Save Gnarabup
25th February 2001
David Tomlinson
Chief Executive Office
Shire of Augusta – Margaret River
PO Box 61
Margaret River WA 6285
RE: Proposed new development at Gnarabup Beach
Dear Sir
This submission has been prepared by Surfrider Foundation Australia – National Office, to reflect our opposition to the above-mentioned development proposal being considered by the Shire of Augusta Margaret River (or ‘Council’).
Surfrider Foundation is an international marine conservation organisation dedicated to the protection and enhancement of Australia’s oceans, waves and beaches for all people, through CARE: Conservation, Activism, Research and Education. Surfrider Foundation is active in many regions around Australia. We have prepared this correspondence with regard to our organisation’s examination and evaluation of the proposal to develop – and ancillary uses – on the subject parcel of land.
We understand that the coastal zone currently fronts a wide range of complex and conflicting issues over the use and demand of its natural resources.
With regard to this, it is considered by Surfrider Foundation that there exists a number of significant implications to the nature and regard of the development proposal. Aligned with this is the consequential and adverse impact upon the social and environmental integrity of the Gnarabup area. Central to the notion of such impact includes the issues and concerns being expressed by members of the local and wider community.
Surfrider Foundation considers the proposed development at Gnarabup to be inappropriate, and asks that Council refuse any form of development approval.
Should you have any queries relating to this correspondence or issues contained, please feel free to contact the Surfrider Foundation National Office. We look forward to your response.
Yours sincerely
Greg Howell Michael Legge-Wilkinson
Executive Director Chairman – Board of Directors
Our opposition to the development proposal is based upon the following grounds:
Illegal development
The current development proposal is clearly in contravention to that stipulated in clause 3.3.3.1b of the Town Planning Scheme for the area on the following grounds:
· it provides for an expansion from 140 to 243 units;
· the additional tourist site is outside of the approved development area; and
· building height has been increased from 6 to 8 metres.
Non-compliance with the Leeuwin Naturiliste Ridge Statement of Planning Policy (LNR-SPP)
The overall objectives of the policy include the statements “conserve and enhance the special benefits arising from landscape elements that form the fabric of the region” and “respect and conserve its outstanding natural and cultural heritage and environmental values.” The policy states that the landscape of the ridge is part of the nation’s heritage and includes:
· PS 3.2: Development must be responsive to local values, and be compatible with the natural characteristics and traditional settlement patterns of the area.
· P.S.3.3: Development will have due regard for the landscape integrity and value of the ridge.
· P.S.3.8: Where the LNRSPP identifies development opportunities on the ridge, such development will “maintain the natural character where this exists” and “utilise sites of least visual impact.”
These three important issues have all been disregarded.
Lack of public consultation
As elected representatives of the people, Council is required to engage the community in any decisions that have the potential to effect the lifestyle, amenities, infrastructure, viewshed – visions for the future. The lack of effective community consultation, both from Council and the Developer, and the refusal of council to take on board the wishes of the community, indicates a complete disrespect for the democratic process and calls into question the legality of the process. Council is aware of the fact that in recent years, over 1000 submissions have been received from residents of the Shire, clearly stating their vision for the region. At what point will YOU start to listen to us?
As an active community group, we object to the development application because:
· Development size has been increased without public consultation;
· The size of the current development proposal has not been subject to public comment; and
· There has been a lack of legitimate community participation in the process.
Council, for its part, is clearly out of touch with manner in which natural resource management should be undertaken today. The community will no longer be ignored. ‘Stewardship’, the active involvement of the community is an indispensable component in the decision-making process.
Cumulative impact of development in the area:
Surfrider acknowledges that the area around Gnarabup is a popular tourist destination and residential node. We are also aware that this region is part of a delicate ecosystem. Our understanding to date is that there is no clearly articulated vision for the region. Further to this, we are concerned about the impacts on the natural and built environment of the subdivision and development of Lot 226 into 9 Lots and over 100 Units considering the recommendation in the Prevelly Area Community Consultative Committee (PACCC) was for a low key tourist development.
Surfrider Foundation encourages Council to place a moratorium on all further development until a comprehensive Environmental Plan is completed. This plan needs to be:
· Integrated, taking into account all aspects of the natural and built environment;
· Holistic and ecosystem based;
· Compliant with the National Strategy for Ecologically Sustainable Development (NSESD 1992) and Agenda 21 (1992); and
· Incorporate community views and vision for the area.
Community Interests and Visual Amenity
There is potential for visual pollution of the night sky by the requirements for lighting in the development site. This may not seem significant until you do a bit of star gazing over the bay.
· The reason most visitors come to this is area is for its natural unspoiled beauty and this development will strongly affect this amenity.
· The high density urban style development will create an unacceptable change to an area of extremely high natural beauty.
· The development will be visible from several scenic view-points and so degrade the natural landscape amenity of the area, for example Grunters Hill.
· The development will create an increase in the number of people who will be resident at Gnarabup during holiday times thus affecting the relaxing atmosphere of quiet tranquillity of the area which is currently one of its main attractions.
· Further high-density urban style development will create an unacceptable change to an area of such obvious natural beauty.
· The development will be visible from several scenic viewpoints and so degrade the natural landscape amenity of the area.
Impact on Integrity of Site
The high density development will necessitate clearing obviously visible areas of vegetation that are an integral feature of the sloping hillside site.
Inadequate Infrastructure
· Sewerage
The sewerage system will not be able to cope with the increased load. There have been significant problems with regard to the current integrity of the sewerage treatment system. The proposal to further overload a system that has already failed on numerous occasions presents significant threat to the health of the local community and the fragile natural environment.
· Stormwater Runoff
There is a danger of storm water runoff polluting the pristine beach and water. The valuable coastal inshore waters have been recommended as part of a marine park for the area and will be impacted upon by the development.
Ethical nature of submission
The strategy of the developer submitting the Plan at this busy summer holiday time may be another indication of the impact this development is likely to have on our coast and an effort to get as small a response from the public as possible.
In conclusion:
Surfrider Foundation is not opposed to development. We assess each development on its merits and respond accordingly. Gnarabup is an area of high ecological and spiritual integrity. The current development proposal clearly contravenes the vision that the local community has for the area, it compromises the integrity of the natural landscape and disregards the restrictions of local and regional planning policies and strategies. Council has a responsibility to its constituents. Development at all costs is simply not an option.