Save Smith's Beach

12 February 2001

Mr. Michael Swift
The Chief Executive Officer 
Shire of Busselton
Locked Bag 1 
Busselton  Western Australia  6280

Mixed-Use Development
413 Smiths Beach

Submission Prepared for Bussleton Shire Council

Dear Sir 

Surfrider Foundation Australia (SFA) is pleased to provide the following submission in order to express objection and provide formal comment to the Shire of Busselton concerning the proposed mixed-use development (the proposed development) at Location 413 Smiths Beach (the subject site).  We understand that the proposed development comprises 230 residential sites and 460 short-stay accommodation units and ancillary uses on the subject site. 

Surfrider Foundation is an international non-profit environmental organisation dedicated to the protection and enhancement of our coastal environment through Conservation, Activism, Research and Education (CARE).  SFA has affiliates in America, Japan, Europe, New Zealand and Brazil.   

The attached submission comprises a position statement followed by specific comments with recommendations.  We ask that the Shire of Busselton acknowledge and integrate SFA’s recommendations to ensure that the interests of surfers are incorporated into the Shire’s coastal planning and management process.  Further, we ask that the Shire of Busselton facilitate the continuum of community concern over coastal development issues as a fundamental component of future strategic planning initiatives.  SFA considers that the incorporation of community participation in the coastal planning and management process will be of considerable benefit to the range of conflicting ideals and interests relevant to the Shire’s coastal zone. 

If you have any queries or require further information, please do not hesitate to contact Mr. Greg Howell on 07 5534 2855. 

Yours for Clean Oceans

MIXED USE DEVELOPMENT - 413 SMITHS BEACH
SUBMISSION PREPARED FOR BUSSLETON SHIRE COUNCIL
SURFRIDER FOUNDATION AUSTRALIA

16 FEBRUARY 2001

Part A - Position Statement

The coastal zone is extremely important to most coastal countries. Consequently, there is concern for its future, particularly regarding the status of its natural resources, which provide life support and economic development opportunities to coastal settlements.

Food and Agriculture Organisation of the United Nations - 1992

The Australian coastal zone is a significant national asset that is comprised of a wide range of aquatic and terrestrial environments.  This area however, currently fronts a wide range of complex and conflicting issues over the use and demand of its natural resources. 

While some of these issues stem from the effect of natural process and climate change, many of them have evolved from the development of human lifestyle choices and social welfare issues, such as population growth and associated urban settlement activity and response.  Among the wider interests of social and economic pressures, SFA considers that there also exists a complex and inadequate planning and management process for the protection and conservation of the coastal zone's natural and cultural resources.  It has been considered across divergent levels of government, private industry, and the community, that the complex and conflicting issues facing the coastal zone can be better addressed with a more co-operative approach to the process of decision-making for coastal planning and management initiatives made by government. 

While the concept of community participation in decision-making is by no means a revolutionary one, it has been recognised that is fundamental purpose and application to coastal zone initiatives can bring benefits to both administrative and environmental processes and outcomes.  Central to the concept are broad social justice issues such as participatory democracy, procedural fairness, and enhanced levels of community knowledge and education.  Other issues of benefit include the potential self-sufficiency of the decision-making process through partnership, an increase in community support for decisions put in place by government, and a sense of a stewardship ethic for coastal zone issues.  The enhancement of a co-operative approach to decision-making would be of significant benefit to the sustainable resource use of the Australian coastal zone, and in the development of effective planning and management initiatives made by government.

Part B – Specific Concerns

Plans and planning decisions must reflect the values of local communities on the use and development of resources...
Bob Graham and David Pitts - 1998

In lodging formal objection to the proposed development, SFA has the following specific concerns:

• There has been significant community anger and objection to the development.  This objection has stemmed from a wide range of social and environmental issues that have not been properly addressed by the proponent.  We recommend that the Shire consider the local community as the major stakeholder to any form of governmental decision-making process.  Aligned with local community response to the proposed development, SFA recommends that the Shire of Busselton refuse to grant approval to the proposed development.

• There has been a significant flaw in both the process and application of the [Draft & Final] Leeuwin-Naturaliste Ridge: Statement of Planning Policy ('the Policy').  It appears that the proposed development is in conflict with the planning intent of the Policy, whereby the nature and scale of the development will have significant adverse impact upon the social and environmental integrity of the subject site and surrounding area.  The local community have also expressed concern and anger over this element of the planning and development process.  For this reason, SFA recommends that the Shire of Busselton refuse to grant approval to the proposed development.

• Upon an evaluation of the community participation process - and the claim of extensive community consultation - a principal conclusion suggests that the local community was not kept appropriately informed of any specific detail of the proposed development.  While statutory requirements for community consultation might well have been adhered by, it is hardly representative of best-practice methods, given the significant impact of the development upon the local community.  The role of community participation has been largely tokenistic.  The response of the Shire to community concerns has been largely reactive and adversarial.  For this reason, SFA recommends that the Shire of Busselton refuse to grant approval to the proposed development.

• The proposed development is highly inconsistent with the environmental values of the subject site and surrounding area.  There is a potential for there to be significant adverse social and environmental impacts associated with the proposed development.  These impacts relate to both the construction and operational phases and will compromise both the local environment and the existing culture that is currently enjoyed by the local community including important lifestyle elements such as natural beauty, visual amenity, and access to the coastline and uncrowded surfing conditions.  These elements are integral to the quality of life of the local community and visitors to the area.  For this reason, SFA recommends that the Shire of Busselton refuse to grant approval to the proposed development.

• It is considered that the proponent has not adequately addressed a wide range of social and environmental impacts associated with the proposed development.  These include significant issues such as the impact upon public amenities, services, and infrastructure at a local and regional scale (e.g. Ambulance Service, Australia Post, Fire Brigade, Surf Life Saving Association).  Furthermore, there are serious concerns with traffic impacts; increased localised air, water, and noise pollution; and the impact of the energy and waste demand of the development.  There are also site specific impacts that are inappropriate, such as setback from the coastline, access to the coastline, and the potential need for vegetation clearing.  For this reason, SFA recommends that the Shire of Busselton refuse to grant approval to the proposed development.

• The approval of the proposed development will place increased pressure upon greenfield land in the Smiths Beach area.  For this reason, SFA recommends that the Shire of Busselton refuse to grant approval to the proposed development.

Given the serious shortcomings of the proposed development, SFA recommends that the Shire of Busselton refuse to grant approval to the proposed development.  SFA suggests that the Shire improves facilitation of community participation in the decision-making process for coastal planning and management in the Shire.  SFA also suggests that the Shire re-evaluates its town planning objectives with respect to the need for the proposed development and its conflict with the social and environmental values of the subject site and its surrounding environment.