The Department of Environment, Land, Water and Planning (DELWP) is seeking your views in helping develop long-term objectives and a shared vision for the Great Ocean Road region. Please have your say by completing the online survey: https://engage.vic.gov.au/great-ocean-road.
For those interested the 3228R submission:
Registered Number – A0058442K
Submission to the Great Ocean Road Action Plan
As a community organisation whose members live within the area that is to be covered by the GOR Action Plan, 3228RA would like to make comment on the implementation of the proposed Plan. Our input is based on attendance at the initial consultation in 2017 and the most recent sessions held in Torquay as well as extensive reading of the available documents – see References below.
We acknowledge that the focus of the plan has been broadened from what was initially proposed ( tourism and the visitor economy focused) to include the importance of environmental protection, the effects of climate change and LIVEIBILITY of communities along the GOR.
As a town - Torquay/ Jan Juc has been targeted as a “ growth node” over the past 15 years and coupled with the increase in tourists our town has already reach a point of crisis in terms of liveability -
“Liveability is the sum of the factors that add up to a community's quality of life—including the built and natural environments, economic prosperity, social stability and equity, educational opportunity, and cultural, entertainment and recreation possibilities.”( Partners for liveable Communities, firstname.lastname@example.org)
It seems that the state government has finally recognised the importance of protecting our coastal towns and is now listening to the community - the instigation of the DAL process and, we hope, the Statement of Planning Policy will protect our town from future overdevelopment and unrealistic expectations of population growth by defining our town boundaries and building heights in line with community expectations.
It is unfortunate that the consultation for the DAL and the GORR action Plan consultation were held at the same time – many people found it confusing and conflicting, especially when one of the lead questions re the GOR was “what infrastructure is needed to enhance the visitor experience?” This was a poorly worded, leading question as it put all the emphasis on the “visitor” and none on the residents. Many in the community see the increase in the “visitor” numbers as part of the problem, not the solution. Economic benefits from tourism only flow to a few in the community and more often flow out of our communities to large commercial interests by way of “profit leakage” (Profits going out of local area because the business owners are outside the community. Also although there is often a lot of emphasis put on “escape expenditure”, this is often not a true description as any larger commercial interest is more likely to purchase wholesale from outside the local area. The sum of profit leakage and wholesale escape expenditure results in an overall loss to the communities. Along with that, tourism related jobs are often low skilled and low paying and with property prices in the coastal communities very high, we need to the emphasis to be on medium to high paid jobs.
We would also like to comment on the current management arrangements that the GOR Action Plan seeks to overturn. We consider that the GORCC is and has managed the coastal strip under its management extremely well with the limited resources it has under its control. We value the ease of communication with them, their understanding of community expectations and their willingness to work with local community groups. We fear that the proposed GORCPA will not be as easily accessible to our community and will not provide the same level of consultation/ input into decisions which affect our community and environment, especially planning decisions. We can’t speak for areas beyond the GORCC managed strip and it may be that those areas have management issues.
An over arching body will only be acceptable to our community if it includes, in its legislated form, the inclusion of defined community involvement in the decision making process for our area which includes the coastal strip and the hinterland.
By this we suggest that a community consultation group (or groups) be formed and that these groups are more than just ‘advisory”. Alternatively we suggest that a minimum of 2 members of the board for the new authority are drawn directly from the local residents as community representatives and that the remainder of the board are persons with expertise and of which 80% are local residents.
If the suggestion above is not feasible because the local residents do have the required expertise, then we suggest that the experts are brought together as an advisory group and the board is made up of local residents.
We are also concerned at the lack of definition of terms which reoccur throughout the documentation. The most repeated word without definition is “ sustainable” - sustainable tourism, sustainable visitation, environmentally sustainable - without a definition for sustainable these terms are at best confusing and at worst, meaningless. Without definition there is no way to assess if the implementation of the Action Plan is achieving what it stated outcomes are.
We suggest a glossary of terms be included in the document and that ‘sustainable’ be clearly defined.
Objectives of the Action Plan
1.Protect the ecological and landscape integrity of coastal and marine environments.
We agree with the 4 Principles of this objective but feel that the contribution of local community groups towards the protection and rehabilitation of coastal and marine environments should be recognised and their future involvement should be improved with defined requirements for consultation.
2.Increase Traditional Owner inclusion
Acknowledgement of the traditional custodians of the Great Ocean Road Region is long overdue. Their involvement should not be restricted to planning and management but there should be an effort made for the truth of their past existence to be told. There is an educational opportunity to that would benefit us all by providing information on all aspects of indigenous culture.
3.Protect Distinctive areas and landscapes
We agree with 3 the principles of the objective and in particular we believe that the inclusion of “heritage and cultural values, and distinctive characteristics of the GOR it’s landscapes and towns” is of great importance to our town which is at risk of inappropriate and excessive development. We believe that each township along the GOR have a defined town boundary and defined building height limits set for each zone within or outside the boundary. We also believe that significant restrictions be placed on commercial developments outside the town boundaries.
4.Grow the local, state and national visitation economies
It was been stated in the Issues Paper that the GOR now attracts more tourists than the Great Barrier Reef and Uluru.
