LEGISLATIVE COUNCIL COMMITTEE INQUIRY SUBMISSION
SUBMISSION…..MELBOURNE’S FUTURE PLANNING FRAMEWORK REVIEW
MEG is grateful to have heard of this review from Clifford Hayes (MLC Southern Metropolitan Region and we are surprised that DELWP didn’t send notice of the Review directly to us. We are also grateful to Mary Drost, Convenor of Planning Backlash. Mary forwarded this to all the residents’ groups in the network.
In our opinion this document should be called “just more of the same” rather than a “review.”
State Government Planning Reforms
We did not notice a reference to the recent ‘reforms’ to Planning made by State Government in this document….the reforms to which there was no community consultation, indeed not even consultation with local councils. Certain members of staff were consulted and had to sign confidentiality agreements.’ Surely these so-called reforms form part of the planning framework in which they are to operate and yet DELWP does not even mention that the ‘reforms’ give the Minister “unprecedented’ power and seem to be aimed at providing CERTAINTY for developers so WHY are these new powers not mentioned in a “Planning Framework Review.?’
There was no ‘engagement with the community’ over these outrageous invasions of our rights.
Regionalisation…..formerly known as ‘decentralisation.’
For some years MEG has promoted the notion of ‘decentralising’ the State’s population.
Strategically directed, incentive driven decentralization has been our mantra. This does not mean just nominating towns such as Geelong, Ballarat or Bendigo and having more transport between each of these centres to Melbourne. Doing this leaves Melbourne as the centre to which endless attention is paid. It means have a transport system that crisscrosses the State.
Big infrastructure plans should not just concentrate on what is proposed for Melbourne…such as that tunnel that has ground to a halt, a network of roads for Melbourne that, so far, has resulted in the destruction of so much green space, so many canopy trees that clean the air we breathe with the obvious effect of being a detriment to health. Combined with Local Councils’ efforts to FILL open space with STUFF this is a negative use of the ‘tax dollar.’
Big infrastructure plans should focus on building rail lines across the State linking regional centres with each other as well as with Melbourne, building tram lines in the regional cities, linking the regional cities with airports. This sort of thing is what regionalization is all about. If State Government made a real effort to be a government for the STATE and not just for Melbourne we could begin to see some hope of this city surviving.
Encouragement should be given to establishing manufacturing industries both in the regions and in Melbourne so that Victoria could become a centre for all of those things that are at present made in certain Asian countries.
Encouragement should be given to wealth accelerators. We cite the instance of the small company in W.A. that is experimenting with the notion of removing carbon from coal. The idea of offering incentives for manufacturing activities should be both city-based and region-based.
We should mention first that the Green Wedges do not have sufficient protection and this is a matter that State Government should deal with immediately.
No planning scheme (or ‘framework’) can continue to promote the wanton destruction of thousands of trees and fob off the protesters with that old perennial….”we will plant double the number of saplings.” All forms of Government say this forgetting just for the moment the number of YEARS it takes for a tree to develop a canopy that will start absorbing pollution, provide shade, counter the ‘heat island’ effect. Stonnington Council is as guilty of doing this as is State Government.
The push by Government for dense high-rise developments is a deliberate act of vandalism which is whimsically called ‘progress.’
We can find no mention of ‘ventilation’ in any of DELWP’s document and surely this matter must be dealt with in the light of our experience with COVID.
We can find no mention of the ‘flammable cladding’ scandal in the Review of the framework for “Plan Melbourne 2050.” Another issue that does not rate a mention.
With Melbourne’s population slowly decreasing due to COVID and more and more workers opting to ‘work from home’ now is the time to encourage a decrease in numbers for the city rather than putting forward a framework to handle an increase. State Government should grasp this opportunity and set out for the State a framework of development with environmentally sustainable objectives rather than spending an enormous amount of time and effort on producing yet another lengthy document filled with what has become known as ‘weasel words.’
In the category of ‘weasel words’ come such terms as……..
‘engagement with the community’… emerging character…. making Melbourne marvellous….. integrated transport…,,.liveability…..,,sustainability & resilience.
We have heard them all SO OFTEN…. We have even been guilty of using one or two of them at times.
State Government Departments such as DELWP could lead the way by using a new vocabulary as it develops new ways of developing the STATE instead of just more of the same only FASTER.
Initially the ‘zones’ provided the community with a degree of certainty. With the present Minister’s constant ‘watering down’ of the requirements of the zones such certainty is gradually being whittled away.
In the original legislation regarding ‘zones’ there was one glaring omission. There was, and is, no grading of Commercial Zones. It is all Commercial 1. A Small Neighbourhood Activity Centre can have the same level of development that is allowable in a Principal Activity Centre. This results in far too many anomalies and has resulted in
gross invasions of residential amenity in NRZ and heritage areas. This matter should be addressed.
Let us finish with an apt headline from The Age on October 12.2021
City’s new design mantra: Cut the ‘crap’
Planning scam, or should I say, planning scam juggernaut. The speed of so-called consultations for new development proposals is overwhelming democracy. No-one, except wealthy professional developers, with dedicated teams of staff, can keep up with the proposals. Maybe that’s the point. Still recovering from two recent surgeries, and on the heels of an unavoidable community organisation event, involving time consuming preparation and sequelae, I was looking forward to taking a break. I could see about 3 weeks of "clear sky" ahead of me, in which I could deal with an issue of mutual concern with my neighbour, do my tax return, prune the lemon tree, wash the curtains, and organise the hard rubbish for Friday. This feeling of relative freedom lasted about two days, before yet another "opportunity" for consultation from Melbourne Planning reared its head.
Or was it an obligation? This latest one involved a new parliamentary act about Public Land:
"Have your say and contribute to a project to renew Victoria’s public land legislation for the benefit of the community through the creation of a new Public Land Act." https://engage.vic.gov.au/renewing-victorias-public-land-legislation
I ran my eye over the document. The call for ‘streamlining’ and the reiteration of reassuring statements that ‘current tenures’ would not be disturbed, alerted me to the need to know what was going to happen to ‘future tenures.’ Of course, there was no clear information on that burning question. Just appendices talking about ‘sustainable’ use, to “enhance the natural, cultural, social, and economic values of public land.” Knowing that Victoria’s parliament always puts ‘economic’ values above environmental ones and any others, I did not like to think what the developers, who more or less run parliament these days, want to push through under the bleary eyes of community group members.
But this threatening document, albeit smiley-faced, is just the latest of many. Last year the Victorian State Government sought submissions on "environmental infrastructure for growing populations" and another one on "ecosystem decline," another on "A regional climate change adaptation strategy for Greater Melbourne," another on, "Waterways of the West Action Plan," another on, "Future of our forests". Making a serious submission is not just a walk in the park for a working person! Furthermore , these were highlights in an endless stream, which had begun as a trickle with a Plan for General Development (1929), then Melbourne Metropolitan Planning Scheme 1954: Survey & Analysis, and Report (1954), Planning Policies for Metropolitan Melbourne (1971), Report on General Concept Objections (1974), Metropolitan Strategy Implementation (1981), Living Suburbs (1995), and gathered into a torrent around the turn of the 21st century, with Melbourne 2030: Planning for sustainable growth (2002), A plan for Melbourne's growth areas , Melbourne 2030 Audit [2007-2008], Planning for all of Melbourne [May 2008], Melbourne @ 5 million [December 2008], Delivering Melbourne's newest sustainable communities [See Amendment VC68 (July 2010)], Plan Melbourne 2014, Plan Melbourne 2017 - 2050 (2017), Plan Melbourne Addendum (2019). As well as this there were vast new tollways to connect new suburbs that never should have been built, and VCAT was transformed from a low-key tribunal where people represented themselves at low cost, to a high-powered, development-biased kangaroo court, defiantly serving the legal and development industries. All this affected public land, and changes were often spear-headed by superficially innocent ‘bike-paths’, and new sports-grounds, which so-called ‘environmental groups’ would try to bludgeon through.
The Melbourne City Council gains community input via its website under the banner of "Participate Melbourne." I have participated a number of times, on behalf of community organisations. Most people probably never hear of these invitations to submit [to fruitless pain] but, if you belong to a community group, particularly if it is concerned with the environment, somebody will bring each “opportunity” to your attention.
Repetition is forcing me to question whether these "consultations" are actually wonderful opportunities for my ideas to be carried forward. More and more they amount to tedious homework exercises to keep me quietly beavering away at home, unpaid, alone at my computer, away from my friends, the books I long to read, and facing a deadline. Occasionally I will let one go by, as it might save me a week of my life, when I can catch up with my grocery shopping, mow the lawn (yes, I am lucky enough to have a little green patch), and clean the windows.
Mostly however, I am a fairly compliant "environmental activist," dutifully submitting or assisting others' diligent efforts. What happens to our high-quality work? Usually, we agree to it being visible to the public, so it has to be of a standard that we would not be ashamed of, and which will possibly bring credit to the organisation we are representing. Are we listened to? Not according to the late Paul Mees, in "Who killed Melbourne 2030."
“Mees (2003, 2007) criticises both the content ofMelbourne 2030and the process by which it was produced,arguing that both the consultation process and the commitment to sustainability praised by the strategy’s admirers were shams. Although there was a very extensive process of consultation, this was not allowed to influence the strategy, which was written in private by members of the Strategy Development Division. And the strategic directions involved only a rhetorical, rather than a real, departure from the policies of the previous Kennett government, which focussed on market-led residential infill and road-based transport. Mees (2003, p. 298) predicted that the strategy would not survive a change of government, as it had no legitimacy in the eyes of the public, and did not deserve to survive, as it lacked substance and rigour.” [...]
“A series of ‘strategic directions’ ranging from the trite (Direction 8: Better transport links) to the completely content-free (Direction5: A great place to be) was presented for public endorsement. When people agreed with these platitudes – as if there was an alternative: worse transport links, or a terrible place to be, perhaps? – the Department of Infrastructure then treated this as endorsement of its actual policies and proposals, which were never submitted for public discussion or approval. An additional round of consultation to review the draft was proposed early in the process, but then cancelled without explanation (Mees, 2003).” ("Who killed Melbourne 2030.")
These “democratic” opportunities are becoming a burden and a way of life. My feeling is that I, as a member of the public, am being consulted because something valuable to the community, and to our environmental health, is about to either come under attack or be radically changed in some way. The imperative to make a submission within a deadline, and with proposals and deadlines coming down the planning pipeline at ever accelerating speed, puts members of the community in an invidious position. If we don't make a submission, it will appear that we don't care or we are asleep at the wheel. It's almost as though, if, under our watch, the government authority stuffs up, we have only ourselves to blame. But this is not so. In Australia, we have three levels of government which should be responsible for protecting their constituents from unfair, unsafe, overly rapid, intensifying development.
This constant need for public consultation, however, would indicate to me that they are not governing in our interests. Governments should have access to whatever expert advice they need in order to avoid environmental damage, yet it seems they are powerless or unwilling to prevent environmental destruction, rural or urban. Is all this public consultation the "get out of gaol free card" for ministers and public servants nominally at the head of planning departments that have actually contracted out their responsibility to private developers?
We know from successive government environmental reports that the Victorian environment is in steep decline. At the end of the day, when there is no wildlife, no native forests, and no public urban parklands, do members of the last government delude themselves with this declaration, "We consulted the public, and they obviously wanted to live in urban deserts?"
Or are we seeing a ‘tick-boxes’ to satisfy the community consultation auditor, whilst really satisfying the demands of mafias and triads in property development, that have got their claws solidly into government and opposition?
The unreasonable pace of 'planning' abets destructive development by overwhelming democratic participation
This trend to overwhelming community groups and individuals committed to democracy, with avalanches of consultations, seems like part of a cynical plan. The key to it all is the unreasonable pace. Something similar was burlesqued in 1970 in a film called The Rise and Rise of Michael Rimmer. Politically agile polling expert, Michael Rimmer, finally extracts total power from the people by requiring them to engage in endless postal voting on trivial matters. They are so exhausted, that they finally vote to pass all power to Rimmer.
You can watch the movie on youtube here. Or you can watch Melbourne Planning. There isn’t much difference, although the film is funnier.
More information about The Rise and Rise of Michael Rimmer: https://en.wikipedia.org/wiki/The_Rise_and_Rise_of_Michael_Rimmer “The mysterious Michael Rimmer (Cook) appears at a small and ailing British advertising agency, where the employees assume he is working on a time and motion study. However, he quickly begins to assert a de facto authority over the firm's mostly ineffectual staff and soon acquires control of the business from the incompetent boss Ferret (Arthur Lowe). Rimmer then succeeds in establishing the newly invigorated firm as the country's leading polling agency, and begins to make regular TV appearances as a polling expert. He subsequently moves into politics, acting as an adviser to the leader of the Tory opposition, and then becomes an MP himself, for the constituency of Budleigh Moor (a reference to Cook's frequent collaborator, Dudley Moore), along the way acquiring a trophy wife (Vanessa Howard).
Relying on a combination of charisma and deception—and murder—he then rapidly works his way up the political ladder to become prime minister (after throwing his predecessor off an oil rig). Rimmer then gains ultimate control by requiring the populace to engage in endless postal voting on trivial matters. At last, exhausted, they acquiesce in one final vote which passes dictatorial power to him. Ferret attempts to assassinate Rimmer as he and his wife ride through the capital in an open-topped convertible, but fails and falls to his death. (1970 British satirical film starring Peter Cook, and co-written by Cook, John Cleese, Graham Chapman, and Kevin Billington.)
 “Plans” for Melbourne have been coming ever thicker and faster. You can read about them via the links below:
• Plan Melbourne Addendum (2019) https://www.planning.vic.gov.au/policy-and-strategy/planning-for-melbourne/plan-melbourne
• Plan Melbourne 2017 - 2050 https://www.planning.vic.gov.au/policy-and-strategy/planning-for-melbourne/plan-melbourne
• Melbourne's strategic planning history https://www.planning.vic.gov.au/policy-and-strategy/planning-for-melbourne/melbournes-strategic-planning-history
• Plan Melbourne 2014 https://www.planning.vic.gov.au/policy-and-strategy/planning-for-melbourne/melbournes-strategic-planning-history/plan-melbourne-2014
• Melbourne 2030 Audit [2007-2008]
• Melbourne 2030: Planning for sustainable growth (2002)https://www.planning.vic.gov.au/policy-and-strategy/planning-for-melbourne/melbournes-strategic-planning-history/melbourne-2030-planning-for-sustainable-growth
• Delivering Melbourne's newest sustainable communities [See Amendment VC68 (July 2010)] https://www.planning.vic.gov.au/policy-and-strategy/planning-for-melbourne/melbournes-strategic-planning-history/delivering-melbournes-newest-sustainable-communities
• Melbourne @ 5 million [December 2008] https://www.planning.vic.gov.au/policy-and-strategy/planning-for-melbourne/melbournes-strategic-planning-history/[email protected]
• Planning for all of Melbourne [May 2008] https://www.planning.vic.gov.au/policy-and-strategy/planning-for-melbourne/melbournes-strategic-planning-history/planning-for-all-of-melbourne
• A plan for Melbourne's growth areas  https://www.planning.vic.gov.au/policy-and-strategy/planning-for-melbourne/melbournes-strategic-planning-history/a-plan-for-melbournes-growth-areas
• Living Suburbs (1995) https://www.planning.vic.gov.au/policy-and-strategy/planning-for-melbourne/melbournes-strategic-planning-history/living-suburbs
• Metropolitan Strategy Implementation (1981) https://www.planning.vic.gov.au/policy-and-strategy/planning-for-melbourne/melbournes-strategic-planning-history/metropolitan-strategy-implementation-1981
• Report on General Concept Objections (1974) https://www.planning.vic.gov.au/policy-and-strategy/planning-for-melbourne/melbournes-strategic-planning-history/report-on-general-concept-objections-1974
• Planning Policies for Metropolitan Melbourne (1971) https://www.planning.vic.gov.au/policy-and-strategy/planning-for-melbourne/melbournes-strategic-planning-history/planning-policies-for-metropolitan-melbourne-1971
• Melbourne Metropolitan Planning Scheme 1954: Report https://www.planning.vic.gov.au/policy-and-strategy/planning-for-melbourne/melbournes-strategic-planning-history/melbourne-metropolitan-planning-scheme-1954-report
• Melbourne Metropolitan Planning Scheme 1954: Survey & Analysis https://www.planning.vic.gov.au/policy-and-strategy/planning-for-melbourne/melbournes-strategic-planning-history/melbourne-metropolitan-planning-scheme-1954-survey-and-analysis
• Plan for General Development (1929) https://www.planning.vic.gov.au/policy-and-strategy/planning-for-melbourne/melbournes-strategic-planning-history/plan-for-general-development-1929
Planning Policy, City of Melbourne, has recently solicited submissions and submissions about submissions ostensibly to establish guidelines for minimum sunlight for parks. Whilst it claims to be protecting the parks, it is obvious that it is really seeking to establish minimal sunlight rules so that it can continue to add to the bristling thicket of skyscrapers that is presently engulfing the city in shadow at the behest of the property development and immigration lobby/state government and town hall. We attach a submission from the Secretary of Protectors of Public Lands Victoria on sunlight and public parks. It's a fairly simple matter, but can be made complicated. There has been one round of submissions. Now there is a call for verbal submissions on those submissions  and for an 'independent' committee to evaluate those submissions, presumably until the opposition to sunlight-theft falls away from exhaustion in the face of the well-paid forces of darkness. [Ed. See update here: /node/5934"]
Overshadowing policy for parks in the city of Melbourne-Amendment 278 SUBMISSION from Protectors of Public Lands
To: Robyn Hellman, Planning Policy Coordinator, City of Melbourne, GPO Box 1603, Melbourne, Victoria 3001. [email protected]
I write on behalf of the Protectors of Public Lands to endorse the MCC [Melbourne City Council] amendment to increase protection of parkland from overshadowing. As stated in the guidelines, winter sunshine is vital for human health and people must have maximum access to this amenity in public parks.
This necessarily means that construction of high buildings in the vicinity of parks must be tightly controlled. With past and ongoing very rapid population growth the accommodation of the population in apartment living with no private open space increases the need not to encroach on useable public open space. Melbourne's liveability has already deteriorated significantly over recent decades with densification of living especially close to the city and anything the MCC can do to stop further deterioration with respect to our parks is most valuable.
In winter people will avoid shaded areas, which naturally concentrates usage of a given space in the more pleasant sunny areas. With increased population this effect is further increased. More shade can change microclimates and make once suitable vegetation unsuitable to new conditions in shadow. This can adversely affect other biota such as birds, animals, insects and microbial life in the area.
Our parks need protection from overshadowing as proposed in Amendment C278 and also from the visual effect of tall buildings near parks. Part of the calming effect of being in a park is the illusion of isolation and the visual pleasure from seeing an uncluttered sky. I mention this because the effect of surrounding buildings is not solely about overshadowing. A building to the south of a park and close to it may not overshadow but it over arches, reducing the restorative qualities of the park of which the view of the sky is part. Additionally the light at night from tall buildings close to parks reduces the darkness which is part of the natural pattern that parks should be able to claim.
The council's recommendation in parks designated "type 1" for "no additional shadow onto the park between 10.00a.m. and 3.00 p.m" is realistic, and very desirable .
Protectors of Public Lands would like to see this standard applied to all the parks that have been assessed for this exercise.
It is obvious that there is a conflict between maintaining current amenity and the push for growth and building of high rise accommodation. This should be resisted to the extent that all the precious parkland in the municipality is preserved with the current level of amenity.
The parks designated type 2 "no additional shadow onto the park between 10 a.m and 3 p.m. on June 21st beyond the existing shadow or allowable shadow (whichever is the greater) " allows for added overshadowing. MCC should fight to preserve current amenity even if it means battling the planning system with respect to allowable heights in order to do this.
In the case of parks type 3 "no additional shadow onto the park between 10 a.m. and 2 p.m." This standard should be extended to 3.00pm.
MCC has one chance to save its local parks and now is the time to stop further deterioration of the quality and amenity of these important places. A park without sunshine in winter is cold and has little appeal. This applies to the affected part of the park at the time it is overshadowed and once overshadowing occurs is unlikely ever to be undone.
Protectors of Public Lands
Re: Melbourne Planning Scheme Amendment C278-Sunlight to Parks
Amendment C278 proposes to protect winter sunlight in our parks with new planning controls.
I would like to advise you that Council’s Future Melbourne (Planning) Committee will be considering submissions received during the exhibition of Amendment C278 and whether to request the Minister for Planning to appoint an Independent Panel to consider all submissions received. The details of the meeting are below:
Date: Tuesday 4 February 2020
Venue: Council Meeting Room, Level 2, Melbourne Town Hall
“This is where we have got to with government-engineered breakneck population growth that also puts property developers and associated professions in charge of planning. 110 golf-courses, which occupy green, treed spaces, in all kinds of areas in Melbourne and its suburbs and another 374 in Victorian regions, now carry hugely increased potential resale value if speculators can get them rezoned for more intensive use. Predictably, golf-course owners and probably management committees are now complaining that they aren’t making enough money. Some of their complaints will be well-founded, because state-imposed population pressure has caused demand for land, water and power, hence their costs, to rise rapidly. If nothing is done, either to reduce population growth, or exempt golf-courses from paying these charges, they will skyrocket.” (Sheila Newman, Population, environment and land-tenure systems sociologist.)
After a 2017 discussion paper that not many of us heard about, the Department of Environment, Land, Water and Planning, has again discreetly invited people to provide feedback to draft guidelines for their Golf Course Redevelopment Standing Advisory Committee, which is composed of property development industry professionals
SUBMISSION IN RESPONSE TO PROPOSAL FOR GOLF-COURSE REDEVELOPMENT
by Sheila Newman, Population, environment and land-tenure systems sociologist.
Redeveloping golf courses and land-speculation:
This is where we have got to with government-engineered breakneck population growth that also puts property developers and associated professions in charge of planning. 110 golf-courses, which occupy green, treed spaces, in all kinds of areas in Melbourne and its suburbs and another 374 in Victorian regions, now carry hugely increased potential resale value if speculators can get them rezoned for more intensive use. Predictably, golf-course owners and probably management committees are now complaining that they aren’t making enough money. Some of their complaints will be well-founded, because state-imposed population pressure has caused demand for land, water and power, hence their costs, to rise rapidly. If nothing is done, either to reduce population growth, or exempt golf-courses from paying these charges, they will skyrocket.
The proposal is outrageous, of course. It is outrageous in scale, in potential irreversibility, in lack of statistics, and in lack of adequate notification of all Australians that something so huge is in train. If a government can provide wide, ongoing promotion of the dangers of bowel cancer, it could have reached more people on this.
It is also outrageous in the impossibility of most Victorians to find the time to contextualise, assess, and reply to the proposal, even if they knew about it.
It is notably shocking in its potential costs to environmental quality and diversity for all Australians.
It is especially outrageous in its potential strategic profit-grabbing by the property development and construction industry, which has positioned itself with government to generate focused benefits in demand from the massive population-growth engineering it has lobbied for so successfully and undemocratically. In the game of mates, the property developers and the state government (which has become dependent on stamp-duty in lieu of a real economy) are organised to receive the focused benefits, but the public will pay – and not just in dollars - the diffuse costs of this massive expansion and intensification.
This proposal, which flags a copious series of case-by-case fights over rezoning golf-courses for development, is a fine example of the kinds of diffuse and hard to identify costs that the public will bear if this goes ahead. The proposal would require Melbourne’s increasingly socially precarious population, already severely stressed by constant change, to endlessly monitor what is happening to golf courses along with all the other continuous development.
We should have the ability to reject out of hand such proposals all at once, in a job lot.
We should not be expected to devote our lives to fighting to keep what we have, against people who are supposed to be protecting it on our behalf.
