Submission to Corangamite Shire - 181 Manifold Street, Camperdown (PO Box 84) VIC 3260 planning@corangamite.vic.gov.

09/11/2016 Subject: Princetown Eco-Tourism Development Application no1002429 Montarosa Pty Ltd. 78 Old Coach Road Princetown, Vic. 3269 All photos included in this submission are the property of the owners and subject to copyright Further information about any aspect of this objection is available on request.

The planning Permit Applications (pp2016/126) and a works Approval Application (1002429)EPA for the proposed Princetown Eco-Tourism Development at 79 Old Coach Road Princetown, Vic. should not be approved by the Corangamite Shire or EPA. I wish to state that while I’m not against development which may provide jobs for the local community / local Government income in the area I wish to strongly object to this proposal for the following reasons: 1. The site is not suitable for development as it is on a flood plain situated in the Gellibrand Estuary Wetlands area and frequently under water Appendix: Page no 3 2. The Princetown Wetlands are already under severe impact from low summer flows resulting from less rain and increasing demand from an ever increasing Warrnambool and Colac urban population /industrial & agricultural demand

3. Flooding has always occurred across the proposed site which is to be expected as it is on a flood plain that is subject to conditions occurring at the river entrance and estuary arising from storms generated in the Southern Ocean that impact on this South Western Coastline as well as high river levels Appendix Pages no 5-8 4. Artificial Openings Preliminary Hydraulic Report 2015 Table 4-2 Scenario 2 Analysed conditions produced from data modelling. They have interpreted this to mean that CCMA would artificially open the river before it reached the height of 1.80 AHD. This sort of information is not accurate and could negatively affect future management decisions Appendix Page no 9-11 5. The project application does not present a true and accurate representation of the proposed site. Information presented in the Permit application are only an indication and may not be accurate nor sufficient basis to predict a possible outcome Appendix Page no 11-12

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6. The document seems to be prescribing River Management issues that must be left to CCMA in order to incorporate all the complex aspects that are involved. Appendix Page no 6 7. Community consultation was not undertaken as presented in the document. Appendix Page no 12 8. Despite claims of indemnity as regard to GHD and their client Montarosa by stating that the information contained in the document was an agreement between them alone, if the Corangamite Shire does actually pass the application and grant a permit then the Shire will be liable for any damage sustained at a later date by them or future owners

Also there is no liability if the information provided by Montarosa and GHD is proved to be incorrect.

Appendix Page no 13 9. The site is on a flood plain incorporating an important historical geological/geomorphological land formation. Appendix Page no 14 10. Fishing has historically been and currently is an important destination for anglers and continues to attract a large number of people to the area. This activity is not mentioned Appendix Page no 15 If the Corangamite Shire permits this development to proceed

The Shire is creating a very dangerous precedent for facilitating any future development on rare coastal wetlands. This would also apply to river flood plain modification and drainage

The Shire may be liable for litigation if damage occurs to the developer’s property/or future owners by future flooding events.

There is no guarantee that extensive modifications and more buildings will not be added at a later date. (The Shire’s support for the failed Moonlight Head development (about 1999) which currently after many years exists now as an excavation on a bare hillside)

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1. Wetlands 1. The site is not suitable for a development as it is on a flood plain area situated in the Gellibrand Estuary Wetlands area and frequently under water

1.1 The Princetown Wetlands (VIC093) are listed as Wetlands of National importance (ANCA 1996) http://www.ea.gov.au/water/wetlands/database/, 2002 They were included in the directory because of three characteristics

It is a good example of a wetland type occurring within a biogeographic region in Australia

It is a wetland that plays an important ecological or hydrological part in the natural function of a major wetland system/complex

It is a wetland which is important as the habitat for animal taxa at a vulnerable stage of their life cycles, or provides a refuge in adverse conditions such as droughts (Sherwood and Barton 2004)

Princetown wetlands are subject to two international migratory bird agreements JAMBA /CAMBA and are important breeding grounds for migratory birds which attract many international visitors to the area