If that is true, then there is no need to attract even more visitors, but rather to entice those visitors to ‘spend’ locally. However, the intention of this objective is unclear. Does it mean grow the numbers or does it mean grow the value?
We agree the GOR, its land and seascapes are important for the liveability and wellbeing of local communities but as stated, we are not convinced that our economic prosperity is necessarily dependent on the visitor economy.
Enhancing the touring route experience and its destinations must not be at the expense of coastal communities’ liveability.
Many places in the world are now experiencing a backlash against over tourism and a subsequent drop in visitor generated income. We need to manage our tourism and not be managed by the tourism. We need to enhance the visitors experience. Eg; The twelve Apostles is now being touted by some as a place NOT to visit as it is crowded and the visitor experience is poor. This has arisen due to poor management, the numbers of visitors on a popular day are too large for the area to cater for.
As already stated we are satisfied with the current governance of the GOR area covered by GORCC.
In our previous submission we suggested that any governance model developed be local resident focussed and the best way to achieve that outcome is to have significant representation from the local community, especially in relation to decision making that specifically relates to their area. The proposed GORCPA should be significantly answerable to the local communities along the GOR, not just the Minister.
Action 4 – GORCPA -It is unfortunate that the composition of this body is still lacking detail as is the detail of how coastal communities will be involved.
The priorities of preserving the scenic beauty needs to continue as the first and major priority, with the local community’s social needs as an important second priority when decisions are made. If the governance model has the local community and the maintenance of the environment as its focus, all other issues will follow from those positions to continue to have the GOR as an iconic destination for tourist and a desired place to live for the residents.
Decision makers, who are not residents and whose only concern is an overall tourist dollar increase, irrespective of whether the spend is local or non-local, will not make good long-term decisions for the region and will be more likely to use statistical figures on ‘Victorian economy’ or ‘Australian economy’ to justify poor planning and infrastructure decisions. We fear that the emphasis will be on visitors rather than residents, and that will result in long-term poor outcomes, both economically and for the liveability of the region and for the State.
We have particular concerns about the future management of Bells Beach, which is currently under Surf Coast Shire control and the future management of Taylor Park in Torquay (currently GORCC managed). We understand that the Shire is interested in taking over management of Taylor Park with the intention of “gentrifying” the park, extending the leased area of the bowls club and using the park to hold more events. This is despite extensive community consultation resulting in a desire to keep the park as it has historically been – an oasis of green in our town centre. Allowing the council to control Taylor Park would be a clear indication of how the local community is NOT being listened too. The management of Bells Beach has seen some very turbulent years in the past but is currently being well managed by the Shire, this is in no small part due to the Bells Beach Advisory Committee that is made up of concerned local community members. The loss of this current relationship and effective stewardship would be a major blow to the community that fought so hard for their voice to be heard.
Action 5 - Work Closely with local communities is obviously very important to our community. This must include the community being part of the decision making around planning decisions and what is appropriate for our community and not just ‘consultation’ which often does not translate into the uptake of community values.
Action 6 – Traditional owner capacity is an important initiative that will benefit all Victorians and visitors to the region as well as recognising the significance of the cultural heritage of our first nations people.
Action 7 – Sustainable funding – Too often the financial burden for the provision and maintenance of infrastructure and services along the GOR falls to the councils/shires through which it passes.
It is imperative that a sustainable funding model be developed that does not place an unreasonable burden on local communities through its rate base.
Action 8 Community involvement – Balancing the long term objectives and vision of local communities that protects the distinctive landscapes and their liveability while providing a great visitor experience can only happen with strong community involvement. How that will be delivered is not currently clear and we would urge the creation of permanent planning structures that are not just a token of “community consultation”. These structures should be implemented as part of the creation of the authority and not be left to develop in the future. We look forward to further discussion on how this can be achieved.
Action 9 – A GOR Strategic Framework Plan is a very important piece of strategic work for the region. We expect that there will be more community consultation prior to the production of the final plan. The 50 year outlook seems unrealistic unless reviewed on a more regular basis than the currently suggested 10 yearly review. We suggest that 5 years be the maximum between reviews. This will allow for the framework to alter in line with altering trends, whether that be population growth, visitor numbers or climate change effects.
The fact sheet on the Framework Plan states that it seeks to streamline and improve the uniformity of planning procedures across the GOR. Given the diversity of the areas, communities and the landscapes we question whether this approach will provide the best outcome.
We are also concerned that the Plan may require the Planning Schemes of individual councils to be amended. If such amendments are required will the normal process of public exhibition still occur?
“It will deliver the right balance between appropriate protection, sustainable development and facilitating the visitor experience” – how are appropriate and sustainable defined and who decides whether these conditions are met?
Who decides on the planning guidelines on land use and design standards and who will regulate these standards?
We suggest that the above questions be addressed prior to the authority being formed and as stated above, we suggest that the terms be defined so that it is clear to everyone what is being put forward. Again focussing on the word ‘sustainable’ – economically sustainable may mean anything from large profits to break even. Environmentally sustainable may mean anything from have little impact on the environment to having a mega development that is self-contained.
