formed the Green Wedges Coalition to make representations to State Government and to the Opposition for green wedge protection. (Attached please find the Green Wedges Charter which outlines the history of green wedges and our analysis of what policies are needed for their protection.
 
 
 
In this we were successful when the State Government announced green wedge protection policies before the 2002 election is to protect Melbourne’s green wedges from subdivision and inappropriate urban uses. Opposition support for the green wedge protection legislation passed through the Legislative Assembly before the 2002 election meant support was bipartisan. 
 
We now have 162 environmental and community group members, including resident, ratepayer and progress associations and strong community support, coordinated by the peak environment coalition or green wedge protection or defender group in 10 of Melbourne’s 12 green wedges and by prominent environment group representatives in the wedges without such an umbrella group. (Please see attached our membership contact list.)  
 
 
2. Policy context: Green Wedges and the UGB
 
The UGB changes proposed in the Melbourne @ 5 million report will in our view seriously erode the green wedges. It is proposed to excise a further 22,855 ha from the green wedges. The proposed land-grab contradicts the Government’s 2005 promise when 11,500 ha was excised from the green wedges, that it would last until 2030. 
 
It also contradicts
-          the recommendation of the Melbourne 2030 Audit, that there was no need for any further review of the UGB for at least five years, and
-          undertakings in letters signed by the Minister and a senior officer just weeks before the Government’s Melbourne @ 5 million announcement that no review of the UGB was then underway. (following.)
-          The Minister’s undertaking to us that he would not undermine any of the achievements of his predecessors, eg that the Calder Highway would not become a new Growth Corridor and that the UGB around Sunbury would not be moved.
 
This is the most serious assault on Green Wedges since 2003, possibly since they were inaugurated in 1971. It brings into question the question of whether Government has any commitment to Melbourne 2030 or to protect green wedges. Our Coalition has loyally supported State Government and Melbourne 2030 since the Green Wedge Protection Policy was launched but we wonder whether there is any point as no-one seems to be listening to anything we say or to have any continuing concern for green wedge protection.
 
Does Government still support Melbourne 2030? And what commitment does it have to protecting green wedges? Forgive our cynicism but there is much confusion and concern in the community and in our view the affirmations contained in the “Melbourne @ 5 million” planning “update” ring very hollow indeed.
 
 
3.       Some specific points:  
 
3.1.  The need for more rigorous minimum density measures. Please find attached analysis by Jenni Bundy of the Green Wedge Protection Group in Nillumbik which clearly demonstrates that there is ample land in the existing Growth corridors if rigorous urban density measures were applied. 
 
 
3.2 Bushfires. 
Last week’s tragic bushfire losses are a reminder of the risks run by those who live on and beyond the urban fringe and, we hope a reminder to urban planners and to Government of the peril in allowing untrammelled low density residential development on the urban fringes.
 
What does seem to us to be clear is that fire risk will be minimised if State Government:
-          requires rigorous minimum density standards for residential developments on greenfields sites and on substantial infill sites (eg on former industrial land) in existing urban and growth corridors where the amenity of existing residents is not adversely affected;
-          reverses plans to extend the UGB into current green wedge areas of fire risk;
-          initiates firm planning controls to discourage or prevent the building of more houses in areas of bushfire risk, backed by a buyback of bush blocks in green wedge as recommended by recent RMIT research which identified 17,000 vacant small lots on old and inappropriate subdivisions in the Bendigo corridor.
-          strategically plans such buybacks so as to be added on to national and local parkland and to add to the store of public open space needed for the projected expanding future populations.
-          encourages prospective landholders who want cleared land to purchase cleared land and not to use bushfires as an excuse for wholesale clearing of private properties or public land.
 
3.3 Need for an Independent Monitoring Authority
We submit that there is a need for an ongoing monitoring authority to oversee the protection of green wedges and public lands. This proposal builds on our earlier submission to the Melbourne 2030 Audit for the establishment of a Green Wedges Authority, similar to the Growth Areas Authority, which does a good job of promoting and governing the process of development in the growth corridors.
We now suggest that this idea be broadened into a Green Wedges and Public Lands Authority. This should cover existing Crown and other public lands in urban as well as green wedge areas and could also require the provision of open space in growth areas and urban areas currently under-provided. It should have oversight over the performance of Councils, State and Commonwealth Government departments and instrumentalities and VCAT and should play a coordinating role between such agencies to ensure that more public lands do not fall between the cracks of public policy as the Laverton Grasslands and Moorabbin Golf Course have done. 
 
 
Yours faithfully

 
Rosemary West
Coordinator,
Green Wedges Coalition
(incorporated as the Green Wedges Guardians Alliance)
 
Attached to subsequent email:
 1.    Green Wedges Charter ( giving a brief history of green wedges and summarising our current
        concerns and policies).
2.    Green Wedges Coalition membership contact list (for each green wedge). 
3. “Reasons why the UGB Expansion Plans are seriously flawed,” by Jenni Bundy (February 2009)