Destruction of habitat / breeding areas by ever increasing activity and noise from tourist numbers creates a threat to water bird breeding and also to migratory visiting birds; this includes the Musk duck which is seen every year along the site frontage. The endangered Bittern & the Little Egret are residents that have critical nesting requirements as do other vulnerable birds. Increase of noise, light and movement affects shy birds and migratory waders –especially with construction activities and increased use of water craft. The bird list provided in the permit proposal does not show the results of recent observations. ‘Species of birds fluctuates seasonally with changing water levels, also different habitats become available’ (Sherwood & Barton). High inflows of fresh water from May – Nov. have a major influence on fish species distribution and abundance; they seem to be a trigger for many species migration and breeding (Tunbridge & Glenane 1988. Wetlands are substantially impacted by changes to their natural water regimes, by drainage, raising or lowering of water tables, construction of levee banks and the use of wetlands for water storage or waste water dispersal. The information in the application does not reflect the findings of Ecological Vegetation mapping 2010. The Estuarine Reedbed EVC which has ‘rare ‘status in the Warrnambool Plains bioregion is dominant along the lower areas and is targeted for the construction of a boardwalk. Any increased modification will facilitate increased spread of weeds and pathogens and destroy habitat. The Princetown Project proposed by Montarosa would at least double the number of people and traffic on and around the Gellibrand estuary/wetland area The existing Camping Ground already can have over 300 people during the holiday period and there are also day visitors to the area. School groups also bring in large numbers into the area

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2. Impact from low flows 2. The Princetown Wetlands are already under severe impact from low summer flows resulting from less rain and increasing demand from an ever increasing Warrnambool and Colac urban population /industrial & agricultural demand

2.1 Low flows are already creating higher concentrations of nutriments and this will be seriously increased by any additional sewerage/ waste water seepage from the proposed development, especially when combined with that from the Recreation Reserve. 2.2 The Gellibrand River Estuary is highly stratified and during periods of low flow, saline bottom water can become depleted in dissolved oxygen and have increased concentrations of toxic compounds such as ammonia and hydrogen sulphide (Sherwood 1984) If the river is opened artificially when the bottom layer is anoxic, the top fresh water may simply drain out to sea, leaving the anoxic layer behind, leading to fish kills in the estuary. High Phosphorus readings on the site have already been recorded and any increase in Phosphorus levels could provide the nutriment balance required for blue green algal bloom. Start of Blue Green algae formation in the salt wedge was indicated during 2015 -2016. Algal build up occurs and fish and invertebrates become entrapped by algal mats during artificial openings. 2.3 Recently, parasites were found to be causing fish deaths. This occurred because of high water temp providing opportunistic breeding conditions. 2.4 Serous impact on important sea grass beds close to the south & south west of the proposed development site could occur from increased algae, turbidity and toxic compounds not flushed from the estuary.

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3. Flooding The Gellibrand River Entrance and Estuary are subject to the full impact of storms generated in the southern ocean that have shaped this south western coastline, this also affects the Gellibrand Wetlands which when combined with the other conditions mentioned below causes serious flooding 3.1 Flooding has always occurred across the proposed site which is to be expected as it is a flood plain (Latrobe mentions flooding in 1864)

The Wetlands can flood at any time of the year because of: 1 High flow from heavy rainfall in the catchment 2. Local heavy rain resulting in run off from steep surrounding area 3. Storm surge

4. Combination of all above 3.2 The area is subject to annual flooding and inundation which is often reoccurring and can last for long periods of time. Flooding is a natural process and has been a factor in the formation of the estuary and the natural wetlands. The flooding inundates farm land that was formerly natural wetlands as far up as 10km upstream and has been an impediment to agriculture and transport since early settlement. (Gellibrand River Estuary and Wetland Management Plan (May 2001) Despite assurances in Land Capability Assessment 2.3 which are supported mainly by desk top data, the proposed project area will still be subject to flood & storm damage. Flooding has always occurred across this property and it was for that reason the proposed site was never previously built on as the community was under the impression that a permit for development would never be granted. This is the reason that the developer was able to purchase the land at such a low price. 3.3 Important to note, that the modelling supplied in the planning document does not include early dates of flood modelling. There is only a, limited assessment of flooding history. Previous high levels occurred 2010, 1952, 1941, and 1924; this historical information is supported by community photos and newspaper reports taken from historical information obtained from SLV) (Flooding also occurred during both 2016 and 2015 when the G.O.R was flooded). Therefore the estimate of 1:100 or 1:20 year flood may have to be revised. Flooding was mentioned by Latrobe in his journals as early as 1845-46 and has continued frequently ever since (Flooding also occurred during both 2016 and 2015 when the G.O.R was flooded). Therefore the estimate of 1:100 or 1:20 year flood may have to be revised. 1952 Historical records in local Newspapers show