Who, except developers, who are networked, resourced and organised at national, state and local level, could find out where all the golf-courses are and then attend, in person or by proxy, all the hearings and reviews, and engage in all the processes, that a Golf Course Redevelopment Standing Advisory Committee would apply to each of them? Who else could afford to do this? Who else controls the process?
On the technical side, these ‘planning guidelines’ lack adequate recognition or an overview of the huge natural benefits of relatively undeveloped land. Golf courses have important uses other than golf – as habitat for birds and other fauna, for climate stability, and for the green relief they provide from densely populated spaces. I personally prefer natural landscapes with native plants and animals to golf-courses, and I prefer landscape painting and bird-watching to golfing. Nonetheless, I can see that golf courses are much better for ecology and environment than buildings, roads, and other intensified land-uses. Melbourne, which was planned with large avenues and many green spaces, now lacks green spaces and is choked with traffic. Unfinancial golf-courses, if they cannot be made financial (see further on) should be returned to nature, to provide scarce habitat to our native animals and contact with nature for humans. These golf-courses often got by on the pretext that they would preserve open land and some habitat in the form of golf courses, as a trade-off for more development. “Since 2000 around over 10 new golf courses have been established as the centrepiece of high-end residential developments in Victoria.” No surprise if they want to develop it now.
Golf courses per capita and Victoria’s population juggernaut:
Given that the Victorian Government intends to keep inviting people to come and live and work in Victoria, anticipating doubling and redoubling of the population, if Victoria has more golf-courses per capita than other states, it will need them, for golf or for return to nature.
The situation is particularly dire for birds – they really need golf-courses. Australia is a land of birds; we have the most extraordinary range. Doesn’t anyone in planning know of our amazing evolutionary history? It is world famous! The majority of the world’s bird species started here, notably perching birds and song-birds. Humans who are able to hear and see birds deeply enjoy this experience, which seems to become more important as they get older. Bird-watching is an extremely popular activity in Australia. Birds Australia has multiple branches and a busy membership. Does the property development lobby/government really want to be responsible for wiping birds out in more and more places, and removing our age-old relation with them? Although birds are equipped to survive in many circumstances, able to move in search of water and food, massive population growth-fuelled development is transforming the sparse green fringes of this land into a hard-surface desert.
The situation for birds in the South East Region of Australia – Melbourne and Victoria – is increasingly difficult. Birds that require nesting hollows are devastated by the destruction of trees. ‘Common’ much-loved species like kookaburras, magpies and willy wagtails are now struggling, and shorebirds are in steep decline. Golf-course land, because it is not intensively used and retains trees, is a vital resource for birds. There are golf-courses in just about every kind of habitat, including near sea-shores.
Reward golf courses for their environmental services:
With regard to strengthening the viability and continuity of golf clubs, governments should reduce or remove the rates paid for land, water, and power, for golf courses (and any other undeveloped land). The government could pay golf-course owners for mitigating climate change and urban island heat effects through their green spaces. Developers should be levied for this purpose in order to compensate the damage that they do.
Development, with its land-clearing and massive use of materials and energy, as well as creating huge carbon emissions, creates clumps and blocks of aggregate dead material. This is hard for organisms to break down, and incapable of re-ordering and reproducing itself. Living things, however, are the only things that can actually reorder energy and materials, in the acts of ingestion, reproduction and cellular repair. The exception here is ‘modern’ human life, because humans come with more and more dead stuff per capita, in the form of roads, buildings, cars, and other consumables. Hence, we need more golf courses, or to return them to nature, more natural spaces, trees, forests, and healthy water bodies to support the organisms and ecologies that can clean up our synthetic concretions.
In this regard, the current economic model which taxes land in order to induce profit-making activity on it, is now a liability. It needs to change in order to promote natural land. State Governments have to get over their addiction to stamp duty. Otherwise, all this land will disappear under tar and cement.
Redevelopment is a bad thing for golf-courses. We have too much development now, and too much human population growth. Any golf-courses that are going to be abandoned as such, should be returned to nature.
No Re-zoning and prices capped:
Government may need to buy this land from owners of golf-courses who do not want it, and this is a major reason why this land should be excepted from rezoning possibilities. Overpopulation has already drastically overpriced land in Melbourne, even if it is not zoned for development. This makes it difficult and often impossible for local governments to purchase it in order to preserve natural space for Australians. This is why golf-course land and other relatively natural land must not be alienated from its low-use zoning. It must be taken out of the insane speculation cycle, for the thermodynamic reasons stated above as well as the social ones. Speculative gains are not a citizen’s by right.
Sports grounds and Playgrounds:
The ‘guidelines’ have also skewed the idea of open space with social, ecological, and environmental benefits to something always involving some infrastructure, such as ‘playgrounds’ and ‘sports grounds’. It is a form of regimentation as well as an unnecessary kind of capitalisation. As I have intimated, people can enjoy natural surroundings just by walking, and these places can provide habitat for our native animals. They already provide bio-links or wildlife corridors. Any further ‘development’ would reduce the size and viability of these bio-links, which should be increased and consolidated.
Hospitals, affordable Housing etc:
If we have to put hospitals on golf course land then we should realise that we have gone too far in our population and development paradigm. Unaffordable housing and homelessness have increased as Australia’s population has grown, especially from 2009 with massively increased its overseas immigration. Once again, unaffordable housing is a sign that we should interrupt our population and development juggernaut.
The Composition of the Planning Committee lacks diversity and disinterest.
There are no ordinary people on it who do not have deep involvement in the commercial property development industry. One of them was the secretary of population growth-lobbying APop from about 1999 to 2015. For this reason the Committee should not have the power to say whether or not a golf-course may be considered for development. A cross-section of ordinary people should be able to decide this on a case by case basis. Only after this, in the unlikely event that such a democratic cross-section felt that any golf-course could be let go for development, it might be passed on to the Committee for more technical assessment.
The documents for this golf course redevelopment proposal have rationalised the closure of golf-courses largely in monetary terms, especially noting that some were not making a profit. The proposal seems to have attempted no education of the public on the main reason why, which is that state- engineered population growth had raised the costs of land and water involved in running golf-courses, thus narrowing their profit margin, and making it tempting for them to cash their land in. It is also suggested that people are not playing golf as much as they used to. We are not told why this is, although the 2017 discussion paper suggested that ten new golf courses that established themselves as centrepieces of high-end residential developments in Melbourne, had added to an oversupply. The development industry runs VCAT planning; it authorised those developments. It should return that land to nature. Many other possible reasons present themselves – changing demographics, difficulty in travelling due to congestion, increased fees, subtle discouragement of golfing by owners wanting to speculate, overwork among the financial, and poverty among the unemployed. The point is, we should not allow the developers or the government to goad us into a situation where land-availability becomes so desperate that it must be constantly used and attract a high financial return.
Low standards in the development industry:
As for redevelopment and the construction industry: The cladding crisis has highlighted the long-known fact that our construction and development industry is largely incompetent, unaccountable, and uninsurable. With respect, it seems quite remarkable that the same industry thinks it should get golf course land or do any more building at all, let alone continue to be in charge of major decisions in Victorian planning.
This golf course redevelopment proposal is very important. It flags a major danger-point that we have reached, preparing to sacrifice something Australians have counted on – natural land. It shows what happens when a government engineers break-neck population growth and then puts property developers in charge of planning. All natural spaces are threatened. The fewer green spaces there are, the more their potential price for resale as developments increase. If you have planning outsourced to developers, as we do in Victoria (and all States) you will finish up with no green spaces, no birds, no native animals, and hugely priced high-rises.
Democracy and the pace of change:
The massive population-growth engineering that our governments/growth lobby are carrying out, with their push for infrastructure and housing, is breaking our democracy. The pace of change is undemocratic because it is impossible for people to effectively engage, let alone democratically participate, and this juggernaut has been set up by an industry that invests all its time in it for massive profit. There is no way that people with normal responsibilities can keep up with what is happening, even when they desperately want to. Elected members of parliament cannot keep up with this either. In Sleepers Wake, Barry Jones MP warned of the danger that we were heading to a time when government would outsource things it could not understand to a technocracy and that is part of what is happening here.
I personally had no desire to make a submission, but I feel I must, if only so people can read my reasons. Just reading the material provided by DELWP was enough to give me nightmares, because I know that DELWP has the bit between its teeth. The property development, infrastructure, and population growth lobby inside and outside of government is waging war on the rest of us in their quest for personal profit and power. The only difference is that they are using bulldozers instead of tanks.
 I am a population, environment and land-tenure systems sociologist. I completed a 143,000 word research thesis called The Growth Lobby and its Absence in 2002 on the difference between the Australian and French systems for housing, land production and policies on environment and population. Since then I have edited two editions of The Final Energy Crisis, Pluto Press, 2005 and 2008, a book of articles by different scientists on the subject of the future of energy resources. I have also written two volumes of a planned four volume series entitled Demography, Territory, Law. The titles published so far are Demography, Territory, Law: The Rules of Animal and Human Populations, Countershock Press, 2013, and Demography, Territory, Law2: Land-tenure and the origins of Capitalism in Britain, Countershock Press, 2015.
 “Notification was given via letter or email to all golf facilities, local governments, industry bodies such as Golf Victoria as well as all people and organisations who made a submission to the Planning for Golf in Victoria Discussion Paper released in 2017. For more information (and access to the 2017 discussion paper itself) on the Planning for Golf in Victoria process please click here. This process was also publicised on the Engage Victoria website.” Source: Personal correspondence with Michael C. Everett of DELWP. My criticism is that this notification went to local governments and industry bodies and boards in golf, who would not necessarily have passed it on, and who would probably not have looked at or communicated the wider impact of the loss of such spaces to all of Melbourne. Notification did not go to the wider population that will be impacted, or to wildlife networks, such as Birds Australia.
 Stamp duty income for the Victorian Government was $1.284b in 2001/2 and only 17 years later it was $6.933b in 2017/18. Source: https://www.sro.vic.gov.au/land-transfer-duty-stamp-duty-statistics
 James Q Wilson in Wilson, J.Q., ed., The Politics of Regulation, Harper, New York, 1980,) classified four types of politics depending on whether the benefits and costs of policies were concentrated or diffuse, and he applied this model to immigration politics. In this way, mass immigration has become entrenched in systems where its benefits are narrowly focused but the costs that it imposes are diffuse (and therefore not easily identified by the public that is paying for them). Narrowly focused benefits mean that those benefiting from immigration are consciously aware of this and are able to recognise each other and organise to keep those benefits flowing. Where costs are diffuse and fall upon a disparate population at many different points in many different ways, they are difficult to identify and there are no obvious political rallying points for the public to organise a protest around. I used this methodology in my research thesis, Sheila Newman, The Growth lobby in Australia and its Absence in France, 2002. https://researchbank.swinburne.edu.au/file/a3115a39-c50a-4504-8d1f-4aca21be26fd/1/Sheila%20Newman%20Thesis.pdf
 “Planning for Golf in Victoria Discussion Paper (2017). https://engage.vic.gov.au/download_file/3592/907
 State of Australia’s Birds, 2015, Birdlife Australia, 2015; Threatened species recovery hub, National Environmental Science Program, https//www.nespthreatenedspecies.edu.au/news/gimme-shelter-conserving-hollow-nesting-birds
 Tim Low, Where Song Began: Australia's Birds and How They Changed the World, Penguin, 2017.
 State of Australia’s Birds, 2015, p. 11.
 Excerpt from “In the end: Thermodynamics and the necessity of protecting the natural world, Chapter 23 in Sheila Newman (Eds), The Final Energy Crisis, 2nd Edition, Pluto Press, 2008. See most of the article below:
“Humans already use most of the land on the planet. In many places in the world the competition is between the land-poor and the land-rich. This is a political problem which needs to be solved without further trashing the natural environment. Some systems are more equitable than others and, as discussed in other articles in this volume, the Anglo-Celtic system used in most English speaking countries is worse than most. We humans have to share the land we already have more equally with each-other. If we insist on growing our population then the competition for land will be increasingly severe. We have already taken enough from other creatures and need to give some (a lot) back. Land for wildlife is not a luxury. The perception that it doesn't 'do' anything needs scientific countering with a thermodynamic explanation. That explanation is that Life is the only force that can reorder spent energy.
The First Law of Thermodynamics states that energy cannot be created but is never lost. However the Second Law of Thermodynamics states that energy is transformed by use and that you can never make it how it was before. (You can't have your cake and eat it.) Industrial society provides a good example in biological energy (food) with the idea that a machine can make a sausage out of a pig, but it cannot make a pig out of a sausage. Once you have turned the pig into sausage for human consumption the energy in the sausage will never be pig again. It will be human waste. The passage of the cake or the pig into something less coherent is part of the usual flow of chemical and physical reactions in a process known as ‘entropy increase’ or a tendency to ‘disperse’.
Otherwise the planet and the atmosphere would be completely filled with sludge and debris. This is the way that ecology and the life-cycles that make up an eco-system are able to temporarily make order from disorder. Industrial manufacturing can grossly restructure dead things, but life is the only process that is able to do this efficiently, keep the process going, and reproduce itself.
Of course if you feed a pig a pork sausage, some of that sausage will become pig again. Most people would see, however, that converting a pig into a sausage through an energy intensive industrial process and then feeding the sausage back to a pig so that the sausage contributed to a miniscule portion of pig-flesh is a pretty inefficient way to make pigs. Nonetheless pork sausages and many other processed foods do find their way back to pigs' troughs. This is quite illustrative of the circular and needlessly wasteful (and cruel) cycles that occur in consumer-industrial societies.
Modern human societies are in fact quite different from those of pre-fossil-fuel human societies and those of other animals.
We modern humans no longer just produce animal waste that is 'biodegradable' in a normal ecological cycle. Through extractive technologies we have artificially extended our bodies and amplified our activities, so that we consume quite enormous quantities of material and energy. In the process of digging up the materials and burning the energy to make things with, we also clear almost every other living thing in our paths. The waste carbon, nitrogen, phosphates, sulphur and other products which our artificial system puts out largely overwhelm the services of the remaining (shrinking) natural eco-systems. Yet the natural eco-systems are the ONLY agents capable of saving us from being buried, suffocated and burned by the physical and chemical interactions of our industrial-society waste.
That is how the second law of thermodynamics can be used to explain why it is vital to allocate increasing space to natural processes. Returning land to wild grass and forests and giving animals their freedom to live naturally is the most positive thing that we humans can do about the accelerating rate of planetary entropy that consumer society multiplied by huge human populations is causing. Entropy comes in the form of increasingly unpredictable climate and in broken, dead and dying eco-systems. [...]”
 Geoff Underwood (who chaired the Victorian Planning System Committee 2011) was the Secretary of APop, (the Australian Population Institute) from 2000 to at least 2015. This was an organisation with the sole aim of vastly increasing Australia’s population, and almost entirely officiated by property developers who had the money and clout to aggressively promote this. Ordinary Australians had no ability to combat this organised input to policy and media. APop has largely been replaced by the Property Council of Australia, of which several government departments are members, and which, in 2009, announced to its members via a Powerpoint display that its number one aim was “More political influence.” It seems to have achieved this.
 See Anne Paton, of Victorian Building Action Group (VBAG) on the long history of bad building and its costs: https://youtu.be/zsyyVILjGpE. Also see Nerrida Pohl on cladding: https://www.youtube.com/watch?v=LFVNL8rV_ZQ .
“Since July 2002 there have been 54 separate reviews of the building industry, including by the Victorian Ombudsman and the State Auditor-General, all pointing to serious shortcomings and all calling for reform.” Clare Kermond, “When your dream becomes a nightmare,” The Age, August 16, 2015.
[Candobetter.net Editor: This submission was made available as a pdf attachment to an earlier article. It is such a useful document that we have converted the pdf version to a web document for easier reading.]
Submission in response to the issues paper on Managing Australia’s Migrant Intake
Peter G Cook, MA PhD
2 February 2018
It is commendable that the Australian government, through the Department of Home Affairs, is seeking to broaden its consultation with the Australian public about the future shape of Australia’s migrant intake. This is consistent with Recommendation 3.1 of the recent Productivity Commission report  , Migrant Intake into Australia, that:
The Australian Government should:
• develop and articulate a population policy to be published with the intergenerational report
• specify that the primary objective of immigration and the Government’s population policy is to maximise the economic, social and environmental wellbeing of the Australian community (existing Australian citizens and permanent residents) and their future offspring.
Australia’s immigration and population policy should be better informed through:
• genuine community engagement
• a broad range of evidence on the economic, social and environmental impacts of immigration and population growth on the wellbeing of the Australian community
• a published five yearly review of Australia’s population policy.
The Australian Government should calibrate the size of the annual immigration intake to be consistent with its population policy objectives.
It is to be hoped that this current Departmental consultation is just the first step towards implementation of the remaining parts of the Productivity Commission’s Recommendation 3.1. In particular, towards the ongoing development of an explicit population policy which would draw upon a wide range of input and evidence from government, the community, other stakeholders and experts. As the Commission points out in Finding 3.1, Australia has low and stable rates of natural population growth, therefore “decisions about the size of the permanent and temporary immigration intake amount to a de facto population policy.”
If migrant intake planning is not integrated with a broader, systematic and explicit focus on population policy, then planning for migrant intake is not doing justice to the great importance which this matter holds for the national interest.
The following brief comments may be of interest in the Department’s consideration of the questions which it has raised in the issues paper. I have organized the comments under some of the relevant questions posed in the issues paper. I draw considerably upon the Productivity Commission’s report because this is a major work of synthesis which draws upon a large range of expert evidence and community input. While I do not necessarily agree with all of the Commission’s conclusions, it is vital that this report be closely studied within government and that its major findings and recommendations (eg Recommendation 3.1) be acted upon.
Underlying my comments throughout is the following policy prescription which represents my viewpoint, and which I commend to the Department:
Australia must stabilize its population at less than 30 million people. This can be done through a gradual tapering of our net overseas migration towards zero. This could be initiated by an immediate reduction, by some twenty thousand, of the annual migrant intake from its current level of 190,000. Further reductions could be implemented over time to a point where intake is approximately equal to annual emigration – previous estimates have suggested this could be approx. 70,000 places, which is also considered to be around the historical 20th century average annual intake.
1. What factors are important to consider in planning the Migration Program over the next five years? Would those factors change over the next 10 or 15 years? If so, how?
If by ‘factors’ it is meant something like ‘goals’ or ‘criteria’ for assessing what size the migrant intake should be, then the key factors are:
- The quality of life (well-being) of the Australian people, in particular a quality of life that is not continually being degraded as it is presently by increasing congestion and deteriorating infrastructure in our main cities, due to high levels of immigration-fuelled population growth.
- The price of housing is surely a key factor for both the quality of life and standard of living of Australians. In its Finding 7.1 the Productivity Commission reached the unambiguous conclusion that: “High rates of immigration put upward pressure on land and housing prices in Australia’s largest cities. Upward pressures are exacerbated by the persistent failure of successive state, territory and local governments to implement sound urban planning and zoning policies.”
- The continuing destruction of ecosystems (habitat for human and non-human creatures) and agricultural land in Australia’s urban fringes, caused by urban sprawl. This may not necessarily be caused directly by immigrants but it is caused by immigration-fuelled population growth. This destruction needs to be much more closely controlled, if not called to a complete halt.
- The alternative to continual expansion of housing outwards into peri-urban areas – namely inappropriate infill projects that destroy traditional urban and suburban neighbourhoods – is equally unacceptable. For a perfect example of such ugly and inappropriate inner city development, look no further than the inner suburbs of Brisbane such as Newstead, Fortitude Valley and West End, where 20 or 30 story (and higher) high rise apartments are being packed together like so many upended and oversized shipping containers. Urban infill must also be reduced and much more tightly controlled for aesthetic, amenity and sustainability reasons.
- The Productivity Commission report also noted that: “Population growth also increases the pressure on environmental services where these are major inputs into the provision of a range of water, sewerage and sanitation services. These too can be resolved by investing in more technical solutions, adding to the cost of living.”
For each of the above criteria, the indicators are going backwards: more congestion, more crowded amenities, higher housing prices in the biggest cities, unsightly and shabbily built high rises, higher costs for environmental services and, finally, destruction of biodiversity and vital agricultural land.
The Productivity Commission report clearly recognized the population pressures that Australia’s current high levels of immigration places upon our cities and our environment, and concluded that “Without substantial change in policy settings and the effectiveness of government action, high levels of population growth will impose adverse impacts on the quality of Australia’s environment.” (p. 333)
2. How can we plan migration to ensure it is balanced to manage the impact on the economy, society, infrastructure and the environment in a sustainable way?
At the risk of being repetitive, the only hope of ‘planning migration’ to manage the impacts mentioned, is to make the planning part of the development of a population policy which is well-integrated into the machinery of government at all levels in Australia. The purpose of a population policy is to enable the setting of objectives for Australia’s future, and in particular:
(a) What is the ‘absorptive capacity’ (to use the Productivity Commission’s phrase) of our natural environment and social infrastructure to accommodate further population growth?
(b) what should be the size of our population in order to keep at or (preferably) well below this absorptive capacity, and still enable a reasonable level of well-being for all of us human inhabitants along with all the other creatures with whom we share this planet?
It is probably obvious, but perhaps still should be stated, that population policy assumes that the size of a country’s population is, in fact, under the control of the inhabitants of that country, at least to some degree. This would seem to be a reasonable assumption, particularly in the case of Australia, where the level of population growth can be altered by a simple administrative decision made annually – namely what is going to be the prescribed migrant intake for the coming year. This decision need not cause the sort of angst about interfering in personal reproductive decisions that might be the case if the decision was about trying to influence the rate of natural population increase in Australia.
And yet, despite this seeming to be a no-brainer, governments have, in the main, shied away from developing population policy. In doing so they have committed Australia to a default policy of unending population increase, driven overwhelmingly by those special interests who can clamour the loudest to seek the spoils from, for example, the unending subdivisions of land and construction of new ‘development’ required to meet new population-driven demand.
By refusing to entertain discussion about possible constraints to unending population increase, there is an absurd scenario where Australia could continue growing at the same rate of increase until it reaches 100 million people, or 200 million people, and beyond. Although there are some players (eg wealthy property developer Harry Triguboff) who actually hope for this scenario of not merely a ‘big Australia’ but a ‘gigantic Australia’, is this scenario actually what the government, or indeed most of the Australian people, wants? If not, then wouldn’t it be wise to develop a population policy which explores what the Australian community does want?
This is where the Productivity Commission’s report makes a critical intervention in calling for an injection of democracy into the whole area of migration planning and population policy:
…decisions on the migrant intake should be part of a transparent population policy based on well-informed engagement with the Australian community so that the policy reflects the preferences of the broader community as well as businesses. (Migrant Intake into Australia, p. 244)
Not only do I totally concur with the Commission’s assessment on this point, but also with its scepticism that the current operation of our parliamentary democracy is serving us well when it comes to migration and population issues:
Consistent with a large body of political economy literature, the opinion of many participants … is that Australia’s system of parliamentary democracy has an in-built predisposition towards ‘hearing’ from certain stakeholders (who typically have a vested interest and are well organised). In contrast, members of parliament are less likely to ‘hear’ from affected constituents for whom the effect of a policy change is individually small, but is large when added up over many constituents. The debate surrounding tariff reductions is one historical example of this type of imbalance. Debates surrounding immigration and population policy may be subject to a similar imbalance. (p. 106)
The Commission goes further, to politely highlight the fact that the ‘incentives’ for the various stakeholders are not ‘aligned’. There is a key difference between the incentives of:
businesses who benefit from the increased supply of labour and, with this, demand for their goods and services, and [the incentives of] members of the community, as reflected in the large number of submissions raising concerns about house prices, congestion, and other environmental impacts. Even if all of the concerns raised are not proven, these views do need to be taken into account in setting the migrant intake. (p. 243)
Had it been published at the time, I wonder whether the Commission could also have made good use of the cogent arguments and evidence presented by Cameron Murray and Paul Frijters in their book Game of Mates (2017)  , which lifts the lid on the way the decisions of various levels of government are used to distribute the spoils of property development and other industries to those ‘in the know’. This is not necessarily by means of overt, legally definable corruption (although it can be) but more a revolving door system of mutual back-rubbing in which everyone in the know wins a prize.
