The proposed expansion of Melbourne's Urban Growth Boundary (UGB) will involve the rezoning of up to 46,000 hectares of land for residential development, new roads and a freeway. Please make a submission on this significant development.

The proposed expansion of Melbourne's Urban Growth Boundary (UGB) will involve the rezoning of up to 46,000 hectares of land for residential development, new roads and a freeway.  These areas are largely in the north and west, and in the outer south east.

This policy could see unprecedented destruction of the green wedges - the non-urban areas of Metropolitan Melbourne often referred to as the cities lungs. There will be environmental damage, including the loss of considerable sections of western and northern grasslands, destruction of wildlife including endangered species, increased greenhouse gas emissions, the construction of even more freeways/ the ring road, and loss of farm land.

In a very real sense, this proposal is about what type of city we want to live in. This massive expansion, to allow low density sprawl, is the anti thesis of sensible urban design. In a time of climate change we must be protecting at risk and fragmented ecosystems, such as native grasslands and grassy woodlands - not further fragmenting them. In a time of rising energy and fuel costs, we should be re-localising much of our food production - which means protecting arable land, not putting it under low density sprawl. We should be building compact urban areas which are well serviced by public transport - not allowing more growth out beyond the reach of PT.

This proposal could also see the erosion of democratic structures because the state government is considering taking over planning powers of these new growth areas.  This could allow the government to bypass parliament and local councils over planning and environment issues.

The government's proposal to establish 15,000 hectares of new grassland reserves outside the growth areas is welcome news. However, it does not excuse the potential loss of more than 6,000 hectares of grasslands that could be destroyed by new urban developments within the UGB area.

If allowed to proceed, this expansion would further condemn Melbourne to being a car dependent, low density and sprawling mess. In the 21st century we can do far better than this - making our city compact, diverse, vibrant and liveable.

TAKE ACTION!

You can help protect the most important biodiversity sites by writing a submission on the EPBC Impact Assessment report.

This is because the federal government can protect important endangered species through the EPBC legislation, and it has to approve the state government project, which will mean it can place additional protective measures on it's approval of the state government proposal.

Unfortunately, the state government has not allowed much time for adequate consultation and the deadline is on 17 July.

It needed be too formal, just explain briefly in your own words what your concerns are.

See the Government’s website: http://www.vic.gov.au/planningmelbourne for details on the proposals.

The Government is seeking public feedback on the following proposals:

* Melbourne's revised Urban Growth Boundary and land designated for development.
* An alignment for the Regional Rail Link (west of Werribee to Deer Park).
* An alignment for the Outer Metropolitan Ring / E6 Transport Corridor.
* The boundaries and management of proposed grassland reserves in Melbourne's west.

Public feedback is also sought on the findings set out in the Strategic Impact Assessment Report for Environment Protection and Biodiversity Conservation Act 1999, as mentioned above. You can find this document at: http://www.dse.vic.gov.au/ (and search for the document).

Please make a submission by close of business on 17 July.

You can submit via the following options:

On Line:        Click on: http://www.vic.gov.au/planningmelbourne

By Post:        Growth Areas Authority, PO Box 116, Carlton, Vic, 3053.

Hand deliver:   Growth Areas Authority, Level 6, 35 Spring St, Melbourne.

WRITING YOUR SUBMISSION

Some points you may want to make in your submission:

Most of this information comes from the document 'Top ten Biodiversity Issues in the Merri catchment', produced by Friends of Merri Creek (FoMC), who describe the expansion plans as "the biggest threat to the Merri ever", with some additional comments from FoE.

1.                  the expansion is not needed or warranted

The proposal to expand the Urban Growth Boundary (UGB) is completely unnecessary. The State Govt says that expansion is required in order to house our growing population. However, at 15 lots per hectare, there would be enough development land within the current UGB to last for more than 15 years, while at 20 lots/ha there could be enough for 25 years. Increasing the housing density would also make homes more affordable, as well as reducing the overall physical footprint of our new housing.

By implementing simple measures – such as insulation, orientation, high efficiency cooling and heating, and window shading – the ecological footprint of a home can be cut by a factor of five. When clever design features are included, it is also possible to get much better use of space, meaning you can fit more houses onto the same amount of land without compromising amenity. According to research carried out in Queensland by Lend Lease Delfin, the EPA and GreenMode,  when construction and the physical maintenance of the house are also included in this type of planning, three of these sustainable homes could fit in the footprint of one ’standard’ house.

Most people living in the proposed new communities will be forced into car dependence, and hence be locked into rising petrol costs and increased greenhouse gas emissions. The government should be placing a moratorium on developing new suburbs if they don't have funded plans to ensure adequate public transport to these areas.

2.                  extensive on-the-ground surveys needed

Extensive on the ground surveys for native vegetation and targeted fauna are needed over much of the upper Merri catchment. The ecological consultants for the Strategic Assessment report acknowledged that their own surveys were inadequate so these limitations need to be addressed before any expansion is approved.