01/6/1863 - reports from early exploration 01/10/1881 - including serious rock fall at mouth 21/09/1886 - mention of floods in C.C. article for 09/04/1887 31/05/1887 -feasibility study into removal of rock removal 21/09/1887 - subsidence of flood waters 23/02/1889 - Break water removed by force of waves 29/01/1889 - Flats liable to flooding Page 5

18/01/1890 - All low lying land under water 27/28/7/1893 - High flooding from heavy rain 19/12/1895 - Floods 12/09/1896 - Flats flooded to depth 4ft. –heavy rain in catchment 03/05/1900 - Not possible to undertake snagging because of flooding 25/07/1903 - Flooding 04/04/1905 - Efforts to release flood water unsuccessful because of tide 19/05/1905 - Description of bar forming process 22/01/1906 - Periodic flooding necessitate action to build tunnel 08/06/1906 - Floods and rough seas 17/07/1906 - High floods and rough seas 18/04/1907 - Flooding and high seas water 2ft. deep over roadway 08/09/1911 - Flooding 27/04/1914 - Flooding water across low roads 24/11/1914 - Mouth barred -flooding 23/01/1915 - River barred flats flooded 02/07/1915 – 5 - 2.5ins rain - Extreme floods expected 21/09/1915 - Flats covered with water 07/10/1916 - Heavy rains -flooding 28/02/1924 - water 2ft. over road 12/06/1924 - Rain, high tides, inundation of flats 13/05/1926 - Rough weather bar and daily inundating of flats 24/05/1927 - Storms, gales and high seas –river barred and flooding 09/05/1933 - Heavy seas, bar and flooding 02/05/1935 - Gellibrand flooded several times since Xmas. Flood in Feb 12/01/1937 - Heavy rain on 31/12/1936 -flooding 31/08/1939 - Football postponed because of flooding 27/01/1941 - GOR blocked 16/02/1945 - Flooding and high seas 28/03/1946 - High seas keeping flood level up 19/06/1952 -9 ins. rain at Beech Forest - Flood warnings issued 10/12/1953 - GOR flooded

/06/2000 –G.O.R closed because of flood waters from mouth closure, with water levels 1.5- 2m higher than normal (Kelly 2000.)

About 1949 Page 6

2010

2015 Image shows inundation resulting from storm surge only. If this was combined with heavy local runoff and heavy falls in the catchment the height would have been considerably higher. Note direction of wave surge toward Recreation Reserve and Project development

2015 The above image also shows inundation resulting from storm surge only it also clearly shows the shape of the Princetown Spits and proposed access road/ Old coach road under water. Future construction and modification of this important land form are to take place in that area Page 7

1896 Historical photo taken 1896 shows Princetown landscape showing mouth and dune formation This formation allowed the storm surge to cross over the wetlands and enter the river channel along the

About 1980 Page 8

4. Artificial Opening 4.1 Possibly to provide a solution to the ongoing flood threat to the development site, mention is made in the permit application document of Artificial Openings. Appendix M Preliminary Hydraulic Report 4.3 Scenario 2 Closed estuary Table 4-2 Scenario Analysed Conditions River Mouth Condition ‘Assumed closed at a level of 1.8 CCMA have indicated that existing evidence suggests that the estuary would be artificially opened before reaching a level of 1.8m AHD’ this is not accurate.

2015 AHD 1.97 Neither is the information in Table 3-3 River Mouth Closures on some of the dates included flow was observed at the mouth. Also some of these events resulted in a Natural Opening CCMA Data Analysis and Interpretation Gellibrand River Estuary 2007-2012 recommendation is made that addition of quality profile assessments should be used to support Hydro share information Concern has been raised about the risk associated with Artificial opening, in particular the effect of the manipulation of wetland water levels by artificial opening and altering the natural flooding regimes of the wetlands (CCMA 2001) Information included in Estuary management documents seems to have been ignored or not considered. 4.2 Exposure of wetlands from sudden openings can cause drying out of wetlands; exposing iron pyrites to the air forming acid soil and later after rain (or irrigation) run off will kill vegetation, fish and macro invertebrates. 4.3 Artificial or Permitted openings are expensive and can be very dangerous because of unpredictable fast flows, which also affect areas upstream of mouth as well as the channel and estuary. Steep side collapse of river channel can suddenly occur. Rock falls and high wide storm surge from the ocean. Page 9