So in summary to answer question 2: For all of the above reasons, particularly dominance by large special interests and the existence of decision making processes at all levels of government that are lubricated by the circulation of rewards to a limited number of insider ‘players’, the Commission’s recommendation 3.1 must be implemented in full. That is the only hope we have to ‘plan migration’ to ensure it is balanced to manage the impact on the economy, society, infrastructure and the environment in a sustainable way.
3. How can governments, industries and communities help ensure infrastructure and services best support migration as well as the broader population?
i. Do you think migration is currently being planned with a sufficient view of Australia’s long-term needs?
ii. If not, how could these considerations be better incorporated?
In short, the answer to (i) is a definite no. But to go back a little, the phrasing of the main part of question 3 is a little strange in the way it seems to put support for migration ahead of the general population, when you would think it should be the other way round.
Be that as it may, we can draw again on the Commission’s report to highlight that Australia’s infrastructure and services are patently not keeping up with increasing demand generated in large part from immigration-fuelled population growth.
The Commission issues a number of devastating judgements on this matter, including its Finding 7.1 (above) which refers to “the persistent failure of successive state, territory and local governments to implement sound urban planning and zoning policies.” The Commission also notes that, “[a]s past Commission reports have identified, state, territory and local governments have not always distinguished themselves in managing the environmental implications of population growth.” (p. 239)
This is a matter of obvious frustration for the Commission, which patiently (re)explains that:
..it is important that there are appropriate coordination and governance
arrangements in place to help deliver better planning outcomes. Although as has been noted previously) coordination is strong in some planning areas, it is weak in others (PC 2011f). The Commission enunciated principles of good governance — transparency, accountability and responsibility, and capability — as part of its inquiry into public infrastructure (PC 2014c). The recommendations made by that inquiry remain valid, and in view of the population pressures created by immigration even more important. High immigration rates only reinforces the need to get planning right, and attention to the ability of cities to absorb immigrants should be part of the consideration in determining the migrant intake. (p.241)
The Commission tends to have a predilection for market-based solutions for many of these planning issues – something of which the present author is not so readily persuaded – but it is interesting that the Commission also seems sympathetic to a proposal that:
clear and enforced outcome-based codes and standards that apply suburb wide and can be assessed by a builder, surveyor or consultant should replace the more lengthy and often discretionary local government processes or approval. For this to work, buildings that do not comply need to be forced to do so or be demolished at the expense of those who assessed the building as compliant. Codes would also need to cover all the issues that existing residents care about, such as maintenance of privacy, limiting overshadowing, and traffic management. (p. 230, emphasis added)
Such is the level of frustration that the Commission seems prepared to entertain some rather drastic measures.
To summarise, it is clear that there are multiple failures in Australia’s ability to cope with the immigration-fuelled population growth that is thrust upon this country annually by administrative fiat. The Commission has unambiguously called out this failure of governance and planning in its Migrant Intake report.
The question then is, what to do about it? One idea which comes to mind is to say, ‘well, if immigration-fuelled population growth is adding to the stresses and strains on Australia’s environment, services and infrastructure, and if this is being exacerbated due to failed planning and governance processes – then perhaps it would be a good idea to slow down the rate of population increase by reducing the annual migrant intake. Perhaps this could be done just for a few years to give us some breathing space while we embark on institutional and planning reform, including population policy development, which will greatly increase our adaptive capacity, improve the quality of life for the vast majority of us, and give the Australian community some sense of ownership over the direction in which the country is heading.’
Such a course of action could be undertaken irrespective of whether one thinks that, in the longer run, Australia could or should end up with a population of 50 million or even 100 or 200 million (and so this temporary reduction could be seen as ‘preparation for the deluge’) – or whether one sees this action as the beginning a more prolonged reduction in migrant intake to eventually reach a stabilised level of population.
It could also be done, dare it be said, with an eye to various political side-benefits which have to do with the apparently growing concern within the Australian community about the impact of immigration upon social cohesion. Although this topic is not a focus of the current submission, there is no doubt a significant segment, if not a majority, of the Australian community with such concerns, including a great number on the conservative side of politics. Depending upon how they are framed (ie in non-racist terms), these concerns should not be automatically dismissed outright and without careful consideration – social cohesion is indeed an important societal goal.
And yet, for all the apparent merits of this simple idea to significantly reduce the migrant intake just for a few years, one has the feeling that this idea would not be able to ‘get up’, as they say. Why is that? It has a lot to do with the problems or our democracy highlighted in the previous section: The special interests are indeed very ‘special’, and the mates are indeed very good mates with the other players in the rewards game.
4. Does the current size and balance of the Migration Program reflect the economic and social needs of Australia?
i. What information do you need about migration? Would information about future migration planning levels numbers assist you?
Probably enough has been said already in order for the reader to accurately predict that my answer to question 4 is a categorical no – and some of the reasons for this should be clear from the above.
In terms of question 4 (i), there is very definitely some extra information that would assist me and the Australian community to have more informed discussion about Australia’s (nascent) population policy.
One of these, highlighted in the Commission’s report, is the need for ongoing systematic research into Australia’s ‘absorptive capacity’, which the Commission defines as:
the capacity of the market and non-market sectors to respond to the increased demand for goods and services induced by immigration and population growth. A sustainable rate of immigration (and population growth) is one that gives all residents the opportunity to engage productively in the economy and the community. It is also a rate that does not put undue burden on the environment to the extent that it undermines the wellbeing of existing and future generations. However, a rate of immigration that is defined as ‘sustainable’ may not necessarily be one that maximises community-wide wellbeing. (p. 3, emphasis added)
In one of Commission’s concluding chapters, on long-term impacts of migrant intake, it makes the following interesting observations:
A positive rate of immigration that is within Australia’s absorptive capacity and oriented towards young and skilled immigrants is likely to deliver net benefits to the Australian community over the long term.
However, there are various weaknesses inherent in current processes surrounding immigration policy decision making, particularly in terms of their ability to take into account broader and longer-term considerations (chapter 3 and finding3.1).
Taken together, these issues raise questions as to whether, without changes to increase Australia’s absorptive capacity, the annual intake (which is currently at historically high levels) is consistent with achieving a population that at least sustains (and over time maximises) the wellbeing of the Australian community. (p. 367, emphasis added)
In that context, I support the Commission’s very important Recommendation 10.1 of the Migrant Intake report:
The Australian Government should fund the Commonwealth Scientific and Industrial Research Organisation (CSIRO) to publish projections of the likely impact of varying rates of population growth on the built and natural environment. This analysis could form part of the CSIRO’s National Outlook publication.
The release of this analysis should be synchronised with the release of the Australian Government’s Intergenerational Report
It is only proper that this important task be undertaken by a respected and independent body such as the CSIRO. This is despite there being some questions raised about the plausibility of certain scenarios described in its recent National Outlook project. However, such issues can be further reviewed during CSIRO’s continuing work on this matter.
There is also clearly a need for ongoing studies of public attitudes and values relating to population growth, immigration, and the desired future for Australia. It would be preferable if there were funding for ongoing (eg annual or two-yearly) tracking studies on these topics.
5. How could the permanent Migration Program be more responsive to global migration trends, including the rise of temporary migration?
First of all, let it be said that there will never be a shortage of people wanting to migrate to Australia. National pride aside, there can be no doubt we have a quality of life that is second to none. The challenge is that such quality of life is deteriorating due in part to immigration-fuelled population growth.
The interest in migrating to Australia can be only expected to increase during the remainder of this century. This will include more pressure for temporary migration.
Many experts point to a series of inter-related ecological and energy problems (including of course climate change) which are intensifying on a global basis and multiplied by global population increase to 9 or 10 billion (or more) before the end of this century. This is very likely to make the 21st century an era characterised by slow or no growth and looming threats to the adequacy of global food supply due to increasing population, climate change and peak oil. It will definitely be an epoch of large and increasing movement of populations responding to war, social and environmental disruption, and the search for a better quality of life.
This future scenario may be unpalatable and does not square easily with the orderly world assumed by economic modelling or the short-term growth fix sought by politicians. No one can know the future exactly, but the above scenario is a very plausible one supported by an abundance of expert analysis. 
If such a scenario eventuates it can be fully expected that there will be immense pressure on Australia to further ‘open its borders’ to some degree or other. By all means we should offer a generous refugee quota and an even more generous, well-targeted foreign aid budget which aims to improve quality of life at source and thus obviating the need for people to migrate to new lands for the sake of survival or improvement.
However, I submit that no matter how much such global population pressures grow, we need to adhere to a goal of a stable population at no more than 30 million. That is the way to guarantee a rich, biodiverse, thriving Australian continent and an ongoing high quality of life.
 Productivity Commission, Migrant Intake Into Australia, Inquiry Report No. 77, (2016) Canberra, Australia.
 Cameron Murray and Paul Frijters, Game of Mates, 2017. Published by the authors. www.gameofmates.com
 Betts, Katharine, and Bob Birrell. "Australian voters’ views on immigration policy." Australian Institute of Population Research (October 2017). http://tapri.org.au/wp-content/uploads/2016/04/TAPRI-survey-19-Oct-2017-final-3.pdf
 Alexander, Samuel, Jonathan Rutherford, and Joshua Floyd. "A Critique of the Australian National Outlook Decoupling Strategy: A ‘Limits to Growth’ Perspective." Ecological Economics 145 (2018): 10-17.
 See, for example: Moriarty, Patrick, and Damon Honnery. "Three futures: Nightmare, diversion, vision." World Futures (2017): 1-17; McBain, Bonnie, Manfred Lenzen, Mathis Wackernagel, and Glenn Albrecht. "How long can global ecological overshoot last?." Global and Planetary Change 155 (2017): 13-19; Ripple, William J., Christopher Wolf, Thomas M. Newsome, Mauro Galetti, Mohammed Alamgir, Eileen Crist, Mahmoud I. Mahmoud, William F. Laurance, and 15,364 scientist signatories from 184 countries. "World Scientists’ Warning to Humanity: A Second Notice." BioScience 67, no. 12 (2017): 1026-1028.
It is a peculiarity of Australian policy making that a decision with major import for our society, economy and environment — namely the size of our annual intake of permanent migrants — is made in virtual secrecy and announced in an obscure line of the annual budget papers and an equally obscure line of a Departmental press release. The decision is important because our prescribed annual migrant intake (last year it was set at 190,000) makes a large contribution to Australia’s annual population growth.
According the Australian Bureau of Statistics, in the year to 30 June 2017, our population grew by 388,100 to 24,598,900 people. We are adding people in numbers equivalent to a city the size of Canberra, every year. Net overseas migration (NOM) contributed 245,400 or 63.3% to this increase, while ‘natural’ increase was only 36.8% or 142,700 people. NOM is overwhelmingly the biggest contributor to our annual population increase, which at an annual growth rate of 1.6% is one of the highest in the OECD, in third place after Luxemborg and Switzerland. These facts are worth re-stating here because many people may not be aware just how much immigration is contributing to our very high rate of population growth (including a red-hot 2.3% in Victoria).
In turn, this population growth is putting pressure on housing prices, infrastructure, services and the environment.
However, a small change has occurred this year. For what is probably the first time, the Department of Home Affairs (formerly Immigration) has sought public submissions on the question of what are the ‘right’ settings for migrant intake. I have contributed a submission here (PDF). It is possible that this new step has been taken as a result of the recommendations of the Productivity Commissions report on Migrant Intake into Australia. This report, to which yours truly contributed two submissions, is a major work of synthesis which draws on a wide range of community and expert evidence.
It is important that the findings of this report be fully studied and the major recommendations implemented. One of the most important is Recommendation 3.1, for the Australian government to develop an explicit population policy to serve as a context for making decisions about migrant intake. A significant part of the Commission’s findings and recommendations are for more public consultation and input into the development of the proposed population policy, and into decisions about migrant intake in particular. In short, the Commission is calling for an injection of democracy into this whole policy area.
In the past I have been critical of the Productivity Commission for its narrow economic focus and lack of attention to broader sustainability issues. However in this case it is important to give credit where it is due. The Commission has made some important findings relating to the impact of immigration-fuelled population growth upon the environment, society and economy — albeit still discussed within an orthodox and unadventurous framework of economic analysis.
My submission [or submission second location] to the latest invitation by the Department of Home Affairs, goes into some detail to highlight the important findings and recommendations of the Commission report.
This article was first published at http://www.peakdecisions.org/2018/02/managing-australias-migrant-intake-submission-dept-home-affairs/, Peter Cook's blog, "Peak Decisions."
See the full submission as a web page here: "Peter Cook's very useful submission on immigration to Dept Home Affairs".
Lawyers for Animals have sent in this very interesting submission to the Victorian Inquiry into the RSPCA. (See link to inquiry here: "RSPCA Vic Inquiry about to close but you could make a late submission".) It will be helpful to some of you who want to make submissions and generally informative about the role and duties of the RSPCA. Basically it argues for a new dedicated Animal Cruelty Investigation Squad (or similar) within Victoria Police and the removal of the RSPCA's Inspectorate powers and funding, permitting it to refocus on animal care and to engage in public advocacy for animal welfare. Among the reasons given are that the RSPCA has not got the funding to attend to the thousands of complaints it receives and that it lacks financial indemnity against being sued. The submission mentions a case where the RSPCA was recently sued for over $1m in farm losses, which has caused it severe financial problems. We have republished this interesting and useful submission from Lawyers for Animals with some slight changes to layout but none to content.
Economy and Infrastructure Committee
Parliament House, Spring Street
EAST MELBOURNE VIC 3002
6 March 2017
Dear Secretary and Committee Members,
Inquiry into the RSPCA Victoria
Thank you for this opportunity to make a written submission to the Committee's Inquiry.
Who we are
Founded in 2005, Lawyers for Animals Inc. (“LFA”) is a (not-for-profit) animal law think tank based in Melbourne. We are committed to alleviating animal suffering through education and law. Since mid-2013, LFA has partnered with Fitzroy Legal Service to provide Australia's first Animal Law Clinic: a free legal advice service assisting clients whose interests are likely to coincide with those of the animal(s) legally concerned. During 11 years of operation, LFA has accreted knowledge and practical experience of the animal welfare system, including the role and practice of RSPCA Victoria (“RSPCA”).
The appropriateness and use of RSPCA Inspectorate powers and Government funding
LFA recognises the enormous and unenviable burden borne by RSPCA – a charity – in attempting to fulfil a government function: law enforcement. LFA submits that as a non-government, charitable body, RSPCA is fundamentally incapable of ongoing animal cruelty law enforcement, whereas Victoria Police is. There are three main reasons for this:
1. Perpetual resource deficiencies
RSPCA receives about one third of its annual Inspectorate budget from government. Their total Inspectorate budget allows employment of ten full-time inspectors on average – with
only one rostered on weekends. Based on there having been 10,740 cruelty reports received in 2014-15, this means there were an average of four cruelty reports per day for each Inspector to thoroughly investigate, prosecute or otherwise resolve, as well as to organise care of vulnerable animals. That is simply impossible. As a result, large numbers of
cruelty reports are necessarily ignored or not properly investigated or prosecuted. Little wonder that despite 10,740 cruelty reports, only 69 cruelty prosecutions were finalised by
RSPCA in 2014-15 (0.64%).
RSPCA relies on charitable donations and bequests to cover the two-thirds shortfall in what is already a totally inadequate Inspectorate budget. To attract donations/bequests and
ongoing government funding, RSPCA attempts to maintain public confidence by projecting strength and stability. Underneath, the stresses of financial deficit and being inherently
unsuited to law enforcement erodes its integrity and morale. Staff and animals suffer the consequences. Governments are not directly blamed for the failures to enforce animal
cruelty laws, so they do not feel the full force of public fury when animals suffer unnecessarily over prolonged periods – such as under Bruce Akers'  and Heather Healey's 
care. Without such public pressure, the Government is less inclined to prioritise resources appropriately.
The city of New York faced a very similar situation before the American Society for the Protection of Animals ("ASPCA") and the New York City Police Department devised a joint-
solution from which both the public and animals have benefited, see:
In 2016, LFA contacted the Animal Legal Defense Fund USA ("ALDF") to ascertain their independent view of the New York model of animal cruelty law enforcement. The ALDF lent its positive endorsement to the model and strongly recommended its adoption in Australia and elsewhere.
2. Lack of power and public attitudinal change
Animal cruelty reporting is expanding commensurate with increased public awareness of animals' right not to suffer and society's growing intolerance of animal cruelty. Animal cruelty is regarded by offenders and (to a decreasing extent) the general public, as child abuse and domestic violence once were: private matters between a person and their 'property'. Unless responsibility for animal cruelty law enforcement is transferred to a dedicated, adequately resourced squad within Victoria Police, examples of failure to protect animals will increase.
Further, in contrast to Victoria Police, RSPCA Inspectors have extremely limited powers of entry to residences and/or arrest; no weapons or other training to equip them to deal with
situations of violence. The RSPCA also lacks the public imprimatur for strong law enforcement afforded to Victoria Police.
3. Lack of financial indemnity
No law enforcement agency – police or otherwise – can operate effectively when it is not indemnified for debts resulting from civil proceedings, occasioned by its enforcement work. On 10 September 2015, RSPCA was refused leave to appeal against a judgment ordering it pay $1.167m compensation for what His Honour Judge Bowman of the County Court had determined was a negligent destruction of cattle undertaken in May 2003 [RSPCA v Holdsworth  VSCA 243]. This one case has substantially impacted on RSPCA's budget – which was already in deficit, requiring it to obtain a bank loan which must now be repaid. It is likely to have undermined RSPCA's confidence in enforcing animal cruelty laws, especially following its unsuccessful prosecution of the parties in the Ballarat Magistrates' Court in 2005. The financial risks are simply too great and (apparently) uninsurable, at least by RSPCA.
All law enforcement agencies should be indemnified by the governments to which they are responsible.
Key reform proposals
LFA outlines the following constructive alternative model of animal cruelty law enforcement for the Inquiry's consideration:
◦ creation of a dedicated Animal Cruelty Investigation Squad (or similar) within Victoria Police;
◦ creation of an Office of Animal Welfare within the Department of Justice to oversee the Animal Cruelty Investigation Squad and fulfil many functions of the former Bureau of
Animal Welfare, keeping it independent from the Department of Agriculture; and
◦ removal of RSPCA's Inspectorate powers and funding, permitting it to refocus on animal care and to engage in public advocacy for animal welfare without any perception of conflict
Victorians don't expect human welfare charities to enforce our criminal laws, so it's high time we stopped expecting the RSPCA to enforce our animal cruelty laws.
Thank you for considering this submission. Should there be any queries concerning its content,
please contact Lawyers for Animals via email: [email protected]
Per: LAWYERS FOR ANIMALS INC.
247-251 FLINDERS LANE
MELBOURNE VIC 3000
 See, for example: http://www.heraldsun.com.au/news/victoria/starving-bulla-horses-highlight-rspca-failure-writes-
 See, for example: http://vetpracticemag.com.au/dogs-rescued-puppy-farm/
"Home ownership is a means to an end. It is not necessary for all people in all places. What all people want is housing affordability, security, and autonomy. A place they know they can come to, where they are in control of their own lives, which can be arranged to best serve their interests, tastes and lifestyle, and which will not enslave them financially. It is these values which have been so steadily undermined in Australia over the past decade in particular.
In some European countries like Germany, only about half of all households own their home. Many people have cited them, in an effort to wean Australians off their preference for ownership. However, the situation here is very different to that in Germany. There, tenants have substantial rights protecting their tenure and enabling them to decorate and to a certain extent modify their abode. Most importantly, the housing market is not inflating, so there is no expectation that rents will outstrip inflation into the future." (Dr Jane O'Sullivan) 
Submission to the Home Ownership Inquiry
House of Representatives Economics Committee
By Dr Jane O’Sullivan, June 2015
I am grateful to the Committee for its consideration of Home Ownership, which is an issue of increasing concern for Australians.
Home ownership is a means to an end. It is not necessary for all people in all places. What all people want is housing affordability, security, and autonomy. A place they know they can come to, where they are in control of their own lives, which can be arranged to best serve their interests, tastes and lifestyle, and which will not enslave them financially. It is these values which have been so steadily undermined in Australia over the past decade in particular.
In some European countries like Germany, only about half of all households own their home. Many people have cited them, in an effort to wean Australians off their preference for ownership. However, the situation here is very different to that in Germany. There, tenants have substantial rights protecting their tenure and enabling them to decorate and to a certain extent modify their abode. Most importantly, the housing market is not inflating, so there is no expectation that rents will outstrip inflation into the future.  This Submission was made in the name of Dr Jane O'Sullivan.
In Australia, renters are faced with ever-tightening budgets as rents are ratcheted up, and the prospect of termination of lease forcing them to move, with great uncertainty about where they might be able to afford to move to. They generally have little if any control over the fittings and finishes in their home, the energy mix and efficiency, or the level of security afforded. The only insurance against ever-increasing insecurity is home ownership.
I hope that this inquiry will consider policy options both to improve the accessibility of home ownership, and to improve the security and rights of tenants.
Current rates of home ownership
Home ownership is still relatively high in Australia, but most current households bought their first home before the escalation in property values, that began in the late 1990s. The rate of decline in home ownership among younger cohorts between the 2006 and 2011 census is disturbing. The following chart is reproduced from Leith van Onselen 
Behind this relatively small change in overall home ownership is a vast increase in household debt levels. The ratio of mortgage debt-to-disposable income exceeded 140% in December 2014.  This is up from an average debt of 27 per cent of average income in 1985. The Economist reported that, since the 1970s, virtually the entire increase in the ratio of private-sector debt to GDP around the world has been caused by rising levels of mortgage lending.
LF Economics documents that housing in Sydney and Melbourne requires more years of median income to pay down the capital value than in any other city except Vancouver. Vancouver is another city beset by very high rates of immigration-fuelled population growth. When one factors in that mortgage interest rates are higher in Australia than elsewhere, even at our current relatively low rates, affordability in Australia is extremely low on world standards. If setting aside 30% of a median income for the purpose, Sydney or Melbourne households would spend 6 years saving for a 20% deposit, and 23 years paying down the principle on a loan for 80% of median home price, plus a further 20 or more years to cover the interest, according to the LF Economics report. Spending 30% or more of disposable income on housing is considered to indicate housing stress. Thus the median household entering the market faces official housing stress for their entire working life. Let us remember that households entering the market as first-home-buyers initially average incomes well below median.
The ratings agency Filch found Australia had the highest growth in dwelling prices since 1997. This is unsurprising, since we had the highest population growth also.
Source [of Nominal House Prices diagram]: http://www.abc.net.au/news/2015-01-15/fitch-graph-of-housing-price-growth-since-1997/6018762
Thus Australians have shown very low elasticity of demand for housing, absorbing huge cost increases with relatively little change in purchasing behaviour – accommodated by a massive change in debt, impacting on consumption behaviour and work-life balance. A declining proportion of income spent on every-day consumption means a smaller multiplier-effect of each person’s productivity in the whole economy: fewer jobs are needed to service this consumption, while more people try to increase their hours of work to pay their mortgage. Workforce participation can only fall as the least competitive in the labour market are forced out.
There are two main reasons for this low elasticity:
a) Conditions in the rental market have worsened also, making long-term renting ever less attractive. Median rent statistics hide the fact that new additions to the rental stock offer less and less amenity. Like-for-like, rents have risen faster.
b) Expected further inflation of housing makes those without property nervous that they will be permanently locked out if they do not buy in as soon as possible.
It is often argued in the media that rising house prices have been driven by Australians demanding bigger and fancier houses. This is patently untrue. If it were true, the standard post-war three-bedroom bungalow in inner ring suburbs would be decreasing in value. The average ‘house’ may have increased in size, but not the average abode, when apartments are included. It is land which is inflating, not the cost of construction nor the scale of homes.