Studies to inform the Strategic Framework Plan:
We understand that three studies: infrastructure, accommodation and landscape will be undertaken to provide a better understanding of current conditions. We consider that there is also other essential studies that should be completed.
We at the 3228 Residents Association have been advocating for an extensive ‘Impact Study’ so that future decisions are based on solid cohesive knowledge and not ad hoc information taken at differing times.
There should be a study into the carrying capacity of all beaches along the GOR and impact studies for all coastal towns who are impacted by tourist visitation. The assumption that the economy of coastal towns is greatly benefitted by tourist visitation needs to be tested against the benefits of encouraging other jobs growth which generally provide greater income and job security than tourist industry jobs and against the environmental losses that will inevitably occur when visitor number grow.
In particular we would like to see a study on the social, economic, environmental and cultural impacts on Torquay/ Jan Juc of increased tourist visitation combined with the ongoing development of housing estates.
It is vital that the development of the Plan pays particular notice of the effects of climate change to our region. We know that there are already an increase in extreme weather events. Barwon Water has studies that indicate that there is a stepped decline in water inflows into our storage system directly due to climate change.
Of particular concern is the increased risk of bushfires which historically have been the cause of much damage and loss of life. The safety of community and visitors should be a high priority when decisions are made about the Plan.
We note that the recently adopted (by Surf Coast Shire)Rural Hinterland Futures Strategy has been expanded to make greater consideration of bushfire risk and makes reference to bushfire risk in all development references in the document including principles. “Page 51 now outlines key matters to consider when planning developments in high bushfire areas. The indicative map showing areas “Well Suited to Tourism” has been altered to respond to the bushfire assessment report of the Shire.”
“A better planning approval process” – what does better mean and for whom? “the Victorian Government will strengthen the planning system to properly protect the GOR and its landscapes from inappropriate development.” What is the definition of “appropriate” and on what basis is it judged?
Action 11: The GORR Standing Advisory Committee:
We note that the GORR Standing Committee has been appointed by the Minister for Planning and the Terms of Reference were signed off on the 13th April 2019. There are a lot of “mays” used and not enough “musts” - who decides what should and shouldn’t be done?
We find it concerning that this committee has been convened prior to the legislation to protect the GOR region has been adopted. We understand that they will be advising on the GOR Strategic Framework Plan and will also be available to advise on planning matters prior to the Strategic Framework Plan being finalised.
The Terms of reference are extremely broad and appear to be geared towards development of anything that might increase the visitor economy. Without the protection of legislation, decisions by the standing committee are at present not required to consider the wishes of local communities. Nor are they required to comply with the local Planning Scheme provisions but merely to consider them.
Despite the Terms of Reference for the GOR Taskforce “requiring it to make recommendations on governance to increase tourism while supporting local communities (what does this mean?) and protecting the environment: (P2, 18 - Terms of Reference for GORSAC) there is no requirement for it to consider the views of the community. This is despite 12 points that it MUST consider including the views of the proponent. We see this omission as detrimental to our community and something that should be amended.
This is a major flaw and appears to be making a statement that the local residents are not truly being considered in the processes.
The actual extent of the committee’s influence is still unclear. We have grave concerns that development proponents will now automatically refer to this authority if they perceive their developments may not be acceptable to the local community. We are aware of several developments that have been rejected (by council and the community) for Torquay that we suspect may refer to the committee prior to the legislation (DAL) that is meant to protect the area.
Page 3, 19 – 21 - We are also unclear about the reference to “Notice”, and particularly concerned that the committee must agree to the “scope of public notice” – why? Is this to be different to what is currently accepted?
P3 – Hearings – 22-26 - It is of concern the committee will regulate its own proceedings and that it may assess a matter without the need for a public hearing. This lacks transparency.
We respectfully suggest that this be reviewed with the utmost urgency as the last thing the local communities want for the Great Ocean Rd is an organisation that is just a ‘rubber stamp’ for development at any cost.
Victorians love the Great Ocean Road and the local residents wish to continue to share in its custodianship by having a significant say in its continued success as a liveable region that attracts visitors from all over the world. After all, it’s the past and present local residents that have made this region the success it already is today.
Action 15 – Improved road access and safety.
Increased numbers of tourists (particularly from overseas) has seen an increase in accidents on the GOR. A strategy is needed to improve awareness of visitors of the road regulations. Certain sections of the GOR are susceptible to landslides – significant investment is needed to remedy this ongoing problem.
Action 16 - Crown Land administrative arrangements - We note that Government Gazette: No. S 361 Wednesday 1 August 2018 declares Taylors Park(Torquay) not to be Marine and Coastal Crown Land (for the purposes of that act)- http://www.gazette.vic.gov.au/gazette/Gazettes2018/GG2018S361.pdf#page=5 We assume that this will mean that Taylor Park will now not have the same level of protection that is afforded land that is declared Marine and Coastal Crown Land (for the purposes of that act). As already stated we are concerned about the management of Taylor Park and who the managers will be.
Contact: Committee, 3228 Residents Association Inc.
PO Box 368 Torquay, 3228