2013

2008 Discharge of anoxic water with high concentrations of sediment and toxic compounds into 12 Apostles marine sanctuary is a threat to that environment Fish kills are associated with artificial openings In June 2000 the Estuary was artificially opened and large numbers of spawning Common Galaxias, adult Smelt and Gudgeon were killed when de oxygenated water filled the main channel from fringing wetlands (Kelly 2000). Other major fish kills occurred 1999, 2000, 2008, 2010, 2016.

24/02/2013 4.4 Damage to the seagrass beds can be caused by sudden exposure and increased sedimentation. This may occur if the water level drops suddenly when affected by unfavourable tidal conditions Page 10

23/02/2013 Death of fish and macro invertebrates occurs when they become trapped by algal mats 4.6 Raising the Old Coach road height is going to greatly increase the risk involved during artificial openings especially during storm surge events It will affect a narrow strip of protected wetland between road and main channel, which is an important part of wetland system and important aquatic vegetation which is already seriously affected by turbidity (seagrass destruction) any increase from construction/ road works or scouring from new flood paths will seriously affect the seagrass that is extremely important to protect Culverts can block with debris and road surface materials (as experienced along Old Coach Road) The impact of flood levels up stream has not been mentioned. This is important because the river is tidal up to the Burrupa and thus affected by any change in river height. It is also affected by very heavy run off and channel infilling.

5. The project application does not present a true and accurate representation of the proposed site There is insufficient understanding/identification of the complex interconnection of the many aspects that drive natural processes in the estuary and which if acted upon inappropriately especially during construction and modification works these could adversely impact on the whole Estuary and Wetlands. In order to address the requirements of the landscape assessment, excerpts from existing documents have been selected to promote the facilitation of the development e.g. Land Capability Assessment Existing Conditions 4.1 Site Setting 4.1.5 Flood Potential. Here it is mentioned …. ‘That a request was sent to CCMA for information on the 100 yr. and 20 yr. ARI flood levels …… the CCMA 2015 advised that the CMA does not have detailed flood modelling for this area but this location is regularly/ annually subjected to estuarine flooding when the mouth is closed’ Also Appendix M Preliminary Hydraulic Report 3.2.3 Peak Levels due to bar closures Table 3.3 River Mouth Closures - does not present an accurate assessment. CCMA Data Analysis and Interpretation Gellibrand River Estuary 2007-2012 - Recommendations that in addition quality Profile assessments should be used to support Hydroshare information Page 11

Other CCMA documents produced since 2000 are available that describe important conditions that have not been given consideration. CCMA Final Estuary FLOWS Barton J. Sherwood J. Deakin University 2004 Estuary opening management in Western Victoria: An information analysis CCMA Data Analysis and Interpretation Gellibrand River Estuary 2007-2012

6. The document seems to be prescribing River Management issues that must be left to CCMA in order to incorporate all the complex aspects that are involved. 6.1 Wetland management and Environmental considerations such as the hydrological and ecological processes operating in estuaries need to be carefully considered if degradation of wetlands / riparian vegetation and reduced fish populations are to be avoided. Concern has been raised about the risk associated with artificial opening, in particular the effect of manipulation of Wetland water levels by artificial opening and altering the natural flooding regimes of the wetlands (CCMA 2001) 6.2 The management of the estuary is currently under review by CCMA and no decision about the development should be reached before the completion of this management document. 6.3 Any management action needs to be undertaken by all Gov. Departments involved and needs to include extensive community consultation with all stakeholders. Information included in ‘Estuary Opening Management in Western Victoria’ (Barton J. & Sherwood J.) seems to have been ignored or not considered 6.4 All documentation based on modelling provided in the Permit application must be regarded as an indication only