The truth is that the average standard of accommodation in Australia has been steadily declining, with the average young couple settling for a smaller apartment, in a noiser and less green neighbourhood, with less contact with neighbours, and/or a greater distance from work and community amenities. Most will have spent more of their adult life either in their parental home or in share-houses, than their parents’ generation. Most will spend a far greater proportion of their life-time earnings just keeping a roof over their head. All these factors contribute to considerable loss of quality of life in Australia.
An increasing number of reports document the social stresses of housing unaffordability. The Age reported on multiple families living together because they can't afford the rent. Minimum wage workers are being pushed to the fringes of Sydney, with UWS urban studies researcher Dallas Rogers affirming that geographical separation of rich and poor creates a cycle of disadvantage.
The inflation of house prices does not benefit home owners, as the inflation will equally affect the home they buy to replace one sold. This was well explained in a recent letter in the Canberra Times:
“If you bought a house in 1995 for $200,000 and sold it in 2007 for $600,000, how much profit did you make?
“A) Nil. B) About $200,000. C) $400,000. D) None of the above. The correct answer for most people would be D. If it was your only house, you would have needed to buy another house in 2007 to replace the one you sold. An equivalent replacement would cost $600,000. Add to that the costs of selling (say $20,000) and the costs of buying and moving (around $40,000), then you would have spent an extra $60,000 to be in the same position you were in 1995.
“Many people think that they are better off when the price of their house goes up. They aren't. It is still the same asset. What does go up is their capacity to borrow.
One of the most outstanding achievements of the last Liberal/National government was to double household debt. The profit of Australia's major banks was closely aligned with this increase in debt.”
The Reserve Bank of Australia suggested that consumption growth in Australia will depend on further housing inflation, with the ‘wealth effect’ (the illusion of greater wealth) encouraging households to spend. Thus they are relying on households exercising their greater capacity to borrow, using debt to pump up GDP. Given the effect of housing unaffordability on the ability of households to save for retirement, others stress importance of housing equity to fund retirement, advocating the use of reverse mortgages. Yet, if households are coerced into spending their growing home equity instead of paying down their mortgage, they will not have equity to draw on in retirement. This attitude appears to be merely kicking the can down the road – to land in a very rocky place, when the current young and over-leveraged cohort reach retirement. Private debt cannot sustainably grow GDP any more than fiscal debt, and it’s about time our macroeconomists admitted it.
In an article in The Conversation, Keith Jacobs argues that the majority of people would benefit from falling real estate prices, but the media and political discourse spruiks housing inflation as enrichment:
“Why has this crisis of affordability not been addressed by government? A major reason is that powerful industry groupings such as the financial sectors, property developers and real estate lobby groups have been spectacularly successful in maintaining pressure on the policymakers to privilege wealthy homeowners at the expense of less well-off households.”
Demand and supply drivers in the housing market
The main factor driving these stressors is population growth. Population did not initiate the past 15 years’ hyper-inflation – that was primarily the capital gains tax discount. But population growth was used since the mid-2000s to prop up the bubble caused by that rash and inequitable gift to the rich.
Was it the faltering of housing inflation in 2011 that caused the Gillard government to backflip on its election promise of reducing immigration, and further escalate population growth despite worsening unemployment?
In countries with stable populations, like Germany, property values are near stable, and housing is not a magnet for speculative investment. It is free instead to serve its occupants. Japan’s property bubble ended as its population growth tailed off. Australia’s population growth remains far higher than almost all other OECD countries. This is not only at the expense of affordable housing, but of fiscal balance, with the increased infrastructure costs amounting to over $100,000 per person added , and already accounting for State government debts.
Yet, because it forces up aggregate levels of debt, population growth is great for the banks. Unfortunately, policy-makers tend to turn to banks for macroeconomic advice, apparently oblivious to the conflict of interest between the banks and the populace they leverage. CommSec’s quarterly State of the States reports, which Premiers spruik as a measure of their personal success, invariably places population growth as a dominant determinant of economic performance. Yet the same reports show incomes more consistently outstripping cost-of-living in the states with least population growth. Only by ignoring per capita metrics are the faster-growing states portrayed as more successful. If headline economic indicators were routinely reported per capita, and change in public and private debt were subtracted from them, we would have a much more realistic view of wealth trends. This is the story the banks do not want to tell.
It is frequently claimed that house price rises are due to inadequate supply of housing. This excuse is wearing thin with the public, who see that government policy has taken every opportunity to increase demand. In addition to the expanded immigration program has been added increasing access of foreign investors to Australian real estate. The capital gains tax discount remains sacred, even as welfare and community services are sacrificed as ‘fiscally irresponsible’. Intermittently, first-home-buyer grants further fuel demand and ratchet up prices.
Foreign investment in real estate does not increase supply, it merely fuels the demand, and further displaces prospective home-owners. Without foreign capital inflows, the supply of housing outstripped demand growth continuously from 1950 to 2007. There is an acknowledged tendency for foreign owners, particularly Chinese, to leave properties empty, with the effect that their purchase decreases, rather than increases, housing supply. If developers claim that they can no longer find up-front funding for new ventures on-shore, it is only because, at the current value of land, their proposed development is not commercially viable. A liberal government should not be interfering in the market-place to prop up such unviable ventures.
By introducing investors who have much lower costs of capital than Australians, as well as providing a haven for those who may be laundering corrupt earnings, the prices can be ratcheted even further beyond what is economically rational for Australians. This can only progressively lock Australians out of home ownership, and leave them increasingly beholden to foreign landlords.
Such fuelling of demand plays into the hands of those with control over supply. A recent University of Queensland study found that speculation in peri-urban land was highly lucrative for those with political connections, who have more than a knack for picking the next area to be rezoned. Likewise, approvals for height relaxations on inner urban developments are equally lucrative. It serves developers to present supply as the problem for housing affordability, and themselves as the heroic saviours. Their claims that foreign investors are needed to get projects up are purely self-serving. Their investment in numerous lobbyists and think tanks spruiking population growth ensures that supply is never met, and ever more concessions from government can be requested to help them ease the pressure that they themselves have bought and paid for.
The proportion of investment housing relative to owner-occupied housing
The main impact of the capital gains tax discount was to attract investors into the property market, massively intensifying demand. It goes without saying that housing investment decreases home ownership. Investors need tenants, and those households competed out of home ownership by cashed-up investors are forced to remain tenants. Population growth ensures rental vacancy rates are kept very low, forcing up rents and motivating renters to stretch their credit limit to purchase property. Once heavily mortgaged, both home owners and investors depend on further price increases to recover their investment. But this can only happen at the expense of younger people entering the housing market, each cohort facing higher indebtedness than the last. Each year housing inflation continues, more investors are attracted, further decreasing the proportion of housing that is owner-occupied. It is a vicious cycle.
The Prime Minister was clearly declaring himself on the side of investors against home-owners, when he recently said “I do hope that our housing prices are increasing.” Anyone who thinks that property owners can continue enjoying investment growth well above CPI, without housing affordability deteriorating inexorably, is deluding themselves. Yet, as the old adage goes,
“It's hard to get someone to understand something when their salary depends on them not understanding it.”
The impact of current tax policy at all levels
Tax policy currently preferences investors over home owners, particularly through the following elements:
• Capital Gains Tax discounting;
• Tax deductibility of interest rates;
• Depreciation of buildings;
• Negative gearing.
Together, these measures mean that financing an investment property is much cheaper than financing a home. This is inequitable. Changes should aim to level the playing field, removing systemic advantages of investors over owner-occupiers.
No interest payments on real estate should be tax deductible. These are not productive investments, they merely serve to flood demand and inflate housing prices. Those with money to invest should be free to invest in property, but those who have to borrow to do so should not get special treatment from government, as if they are doing the economy a favour, because they are not.
The ability to depreciate buildings, rather than merely deduct the costs incurred in maintaining them, is also an inequitable means for investors to minimise their costs. In a rising market, where the building has probably increased in value in spite of wear and tear, this is a dishonest device which further disadvantages owner-occupiers.
The capital gains tax discount is a gift from the tax-payers to the richest members of society. Saul Eslake documented the extent to which the introduction of this discount in 1999 stimulated an enormous increase in the use of the negative gearing facility to shift taxable income to lightly-taxed capital gain. Borrowing for property investment and the proportion of loss-making landlords increased dramatically.
Before the capital gains discount, negative gearing was mostly only a means of deferring tax from current income to future capital gain. However, the ability to deduct interest and depreciation contributed to the amount of income offset. It is the capital gains discount that has turned negative gearing into a major tax rort. Saul Eslake (op. cit.) estimated the tax avoided to be in the order of $5 billion in 2011. He concluded, “This is a pretty large subsidy from people who are working and saving to people who are borrowing and speculating.”
The claim that abolition of negative gearing would force rents up has been debunked by a number of commentators, who have demonstrated that its abolition between 1985 and 1987 did not result in any consistent rent response across Australian cities – in Sydney and Perth, where vacancy rates were unusually low, rents rose, but in other cities they were unchanged or fell.
Other measures have been implemented to advantage first-home buyers in the marketplace. These include first-home buyers’ grants and stamp duty waivers. These measures invariably serve merely to push the price of real estate further upward. Prices are limited by buyers’ capacity to pay, and if this is supplemented by government, the first-home buyers simply pay more. The impact on prices affects all buyers, and has the impact of increasing total mortgage debt carried by the community.
What is needed is to remove the advantages enjoyed by speculative investors, not to fuel an arms war between investors and home buyers.
Opportunities for reform
It is not difficult to identify a range of measures which would stem housing inflation and shift speculative investors to more productive investments. What is lacking is the political will.
The following measures are roughly in order of impact, from the greatest and most certain to the least or less probable.
1. Drop immigration quotas significantly and tighten conditions on most forms of temporary work immigration, allowing population growth to taper off.
2. Remove the capital gains tax discount (across all forms of investment income), allowing only a CPI adjustment. Capital gains tax should not apply to the family home, or at least should be net of all expenses in buying the next home.
3. Disallow foreign investment in property. This is purely inflationary, and allows foreigners privileges in Australia which are not reciprocated.
4. Disallow mortgage interest payments and building depreciation as tax deductions.
5. End negative gearing, allowing tax deductions to be claimed only against the income from the activity that incurs them (but permitting costs to be carried forward against future rents or capital gains).
Land tax has been proposed as an additional measure, but is problematic in an inflating housing market. It means that people can no longer even count on home ownership to insulate them from rising costs of housing. As their home rises in market value, through no fault of their own and conferring no advantage on them, they nevertheless face rising tax. Rates are already a land tax that many long-term residents find hard to endure. A land tax can only force more of them out and accelerate the geographical separation of rich and poor.
However, tax on vacant property may be worthwhile, to deter speculative behaviour and prevent investors withholding stock from the market. Any property vacant for more than three months, without being under contract or development application, may be subject to the tax.
The nation’s elected representatives need to decide whether they support:
- on the one hand, ongoing profiteering by developers and real estate speculators, who are increasingly not even Australian, knowing that this can only mean increasing levels of household debt, housing stress, homelessness, inequality of wealth and geographic separation of rich and poor generating slums, crime and civil unrest,
- or on the other, stabilisation of land values and the diversion of speculative investment to productive uses in enterprise and infrastructure, knowing that this means an overall drop in investment returns (including their own) compared with recent expectations, but may avert a bigger drop that an over-inflated bubble must ultimately cause.
To use Tony Abbott’s parlance, “Whose side are you on?”
A rational and sincere public servant should know that the current situation is unsustainable and highly damaging to the fabric of society. Unfortunately I have seen little evidence of such a combination of wisdom and sincerity.
“Surely by now there can be few here who still believe the purpose of government is to protect us from the destructive activities of corporations. At last most of us must understand that the opposite is true: that the primary purpose of government is to protect those who run the economy from the outrage of injured citizens.”
Derrick Jensen – “Endgame: The Problem with Civilization”
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 Ridiculous immigration fires housing spike – Bob Carr. The Australian http://www.theaustralian.com.au/national-affairs/immigration/ridiculous-immigration-fires-housing-spike-bob-carr/story-fn9hm1gu-1227393713757
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 Daly, J. 2014. Budget pressures on Australian governments 2014. Grattan Institute. http://grattan.edu.au/report/budget-pressures-on-australian-governments-2014/
 Soos P. 2011. Debunking the myths peddled by Australia’s property bubble ‘deniers’. The Conversation 14/12/2011. https://theconversation.com/debunking-the-myths-peddled-by-australias-property-bubble-deniers-4488
 Callick, R. 2015. Why the Chinese are willing to pay over the odds for local property. The Australian, 11/06/2015. http://m.theaustralian.com.au/business/opinion/why-the-chinese-are-willing-to-pay-over-the-odds-for-local-property/story-e6frg9fo-1227392052366
 Nick McKenzie, Richard Baker, John Garnaut 2015.Corrupt overseas buyers ramp up property price, burn locals. The Age, 23/06/2015. http://www.theage.com.au/national/corrupt-overseas-buyers-ramp-up-property-price-burn-locals-20150622-ghu5pn.html
 Murray C. and Frijters P. 2015. Clean Money in a Dirty System: Relationship Networks and Land Rezoning in Queensland. IZA Discussion Paper No. 9028, April 2015. http://ftp.iza.org/dp9028.pdf
 Saul Eslake 2013. Fifty years of housing failure. Address to the 122nd Annual Henry George Commemorative Dinner The Royal Society of Victoria, Melbourne 2nd, September 2013. https://www.prosper.org.au/2013/09/03/saul-eslake-50-years-of-housing-failure/
 Greg Jericho 2015. Negative gearing: a legal tax rort for rich investors that reduces housing affordability. The Guardian 19/03/2015. http://www.theguardian.com/business/grogonomics/2015/mar/19/negative-gearing-a-legal-tax-rort-for-rich-investors-that-reduces-housing-affordability
The policy and position of Australian government with respect to population issues is the most influential factor likely to impact on Australia’s future sustainability and hence the prosperity of current and future citizens. Because of the bipartisan government position on population/immigration numbers it is all but impossible to engender an effective public debate on these issues. I therefore welcome this opportunity created by the Productivity Commission to have this debate in a manner that is untarnished by vested interests and scaremongering about perceived xenophobia.
The current fertility rate for Australian women is hovering at around replacement levels. This level decreased significantly in the decades leading up to 2000 and has substantially stabilised since then. I believe this choice by Australian families at once represents a level of confidence in future prosperity of the nation as well as a desire to ensure quality parenting that can be better delivered through smaller family sizes. Given a continuance of this statistic our population would stabilise at around 28 million. This is more than 20% higher than the level recommended by the Australian Academy of Science as a sustainable level while maintaining the current standard of living that all Australians expect to pass on to our descendants. The corollary to this statement is that our population growth levels are already such that they are compromising the prosperity of future Australians. Nevertheless, at this level the nation would be able to respond effectively to both positive and negative externalities that may impact on our future prosperity.
The major impediment in the way of us achieving this flexible and optimum outcome is our level of immigration. Immigration has been by far the most significant driver for Australia’s rapid population increase over the last two decades.
Population increase as a result of immigration impacts the country in a number of ways:
- Upfront impacts to infrastructure congestion and costs
- Increased impact on the environment
- Dilution of wealth creating resources over an increased distribution
- Increased disparity of wealth
- Erosion of amenity and culture.
Having a local market is now irrelevant
Whilst there is some truth to the idea of innovation being enhanced by diversity the concept that increasing population of itself somehow makes us all more wealthy is simply unsubstantiated spin, put out by vested interests. In the past, Australia has benefited from growth to our critical mass of population. This has facilitated domestic industries to develop where a smaller population could not have sustained these industries. Those days are gone. With global capital, communications and distribution networks industries will develop and flourish where they incur the lowest costs. Through the internet, individual consumers now, and increasingly so in the future, will purchase directly from the lowest cost supplier and the lowest cost distributer in the world. Whether we agree with it or not, governments are actively ensuring that no legal or commercial barriers can be used protect local industries. Having a local market is now irrelevant. As such, any petition that argues that increases to our population will enhance local market strength should be dismissed.
Wealth and wealth generation and our standard of living in Australia is supported by an array of public infrastructure, much of which is owned and controlled by government. A review of the value of the government portion of public assets across the three levels of government indicates a total current value of approximately $1.9 – $2.0 trillion.
It is reasonable to argue that any increase in population resulting from immigration will need to be supported by a commensurate increase in this public infrastructure. This equates to a value in excess of $83,000 per immigrant.
Note that the previous number represents a depreciated value of assets and not the current replacement value. It can be argued that migration necessitates the building of new infrastructure and so should be costed at the current value but I will ignore this argument for the sake of presenting a conservative position.
There are three major factors that impact on this argument:
- Higher population density will result in more efficiency in the utilisation of some assets.
- The cost of provision of supplementary infrastructure to provide additional capacity in an already built environment is significantly higher than the cost of the original assets ie. a tunnel costs far more than the above ground road it supplements.
- Provision of major infrastructure is almost always incremental. For a continually increasing demand, this results in an infrastructure complement that is always operating at either below or above optimum capacity. The more rapid the population change, the more severe the impact of this derogation in efficiency.
I believe in an Australia at the current time and with our current growth rates the last two of these negative factors will far outweigh the benefits of the first.
Australians currently are responsible for one of the highest GHG emissions of any country. On average we emit around 16T of GHG per person per year. The bulk of immigrants arriving here originate from countries with GHG emissions at a fraction of the Australian numbers. From a world perspective this flow of people therefore represents a huge negative impact on the effort to limit climate change.
Putting the world perspective aside and looking purely at the financial impact to Australia the immigration numbers will result in a significant increase in the costs this country will incur in order to meet our international obligations. Although GHG emissions are currently trading for around $20 per tonne it is expected that this value will rise to over $60 per tonne in order to meet the 2050 target of a 50% reduction. The price will continue to climb beyond this point.
Running an NPV analysis for a 30 year old on the basis of a GHG price of $40 per tonne will yield an upfront cost of approximately $16,000.
Note that this figure represents a small fraction of the total environmental cost of population increase but it is that portion that can be readily quantified and has a high degree of certainty in terms of our national cost obligation.
Dilution of Wealth Resources
A number of studies have been done in other countries to assess the net benefits of migration. Invariably these studies have determined that there was no net benefit to the existing population derived from immigration. The most definitive of the studies was conducted by the UK government that came to this same conclusion.
The most significant aspect where the Australian situation differs from the UK case is in the basis of the two economies. The UK derives most of its wealth through the leverage of labour whereas most of our core wealth is derived from exploitation of both renewable and non-renewable resources. The income that Australia earns from these sources represents around 80% of the amount we use to pay our way in the world.
The sources of this income are finite. The thinner we spread these income sources over our population the less there is for each of us to enjoy.
Assessment of the per capita value of national resources is quite a difficult exercise and subject to a range of assumptions regarding public and private returns from these resources. The diminution of per capita wealth through the dilution of resources cannot be ignored and should be the subject of a public enquiry by the Productivity Commission.
Total Financial Impact
Given the above factors each new immigrant costs the Australian public well in excess of $100,000 per person in public infrastructure, environmental and dilution of public wealth. If the government’s objective is to provide a net wealth benefit to its citizens through immigration, then this is the minimum that we should expect new migrants to return to Australian society.
Often there is an argument that new immigrants will pay back their upfront infrastructure costs through the taxes they pay during the course of their working lives. The trouble with this argument is, that the bulk of taxes simply go towards the costs of recurrent government expenditure. New infrastructure spending represents only around 4% of total government expenditure. Using this proportion and an NPV analysis on the tax payable by a 30 year old immigrant, in order to pay off the upfront infrastructure cost, they would need to pay over $95,000 (present value) per year in tax over the entire course of their working lives. This level of tax is unlikely to be recovered from even the top 1% of new immigrants.
It therefore makes sense to recover the upfront costs from new migrants upon entry thus allowing market forces to dictate those immigrants that will be in a position to make a positive financial contribution to Australia’s net wealth.
Increased Disparity of Wealth
The effect of population increase on labour prices can be analysed using the most well established economic tool, the cost demand curve. The greater the availability of labour in the economy the lower the price will be for that labour. Although we may want to pretend otherwise, the bulk of immigrants to Australia commence on the bottom end of the labour market. Even skilled migration applicants generally bring with them family members who will be taking entry level positions in the jobs market. It is undeniable that this will push down the price of the bottom end of the labour market.
At the same time there are substantial corporate benefits associated with increasing the population. Land development, banking, retail of consumer and whitegoods all derive the bulk of their profit growth from the growth in population. While in itself this is not bad. On a balanced playing field these profits would circulate into the economy therefore growing Australia’s overall net wealth. The trouble is, there is not a balanced playing field. There is a disproportionate ownership of most Australian corporations by foreign owners. The extra profits generated are not recycled back into the Australian economy but instead are siphoned off to overseas investors. There are some Australian owners of corporations that have derived substantial wealth from population growth, but as a general rule, the greater the rate we stimulate the economy through population growth, the greater the rate that profits generated are siphoned off overseas.
The use of 457 visas only exacerbates the above effect. I know for a fact that the 457 visa scheme is being rorted in the computer programming industry. Indian programmers are being brought in on 457 visas at a salary of around $25,000 per year. They have been used to replace Australian programmers who previously held these positions and earned around $60,000 per year.
The major companies involved in this rort are following the government procedural process to the letter. They are advertising the positions in the Australian market making the low salary offered for the position very clear. Naturally they receive no applications at these low rates. They then use this information to justify that they cannot acquire employees in the local market and hence the need to import labour through the 457 scheme. Virtually all of the salaries earned by these 457 workers is being repatriated back to India. Meanwhile, there are hundreds of experienced Australian programmers either working as unskilled labour or collecting unemployment benefits.
So an industry that was entirely self-contained, training and employing local people to generate wealth has been replaced by one that has a net effect of draining wealth out of the economy.
If this is the known case in this one field then it is very reasonable to expect that this same practice is being utilised across all industries. How is this scheme beneficial to the Australian economy?
Both the importation of low skilled labour and the 457 visa scheme is eroding the earning capacity of the less well off in Australia. At the same time these arrangements are benefiting corporate owners. This practice has already diminished the egalitarian nature of Australian society and will cause further deterioration if allowed to continue.
Erosion of Amenity and Culture
It is very difficult to put measures on amenity, and even more difficult to quantify loss of culture.
The argument for the correlation of higher population and the erosion of amenity is obvious. Congestion on roads and public transport, the need to live further from places of work, lack of provision of government services once taken for granted, the overcrowding of beaches, parks and recreation areas are all the direct result of population growth. The counter argument is that much of this loss of amenity is due to low infrastructure spending. Higher relative spending will certainly fix some of the problems, but not all. And, as indicated above in the economic analysis, this higher spending is simply not financially feasible without governments going into higher debt or a higher tax regime.
While I am sure the advantages of a diverse culture will be put forward by proponents of high immigration numbers, it is worth considering one negative aspect that is rarely discussed.
In the first half of the 20th century, Australia had by most standards a very homogeneous culture. Because of this homogeneity the various governments of the day were able to make bold plans for the future that were generally supported by a voting public that spoke with a single consistent voice. Over the last twenty years this capacity to make strong long term plans has completely disappeared from all tiers of Australian government. Politics is completely consumed by the need to satisfy small special interest groups rather than the focus on the general common wealth. Diversity of culture is not solely driven by immigration but immigration is the major contributing factor to it. Thus the capacity of governments to make consistent long term plans for the future has been significantly hampered by our growth in cultural diversity. The detrimental economic effects of this while indeterminate should not be ignored.
It is difficult to justify in a submission to the Productivity Commission the true value to the community of the freedoms we used to enjoy in this country. Freedoms that have been curtailed either directly due to the density of population or have come about as a result of necessary government rules and regulations to control society that has become both larger and more complex. It is these past freedoms that formed the core of what used to be Australian culture. Unfortunately, most such justification will be viewed simply as nostalgia.
