The submission below is endorsed and supported by Port Phillip Conservation Council Inc.
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Port Phillip Conservation Council Inc. A0020093K |
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Comments submitted on the Draft Boating
Coastal Action Plan from Frankston Beach Association Inc,
in
response to invitation to comment from the Central Coastal Board
email: forresthart@netspace.net.au
phone & fax
97500202
1.
Overview
Boating facilities
in
Facilities have been
established:
i.
Where small boats can be launched and recovered across the beach, without
damage occurring to the boat or endangering the crew, and
ii.
Where coastline features provide sheltered water from prevailing winds, weather
and tides and where there is adequate natural depth of water for a small boat
harbour to access the waters of the Bay.
iii
Where local Councils have constructed boat launching ramps, often in places
where there is inadequate shelter from prevailing winds, severely limiting
times that trailerable boats can be safely launched or retrieved eg., on the
eastern shore of Port Phillip Bay.
Historically
locations exposed to prevailing on shore winds and weather, have been ignored
and rejected by both commercial and recreational boating interests.
2.
Expansion of Existing Facilities
One essential
requirement for developing boating facilities has been the availability of
adequate space on shore, for access roads, vehicle parking, maintenance yards
and boat storage.
Most locations
around the Bay which are suitable for boating facilities have, to some degree,
already been developed.
There are very few
remaining undeveloped locations that can provide the basic needs of a boat
harbour; ie., provide natural shelter, away from a predominantly lee shore
position, with easy access to deep water and sufficient shore space for related
infrastructure.
Authorities and
developers must accept that boating facilities and exposed coast lines are
alien and incompatible with each other.
Historically any
coastal harbour facility constructed on a predominantly lee shore, with no
natural shelter, brings enormous problems in the form of expensive
infrastructure necessary to withstand the elements, and extreme danger to life
and property.
These limitations,
which may come as a disappointment to the more entrepreneurial members of the
community, have to be recognized when deliberating and making judgements in
choosing suitable and safe sites.
Rather than trying
to develop new facilities in unsuitable locations, situated in exposed
positions on predominantly lee shores, subject to prevailing winds and weather,
and/or where the foreshore and beaches are at risk of major erosion and
accretion, the use of existing facilities must be maximized.
Existing facilities
must be repaired, improved, and subject to appropriate limits, expanded.
All existing facilities
must be surveyed to ascertain what work is necessary, to provide improved and
expanded first class facilities for the increasing recreational and commercial
boating activities. These studies must be completed before considering new
facilities in ‘new’ areas.
In tandem with this
survey an accurate survey of existing and forecast numbers and types of craft
must be conducted to more accurately determine present and future boating
infrastructure needs.
3.
Strategic Planning
There has been little
strategic planning into the provision of boating facilities in
The Central Coastal
Board is to be commended for initiating some strategic planning at this time.
What is needed is a
comprehensive and competent planning process to consider the lack of boating
facilities in the central coast region, before jumping to premature
conclusions.
Governments since 1983
have walked away from basic maintenance of existing facilities, which have
often been removed when they fall into disrepair. eg. cranes on jetties,
slipways and even jetties themselves have been neglected and removed.
Many jetties remain in
a state of disrepair and the growing demand, for expanded boating facilities to
cater for all forms of boating in
Little money has been
invested by Government in boating facilities. What little investment that has
occurred has come mainly from private yacht clubs and private boating groups.
The Government’s
latest policy is to facilitate the provision of new facilities by encouraging
investment by the private sector.
This avenue of raising
capital is being viewed by the Government as the panacea for not only solving the
problems of the boating industry, but also as an extension of the Government’s
Melbourne 2030 growth plan. However, again strategic planning is absent. Easy
solutions are being sought and long term adverse ramifications are being
overlooked.
Damage to the coastal
environment and expensive maintenance dredging and beach restoration and sand
bypassing appear to be potential problems that no-one wants to consider.
Unsatisfactory
financial outcomes is a subject that has not been properly considered, apparently
to avoid frightening away would be investors and supporters.
One body of opinion is
that a private sector financial loss is acceptable, even though the development
has been encouraged and facilitated by the bureaucracy.
4.