3.                  no Native Grassland or Red Gum Grassy Woodland should be destroyed

Absolutely no native Grassland or red Gum Grassy Woodland should be destroyed. These precious areas are so rare that we need to protect all the remaining remnants. However, the current proposal designates the following important areas for destruction:

(a) All grassland areas within the UGB, except areas identified as ‘significantly constrained,’ or which are deemed to be needed for habitat for certain endangered species will be destroyed.

(b) 924 ha of grassy woodland (River Red Gums), representing 42% of the grassy woodland area identified in the original Investigation Area will be destroyed.

Please state that you believe that all native grasslands should be retained as part of the urban parks network within growth areas. It is vital that new reserves are locked in as quickly as possible before property developers or the State Government start clearing for new housing or infrastructure. This means upfront funding for the new reserves needs to happen now.

4.                  there should be no trade-off of Merri grasslands

Native grasslands cannot be traded off. While we support the proposed reserves, they are mostly species-poor, with only some species-rich areas, and they are a slightly different grassland type to the ones that are proposed to be sacrificed. The values of the north-south link and the Kilmore gap provide a crucial fauna corridor and can’t be traded away or offset.

5.                  any offsets should be in the area they are replacing

Although no native grassland should be destroyed in the first place, if there are to be any offsets as a result of destruction for housing, they should certainly be located close to the areas being destroyed, not over 60km away as currently proposed in the case of the offsets for the Merri grasslands that will be lost.

6.                  important areas need protection and connection

The following important biodiversity areas and habitat corridor connections between these areas need to be protected, but instead they are designated for development. They include:

(The references below refer to the map on the FoMC website: http://home.vicnet.net.au/~fomc/ There is a link on the front page.)

·         Camoola Swamp Biosite (State significance) (No. 2 on map);

·         A large area of Grassland between the Hume Freeway and the Kalkallo Retarding Basin (No. 3 on map);

·         At least half of Bald Hill Biosite (nationally significant) (No. 4 on map);

·         Grasslands in Woodstock area (No. 10 on map);

·         Red Gum grassy woodlands in southern Wollert area (No. 11 on map - in Darebin Creek catchment);

·         Remnant grassland immediately to the north and contiguous with the Kalkallo Common (No. 12 on map);

·         North-south link to the east of Merri Creek between Craigieburn East Grassland/Grassy Woodland (No. 8 on map), the Summerhill Rd Woodlands (No. 6 on map) and the Grassland/Woodland areas north of Donnybrook (No. 4 on map);

·         An east-west link from Kalkallo Retarding basin: west to remnant vegetation on the Old Sydney Rd ridge line, and east along Kalkallo Creek to Merri Creek, and to the woodlands at Woollert (No. 11 on map).

7.                  we need commitment to maintain connectivity

We need upfront commitment to provision of ‘greenways’, bridges, tunnels, etc for fauna to use, including significant bridging and/or tunnelling to avoiding fragmentation). However, the report doesn’t even discuss how connectivity between biodiversity areas will be maintained once major new transport corridors and urban development are in place.

This connectivity is even more significant in a time of climate change.

8.                  new parks needed

The upper Merri needs new parks or conservation reserves similar to what is proposed in the FoMC vision: Nature on Melbourne’s Northern Doorstep, which is available on their website http://home.vicnet.net.au/~fomc/  under “News”

The Government’s proposal mentions areas of biodiversity that are excluded from development, but this is vague and it does not propose any new parks along the lines of the FoMC proposal.

9.                  need to protect a minimum 400 metre width along the Merri corridor

There needs to be an unambiguous minimum 200m ‘buffer’ on both sides along the entire Merri Creek, irrespective of current biodiversity values within this buffer, making a total corridor a minimum width of 400m.

10.             the audit and review process needs more detail

There should be an explanation as to how new ecological information will be dealt with, including any new EPBC listings of threatened species and communities; plus mention of the public input to such processes will occur.

Food production

You may also want to suggest that the state government act to protect all remaining productive farmland in the proposed expansion areas. We could follow Queensland's lead, and introduce a Protection of Agricultural Land Bill, which would aim to stop further encroachment on agricultural areas until a full assessment of agriculture in the light of climate change has been carried out.

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Produced by Friends of the Earth Melbourne, July 2009
http://www.melbourne.foe.org.au/?q=node

For further information:

Victorian National Parks Association: http://www.vnpa.org.au/

Green Wedges Coalition: http://www.gwc.org.au/

Check the analysis by Jenni Bundy: 'Why UGB expansion plans are seriously flawed', available at: http://www.gwc.org.au/node/73

Environment Victoria response to the announcement: http://www.envict.org.au/inform.php?menu=4&submenu=22&item=2087

Friends of Merri Creek: http://home.vicnet.net.au/~fomc/