I retaining an abiding wish to ensure that my grandchildren (as yet unborn) will enjoy the feeling of being Australian and proudly different from the rest of the world. These differences however, are being profoundly diluted as a direct result of the combined effects of immigration levels and the adoption of multi-culturalism. Through these policies we are consigning future children of our nation to be simply amorphous world citizens rather than uniquely Australian. That fact is deeply concerning.
Candobetter.net Editor's note: Sub-replacement fertility is a total fertility rate (TFR) that (if sustained) leads to each new generation being less populous than the previous one in a given area. In developed countries sub-replacement fertility is any rate below approximately 2.1 children born per woman, but the threshold can be as high as 3.4 in some developing countries because of higher mortality rates. Taken globally, the total fertility rate at replacement was 2.33 children per woman in 2003. This can be "translated" as 2 children per woman to replace the parents, plus a "third of a child" to make up for the higher probability of boys being born, and early mortality prior to the end of their fertile life.
Replacement level fertility in terms of the net reproduction rate (NRR) is exactly one, because the NRR takes both mortality rates and sex ratios at birth into account. (Source: https://en.wikipedia.org/wiki/Sub-replacement_fertility#cite_ref-2
This current strategy will be the sixth strategic plan for Melbourne in 25 years... Increasing energy costs ... The role of the construction sector in the State's economy is directly related to repeated extensions to the urban growth boundary. Housing affordability. Food security... ensure all suburbs have access to back up food supplies that are not reliant on transport. Framework for regional linkages should be based on consideration of the protection of environmental and ecological systems. The '20 minute city' and 'Unlocking capacity in established suburbs' proposal is code for high population density and high rise development in existing suburbs and suburban streets; pressure on existing infrastructure to cope with higher population demands but without system renewal; further vegetation clearance and ecological impacts; decline in living standards ...and should be withdrawn.
Melbourne Metropolitian Planning Strategy - Discussion Paper: Melbourne, Let's talk about the future
This evaluation was first presented as a submission to the State Government of Victoria Ministry Advisory Committee to oversee the development of the metropolitan planning strategy in response to a "Discussion Paper" promoted by the Committee entitled "Melbourne, Let's talk about the future." The original title of Liz Burton's evaluation was, "Melbourne Metropolitan Planning Strategy - Discussion Paper: Melbourne, Let's talk about the future." It takes the form of responses by Liz Burton to questions under headings (in upper case) set out by the Department.
1. COMMENTS ON FIVE OUTCOME PRINCIPLES
1.1 QUESTION 1: WHAT DO YOU THINK OF THESE OUTCOME PRINCIPLES?
1.1.1 Melbourne 2030 repackaged
The set of five outcome principles, outlined in the Discussion Paper are more accurately described as generic themes rather than principles as they do not provide clear underlying directions, plans and targets. As a vision for Melbourne the principles:
(a) essentially repackage Melbourne 2030 but add radical free market development (refer Appendix A);
(b) do not seem to advance the significant qualitative long term vision established by early city planners and surveyors such as Russell (survey and plan for Melbourne) and Hoddle (the CBD grid structure); and
(c) most significantly, offer limited response in relation to scientific projections of the impacts of climate change, with specific reference to Australia.
1.1.2 Climate change and international best practice planning response
The set of five outcome principles are limited on the impacts of climate change on planning for the next 40 years.
The major flaw in the Discussion Paper is that it conceptualises carbon reduction strategies as a silo under principle 5 'Environmental resilience', instead of embedding carbon reduction as a strategy within each of the nine principles.
The Discussion Paper's Principle 5, 'Environmental resilience' is sub optimal as regards international best practice planning to mitigate the predicted effects of climate change and helping to reduce carbon emissions. The Minister's Advisory Committee appears to lack appropriate insights into international best practice in planning regarding climate change mitigation in the structure of cities and planning of new suburbs. For example Vancouver, Canada has a 'Greenest City 2020 Action Plan' divided into ten sub plans, each with long-term goals and specific targets  . There is no emphasis in the Discussion Paper on the strategic importance of addressing climate change through planning and this is a major weakness of the Discussion Paper.
Melbourne as a destination will be superseded by the initiatives of countries that are taking active measures to implement an integrated plan with set targets relating to environmental resilience, ecosystems, carbon reduction and waste.
184.108.40.206 Ministerial Advisory Committee
The Ministerial Advisory Committee's membership has no-one with leadership in environmental planning and this absence from the Committee's expertise is reflected in the weak response and lack of integrated vision on this critical issue.
Climate change impacts include: (a) extreme heat waves and hot days; (b) heavy rain; (c) drought; (d) increase in incidence of wildfires; (e) sea level rise and coastal flooding; (f) tropical cyclones and storms. Extreme weather events that were considered a one-in-one-hundred year event are now recurring more frequently in parts of Australia. Associated with these impacts are projections regarding: (i) food security and potential food shortages through impacts on crop yields, distribution, diseases; (ii) health impacts; (iii) cost of living increases; (iv) issues regarding security and social stability.
The Discussion Paper needs to address carbon reduction and environmental resilience strategies as essential components of a new planning strategy for Victoria to ensure its relevance for the next 40 years.
1. That the Discussion Paper be reconceptualised so that carbon reduction strategies and environmental resilience strategies are embedded within each of the nine principles and their associated Ideas;
2. That any successive planning strategy document is informed by expertise from senior academic planning staff whose published research is in the field of addressing climate change through a range of planning strategies.
1.1.4 Economic issues
The question that needs to be addressed in a new planning strategy spanning 40 years is: 'what is the purpose of the State's population growth strategy'? High populations are not of themselves a source of economic vitality and often mask underlying structural deficits in the economy. In Victoria, population growth is clearly masking structural deficits as the retail sector is the State's major employment sector but one of the lowest on innovation and research and development.
In its 2011 report, the Productivity Commission concluded in relation to the retail sector, that “it appears likely that the size of the gap between Australia and the US has been increasing; nor has Australia made any significant gains in its position in regards to other leading countries” (2011: 67).
These deficits in the structure of the economy are significant contributors to decline in competitiveness and productivity and unless addressed, lead to ongoing economic decline.
The response of yet more population growth exacerbates the decline because it does not create the necessary economic productivity and innovation boost required to increase tax revenues per head of population.
220.127.116.11 Nexus between the State's economy, planning and the construction sector
A major difference between planning up to the 1970s and today is the role of the construction sector in: (a) the State's economic performance, (b) major provider of jobs and (c) generating retail stimulus. Construction is among the top four employment sectors in the State and a feature of contemporary planning is its role in enabling construction. Return on investment drives the construction sector and this imperative relates directly to planning and associated built form outcomes through: (a) residential infill, (b) growth corridors, and (c) Melbourne city central and Southbank high rise developments.
This economic nexus today drives and informs planning, which is now an economic tool rather than a distinguishable discipline in its own right concerned with town planning. The subordination of planning to economic ends is supported by provisions in the Planning and Environment Act 1987 to take into account economic and social considerations when making planning decisions - see extract below. As such, planning has a responsibility to take account of the economic effects on the State.
Em>Extract from PEAct 1987
"2(d) to ensure that the effects on the environment are considered and provide for explicit consideration of social and economic effects when decisions are made about the use and development of land; "
Furthermore, the availability of land for construction is essential for the ongoing contribution by the construction sector to supporting the State's economy and jobs. It comes at a high environmental cost owing to the construction cycle of project commencements and completions. Furthermore, while contributing to environmental decline this sector has been declining in productivity in relation to the USA construction sector since the 1990s. Daley and Walsh (2011) have argued that labour productivity in the Australian construction sector declined by half relative to its US counterpart between 1990 and 2005. 
18.104.22.168 Productivity and major employment sectors in Victoria
Based on ABS labour force data and Grattan Institute calculations for 2008-09 , the construction industry ranks amongst the lower percentile of employment sectors on labour productivity performance. Furthermore, Victoria has slightly more low productivity sectors and slightly less high productivity sectors when compared with other states. This has meant that in 2008-09 Victoria's per capita gross value added in industry was 4.9% below the national average. 
22.214.171.124 Why is productivity relevant?
Global competitiveness and housing affordability
The principles of: (a) 'Victoria as a globally competitive city' and (b) 'strong communities', an element of which is affordable housing, relates directly to Victoria's productivity capability and to the productivity of the construction sector. The Discussion Paper in its 'Executive Summary' rightly draws attention to the need for Melbourne to improve its productivity: 'Melbourne needs to improve its "productivity" - the economic value produced for an hour of work or a dollar of investment'. (Melbourne, let's talk about the future, pvi).
The importance of productivity competitiveness to economic success and revitalisation is recognised by business leaders and leading academics. In a recent article in The Conversation Professor John Freebairn draws attention to productivity issues facing the Victorian economy, including productivity stagnation and the need respond to demand for new technology and work practices. A shift in focus from less productive industry sectors to those that are more productive is advocated:
"A major challenge facing the Australian economy — particularly the Victorian economy — has been the stagnation of productivity growth this century. The increase in the terms of trade to record high levels over the last decade largely drove higher living standards over this period rather than productivity growth, but this is likely to be eroded in the coming years.
Restarting productivity growth is vital if Victorians' increasing expectations of higher income are to be realised. There is a major challenge for the government, businesses and individuals to better respond to changing markets and buyer needs, to adopt new technology, to change management and work practices, and to allow the transfer of resources and industries from less productive to more productive uses".
126.96.36.199 Structural constraints to the economy
The case presented in the Discussion Paper on Principle 2 does not address the structural constraints in the economy impacting on productivity and therefore on Victoria's competitiveness.
A number of the State's major employment sectors of: (a) retail trade, (b) health care and social assistance, (c) manufacturing, (d) construction and (e) education and training, are sectors that may have either reached their peak or be in decline in terms of their capacity to attract the best and brightest employment candidates. For example, the retail trade with its low productivity status, combined with low research and development output, is a major employment sector in Victoria that does not appear to be addressing competitiveness and therefore may not be positioned to support the aim of contributing to global competition.
1. That the structural weaknesses of the Victorian economy as outlined above relating to its major sectors and to productivity be addressed by preparing plans and targets to restructure the economy and to attract people with appropriate qualifications and expertise to help business and industry to transform;
2. That infrastructure replenishment be prioritised in relation to rail transport rather than buses.
1.1.5 Contemporary planning deficits
There is concern that contemporary planning lacks capacity to establish strategies that meet the community's long term needs and each strategy is superseded within a few years. This current strategy will be the sixth strategic plan for Melbourne in 25 years; a plan on average about every four years, together with a number of minor plans.
Major elements of strategies return disappointing outcomes. For example according to the Melbourne 2030 planning strategy, the Docklands development, constructed in the 2000s, would be 'a key location for high-order commercial development and retail and entertainment core of the metropolitan area' (Melbourne 2030, p 37). It was intended as the 'preferred location for uses serving the State or nation' (Melbourne 2030, p 37).
188.8.131.52 Docklands examplar of suboptimal planning performance
Although it benefits from its proximity to water, Docklands offers residents, workers and casual users a vast amount of concrete, shadows and wind tunnels. Public open space is provided mainly in the form of concrete walkways and there is little relief from concrete both in its horizontal and vertical elements.
While it has attracted major corporate and business investment, as an entertainment and retail destination Docklands has failed, despite major advertising campaigns. It is now acknowledged that it needs to be reworked to augment its appeal on these core components of the strategy. Such duplication of effort has significant implications for productivity and acts as a poor exemplar for future major projects.
The suboptimal performance of these major planning investments needs to be assimilated by the government and the planning community and the reasons for poor outcomes need to be clearly identified and published so that mistakes are not repeated. This is essential as it has implications for new planning proposals for revitalisation and renewal such as the Fisherman's Bend rezoning to create new residential suburbs.
2. WHAT DO YOU THINK IS NEEDED TO ACHIEVE THESE OUTCOME PRINCIPLES?
The outcome principles (or generic themes) are better assessed in relation to stated performance targets and outcomes. The Discussion Paper does not have the necessary content and structure to facilitate such feedback. However feedback is provided on each Principle under the discussion and associated recommendations outlined above and below.
3. WHAT ARE THE KEY INGREDIENTS FOR SUCCESS IN ACHIEVING THE VISION OF AN EXPANDED CENTRAL CITY?
3.1 Population growth as a measure of economic growth - a falacy?
Based on the discussion above under paragraph 1.1.3 concerning the structure of the Victorian economy, it appears that population growth masks and exacerbates underlying structural deficits and has potential to reduce per capita revenue. The issues of productivity improvements, innovation and research and development are not addressed through population growth as the cornerstone of the strategy. It is noted that attention is given to innovation clusters but they are conceptionalised as stand alone facilities rather than as a vital component of each sector to strengthen the State's economy and its competitiveness.
3.2 Principle 1: A distinctive Melbourne
The current liveability of Melbourne is informed by the vision of early government planners, surveyors and Lieutenant-Governor Charles La Trobe (large public reserves). Their long term legacies include:
• the city framework of major streets eg Collins St, supported by subsidiary streets linked to them eg Little Collins St, and the associated interconnecting network of arcades and laneways to provide a coherent circulation system, particularly congenial for pedestrians;
• reserving large areas as public parks including: the Treasury Gardens, Carlton Gardens, Flagstaff Gardens, Royal Park and the Royal Botanic Gardens.
3.2.1 Urban structure and place
Urban structure and place would benefit from the following elements:
(a) designed in relation to ecologically sustainable design principles including: (i) zero carbon, (ii) zero waste, (iii) sustainable materials, (iv) local and sustainable food, (v) sustainable transport, (vi) land use and wildlife, (vii) local economy, (viii) sustainable building design principles, site design and technologies;
(b) creating a sense of place through including public piazza's or public squares that have access to lunch time sunshine. These public spaces could also serve to promote the history of the area through the use of plaques and photos. Historic references help create a sense of place and its importance and are a common feature throughout European cities and towns.
3.3 Principle 2: A globally connected and competitive Melbourne
The Discussion Paper's identification of building opportunities in the knowledge economy is strongly supported to improve productivity and to create export opportunities. However the discussion in the paper about the knowledge economy is limited in scope and does not appear to advance the importance of facilitating collaboration between universities, business, industry and government in advancing the knowledge economy through invention and innovation opportunities. Competition from rapidly developing Asian states present potential limitations to competing globally in specific market sectors, for example in manufacturing, unless embedded cost structures are overcome through technological advances.
The global connectivity envisaged in the Discussion Paper needs to put in place a plan to address the State's productivity output and to review the major employment sectors and their capacity to contribute to this principle. A review of this kind needs to prioritise sectors with capacity to contribute, including modelling of their growth trajectory over the strategy timeline.
In terms of freight and logistics it is a major concern that Victoria is over committed to road transport and has no intention to transition to rail, a highly efficient, fast and cleaner form of transport. Increasing energy costs may impact on Victoria's competitiveness through its over reliance on road transport.
1. That the Government set targets for increasing productivity in existing sectors to improve global competitiveness;
2. That opportunities in renewable technologies be included in the work of innovation clusters.
3.4 Principle 3: Social and economic participation
The extensive spread of Melbourne in all directions is a major concern and a failure of planning by successive governments. As discussed above, the role of the construction sector in the State's economy is directly related to repeated extensions to the urban growth boundary. Until the government diversifies the economy and becomes less reliant on this sector, the pattern is likely to continue.
3.5 Principle 4: Strong communities
The Discussion Paper rightly draws attention to the need to lower pressure on price. It identifies the costs of commercial construction in Melbourne as being higher than other cities and that this limits the ability to build medium density apartments in suitable suburban locations.
Apart from construction costs, another direct impact on affordability is the significant amount of overseas investment in housing, including apartments. Overseas investment places pressure on demand and its role in creating pressure on affordability needs to be investigated and addressed.
Various strategies are applied by European countries to limit impact on housing affordability through overseas investment and it would not be unreasonable for Australia to review the impact on affordability from foreign investment.
As noted in the Discussion Paper the size and standard of houses needs to be considered. Australian house sizes are the largest in the world and this is clearly unsustainable from both a materials and carbon emissions perspective. The economic model involved in construction needs to be reviewed and productivity needs to be increased.
3.6 Principle 5: Environmental Resilience
3.6.1 Energy efficient urban design
Major omissions from the Discussion Paper concerning the outcomes sought are clear targets regarding carbon reduction strategies. The current Australian Building Code for Victoria has low environmental and energy efficiency performance standards for the class of building comprising residential multi storey built form and for commercial buildings, while for houses the plan to increase to 6 star energy efficiency was not implemented and remains at 5 star.
Typically, Australian dwellings account for higher emissions than in the UK, at around 8 tonnes of CO2 per annum, because of the high proportion of coal used in electricity generation.  Across Australia residential electricity consumption accounted for 24% of greenhouse gas emissions in 2009. Total residential sector energy consumption across
Australia was 401 petajoules (PJ) in 2008, forecast to rise to 467 PJ in 2020 (DEWHA, 2008). 
The following table demonstrates the profile across Australia for energy demand within the home. It should be noted that regionally, the share of heating/ cooling load can vary as result of different climate conditions.
Source: Government of Australia (2011) 
As noted under Principle 4: 'Strong communities' above, new Australian dwellings are a third larger than 20 years ago and are the largest in the world in median floor area at 214.6 square meters in 2009 (ABS). 
It is considered essential that the plan for Melbourne's future contains energy efficiency targets for housing to comply with national targets for the reduction of greenhouse gas emissions by 2020.
1. That effective environmentally sustainable design principles (ESD) including significant energy reduction demand be implemented in new housing communities, including growth corridors and new suburb developments such as Fisherman's Bend;
2. That housing communities based on the UK Bioregional solutions for sustainability such as BedZED be implemented. The Fishermans Bend residential rezoning would be an ideal site at which to implement these standards;
3. That waste reduction combined with recycling be embedded in the infrastructure provided in new housing estates;
4. That with regard to lower impact transport, bicycle paths, separate from roads, be constructed in new housing estates.
3.6.2 Food production
Attention to local food production as a means of advancing food security is strongly supported. This section of the Discussion Paper needs to be advanced with specific plans and targets across the metropolitan area so that all suburbs have access to back up food supplies that are not reliant on transport. The term "Food Security" needs to be addressed as a relevant strategy in the 40 year time line of the Paper.
That the food production section of the Discussion Paper needs to be renamed 'Food Security' and advanced with specific plans and targets across the metropolitan area so that all suburbs have access to back up food supplies that are not reliant on transport.
4. WHAT DO YOU THINK OF THE IDEA OF IDENTIFYING AND REINFORCING EMPLOYMENT AND INNOVATION CLUSTERS ACROSS MELBOURNE?
4.1 Innovation clusters
It is not clear what is intended by this proposal as the present innovation clusters involve universities and their location and numbers are not likely to be flexible. Universities are mandated to conduct research and the outcomes of research include invention and innovation. All businesses ought to carry out innovation and a useful model for this is to seek consultancy engagement with nearby universities on specific aspects of their business. For example, the City of Whitehorse has engaged academic consultancy to assist it to develop and implement a 'Climate change adaptation plan' in 2010 and an associated set of environmental strategies.
While innovation clusters are a good model for reinforcing employment, it may not be feasible to extend the clusters associated with The University of Melbourne and Monash Universities to all Victorian universities owing to cost and expertise limitations. An alternative model is to facilitate consultancy engagement with academic staff with appropriate expertise to assist business and government to develop their plans based on international best practice research and competitiveness.
That business innovation, competitiveness and growth be augmented through facilitating engagement / consultancies with academic staff working as part of a team in business and government to develop their plans based on international best practice research and competitiveness.
5. WHAT IS NEEDED TO SUPPORT GROWTH AND DEVELOPMENT IN REGIONAL CITIES?
5.1 Principle 6: A polycentric city linked to regional cities
The environmental and ecological implications of city and regional linkages throughout the State need to be considered. Victoria has the lowest proportion of its original extent of native vegetation remaining of any Australian state or territory. Across much of Victoria the extent, condition and configuration of remnant native vegetation is the primary determinant of ecological health.
Fragmented landscapes make up nearly 79% of Victoria and account for 54% of the current extent of native vegetation. Fragmentation is a driver of ecosystem fragility and consideration needs to be given to reinforcing green wedges and corridors and ensuring that they are not impacted by infrastructure and development. The condition of each bioregion in Victoria have been mapped and identified and this information can be used in determining sites for city - regional linkages.
Ongoing development of the urban growth boundary is likely under the proposals in the Discussion Paper and there is concern that the vision of a city of cities and regional linkages is a strategy to exploit land indiscriminately for development without setting aside land for agricultural and environmental/ecological purposes.
This is a particularly heavy handed vision that is ultimately self-defeating as the environmental costs are eventually a matter to be addressed by the State. Issues of pollution, congestion, ecosystem breakdown, species extinction, threats and vulnerabilities are likely scenarios under the model being advanced in the Discussion Paper.
1. That no further expansion of the urban growth boundary be permitted;
2. That productive agricultural land be identified and quarantined from development;
3. That agricultural land in the metropolitan area be identified and set aside for this purpose;
4. That documented fragmentation of ecosystems be addressed through funds set aside for restoration;
5. That the framework for regional linkages be based on consideration of the protection of environmental and ecological systems, taking into account the mapping and identification of each bioregion and its condition.
6. WHAT DO YOU THINK OF THE IDEA OF A ‘20 MINUTE CITY’?
6.1 Principle 7: Living Locally - A '20 minute city': linked to 'Unlocking capacity in established suburbs'
The 20 minute city sounds appealing on face value but it has a number of inherent corollaries that are not adequately outlined in the paper. These include:
(a) the assumption that population growth contributes to the economy but without providing documented evidence;
(b) an extensive duplication of facilities and infrastructure implied in this strategy can only be justified economically on the grounds of a minimum quantum of consumers and is therefore based on high populations and building densities;
(c) in areas where the population is ageing it is likely that the population density would need to be higher than otherwise to justify investment as this demographic are lower consumers;
(d) the issue regarding affordability as presented in the Discussion Paper means reducing the price of a three bedroom townhouse apartment by $100,000. What is not disclosed is that developers base their business model on gaining specific returns on investment in any project and this needs to be achieved for the development to proceed. The reduction of $100,000 on the price of an individual townhouse at a development site needs to be made up through more townhouses being built on the site and therefore contributing to higher density.
(e) the 20 minute city is another way of referring to an "activity centre" as defined under Melbourne 2030 but with the disadvantage that high density development and population will be allowed to occur throughout suburban streets and not limited to activity centres.
The '20 minute city' is associated with the 'Unlocking capacity in established suburbs' proposal and together they would involve a radical and undesirable departure from the current planning scheme. As noted above under paragraph 5.2, these proposals devolve planning decisions direct to developers and effectively remove local government from substantive planning decisions. A characteristic of this system is radical free market development together with uncertainty as to the type of developments that would take place in any residential street.
That the '20 minute cit'y proposal be reviewed taking into account the issues outlined above.
7. HOW CAN ESTABLISHED SUBURBS ACCOMMODATE THE NEEDS OF CHANGING POPULATIONS AND MAINTAIN WHAT PEOPLE VALUE ABOUT THEIR AREA?
7.1 Unlocking capacity in established suburbs - code for high density and high rise and radical free market development
'Unlocking capacity in established suburbs' is code for: (a) high population density and high rise development in existing suburbs and suburban streets; (b) placing pressure on existing infrastructure to cope with higher population demands but without expenditure on system renewal and replenishment; (c) further vegetation clearance and ecological impacts; (d) decline in living standards.
As a planning strategy for the next 40 years in Victoria this proposal is one of the most objectionable aspects of the Discussion Paper as it would:
(a) ensure public uncertainty throughout the metropolitan region regarding development levels in individual streets and
(b) devolve planning decisions direct to developers and effectively remove local government from substantive planning decisions.