Analysis of Other
The Western Port Marina
at
The
Since the
A restaurant attached
to the marina has been unsuccessful and a motel type development unable to
succeed.
This marina has 300 wet
berths, 200 dry berth boat storage, and a boat repair yard with extensive
facilities.
The Olivers Hill marina
proposal is for 300 wet berths, no dry boat storage and minimal repair
facilities. It is expected to cost well over $40 million, and cannot be
financially viable.
It is obvious from the
above information that expensive marinas cannot generate enough income from
their marine activities to be financially sustainable unless the initial
capital is provided by a third party (eg., the Geelong Marina was financed
jointly by the Geelong Port Authority and the Royal Geelong Yacht Club) and
maintenance and operating costs are kept to a minimum.
Maintenance and
operating costs cannot be kept low if expensive maintenance dredging and sand
bypassing expenses are part of the total operating costs of the marina.
However these facts
must not be justification for high rise residential and boutique commercial
development as part of the marina complex. Destruction of existing public
amenity, creation of environmental damage and construction of marinas in
unsuitable locations, with inadequate land for road access and parking and
service industries, and in inherently unsafe predominantly lee shore locations
is not acceptable.
Government and local
authorities have no mandate to facilitate high-rise residential and commercial
development on or near to foreshore precincts in order to cross subsidize
marina development. If the necessary associated real estate development
destroys existing public and private amenity, there is no justification for
providing the boat harbour.
Possible financial,
environmental and social outcomes of marina development policies including
related residential and commercial developments must be made known to the
community and not be disguised and hidden at the preliminary planning stage.
The Tassells Creek
Development at
The recently developed
low cost marina at Blairgowrie is having problems with damage to boats from
insufficient protection from onshore wind and weather. Also the build up of
sand around the marina, and erosion and accretion of sand on nearby beaches, is
taking place.
The small marina
complex at Glenelg, a popular beachside suburb of
Significant high rise
residential and commercial blocks of apartments have been built around a small
boutique marina. These apartments have resulted in the destruction of the open
vista looking out over the sea for many inhabitants residing and recreating in
the older part of the town. In the eyes of many they are desecration of the
natural landscape.
The depth of the
entrance to this marina through siltation, has become too shallow to permit yachts
with deep keels to enter and depart and a dredge is constantly working to
maintain sufficient depth of water at the entrance for power boats.
There is a dispute
between the Flinders Port Authority, the Glenelg Council and the marina
operators as to who is responsible for the necessary maintenance dredging
costs.
The entrance has two
artificial stone walls extending approximately 100 metres seaward from the
shore. Due to interference of the littoral drift by these walls, the beach
southwards is suffering with accretion of sand and the foreshore to the north
has been destroyed by the scouring of all sand from the beach. Expensive sand
trucking is taking place.
The apartment blocks
surrounding the marina are exposed to the prevailing westerly weather and
suffer from the strong salt laden prevailing west winds. Many apartments remain
unsold and unoccupied
The weather in
The experience from
other existing and proposed marinas and associated developments must be studied
and given careful consideration with respect to finances, environmental effects
and dredging costs.
These studies must be
catalogued and compared to increase the knowledge and understanding of planners
so pitfalls and mistakes experienced elsewhere can be avoided in the Central
Coastal Region.
5.
Private Investment
The complete coastline
of
Developers are being
encouraged by authorities to investigate foreshore or reclaimed land for
building “community based safe boat harbours” accompanied by residential
apartments and boutique commercial enterprises.
However the developer
rarely sees the ‘boat harbour’ as the primary objective. The developer’s profit
comes from the residential and boutique commercial parts of the enterprise.
Examples of where
residential and/or commercial development is (or has been) considered include
the proposed marinas at Queenscliff, Werribee South; Frankston (Olivers Hill)
and Mornington (Schnapper Point), the new Tassels Creek marina at Mount Martha
and the original Paterson Lakes Marina.
In each of these
locations, a study will show that financial viability hinges, not on the boat
harbour activities, but on the residential and commercial real estate parts of
the development.
As a consequence,
the suitability of the location as a safe boat harbour is not of importance to
the developer. It is merely the bait on the hook.