7. Community consultation was not undertaken as presented in the document. I personally have never received any notification that the document was actually available from the Shire or the developer, despite assurances that this would be done. Estuary Watch was not consulted as stated in the document. Data from a Public database may have been used The permit application document is intimidating especially as it has taken a team of highly paid consultants employed by an international company who work with Government contracts over 12 month to compile and the community have read understood the implications of the document in 2-3 week time period. The presentation of a highly technical 500 page document that required submissions to both EPA and Shire in the time allocated placed the community at a distinct disadvantage. Page 12

8. Despite claims of indemnity as regard to GHD and their client Montarosa by stating that the information contained in the document was an agreement between them alone, if the Corangamite Shire does actually pass the application and grant a permit then the Shire will be liable for any damage sustained at a later date by them or future owners Also there is no liability if the information provided by Montarosa and GHD is proved to be incorrect. With the sudden recent increase of severe storm damage and ocean generated storm surge any rise in sea level will dramatically change the conditions that are now experienced on the proposed development site. With the effects of recent high temperatures and more intense storms and storm surge from the ocean climate change is already evident, the desk top modelling used in the proposal may not be able to predict future outcomes The proposed water activities such as pleasure boats, paddle boards, kayaks/canoes etc. being used by inexperienced persons could have serious consequences Deaths have occurred near the proposed site because of unpredictable flows / surges. Debris from upstream can also be a problem During about 2014 I witnessed about 5 canoes being overturned south of the Camping Ground because of gale force wind from the mouth travelling across the estuary Page 13

9. The site is on a flood plain incorporating an important historical geological/geomorphological land formation. 9.1 The information regarding this land form was provided to the Otway Shire by Neville Rosengren when Princetown and Lower Gellibrand were included in that Shire, but when Princetown and Lower Gellibrand were transferred back to Corangamite this information seems to have been ignored. Surely such important information should have been included on the subsequent Landscape overlays? 9. Appendix K Framework Environmental Management Plan 3.9 Geological and Geomorphological Values While Montarosa’ application states that Rosengren mentions significant disturbance being made to the Spits in the Camping ground this does not justify their intention of further disturbance/ modification by construction of a car park and road across the important land form

1896. Historical photo taken The above photo taken in 1896 shows the estuary entrance and dune formation at that time. It is reported in local newspapers that the dunes were affected by the South West winds and constantly moved toward the river often blocking it sufficiently for a wagon to cross. Barriers were constructed to try to prevent this. An affected area was at the site of the Montarosa development eastern cabins While currently the area is more stable, fire/ clearing could remove vegetation from the dunes and create instability Page 14

10. Fishing has historically been and currently is an important destination for anglers and continues to attract a large number of people to the area Consideration of this important activity is not mentioned in the application; in fact the proposal proposes actions that affect river health, habitat and breeding areas that will be detrimental to recreational anglers Professional fishing is licenced to occur along the river. This has not been mentioned Increased activities and more people will also impact on this activity Increased tourist and water based activities will also be in conflict with Duck shooters who currently operate along the river. Fish species in the estuary and river have not been accurately assessed in the document. The following have been recorded in the river and estuary. The estuary being tidal and subject to salt water travelling up stream explains the marine species. Mulloway, Yellow eye mullet, Bream, Flounder, Salmon, Puffer fish, Tupong, Ling, Estuary Perch, Crabs, Wrasse, whiting, Pigmy Perch, Angle fish, Scrub Yabby, Redfin, Zebra fish, Sweep, also Water rats, Platypus and Tortoises these could all be affected by any increase of sediment and discharge. Both fishing and bird watching will be threatened by declining river health, increased noise and activity as visitor numbers increase Page 15

References Barton J. Sherwood J. Estuary Opening Management in Western Victoria’ O’May J. Gellibrand River Estuary and Wetland Management plan May 2001 Fletcher J. The infiltrators CCMA Assessment of Environmental Flow Requirements for the Gellibrand River Flow 2006 CCMA Environmental Flow Requirements for the Gellibrand Estuary Final Flows Report 11th Sept 2008 CCMA Data Analysis and Interpretation Gellibrand River Estuary 2007-2012 CCMA Interpreting Estuary Health Data Estuary Watch Victoria EPA Environmental Water Quality Guide lines For Victorian Riverine Estuaries Publication 1347 July 2010 DSE Western Region Sustainable Water Strategy 2011 CCMA Corangamite Waterway Strategy 2014 -2022