Established suburbs of high value per square metre and access to infrastructure would be especially vulnerable to high density development. This includes municipalities such as Boroondara, Stonnington, Bayside, Port Phillip and Banyule.
The implications of such a strategy need to be considered in terms of political ramification,s as individuals who invest in these suburbs have a high commitment to their amenity. The convergence of threats to:
(a) the belief that planning is orderly and determined by local government; and
(b) local neighbourhood amenity and character,
are highly contentious and provocative.
That the proposal to unlock capacity in established suburbs be withdrawn.
8. HOW DO WE ENSURE A HEALTHY AND SUSTAINABLE ENVIRONMENT FOR FUTURE GENERATIONS?
8.1 Planning for public open space
As noted under paragraph 3.1, the establishment of major areas of reserves for parks was an essential feature of the layout of early Melbourne. Despite substantial population growth, State and local governments have not supplemented the total area of parkland in relation to population growth. Consequently parks today are under pressure to act as multi purpose facilities, especially for use by sporting groups; in some cases, such as Royal Park, sections of them have been redeployed for public buildings.
The legislative framework supporting public open space, such as provision in the Sub Division Act and in the Planning and Environment Act, is very poor, with the result that minimal increases have occurred over decades.
Historically, it should be noted that Victoria had an open space per capita standard which was originally developed by the Melbourne and Metropolitan Board of Works in 1954. An open space per capita standard used in Victoria is 3.03 hectares per thousand people, of which 1.5 hectares is for organised recreation.
The importance of this standard is that it sets a baseline of public open space in relation to population. The standard needs to be further developed by taking into account population density by precinct, together with the specific needs of each community.
1. That urban structure be designed in relation to ecologically sustainable design principles including: (i) zero carbon, (ii) zero waste, (iii) sustainable materials, (iv) local and sustainable food, (v) sustainable transport, (vi) land use and wildlife, (vii) local economy, (viii) sustainable building design principles, site design and technologies;
2. That a sense of place be created through public piazza's or public squares with access to lunch time sunshine;
3. That provision for public open space be addressed by relating the amount of public open space to population by precinct and municipality;
4. That the Sub Division Act be changed to mandate contributions to Local Government specifically for the purchase of additional land for this purpose rather than allowing contributions to be spent on maintenance of existing open space.
8.2 Public transport infrastructure
It should be noted that early governments, developers and business investors were responsible for establishing an extensive public transport infrastructure through the development of tram and rail networks and systems. The first railway line was established in the 1850s when Melbourne's population was around 20,000 people. The first tram lines were opened in the 1880s when the population of Melbourne was still under 500,000.
Today's tram and rail networks have added limited capacity to the public transport infrastructure in place by the 1920s and investment has not kept pace with population growth and demand. It is significant that there are no fast trains in Melbourne and that the network provides limited service to the growth corridor suburbs and no service to Melbourne Airport, Tullamarine. It is essential for a globally connected city to offer favourable international comparisons and an airport - city train link is well overdue.
There is a strong need for the Federal government to provide funding for states to supplement their aged public transport infrastructure to bring it up to date with internationally benchmarked comparisons including fast rail. Much of the surplus of the previous Liberal Federal government was returned to individuals in the form of tax cuts instead of being put towards public infrastructure replenishment. Policies that ignore national needs create capacity constraints that impact nationally in the longer term. It is considered that the State government needs to argue this case at COAG and to establish the principle at COAG that accumulated surpluses are to be used for national infrastructure upgrades and replenishment and not distributed to individuals as tax cuts.
1. That the State government presents a case at COAG to establish the principle that accumulated budget surpluses are to be used for national infrastructure upgrades and replenishment and not distributed to individuals as tax cuts;
2. That a dual train line from Melbourne to Melbourne Airport, Tullamarine be budgeted and implemented as a high priority.
8.3 Energy efficient urban design
As noted under paragraph 3.6.1, clear targets are required regarding carbon reduction strategies. Electricity consumption accounted for 24% of greenhouse gas emissions in 2009 and this outcome needs to be reduced.
The recommended reduction strategies are: (a) reduction of house sizes by 33% to bring them back in line with the early 1990s and proportional to smaller family sizes; (b) mandated environmentally sustainable design standards including passive solar and other low cost design measures; (c) introduce gradual targets aimed at zero carbon emissions and waste by 2020.
9. WHAT DO YOU THINK ABOUT THE POSSIBLE WAYS OF FUNDING INFRASTRUCTURE?
9.1 Federal government contributions to infrastructure
As noted under paragraph 8.2 there is a strong need for the Federal government to provide funding for states to supplement their aged public transport infrastructure to bring it up to date with internationally benchmarked comparisons including fast rail.
The distribution of previous accumulated Federal budget surpluses to individuals in the form of tax cuts is considered inappropriate. Instead, surpluses should be put towards public infrastructure replenishment. The State government needs to argue this case at COAG and to establish the principle at COAG that accumulated surpluses are to be used for national infrastructure upgrades and replenishment and not distributed to individuals as tax cuts.
10. HOW CAN ALL LEVELS OF GOVERNMENT, BUSINESS AND COMMUNITY WORK
TOGETHER TO CREATE THE CITY YOU WANT?
10.1 Principle 9 Leadership and partnership
Concern is expressed over principle 9 regarding the suggestions of: (1) a new governance structure and (2) a revised planning policy. No details are provided and these proposals are advanced at the back of the Discussion Paper.
1. That clarification be provided about the proposal to introduce: (1) a new governance structure and (2) a revised planning policy.
2. That any changes to introduce a free market for development and remove local government from responsibility for all planning decisions are rejected.
11. ANY OTHER COMMENTS
11.1 Comments on the capacity of the Discussion Paper "Melbourne, let's talk about the future" to effectively support strategic planning
Overall, the principles and ideas advanced in the Discussion Paper, "Melbourne, let's talk about the future" are elusive, vaporous and aspirational as the document contains no clear direction as to what it intends to achieve. The absence of intent makes it difficult to contemplate the vision and strategy being advanced. On this count alone, the document fails as there is no tangible framework being advanced on which one can comment.
The Discussion Paper has been prepared to seek feedback from the community for the preparation of a new planning strategy for Melbourne but as a planning strategy for the next 40 years it fails on several counts:
1. climate change and its diverse impacts are potentially the major influence over the economy, liveability, business productivity and competition but its relevance over the 40 year timeline of the strategy appears to be afforded relatively minor status rather than addressing it as a core component of the strategy;
2. capturing business opportunities arising from innovation and invention in developing resilience against climate change impacts appear to be lacking despite ideas for innovation clusters and a metropolitan framework based on jobs outlined in Principle 2;
3. the relevant legislative framework supporting planning such as the Planning and Environment Act and the Sub Division Act contain weak infrastructure provisions but the document is unclear as to how best to respond to the identified urgent need for infrastructure upgrades;
4. the document appears to be primarily concerned with addressing: (a) questions of economic importance to Victoria such as attracting business investment and facilitating business investment through freight, ports, airport upgrades and additions; (b) optimising existing soft and hard infrastructure by maximising populations within existing suburbs, euphemistically called 'the 20 minute city' and unlocking capacity in established suburbs; (c) job creation; and (d) social questions such as housing affordability and as such appears to be essentially an economic plan;
5. the concept of town planning is subordinated to delivering additional construction opportunities through: (a) density intensification and (b) continuing urban sprawl through linkages with regional cities;
6. an acceptance of road transport as the major means of commuting and for freight instead of directing a transition to rail which is far better developed in the international cities with which connection is anticipated;
7. no tangible plan and enabling mechanisms for delivering additional public open space in the form of parks and gardens to alleviate congestion and to compensate for high density livings;
8. the Discussion Paper is framed around a series of principles and ideas but there is no clear identification of the core strategies that will enable Melbourne to be positioned for the future and to successfully achieve its economic, social and environmental aspirations;
9. lack of protection of the green wedges (p40, Principle 5, Environmental Resilience, does not confirm protection but states that it is expected that protection will continue);
10. absence of vision for developing housing communities based on the UK Bioregional solutions for sustainability such as BedZED. The Fishermans Bend residential rezoning would be an ideal site at which to implement sustainable communities based on the One Planet Communities principles. See website at: http://www.bioregional.com/flagship-projects/one-planet-communities/bedzed-uk/
The Melbourne 2030 document, prepared in October 2002, and made available for public comment, as a planning strategy, was a superior plan in that it outlined a fully formed strategic framework including the following elements:
(a) statement of vision
(b) set of principles
(c) a set of 9 key directions for example, Direction 5: 'A great place to be' (Melbourne 2030 p91);
(d) a range of clear policies supporting each key direction, for example, '5.6 'Improve the quality and distribution of local open space and ensure long-term protection of public open space'(Melbourne 2030 p91);
(e) a set of specific initiatives intended to support each separate policy, for example, 5.6.1 'Review mechanisms for strategic open space planning in consultation with open space management agencies in light of the Parks Victoria strategy 'Linking People and Spaces'.
The Discussion Paper, 'Melbourne, let's talk about the future' barely acknowledges that an existing strategy is in place (it may not agree with it but it ought to recognise that Melbourne 2030, with its various difficulties, is the current planning strategy) and in many ways, this draft strategy builds on Melbourne 2030 - see Appendix A, Table 1.
It should be noted that this will be the sixth strategic plan for Melbourne in 25 years; a plan on average about every four years, together with a number of minor plans. It is clearly unsatisfactory and inefficient for the State government to be directing considerable resources into planning strategies at such regular intervals and implies that the plans are superficial and / or uncertain about the proposals advanced.
According to Michael Buxton  some earlier plans for Melbourne involved years of research and investigation together with the modelling of options. He considers that the Melbourne and Metropolitan Board of Works (MMBW) strategic planning was exemplary for investigation and consideration of options, particularly the 1954 and 1971 plans.
The 1954 plan entitled 'Melbourne Metropolitan Planning Scheme Report' observes:
'The plan has involved three years of painstaking and careful study of Melbourne and its people. Almost every phase of city and community life was thoroughly examined and analysed to ascertain Melbourne's present and future needs, and to determine the most suitable course for sound and progressive development." p132 
This level of research and preparation formed a comprehensive, informative and long-term plan.
That the Discussion Paper, "Melbourne, let's talk about the future" be revised as a fully formed strategic framework including the following elements, as contained in the Melbourne 2030 document:
(a) statement of vision
(b) set of principles (possibly adapted from the current Discussion Paper)
(c) a set of key directions for example, Direction 5 in Melbourne 2030: 'A great place to be' (Melbourne 2030 p91);
(d) a range of clear policies supporting each key direction, for example, '5.6 'Improve the quality and distribution of local open space and ensure long-term protection of public open space' (Melbourne 2030 p91);
(e) a set of specific initiatives intended to support each separate policy, for example, 5.6.1 'Review mechanisms for strategic open space planning in consultation with open space management agencies in light of the Parks Victoria strategy 'Linking People and Spaces' (Melbourne 2030 p103).
11.2 Civil defence and town planning
The 1954 MMBW 'Melbourne Metropolitan Planning Scheme Report' includes a chapter entitled 'Decentralisation and Civil Defence'. In a section called "The problem of civil defence" it draws attention to the need for town planning to consider the risks of warfare and to take precautions to minimise loss of life and property in the event of attack. It recognises the role of public open space in breaking up the urban mass of buildings and residences supported by a system of communication to assist with movement throughout the area.
"The increasing concentration of population in cities must be looked at from a new angle. No large city today can afford to ignore the risks of warfare, and must take all practicable precautions in its civic development to minimise loss of life and property should it be attacked". 
Although contemporary Western society has become complacent about war, the complete lack of planning for its potential may appear negligent.
It is recommended that consideration be given to including the provision for civil defence in the current metropolitan Melbourne planning strategy as its absence appears to assume that planning for this purpose is irrelevant.
COMPARISON OF MELBOURNE, LET'S TALK ABOUT THE FUTURE WITH MELBOURNE 2030
 See http://vancouver.ca/green-vancouver/targets-and-priority-actions.aspx
 The Critical Decade: Extreme Weather. Report by the Australian Climate Commission, April 2013
[3Productivity Commission Economic Structure and Performance of the Australian Retail Industry, Draft Report, Canberra, July 2011
 Daley, John and Walsh, Marcus (2011), ‘Losing the productivity race’, Australian Financial Review, 7 July, 63.
 Sources: ABS, Australian System of National Accounts (5204.0), State Accounts (5220.0), and The Labour Force, Australia, Detailed, Quarterly (6291.0.55.003; Grattan Institute calculations, based on table by Eslake, S. in 'An analysis of Victoria’s labour productivity performance. Presentation to a forum hosted by Victorian Department of Innovation, Industry and Regional Development, 14th April 2010.
 Eslake, S. in 'An analysis of Victoria’s labour productivity performance. Presentation to a forum hosted by Victorian Department of Innovation, Industry and Regional Development, 14th April 2010.
 Freebairn, J. "Flat economy will continue to challenge the Victorian government" in 'The Conversation', an online academic journal, 13 March 2013.
 The contribution of housing to carbon emissions and the potential for reduction: an Australia-UK comparison, 18th Annual Pacific-Rim Real Estate Society Conference Adelaide, Australia, January 2012
 Department of Climate Change and Energy Efficiency. Australian National Greenhouse Accounts, National Inventory by Economic Sector, Commonwealth of Australia, 2009, p6.
 Department of Environment, Water, Heritage and the Arts. Energy use in the Australian Residential Sector, 1990-2020, Commonwealth of Australia, 2008
 The contribution of housing to carbon emissions and the potential for reduction: an Australia-UK comparison, 18th Annual Pacific-Rim Real Estate Society Conference Adelaide, Australia, January 2012, p6.
 Department of Climate Change and Energy Efficiency. Quarterly Update of Australia’s National Greenhouse gas Inventory, March Quarter 2011, Commonwealth of Australia, 2011
 The contribution of housing to carbon emissions and the potential for reduction: an Australia-UK comparison, 18th Annual Pacific-Rim Real Estate Society Conference Adelaide, Australia, January 2012, p5.
 Victorian Environmental Assessment Council Melbourne Metropolitan Investigation Discussion Paper, October 2010, p102.
 “Melbourne Metropolitan Strategy – Con Job or for Real?”. Buxton, M, Professor of Environment and Planning, RMIT University.
 Melbourne Metropolitan Planning Scheme Report 1954, Explanation of the planning scheme submitted to the Town Planning Committee by E. F. Borrie, M.C., M.C.E., MIC . Aust., F.A.P.I., Chief Planner, on behalf of the planning staff.
 MMBW 'Melbourne Metropolitan Planning Scheme Report' 1954, p28
The Australian Wildlife Protection Council (AWPC) is gravely concerned by the ‘use and commercialisation of Australian native animals’, their extinction rates, cruelty inflicted on them, and recreational hunting. Even more so, given that Australia has the world’s highest extinction rate. Instead of apologising for crimes against nature, the Victorian State Government seeks to extend further exploitation.
(Candobetter Ed. Some headings in this submission have been changed for clarity of presentation.)
Australian Wildlife Protection Council (AWPC)
288 Brunswick Street
Environment Policy Division
Department of Sustainability and Environment
PO Box 500 East Melbourne VIC 3002
With reference to
Wildlife Regulations 2013 Regulatory Impact Statement
3 May 2013
The Australian Wildlife Protection Council appreciates the opportunity to provide a submission.
We are gravely concerned by the ‘use and commercialisation of Australian native animals’, their extinction rates, cruelty inflicted on them, recreational hunting. Even more so, given that Australia has the world’s highest extinction rate.
Instead of apologising for crimes against nature, Government seeks to extend further exploitation.
"Protected" wildlife should remain protected.
Australian Wildlife Protection Council (AWPC) was founded in 1969.
Our members are dedicated to the preservation of Australia’s native animals, their protection from exploitation, and any other cruelty to which they are routinely subjected, so that they can live safe in their native habitat across their natural ranges.
We seek their freedom from lethal controls, agricultural toxins, herbicides, pesticides, and poisons like 1080, fenthion, fenitrothion. We believe that wildlife needs to be protected and conserved in their natural ecological habitats.
We seek a change in attitudes, especially when they are needlessly killed, poisoned, commercialised and otherwise persecuted.
We aim to promote the intrinsic qualities of kangaroos and Australia's wildlife heritage so that viable populations are seen as desirable and valuable.
We aim to promote the viewing of large mobs of kangaroos as a first class wildlife experience and support the development and marketing of wildlife-based tourism.
The letter below totally encapsulates the opinion of AWPC, we are repulsed by the subaltern attitude with which DSE and this Government treat the citizens of this state.
The Age, April 27/28/2013 Joan Reilly, Surrey Hills
“The state government is reviewing the wildlife regulations but, although the consultation concludes in less than a week, readers of “The Age” are unlikely to have heard of it. The relevant notices were placed only in the Murdoch tabloid and the Government Gazette, some three weeks ago”.
Members of the public and animal welfare groups and animals themselves are omitted from the list of stakeholders affected by the proposals. Anyone concerned to find out about new rules for those who trap, keep, breed, trade, kill or process wildlife will need to peruse some 200 pages of proposals and also refer back to about 80 pages of existing regulations to understand what will change”.
“The focus is on economic benefit to businesses and reduced public sector workload.
The arrogance of this regulation by stealth is breathtaking”.
“There is a strong and growing interest in the Victorian community to keep wildlife as pets”.
While some smaller native animals such as reptiles, fish and birds can be housed and cared for appropriately as pets, we do not endorse opening up more wildlife species for commercial sales.
“Without the regulations in place, there would be no authorising mechanism to allow legal trade, possession and use of wildlife in Victoria”.
We appreciate that wildlife parks will breed native animals to keep their populations relevant and viable.
However, “there is also a demand for the farming of some species of wildlife, the processing of wildlife products, the control of wildlife causing problems to people through disturbance or damage to property and the private possession of mounted wildlife”.
Kangaroos, in particular, cannot be farmed; kangaroos cannot be yarded, herded or transported as are domestic livestock. AWPC vigorously opposes “farming” of wildlife, the use of their body parts as such practices ignore the most basic behavioural and dietary needs of this living behaving biological entity. “Control” of wildlife is already out of control.
“DSE estimates that the annual expenditure on wildlife by private and commercial licence holders is in the order of $63.7 million per annum”.
There's a very malicious and anthropocentric attitude that wildlife are obliged to satisfy some usefulness to humans, to contribute to pleasure, entertainment or commercial profits, and conversely, wildlife can be eliminated if they cause any “problems”, “disturbance” or “damage” to property or profits of landholders. Wildlife should remain wild, and should not have to justify their existence in monetary terms. The harvest of native animals from their native habitat is prohibited under the Wildlife Act 1975. This should remain the case and legislation regarding wildlife should be primarily for conservation, protection, and education.
The need for regulations
“New regulatory proposals, including the remaking of expired regulations that impose a significant economic or social burden on a sector of the public, require the preparation of a Regulatory Impact Statement (RIS)”.
The “economic” and “social burden” is green tape designed to protect wildlife. Wildlife issues must be addressed holistically, and landholders need to be given expert advice on land use and wildlife deterrents to avoid conflicts. The efficiency and effectiveness of regulations should endorse their original aims and objectives, not increase human gain and economic benefits. Tragically, many unique animals are found nowhere else but south-eastern Australia, Victoria. Yet, they are being pushed to the brink of extinction by habitat loss, introduced species, infectious diseases, fire, urban sprawl and climate change. Clearly, the excessive numbers of human activities means that present legislation and policies to protect wildlife in Victoria are not working, and species are being lost. The Wildlife Act 1975 needs to be upgraded to create better guarantees for species protection, more native habitat for their long-term survival, and interconnecting bio-links (wildlife corridors) to save species.
"The purposes of the Wildlife Act 1975 (Vic) are:
to establish procedures in order to promote -
the protection and conservation of wildlife; and
the prevention of taxa of wildlife from becoming extinct; and
the sustainable use of and access to wildlife; and
to prohibit and regulate the conduct of persons engaged in activities concerning or related to wildlife."
AWPC does not support any “use” of wildlife except for educational and conservation purposes. The original aim of the Wildlife Act 1975 must be strengthened, to provide greater protection of habitat, elimination and/or control of introduced species, fire, urban sprawl and climate change. Australia’s unique wildlife lived safely in near-pristine environments for millions of years, but European settlement has taken a catastrophic toll on their long-term survival. Exemptions for landholders, those with vested interests to utilise wildlife, would create more deaths, increase illegal trade and commercial profits.
3. Proposed wildlife regulations
The proposed regulations incorporate some new provisions and changes, including streamlining some licence categories, resetting fees, adding a number of new species that may be kept and introducing multi-year licences.
We object to “adding a number of new species” that may be kept by the public. Native birds live in flocks. Isolating them in cages is a tragic existence.
It is ethically wrong to keep pet birds in tiny cages where flying is inhibited. Native parrots and cockatoos should not be confined in cages but only in aviaries with sufficient height, depth and width for flight and social interaction with other birds. Cockatoos are large birds and have large requirements. They are not suitable as backyard pets in cages. The numbers in cages need to be limited according to space. (experts must specify according to size, breed and behaviours). They need to be only kept in very large aviaries, in wildlife parks or in regional areas with carers experienced in the care of native parrots and cockatoos - and their special needs.
Native mammals need habitat and specialised food sources to live ethically and naturally. There are already a large variety of domestic pet species of animals available; pet rescue centres struggle to provide services to keep up with demand. We have “death row” for unwanted and homeless cats and dogs, puppy factories that churn out puppies to an already over-saturated market. Cruelty, neglect, over-breeding, abandonment are the flip-side of our so-called pet-friendly society.
It is immoral and unethical to add native animals to these shocking statistics.
Wildlife controller licences are to be categorised into 2 types.
AWPC is already concerned by the liberal and excessive way DSE hand out licences to “control” wildlife with Authority To Control Wildlife (ATCW) permits, without first obtaining expert advice on alternatives to killing, or even checking to see if there is justification that such “control” is valid.
Two categories for “controlling” wildlife is odious, undesirable and totally unnecessary. Instead there needs to be more DSE wildlife officers on the road, visiting farmers and landholders, and making sure that lethal “control” is the LAST RESORT not the first option.
The ATCW permit system is only a quasi set of rules and regulations and is in desperate need of total law reform as evidenced in our letter to Greg Wilson, Secretary DSE dated 26 August 2012.
Wildlife Processors Licence
AWPC is extremely concerned about this licence, the “processing” of wildlife for commercial benefits is something that the AWPC strongly opposes and we believe this licence is a thinly veiled attempt to usher into Victoria a commercial Kangaroo industry.
We are very aware of the changes the Victorian Government has made to the Ministerial control of the Wildlife Act the majority of which is under the control of Peter Walsh Minister for Agriculture and Food Safety which begs the question; what connection is there between wildlife and agriculture? Apart from the frequent issuing of ATCW’s It has been proven on many occasions that a commercial kangaroo industry in Victoria isn’t ecologically sustainable. (CSIRO 1982)
The DSE issues thousands of permits to cull kangaroos in Victoria each year - with the aim of controlling wild populations. Carcasses are often left to rot on the ground after a cull creating potential disease risks while providing a food source for feral animals and in turn, encouraging the growth of fox populations.
The practice of leaving Kangaroo carcasses on the ground has germinated the idea that these carcasses should be available for commercial use, hence the need for a ‘processor’s licence’
The commercial use of Kangaroo carcasses shot under and ATCW permit is insanity because of the logistics of collection, hygiene and knowledge of where and when Kangaroo culling will occur.
The issuing of a processors license for this reason, no matter how illogical or unsustainable it may be does however serve a purpose and AWPC believes this purpose is the subterfuge introduction of a commercial Kangaroo industry into Victoria once processor licenses are available.
A new category of wildlife licence, the Dingo Licence, has been introduced for those wishing to keep dingoes. This will incur a fee similar to a Wildlife Advanced Licence.