The location may be
unsuitable and unsafe for small craft and opposite to the advertised sales
promotion of ‘providing community based safe boat harbours’.
6.
Selection of Sites
In each of the above
locations there will be environmental problems from sand accretion, sand
erosion and sand bypassing. and ongoing maintenance costs for dredging.
No hydraulic model
studies (physical modelling) and no computer (mathematical or numerical)
modelling studies have been carried out to determine the extent or location of
sand accretion and erosion in these areas.
In some instances
extensive beaches and bays will disappear. Areas such as Davey’s Bay and the
beaches to the north of Frankston Pier will be affected to the extent that one
bay And one beach may disappear.
The proposed Olivers
Hill marina at Frankston, according to the Government’s own ‘Safe Boating’
brochure, is situated in the very centre of the most dangerous part of the
coastline within
Rather than being
known as a safe boat harbour, for the ordinary boating person or family it is
in the most dangerous part of the bay and should be called an UNSAFE
7.
Suitability of Sites
Usually where there is a
demand for specific boating facilities and no facilities have been provided,
the site has been regarded by mariners and coastal engineers as being too
dangerous or flawed and unsuitable in some way for establishing the boating
facilities.
This is the reason why
no boat harbours exist between
This stretch of
coastline forms a lee shore to the prevailing onshore winds and weather and has
no natural protection from these elements. There are no parts of this coastline
that in the past era of boating on
A thorough study of the
direction of prevailing winds is just as important in determining locations for
boat launching facilities as it is in determining the directions in which
runways are to be built at aerodromes.
Data should be studied
and published for all potential sites showing the distribution of wind
direction and speed and onshore wave height during launching hours throughout
the year. This data should be mapped against the proposed use of the site.
8.
Preselection Studies
Before developing a
draft Boating Action Coastal Plan that indicates particular sites for specific
major new development, a set of study criteria must be compiled by
suitably qualified and experienced planners. The planners must detail the full
range of preliminary and ongoing studies within the context of all other
legislative requirements and within the context of the community’s boating
needs, and relate these needs to available resources and not to commercial
development imperatives.
Criteria must be
established and relate directly to environmental sustainability, marine safety
requirements, land based requirements and financial feasibility.
Funding options for
boating facilities around
To refer to the
Triple Bottom Line objective, in the Draft Action Plan, without clearly
identifying all the issues is misleading and means nothing.
Preliminary studies for
any potential site must also include:
i.
adequate geomorphological studies of coastlines prior to nominating any
marina/boat harbour type development site, and
ii
determining the impact and consequences that man-made structures, protruding
from the land into the sea will have on nearby coastal beaches and channels.
9. Environmental
Clearance for Olivers Hill
The statement made in
the Draft Boating Coastal Action Plan on Page 73 Part 24.1 that, “A proposal
for a marina at Olivers Hill at Frankston has received environmental
clearance”, is not correct.
The Olivers Hill
Supplementary Assessment from the Advisory Panel, dated February 2003
(Recommendation 7) states:
Coastal Process
Modelling
The approved amendment must provide for the development of
a preferred harbour design solution using all relevant background data. This
design must be subject to coastal process impact evaluation including physical
modelling, before any development approval can be granted. This process must
enable any sand bypassing requirement to be predicted with reasonable accuracy
and for its cost to be calculated.
The Minister’s
Assessment of October 2003, states:
“It is my assessment that this recommendation be accepted
and implemented…Numerical (computer) modelling may be a useful and cost
effective technique for developing, comparing and refining alternative harbour
design concepts, having regard to criteria such as minimising the need for
dredging (as required under Environment Protection Authorities Best Practice
Environmental Management Guidelines for Dredging) and minimising the need for
blasting. Physical modelling should then be used to validate predictions of the
numerical process in terms of a preferred and refined design concept, and may
lead to further design improvements. Subsequent computer modelling may also be
useful to augment the outcomes of physical modelling, but the key
requirement is an appropriately rigorous physical modelling regime which
can provide reliable predictions of harbour performance in both user safety and
environmental terms … The completed modelling (including any computer modelling
as well as physical modelling) should be to the satisfaction of both the
responsible authority and the Department of Sustainability and Environment before
development based on the modelling may be approved”.