We note that some native rats, cockatoos and parrots have been added to the list of species:
Schedule 4A means that there's no licence for commercial trade or possession. There will be little regulation for this species and they will be sold at market. They will end up similar to gold fish or canaries, with no guarantee for their welfare or specialised social, spatial and environmental needs.
4. Regulatory Impact Statement
“Wildlife enthusiasts will benefit from continued recreational wildlife ownership opportunities and businesses that possess, trade or use wildlife will benefit from a well- managed, legal and robust industry”.
The AWPC opposes industrialisation or the commercialisation of wildlife. The idea of a “robust” industry is contrary to the aim of conservation and animal welfare policies of the AWPC. We do not want or support the economic growth of “industries” associated with wildlife, unless they support their holistic conservation and education of the public.
5. Monitoring and Enforcement
“Monitoring of licence holders will be carried out through targeted and random inspections of premises and record books by DSE Wildlife Compliance Officers or in response to suspected illegal activity or non-compliance with the requirement to submit annual returns”.
If there are enough Victorian government personal resources for these random inspections, they should include random inspections of property owners before they are able to lethally “control” (kill) wildlife.
Wildlife Farmer Licence
The AWPC do not approve of “farms” of wildlife. Emu farms means that emus become another exotic “meat” source and end up bred in captivity, contrary to our policies. Emus belong to the oldest living family of birds on earth, the rarities or flightless fowl. They are nomads, designed by 90 million years of evolution to roam over vast tracks of land.
Subjecting emus with their long thin necks and legs, and large fragile eyes, to transport is cruel and inhumane. Slaughter bound birds and mammals are typically starved for hours, even days before they are killed. Hauled in all kinds of weather, they are forced to endure truck vibrations, heat, stress, cold, damp, thirst and terror. They are then shot with a captive bolt, like cattle or, like poultry, electrically shocked (not stunned) and then hung upside down to have their throats cut, being kept alive when their blood drains. They are slaughtered at 12-15 months of age. This is degrading, and trivialising these unique birds. Adding any “game” birds to this farming category is unconscionable and unethical.
Game Bird Farmer Licence
“Allows the holder to farm game birds that have been bred in captivity for the purpose of releasing them on a specified premise for hunting (from Part A of Schedule 5 and specified in the licence)”.
We do not believe in the recreation of hunting wildlife. Breeding in captivity for hunting is akin to canned hunting, and is something which is abhorrent to wildlife activists and lovers.
Attachment (A ) - Key changes in the proposed Wildlife Regulations 2013
“Wildlife Controller Licence Allows the holder to take wildlife from the wild and to destroy, dispose of or sell that wildlife for the purpose of removing danger to persons or property from that wildlife (from Schedule 6, and specified in the licence)”.
Examples of species that may be controlled under this licence are venomous snakes, deer, Common Brushtail Possums and Sulphur-crested Cockatoos”.
Deer are NOT Australian wildlife. Common Brushtail Possums and Sulphur-crested Cockatoo never endanger human lives, and there are non-lethal methods of deterring their impacts.
Possums are native wildlife. All native wildlife is protected under the Wildlife Act 1975. There are non-lethal ways of dealing with possums, such as relocation and trees and gardens around our houses provide modified woodland similar to their natural habitat. People and possums can live together successfully.
There are companies that supply engineering controls for cockatoos, including ultrasonic devices, kites and other visual deterrents, low voltage shock tape, birdspikes and noise deterrents.
[Any Proposal for a Commercial Kangaroo Industry in Victoria..].
AWPC advises that should consideration be given to the introduction of a commercial Kangaroo industry into Victoria, the following must be carefully read and understood before any final decisions are made.
Weekly Times article favours commercial kangaroo culls
“The ban on commercial processing of culled kangaroos in Victoria must be lifted, the Competition and Efficiency Commission has told the State Government. A draft commission report said the ban appeared ‘unnecessarily burdensome’. The Weekly Times asked Victorian Environment Minister Ryan Smith for comment on the issue, but was referred instead to the office of Treasurer Kim Wells... The commission also called on the Government to simplify the process for obtaining permits, estimating the cost of issuing each Authority to Control Wildlife Permit (ATCW) was about $480... ‘Taking into account the need for a site visit and the rigor of the permit system...yields an administrative cost of approximately $480, or $863,000 across industry”, the VCEC report said.
Victoria is the only mainland state to prohibit commercial processing of its kangaroos...” Source: Peter Hunt, 'Processing Ban ROO-Turn, Hop to it', Weekly Times, April 6, 2011.
Relative to the above Weekly times article, AWPC Submits:
"The density of grey kangaroos in western Victoria and south-eastern South Australia is only 15% of that recorded for the pastoral zone of New South Wales. Such low densities reflect the effect of intensive land use and the marginal nature for kangaroos in remaining areas of natural vegetation.” With exponential human population growth and devastation of a prolonged drought, a commercial kangaroo ‘harvest’ for Victoria would be economically unviable/ unsustainable. Kangaroos are facing more threats than ever today, with the 13 year long drought, tragic bushfires, loss of gene pool, urban expansion, floods, disease and climate change factors. Why push them further into ‘extinction’ mode, and threaten their survival even further? This is what commercial profits for kangaroo meat will do.
Kangaroo meat was classified as Game Meat in 1989 by a Game Meat Working Party, established by the Federal Government. The decision to remove kangaroos from the protected List and change their status to Game Meat was made because: (a) Kangaroo meat could not meet domestic health standards and (b) No animal welfare or conservation groups were present
Ramifications of fevered meat entering the food chain is explained by Dr John Auty, Historian, Veterinarian and former Federal Bureau of Animal Health, Canberra, ACT.
“Meat hygiene standards require for all classes of animals that any condition that can cause elevation of body temperature has the potential to cause the condition known as ‘fevered’ meat. Such meat is unsuitable for human consumption.
A condition causing blindness in kangaroos, stress, inability to eat or to find water, elevation of body temperature etc. should result in condemnation of the meat from such diseased animals. It is immaterial if this condition causes generalised septicaemia or not”.
“Kangaroo shooters are not competent to judge disease in animals ante mortem unless the disease is well advanced and it is not in their economic interests to reject animals (kangaroos)”.
“The Australian Quarantine and Inspection Service (AQIS) inspectors inspect kangaroos only after they are transferred to coastal BONING establishments i.e. after they have been eviscerated in the field. Such meat hygiene standards are not acceptable for domestic animals”.
“Whereas the diseases that affect domestic animals are well understood and form the basis for modern meat hygiene, the diseases affecting kangaroos are virtually unknown and there are virtually no Veterinarians based in the areas in which kangaroos are shot”.
How Clean is the Kill?
“Kangaroos are wild animals shot in the outback and they lay on the ground with the flies, airborne bacteria, faeces of other animals and other contaminants. Some of the diseases associated with kangaroo meat are:
*Salmonellae *Coxiella *Sarcocysts *Nematodes *Fasciolia Hepatic Flukes *Subcutaneous and Musculature Cysts *Hydatid Cysts Kangaroos carry internal and external parasites and a range of diseases
The outbreak of a blindness disease infection (Choroid Blindness) which spread across four states in the years ’94, ’95, ’96 caused the death of an estimated one million kangaroos and represented a serious ecological problem to kangaroo populations. Government attempted to keep the issue out of the public arena and displayed ineptitude and an appalling lack of responsibility.
Blind kangaroos were killed or died after jumping in front of traffic, drowning after falling into flowing rivers or starving because they could not find pasture. Source: AWPC 1999. ‘Diseases in Kangaroo Meat’ in The Kangaroo BETRAYED, Hill of Content Melbourne, pp 31-33)
Kangaroos and wallabies can harbour a wide range of parasitic, bacterial, fungal and viral diseases and the majority of infections are unapparent (i.e. animals appear normal). Even meat inspection procedures are unlikely to detect some infections unless gross lesions are detected or routine samples are taken for microbiological and pathological testing.
Worldwide, it is recognised that so-called ‘game meats’ are a source of these infections for hunters, processors and consumers, especially when care is not taken while eviscerating and handling the carcasses or when the meat from these animals is served undercooked or raw. Trichinosis, cysticercosis and toxoplasmosis are examples of parasitic zoonoses (i.e. diseases transmissible from animals to humans).
In Australia, Toxoplasmosis and the bacterial disease, Salmonellosis are two infections with public health significance directly related to the handling, processing and consumption of kangaroo meat. The October issue of Woman’s’ Day (1995) reported that a food-borne outbreak of toxoplasmosis caused acute clinical illnesses in 12 humans and one case of congenital chorio-retinitis (inflammation of the eye tissues) in a new born baby. The mother of the affected baby together with the 12 other people had attended a Christmas function at which rare kangaroo medallions were served. A thorough epidemiological investigation concluded that the most likely ‘risk food’ was the kangaroo meat.
Even ‘new’ human diseases have been shown to have origins in Australian game meat. In 1993 the first confirmed human case of Pseudotrichinosis was diagnosed. The medical investigators concluded that the patient became infected in Tasmania through eating meat, most probably derived from a wild animal. Subsequent research conducted at the University of Tasmania showed that about 2% of Tasmanians surveyed had antibodies to this muscle-encysting nematode.
Professor John Goldsmid, Lecturer in Microbiology at the University of Tasmania expressed his scientific concerns about the lack of research into a range of diseases and parasites transmissible between Tasmanian native animals and humans.
Australia has no dedicated research or diagnostic facility to investigate wildlife diseases. Detections of new diseases are handled on an ad hoc basis by government or university laboratories.
Possums trapped overnight in wire cages (comparable to that described in the brush possum code) show that cage distress and attempts to escape causes muscle damage comparable to capture-stress myopathy of deer. Tasmania is the only State of Australia listed by the WHO as having endemic trichinosis in its wildlife. The Tasmanian Department responsible for permitting a game meat industry denied there was a public health risk associated with the harvesting and processing of Tasmanian possum. Tasmanian wildlife harbour parasitic diseases which are serious infections in humans.
A recent scientific report of the International Health Organisation, the Office Internationale des Epizootes warns that wild animal meats which are raw, undercooked, dried or cold-smoked are potentially infectious to animal or humans that consume them.
The incidence of Toxoplasma abortions and infertility is amongst the highest in Australia. Free ranging wallabies, pademelons, bandicoots and wombats are regularly killed by this infection and surveys show a high percentage of wallabies harbour this infection.
The concern is that chefs and food raconteurs recommend cooking methods which would not kill this parasite.
A newly identified worm thought to be derived from marsupials was found to be responsible for acute illness in two humans. Like Trichinella they invade muscles. The worms are thought to belong to a class of nematodes known as Muscpiceoids. In wallabies and possums these nematodes live in several tissues of the body and can invade muscles.
In his paper to the University of Tasmania (1997 114 ), Professor John Goldsmid said, "Kliks (1983) identified the aetiological agents of human infectious diseases as "heirloom" or "souvenir" species, depending on their evolutionary association with humans. Amongst the most important of the souvenir species are the zoonotic infections, infecting humans as a result of animal-human contact of some kind and varying from companionable contact to utilisation of animals as a food source.
In the last 25 or so years, of 35 new or newly recognised infections in humans, 20 (57%) have been zoonotic in origin - some trivial, some devastating to both the individual and the community.
With the increase in the numbers of immunocompromised people in the community resulting from medical treatment or as a result of the spread of AIDS, the problem of zoonotic infections will continue and there seems little doubt that the likely source for many of these new human infections in Australia will be the native animal population.
People who eat undercooked wallaby or kangaroo meat could be at risk of infection by a newly-discovered animal parasite, Australian doctors have warned. The parasite was found in a Tasmanian man who suffered from inexplicable and severe muscle weakness over a number of years. He was known to consume large quantities of game. ("Parasite Risk to Game Eaters" November 7, 1997 Animal Pharmacology No. 384)
Laboratory tests suggests that the parasite is a new species of microscopic worm. It may also have been responsible for a similar infection in a New Zealand woman who had eaten wallaby meat while visiting Tasmania.
"The cases highlight the risks of eating wild game, the parasites of which are poorly understood compared with those of livestock. More studies are needed to identify disease agents in these animals and to elucidate the role of native animal species in the transmission of diseases to humans."
Victorian Competition and Efficiency Commission (VCEC) call for commercial kangaroo industry
Victoria has no fauna management framework;
Victoria has no scientific kangaroo population data. Given there is no population data, commercial utilization is economically unviable and unsustainable for survival of kangaroos.
DSE data base fails threatened species
Roads are a Threatening process
Genetic variability / Wildlife Corridors and to re-connect bio-links to save species
Human induced threats and self-limiting factors control kangaroo populations
Climate change/ population growth driving species to extinction Climate change/ population growth driving species to extinction
DSE has a Duty of Care -Kangaroos are not a Commodity to be bartered and sold
We know that overwhelmingly, it is mostly ‘hobby farmers’ who seek ATCW permits. We seek Regulations for ATCW permits to be issued only to landowners whose sole income is from legitimate farming, as opposed to ‘hobby’ farmers for tax deductibility write offs.
Left just with the sole income farmers, this becomes an area that needs education/ awareness of productive farming in harmony with biodiversity and ecosystems; Learn to live with wildlife.
This is the only way to stop the ethically, morally and humanely deficient and farcical practice of DSE issuing ATCW kill kangaroo Permits in Victoria.
Prove that the ATCW permits DSE gives away like candy are legitimate, with tight conditions
This is particularly pertinent to wildlife carers who already suffer from ATCW permits given to adjoining landowners placing at risk the very kangaroos they have a license to hand rear.
Under the current system it costs Victorian tax payers for landowners to kill protected kangaroos without their say or consent; (yet taxpayers have to pay hefty $$$ for FOI)
Why then is this cost not passed onto the landowner if they are benefitting from it?
DSE data base fails kangaroos and threatened species
In Victoria 2006, Exec Director Dr Ian Miles arranged for Department of Sustainability and Environment (DSE) Adrian Moorrees, Project Manager, Actions for Biodiversity Conservation (ABC), Biodiversity and Ecosystem Services Division to demonstrate to AWPC, the DSE Actions Biodiversity Conservation (ABC) Data Base system. We discovered that “DSE uses an inadequate Victoria-wide definition of ‘threatened’ which means that local populations can be extinguished without sounding the alarm so long as some numbers remain for the whole state ; pockets where animals appear numerous, due to fragmented populations trapped in small areas, are not assigned official ‘threatened’ status. Little effective tab is kept of numbers. More and more native species simply vanish, Sheila Newman, Environmental and Land Use Planning Sociologist for the Australian Wildlife Protection Council.
In Hamilton the west of the state, will argue that every other state has Environment Australia-approved management plans to harvest kangaroos for export. But in Victoria kangaroos are culled only for damage control. Annually, 9000-30,000 animals are authorised to be destroyed. The council will argue there is a potential commercial use for these kangaroo products, but current regulations did not allow culled kangaroos to be moved from where they died.
Ms Wolf-Tasker said it was "wonderful to see a council being pro-active on this''. "We've used kangaroo meat here for a decade but because of Victoria's rule we have to buy it from South Australia, despite kangaroos being culled here,'' she said. "Kangaroo is a great, healthy product. "It is has a more gamey flavour and is one of the last wild foods. "It is wonderful to use it with locally-grown indigenous plants from this area, such as the mountain pepper.'' Ms Wolf-Tasker said consumers increasingly wanted to know where their meat came from and kangaroo was a very popular, "natural, wild food''.
Despite concerns raised by some animal rights groups over using kangaroo meat for human consumption, Ms Wolf-Tasker said if the "necessary culling was properly regulated, using the meat for human consumption could prevent the waste of what is a very good product''. She said kangaroos needed to be culled when in plague proportions because they "caused havoc on farms and in the local environment''. A spokeswoman for Environment Minister Ryan Smith said yesterday the State Government was evaluating the feasibility of commercial harvesting of wild kangaroos with advice from the Department of Primary Industries. "We will await the outcome of that work before making decision about possible changes to regulation to allow commercial kangaroo harvesting,'' she said.
THINKK, the think tank for kangaroos, based at the University of Technology Sydney and supported by Voiceless, released two reports late last year examining the killing of kangaroos in Australia. Each year over three million kangaroos are ‘harvested’ and over a million joeys are killed as part of the commercial industry. This is the largest land-based slaughter of wildlife in the world.
The reports, titled “Advocating kangaroo meat: towards ecological benefit or plunder?” and “Shooting our wildlife: An analysis of the law and policy governing the killing of kangaroos”, conclude that:
emerging science indicates that kangaroos are not pests;
over 20 years of harvesting kangaroos has had no demonstrable environmental benefit;
increased consumption of kangaroo meat by humans is likely to place kangaroo populations at risk;
State governments once treated kangaroos as agricultural pests yet today they are treated as a resource;
The current law is a form of legalised cruelty.
Please download the reports by following this link. http://www.voiceless.org.au/About_Us/Misc/THINKK_the_think_tank_for_kangaroos.html
For additional information about THINKK, please visit their website at http://thinkkangaroos.uts.edu.au.
From Conservation to Exploitation in South Australia
“In any wild animal if you disrupt in a short period of time the normal reproduction processes that have evolved over tens of thousands of years you are in danger of putting the species at risk. Precedents have been set in other parts of the world where large populations of a species ( seals. Bison, wolves etc) have faced extinction after widespread and destructive ‘culling’ programs. Many of these species suffered incursion of exotic bacterias and viruses when their populations contained a critical and unsustainable gene pool.
To be able to undertake the largest wildlife slaughter in the world today it was necessary to undertake a long and sustained program of misinformation within Australia to convince the community that these animals are in plague proportions throughout the country areas of Australia. This was achieved by presenting he animal as a “resource” that needed to be exploited. A program of ‘shoot and let lie’ would have avoided the introduction of commercial pressures (COOMA, ACT and surrounds + MUDGEE and surrounds) on the wild animals and forced the introduction of the less destructive commercial ‘alternative’.
Where farmers and pastoralists (with sheep, cattle and crops) are in competition with any native animal, the government administrators always favour the land owner. Whatever native animal is involved, that animal is marked for destruction.
There are many examples of this entrenched ‘destructive culture’, now being undertaken in South Australia.” Source: Chapter ‘From Conservation to Exploitation in South Australia’ by Doug Reilly Macropod expert in the AWPC 1999 publication, The Kangaroo BetrayedHill of Content, Melbourne, p.37.
Maryland Wilson President
Vivienne Ortega Vice President
Cienwen Hickey Research
Sheila Newman Environmental Sociologist Land Use Planner
Sustainable Population Australia takes the State of the Environment report 2008 as a warning of the unsustainable path that Victoria is on as the government recklessly engineers its population at a rate about twice the level it would naturally be at present. This state government and its predecessors have actively encouraged population growth through the artificial means of seeking increasing numbers of migrants from overseas to settle in Victoria, using the website "Liveinvictoria.com.au".
This submission represents the overall position of Sustainable Population Australia whose Aims and Objectives are:
- To contribute to the public awareness of the limits to Australian population growth from ecological, social and economic viewpoints.
- To promote awareness that the survival of an ecologically sustainable population depends in the long-term on its renewable resource base.
- To promote policies that will lead to the stabilisation, and then to reduction, of Australia’s population by encouraging low fertility and low migration.
- To promote urban and rural life-styles and practices that are in harmony with the realities of the Australian environment, its resource base and its biodiversity.
- To advocate low immigration rates while rejecting any selection of immigrants based on race.
- To promote policies that will lead to stabilisation, and then reduction, of global population.
There are severe constraints on the population growth patterns for the future in Australia including in the relatively environmentally hospitable state of Victoria. Sustainable Population Australia takes the State of the Environment report 2008 as a warning of the unsustainable path that Victoria is on as the government recklessly engineers its population at a rate about twice the level it would naturally be at present. This state government and its predecessors have actively encouraged population growth through the artificial means of seeking increasing numbers of migrants from overseas to settle in Victoria, using the website http://www.liveinvictoria.com.au. As we know most of those who come to Victoria gravitate to Melbourne. The State’s capital suffers from severely worsening traffic problems, demanding costly solutions, and ongoing pressure to accommodate more and more people such that agricultural land and areas of nature on the city’s fringes are constantly sacrificed. In the established areas of Melbourne and, to a lesser extent, in the regions, greater density of living is imposed on residents who are distraught to see their surroundings changed rapidly before their very eyes and to their great disadvantage.
Planning assumes change
The concept of ‘planning’ in Victoria assumes change. Most changes in building and infrastructure are driven by population growth, especially the building of more houses and roads. Planning without growth would be about improving the way things work for a given population in the face of changes over a longer time scale not associated with growth, especially those over which humans have less immediate control such as climate change. The sole objective, however, of planning today is to accommodate population growth with scant attention to residents' amenity and services.
It is clear that due to the changes to Melbourne in the last few years, residents have been aggrieved by the loss of livability of Melbourne, despite commercially defined indexes to the contrary. This loss includes loss of amenity – light space and quiet, loss of parkland, increased traffic congestion, and diminished Green Wedges. It also impacts on our democracy as authoritarian planning laws are pushed through parliament by development-sympathetic governments against widespread public objection. The schedules of the Victorian Civil and Administrative Tribunal (VCAT) have abounded with planning problems where private citizens have had to devote time, money and energy into trying to preserve their amenity or to mitigate damages impinging on them from potential developments. This type of (often futile) activity does not increase the quality of life for people; quite the opposite, in fact. It is a significant negative for them.
Residents are facing enormous loss under the now proposed planning changes. If changes are implemented, many of their cases will simply not be heard as residents lose their appeal rights. Furthermore they will not be warned about changes made in their immediate neighbourhoods. Whilst this may expedite change and create ‘certainty’ for developers, it creates helplessness and constant uncertainty for residents. People can accommodate moderate change if it is slow, but just not knowing what changes are going to occur in their neighborhoods yet to watch it happen at a rapid rate is truly unsettling. People are depressed and traumatized for a variety of associated reasons.
Planning is for the future
Since planning is mainly about the future the following questions should be asked in considering the proposed changes.
What path does this set us on?
Is it the path of greater livability in the sense of increasing access to nature and green spaces, with secure homes and land and quality of life? Does it have an end point? What is the likely outcome of this plan? In the already established areas of Melbourne, if we understand this correctly, proposed zones are as follows, with 3 different approaches to development applied
1. Residential growth zone
2. General Residential Zone
3. Neighbourhood Residential Zone
Where you happen to live and therefore your future or fate relies on which regime is applied to your area. As this will be a council decision it introduces a further note of uncertainty.
Putting the effect on the individual aside, the aim seems to be largely to break down barriers to change, to maximize and expedite development. Of concern is the removal of the imperative to make planning application for certain developments in certain areas. This means that they will become “as of right” and will include the extension of commercial activities into residential areas.
The aggregate effect, it seems, would be more activity and congestion and more noise, especially in areas with increasing mixed use.
Increasing densification in residential areas means diminished amenity. This might be more tolerable if the city of Melbourne were not simultaneously bulging through its previous urban growth boundary thus rapidly changing the landscape on the fringes of the city. Densification necessarily means reduction of open space especially private gardens. This reduces habitat for urban wild life, much of which is essential to our well being whether we have any conscious affection for it or not! (e.g. presence of micro bats acting as a natural and indigenous control over mosquitoes.) Loss of open space and vegetation in the established areas cities also increases Urban Heat Island Effect. This means that, even without climate change our urban areas will necessarily get hotter as vegetation is reduced and hard surfaces and masses increased. The inexorable loss of open space for children to play no doubt contributes to the much publicized childhood obesity epidemic.
No matter what measures are taken for the provision of infrastructure and services such as public transport, hospitals and schools, there is no way of catching up with these even for the existing population while there is continual extra need for the addition population built into the planning scheme.
The proposed changes to the planning scheme are more accommodating of extra population and extra activity around population centres. It is the accommodation of population that ensures that population in a given area will grow. There is no end to this process and no end envisaged in the proposed plans. This is irresponsible and negligent, considering the impacts of overpopulation are well-known. With increased densification and outward growth, quality of life in population centres, particularly in Melbourne must deteriorate.
Where does this end? It would seem that the process set in place by the proposed changes will lead ever more rapidly to increasingly overpopulated centres built to the requirements of developers, who have the economic motive of forcing more people into less space and show no signs of self-restraint.
A city such as Athens should serve as a warning to those who determine the future of Melbourne – This city grew very fast in the 1970s with high rise springing up like mushrooms bringing a 3rd world quality to the once modest sized beautiful city. It’s not too late for Melbourne. Let’s not do it!
Rural areas especially on the fringes of Melbourne
The most troubling aspect of the zoning changes is that the zones allow industry in areas where this would have been prohibited previously. The Green Wedges, set aside as the lungs of growing Melbourne 40 years ago, would no longer be safe to any degree. Once again the main concern is that there is no end to the process that these changes set up. If it were a finite number of developments and then a cap, the people of Melbourne would have some certainty that their environment will continue to be to some extent livable. But the current proposal does not mean such certainty. Instead it sets up a process whereby the Green Wedges are progressively degraded by development, thus facilitating more intensive development in the future. In effect, it ultimately annihilates them. In the shorter term this change facilitates a land-trading climate conducive to land speculation. Some will make windfall profits as land switches from rural to commercial. This will benefit the few who can take part in this game but ultimately through the rising cost of land will be detrimental to the rest of the population. It is not in the interest of the common good and quality of life for all of us.
What planning needs to be
Real Planning should take into account the physical reality of our time and place in history. It is almost without doubt that the world has passed Peak Oil production and is certainly beyond peak per capita oil production. Oil has lubricated our lives, fed us and transported us for as long as any of us can remember. As per capita production declines over the coming decades, at our peril we will build out our precious back yards and Green Wedges, extend our urban growth boundary and increase car dependency with urban settlement in previously rural areas. Our survival depends on us not doing this. The flip side of the Peak Oil coin is Climate Change and the need to limit Greenhouse Gas Emissions. Stabilising population and building in local self sufficiency and sustainable public transport is essential to this.
Figure 3, ‘World total oil per capita 1960-2011’ suggests that, where once oil came from oil wells, now, to keep up with human population growth we supplement well-oil with all kinds of other stuff, whilst still presenting it as the same old stuff. If we still relied just on crude and lease condensates from oil fields, where trends are shown by the lowest and oldest line in the graph, we would be considerably poorer in total oil supply than we seem to be. Early definitions for total world oil (see EIA Crude and lease condensate from 1960-2011) only counted crude oil and lease condensate. Coinciding with the decline in easy oil availability as it became necessary to look harder and deeper for oil, the definition of oil started to include other sources obtained away from petroleum fields. The BP definition above counts crude oil, shale oil, oil sands and NGLs (the liquid content of natural gas where this is recovered separately). The EIA definition for Crude, condensate and most other liquids from 1970-2009 comprises natural gas plant liquids, and ‘other liquids’, defined as, “Biodiesel, ethanol, liquids produced from coal and oil shale, non-oil inputs to methyl tertiary butyl ether (MTBE), Orimulsion, and other hydrocarbons.” That’s a lot of new sources, all of them requiring more energy to extract than that required to harness the traditional ‘gusher’ close to the surface, now a rare phenomenon. (Excerpt from forthcoming book, Lost Tribes, by Sheila Newman..)
Victoria needs to work within the real constraints that face us for the survival of those who are too young to take part in this submission exercise today and for their children. Changes to the Planning code need to be made with this consideration uppermost.
Wrong way- Go back-
Population restraint is about planning at the local level.
Victoria must plan to achieve a stable population not too far beyond the middle of this century to avoid a severely compromised future. This is possible and planning for it needs to start now.
The issue of zone reform is critical and the changes envisaged are so extensive in scope I would advocate that the state government set up a parliamentary enquiry to address it in detail to ensure the best possible outcome for the people of Victoria.
The so-called “Global Livability Report” ranks Melbourne high, but it also ranks Hong Kong and Vancouver high – both of the concrete nightmares where development trumps democracy, nature and access to natural amenity. http://www.eiu.com/site_info.asp?info_name=The_Global_Liveability_Report
The 'livability index' report comes from the Economist Intelligence Unit (EIU), which is part of a group associated with the Anglo-centric Economist magazine. People in Hong Kong rent cages stacked one on top of the other in rooms in concrete high rises. There are protests about the abrogation of public land and the ever increasing intensity of development. The EIU put overcrowded concrete Vancouver and Melbourne equal at the head of its list in 2002. Clearly this list is a list about concrete spaces and developers' anti-human values and the Economist’s unwise promotion of economic growth and globalisation. The award is used as a manufactured consensus thing promoted by big business for big business and against relocalisation, human scale and natural surroundings. In other words it is corporate propaganda. About the Economist group:
"From its beginnings in 1843, when The Economist newspaper was founded by a Scottish hat manufacturer to further the cause of free trade" ... http://www.economistgroup.com/what_we_do/our_history.html"
"Many of the issues facing the world have an international if not global dimension. The Economist brand family is ideally positioned to be the commentator, interpreter and forecaster of the phenomenon of globalisation as it gathers in pace and impact." [In other words, a propaganda outfit that actually has some deluded ordinary subscribers.] http://www.economistgroup.com/what_we_do/our_brands/the_economist_brand_family/index.html
President: Sustainable Population Australia (Victorian and Tasmanian branch)
Postal address P.O. Box 240
West Heidelberg 3081
On the northern coast of N.S.W. adjoining the Gold Coast and S.E.Queensland lies Tweed Shire, christened as the Green Caldera by once Environment Minister Peter Garrett. This area is famous for one of the highest biodiversity levels in Australia and infamous for the greatest level of biodiversity loss in N.S.W. thanks to the fact that the vast majority of Tweed councillors are pro-development. But in the case of Kings Forest, a massive housing development for 15,000 people worth $2 billion, NSW State Planning took control under the massively unpopular Part 3a legislation, depriving the council of all controls.
If this development is approved, it will be goodbye koalas on Tweed coast within 5-10 years. HAVE YOUR SAY!!
Kings Forest development plan includes 4500 housing lots, a golf course, two primary schools, and shopping facilities, and will occupy a large area between Kingscliff and Cabarita with a single entrance along Tweed Coast Road.
The social impacts of this development are huge. Just what will life look like with another 15,000 or so people driving around, looking for parking, jobs, needing infrastructure like hospitals, schools, libraries? Who will pay for the infrastructure - ratepayers?
While it is commonly believed by local businessmen that this will be good for business, the truth is that an increase in population may not automatically create employment, because most of the jobs created will be short term construction jobs and at the same time there will be an increase in job seekers.
(photo: Cudgen Nature Reserve)
There are many environmental impacts of this development, especially the risk to the remaining population of 144 Tweed Coast koalas, placing the population at high risk of localised extinction. Also at risk are 21 Threatened Species of fauna including the Wallum Froglet, Wallum Sedge frog, Grass Owl, Bush Stone Curlew and Long-Nosed Potoroo, 6 species of flora and 3 endangered ecological communities.
Many changes will be needed to protect adjacent Cudgen Nature Reserve and State Significant Cudgen Lake, which could well be at risk. The developer should dedicate land to the Nature Reserve ahead of the development so that the flora and fauna can be protected from the bulk earthworks. Bulk earthworks will move 1 million cubic meters to flatten out the site for housing. The development application has not indicated when the land will become reserve, it may happen after it has already been seriously disturbed. Fencing of the nature reserve should also happen ahead of the development to protect fauna that try to move through the development. The fencing should be of a different specification to what is proposed by the developer - it needs to be floppy top cyclone fencing, or the koalas will climb over it.
Friends of the Cudgen Nature Reserve is concerned about the water course to Cudgen Lake, and also the drainage pattern which appears to using Blacks Creek as the major channel to drain KF which then goes through the nature reserve. Unless certain extra measures aren’t taken, this development will threaten the viability of the nature reserve, a jewel in the Tweed Coast.
In addition to Section 94 contributions, there should be an environmental maintenance fund established by the developer because a lot of the environmental measures they propose have no monitoring, feedback or evaluation. It's not realistic to assume people are going to move in with their dogs and just obey a few signs.
Kings Forest has confusion and conflicting development application information. It has almost no Ecologically Sustainable Development 'footprints' concerning the future wellbeing of the people who currently live and work on the Tweed Coast. The demonstrated community consultation and awareness about this development is completely lacking. The owner and developer of Kings Forest is not even a Tweed Shire resident, who has cleared and mismanaged valuable ecological wetland areas, native wildlife habitats and altered catchment profiles of Tweed coastal land. There has been no invitation to qualified individuals with excellent local knowledge who could help the developer and workers on the property manage it in a sensible ecologically sustainable framework.
There should at least be a moratorium placed on this development by the NSW and Federal governments until issues of past rezoning processes, past and current land and water management issues and illegal clearing of valuable ecological habitat are resolved. It is up to the NSW State and Federal governments to actively pursue these questionable issues.
Many in the community are voicing an urgent need for remedy to the current mismanagement of this development and to the development's processes which needs to be addressed before further works continue on the site. The habitat and ecological damage that has already occurred could take decades to repair, some may never be repaired, if the development goes ahead as per current planning documents. Nor does there appear to be any documented environmental benchmarks attached to the past and current development process by which environmental accountability can be assessed.
The cost of this urgent remedy should be borne by the developer, not Tweed shire community. The valuable community environmental volunteers who have been serving the Tweed coast for many years appear to have been very poorly treated by the regime that is Kings Forest Part 3a development.
On 11th December, approximately 70 protesters assembled peacefully to protest against Kings Forest. The developer had their own rent-a-crowd comprised of employees (most of whom had Queensland number plates) and their kids, all holding virtually identical (mostly professionally printed) placards saying 'WE WANT JOBS, WE WANT HOSPITALS, WE WANT A FUTURE'. Some protesters overheard Leda's manager Reg van Rij say to one of them "You are not supposed to know me." The rent-a-crowd protesting our protest began by rudely placing their signs over ours. Apart from this flagrantly defiant act, and a few wheelies near our information tent, there was no trouble. Some conversation between their head protester and us revealed that they honestly believed that all the threatened species should be just moved out and put in a sanctuary somewhere. When one of our protesters commented that there had been illegal clearing at Blacks' Creek, they all looked sheepishly to the ground and said nothing. See http://www.youtube.com/watch?feature=player_embedded&v=nvbCBw06OrM
(photo: Protest at entrance to Kings Forest site)
The deadline for submissions on Kings Forest development Stage 1, bulk earthworks, Koala Plan of Management and first lot of subdivisions is January 25th. Your comment can be emailed to [email protected]
For suggestions in making a submission, however short,
and for more information on Kings Forest, go to http://bluecray.org
or view the project application at majorprojects.planning.nsw.gov.au/index.pl?action=view_job&job_id=2642
POEM by Mark Comport
Our home, the valley of contrasts, the beautiful Tweed
We all take a piece of her while she silently bleeds
She bleeds overdevelopment, loss of habitat, erosion, roadkill
We’re taking too much, we’re making her ill
To move more of us in, more of her has to go
Mother nature is dying … dying slow
We argue over who was here first or who could care for her best
While we are, she’s being raped and robbed – we’ll fight for what’s left.
As of 24 January, Tweed Shire councillors recommend that Dept of Planning allow dogs at Kings Forest.
PLEASE make a brief Submission urgently. Under the heading of Competition and Efficiency, economists easily dispense with democratic objections and humane values. Only the strictly illegal is out, and authorities are always willing to change the law if money is involved. The campaign to slaughter kangaroos for their meat in Victoria has been building over the years, despite its unsustainability and the distress it produces in kangaroos and the many people who love this species. The Department of Sustainability has shown itself to utterly lack science or responsibility in monitoring and protecting our native wildlife. More often than not it awards permits to kill kangaroos without checking their justifications. The Auditor General's report in 2009 showed that the Victorian government did not know what it was doing with regard to wildlife. It would therefore be a serious error to change laws to reward kangaroo killing and to make it easier.
Submissions on VCEC draft report and lifting the processing ban on commercially utilising kangaroos
. The Victorian Competition and Efficiency Commission (VCEC) has released a new draft report calling for lifting the processing ban on commercially utilising kangaroos in Vic, and for a more simplified ATCW permit system, which at its best is already simple and badly under resourced. (A pdf of the Report may be accessed here.)
· Kangaroos are not commercially harvested in Victoria, Northern Territory or the ACT. According to Autsralian government data kangaroo numbers have dramatically declined by 55% since 2001 in commercial shooting zones across Australia, the recent floods have added another heavy toll on kangaroos in those areas.
· There is no data or figures of kangaroo populations in Victoria, the DSE state in their fact sheet that a commercial industry is not viable as set up costs would outweigh profit, public opposition, and low kangaroo numbers.
· Currently a landowner does not have to pay any fee for an ATCW permit to be issued to them; the VCEC report states that it costs approximately $480 per permit application.
· Under the current system it costs Victorian tax payers for landowners to kill protected kangaroos without their say or consent, why then is this cost not passed onto the landowner if they are supposedly benefitting from it?
· This is particularly pertinent to wildlife carers who along with their animals already suffer from ATCW permits given to adjoining landowners placing at risk the very kangaroos they have a license to hand rear.
· The real waste is that kangaroos are killed in the first place, not that they are left to rot.
Please help oppose the commercial processing of kangaroos in Victoria by emailing a submission/letter to the VCEC
Call to lift kangaroo processing ban
Regarding the VCEC draft report in relation to lifting the processing ban on commercially utilising kangaroos in Vic, those seeking more information should read from the Introduction p.57 (1). The section on Authorities to Control Wildlife (ATCWs) is on p.104 (48) but it has been pasted at the end of this article for easy reference.
Wildlife carers are already disadvantaged from ATCW permits given to adjoining landowners placing at risk the very kangaroos they have a license to hand rear.
Currently a landowner does not have to pay a fee for an ATCW permit to be issued to them, the report states that it costs approximately $480 per permit application, along with this it’s argued that the system should be simplified!! As we all well know it already is pretty 'simple'. (funny - it costs to get an FOI (Freedom of Information)!
Under the current system it costs Victorian tax payers for landowners to kill protected kangaroos without their say or consent, why then is this cost not passed onto the landowner if they are supposedly benefiting from it?
If those who seek permits to kill kangaroos had to pay for a permit they might think before applying for one and properties would be inspected to ensure valid reasons are given for issuing them.
Most perpetrators of abuse using ATCW permits are hobby farmers. It would be more appropriate for ATCW to be issued only to landowners whose sole income is from the land/farming.
There is a huge need to educate and to create awareness of how essential it is to protect biodiversity. Make ATCW permits harder to get with tough requirements.
Extract from Draft Report: Part 2 – Priorities for Regulatory Reform
An Inquiry into Victoria’s regulatory framework
A draft report for further consultation and input
3.2.5 Authority to Control Wildlife
In Victoria, control of wildlife is regulated under the Wildlife Act 1975 (Vic). In particular, lethal control measures are heavily restricted, requiring approval from DSE through an Authority to Control Wildlife (ATCW). DSE states that an ATCW for lethal control measures is issued only as a last resort where other non-lethal options are impractical (DSE 2008b, p. 1).
The Victorian Farmers Federation (VFF) (sub. 17, p. 5) identifies ATCWs as a source of excess burden for its members. The submission points to several issues, including:
prohibition on commercial use of kangaroo carcasses
the cost and complexity of obtaining permits.
The VFF also identifies health and safety issues arising from an alleged restriction on removing a culled kangaroo carcass from the point at which the animal dies. The Commission understands that DSE’s guidance materials do, in fact, indicate that the carcasses of animals destroyed under an ATCW can be removed (DSE 2008b, p. 1).
Complexity and delays in the permit application process
Obtaining an ATCW requires the applicant to go through a relatively in-depth approvals process and submit an application form detailing the proposed controlmeasures, and details of other non-lethal control measures already attempted. In many cases a site visit from DSE field officers is a prerequisite to approval.
The rationale for extensive assessment of applications is to ensure that pest kangaroos are only destroyed as a last resort. In 2008, 1592 ATCWs were issued for three species of kangaroo. If wallabies are included, the total increases by 1798. Long term data suggest around 30 000 kangaroos are destroyed under ATCWs each year in Victoria (DSE 2010a).
No data are publicly available on the average cost of individual permits. However, information available to the Commission suggests an industry cost of just under $1 million.1
In its submission, the VFF recommends that kangaroos be ‘declared unprotected’ on private land (sub. 17, p. 5). The Commission does not believe that this would be possible without jeopardising policy outcomes. However, it should be possible to reduce the costs to landholders of obtaining ATCWs without compromising protection of wildlife. In particular, DSE could consider simplifying the application process, as there may be room to:
simplify the application form, consolidating the application and landholder self-assessment to eliminate duplicate requests for information
reduce the need for on-site assessments by field staff.
Prohibition on commercial use of culled kangaroos
The Victorian Government, while allowing lethal control measures for kangaroos and other wildlife (in limited circumstances, as noted above), prohibits commercial use of culled kangaroos (DSE 2010a). ‘Commercial use’ would primarily entail sale of the carcass for processing to meat and leather products (Environment and Natural Resources Committee 2000, p. 93).
This ban is linked to the Government’s overall opposition to establishing a kangaroo meat industry in Victoria, based on a stated low kangaroo population density, and community opposition to commercial kangaroo hunting (Environment and Natural Resources Committee 2000, p. 378). The underlying concern is that introducing additional incentives to destroy ‘pest’ kangaroos could lead to de facto commercial exploitation of the wild population.
The tight controls on ATCWs and the high level of monitoring by DSE suggest that the Government should be able to detect and prevent culls proposed
1 Taking into account the need for a site visit and the rigour of the permit system, a reasonable starting point would be one day per permit. Using default wage, overhead and on-cost assumptions from the Department of Treasury and Finance’s guidance on estimating administrative burdens, this yields an administrative cost associated with each application of approximately $480, or $863 000 across industry. There may be further costs from ongoing damage from pest animals where control action is delayed by administrative processes primarily for the commercial value of kangaroos. Assuming no change in the rate at which ATCWs are granted, permitting the sale of carcasses would pose no further threat to the population, with those animals culled under permit, by definition, being within sustainable limits.
While — as noted by the VFF — it is not clear whether the numbers of kangaroos culled in Victoria would make a kangaroo products industry economic (sub. 17, p. 5), a ban appears unnecessarily burdensome and redundant in light of other measures to protect biodiversity and animal welfare. The Government should consider lifting this ban. If this option is taken, impacts should be monitored closely and, in no later than 3 years, the operation of the scheme should be reviewed to assess whether removal of the ban has harmed welfare or biodiversity outcomes. Draft recommendation 3.5
That the Government change aspects of the control of pest wildlife under Authorities to Control Wildlife (ATCW) to:
simplify the process for obtaining an ATCW
allow commercial use of kangaroos and wallabiesdestroyed under an ATCW, where such use does not compromise other policy objectives.
Exposure Draft Planning and Environment Amendment (GAIC) Bill
I understand that the exposure draft legislation for the Growth Areas Infrastructure Contribution (GAIC) has been released for public comment. I am totally opposed to the extension of the Urban Growth Boundary (UGB) and with it the destruction of Green Wedges and imposition of a land tax - the GAIC. My reasons:
1. The proposed GAIC is a grossly unfair tax and is fundamentally flawed. Although it has been substantially amended prior to drafting the legislation, landowners are still significantly disadvantaged. The tax is now to be levied on the purchaser rather than the seller. This will mean the price a landowner receives from the sale will be reduced by the amount of the tax. Only developers are likely to purchase land with a tax liability. I advocate that the State Government withdraw this proposed tax and only impose land taxes at the point of development, as in other Australian States. Fair and equitable taxation is a basic tenet of our democracy.
2. The imposition of a complex taxation system on land sales is likely to expand the bureaucracy of the Growth Areas Authority, thus reducing funds available for infrastructure of new settlements and defeating the purpose of the legislation.
3. The cost of building new homes on the rural fringes of Melbourne is double that of constructing infill dwellings in the inner city. This is the hidden cost of suburban sprawl. The added costs include extra infrastructure. (A report, commissioned by your Department and released in July, cites research that found "for every 1000 dwellings, the cost for infill development (in existing suburbs) is $309 million and the cost of fringe developments is $653 million".) As you stated in Parliament, the funds to be raised by the $95,000 per hectare GIAC tax will cover only 15 per cent of total infrastructure costs of new growth areas.
4. Expansion of the UGB and the rezoning of land from rural to residential will mean Green Wedges land will be engulfed by suburban sprawl. The Government must abandon the Green Wedge land grab as destructive of the environment, a threat to wildlife, including endangered species, and as a major contributor to green house gas emissions. Around the urban fringe is concentrated of some of the most endangered eco-systems in Australia, including the Western Basalt Plains Grasslands and Grassy Woodlands in the Darebin, Jackson and Merri Creek valleys and habitat for a range of threatened species. These will be lost if the UGB expands.
5. Expansion of the UGB will mean reduction of arable land for farming and food production with urban sprawl.
6. Expansion of the UGB will mean increased risk of bush fires with urban sprawl in new fire-prone areas.
7. Expansion of the UGB will mean increased car dependency and increased green house gas emissions.
8. Construction of the E6 through Wollert and Woodstock is destructive of these townships and their landscapes.
9. The State Government has failed to consider the question of what is a sustainable population for Victoria, given scant water supply, peak oil crisis coming up and climate change.
10. As the Prime Minister has just announced the Federal Government’s involvement in planning of Australian cities and provision of infrastructure, the State Government’s move to raise infrastructure funds for new growth areas appears precipitate and premature.
The above was a Submission made on November 2 2009 by Maryland Wilson,President Australian Wildlife Protection Council Inc, to:
The Hon Justin Madden MLC
Minister for Planning
Parliament of Victoria
East Melbourne 3002 Date:
Sent to: Growth Areas Infrastructure Contribution Comment, GPO Box 2392, Melbourne Victoria 3001 or email to GAIC.comment[AT]dpcd.vic.gov.au
Image from cover of Graeme Base, Uno's Garden, Viking, Penguin Australia, 2006
Re: Proposed Urban Growth Boundary changes.
There is a fantastic book by renowned author Graeme Base, that I often read to my children. It’s called ‘Uno’s Garden’. It’s about a guy named Uno, who arrives in the forest one beautiful day, where there are many fascinating and extraordinary animals there to greet him. And one entirely exceptional Snortlepig.
Uno loves the forest so much, he decides to live there. But, in time, a little village grows up around his house. Then a town, then a city….and soon Uno realises that the animals and plants have begun to disappear….
Graeme Base starts his book with this rhyme:
‘The animals go one by one
A hundred plants, then there were none
And all the while the buildings double…
This numbers game adds up to trouble’
So significant is this story, that it featured as the Myer Christmas windows in 2007. If you haven’t already read the book, I urge you to get a copy. It really is easy to read, and makes perfect sense.
On behalf of my children, I would like you to seriously consider the moral of this story when determining the UGB and population expansion.
Sharing our backyard on the periphery of the proposed new South East UGB, are EPBC listed, endangered Southern Brown Bandicoots. To my kids, these are like the ‘Snortlepig’ in the story. They think the Government must be careful to protect them as it’s important we have biodiversity. They really get that. What they don’t get, is that the Government is now planning to shift the boundary of the Urban Growth Corridor encroaching into Green Wedge land further threatening the SBB’s, to make way for more ‘concrete and McMansions’. They are worried that it will never end, and wonder where all the animals and farmers producing our food are going to go. They are worried that when they get ‘old’, their children and grandchildren will suffer for today’s government’s seeming lack of concern for the environment.
What should I tell them?
Submitted by: Catherine Manning [to the Growth Areas Authority]
Friday 17th July, 2009.
Photographs of Southern Brown Bandicoots in our backyard near Clyde.