No modelling has
been carried out for the Olivers Hill site, therefore the statement on Page 74
of the Boating Coastal Action Plan Part 24.1 that, “A proposal for a marina at
Olivers Hill, Frankston has received environmental clearance”, is clearly
misleading and incorrect.
10.
Draft Boating Action Plan
The Draft Boating
Action Plan, is working backwards from the desired outcome and not doing the
necessary preliminary investigation work:
The plan has been drawn
up without:
i.
adequate strategic planning,
ii.
setting out the essential criteria for a safe boat harbour, or
iii.
investigating those criteria.
The Plan is a glossy
sales brochure with little consideration of the necessary ingredients for
successful long term boating facilities.
The proposals for new
facilities identified in the Action Plan are related to a perceived shortage of
facilities, where demographics of population and commercial enterprise suggest
they should exist, with no consideration as to the suitability of the particular
location to accommodate the type of facility being proposed.
This ‘Action Plan’ is
an arbitrary plan that makes token reference to the importance of environmental
considerations, prevailing wind and weather conditions and marine safety, yet
proceeds to indicate the type of major facility to be developed in particular
areas, ignoring these criteria and before geomorphological studies have been
carried out.
This approach pre-empts
decisions and sets in motion potentially disastrous, environmental, safety and
financial issues.
Statements made in the
Foreword and Executive Summary parts of the plan suggest that the primary aim
of the Boating Coastal Action Plan is to provide boating facilities evenly
distributed throughout the Central Region.
As previously indicated
there are areas around Port Phillip Bay that can never be considered suitable
for marinas. This aspect is generally ignored by the Action Plan, and new
facilities are being proposed near centres of major population growth,
satisfying the needs of potential private property investors, rather than
meeting environmental, safety and financial standards and properly meeting the
needs of the boating community.
The greater the
population the greater the argument for a large scale marina. This is a flawed
argument. Even more fallible is the argument that proximity to transit cities
and activity centres justifies large scale marina development.
Inappropriate location
of facilities will undermine the financial viability and sustainability of such
developments and will make marina maintenance, dredging and beach restoration
costs a financial burden on the community.
Land access, traffic,
parking, noise, shore-based support industries and established community
interests and concerns must be satisfactorily accommodated, before any site can
be considered acceptable.
Financial viability of
the development must be investigated. Development capital and operation and
maintenance costs of the proposed marina must not be overtly or covertly
charged to the account of municipal ratepayers.
11
Action Plan Amendment
The financial and
environmental outcomes of other recent marina type developments in the region
have been ignored by this Action Plan, to the extent that the Frankston Beach
Association Inc. recommend the plan in its present form be abandoned, and a
totally different approach requiring full and proper investigation take place,
before any major new development in specific locations is recommended. The
“Boating Coastal Action Plan” should be replaced by a set of “Coastal Boating
Guidelines” drafted to require specific preliminary evaluation be undertaken,
designed to prevent unsatisfactory and unacceptable outcomes before any
affirmation is given to any facility in any location.
12.
What is a Safe Boat Harbour?
The terminology
‘Safe Boat Harbour’ is misused throughout the Action Plan and is
dangerously misleading.
A harbour by definition
is a place that provides shelter for boats.
What is under
scrutiny is the use of the expression ‘safe harbour’, where boats go boating
outside the harbour in a location where the area is a lee shore for 90% of the
time when the winds are blowing at more than 15 knots.
A harbour placed in a
dangerous location on the Bay, subject to prevailing onshore winds and weather,
is an unsafe harbour rather than a safe harbour.
A harbour placed in
such a dangerous location encourages and facilitates maritime accidents, by
attracting boats into the area.
There is plenty of
technical evidence and detailed articles available highlighting the dangers of
boats getting into difficulties on a lee shore and the consequential groundings
and loss of life and property.
Olivers Hill at
Frankston is one such place that is unsuitable for siting a marina on these
grounds. At Frankston 90% of all winds over 15 knots in strength (approx. 29 km
per hour) are onshore winds and place Frankston in a predominantly lee shore position.
Signed,
Frank Hart
President
Frankston Beach
Association Inc.
27/01/2006