Submission on behalf of the ̀ Friends of Gulf St Vincent'

The Friends of Gulf St Vincent is a voluntary organisation, established in 2003, with a rapidly growing membership base, which includes several corporate member groups.

Many of our members have a common background in policy and management of the State's aquatic resources. Members live in various localities around the Gulf, and cover all age groups.

We aim to

1]

Foster a unified community approach to the protection and wise use of the Gulf St Vincent

2]

Advocate for the

a

sustainable use of marine resources

Parliament of South Australia

Environment Resources and Development Committee

conservation of marine and coastal environments

protection of key habitats in the Gulf

Inquiry into Coastal Development

3]

Promote awareness of issues relating to the health of the Gulf St Vincent

4]

Provide a means of conveying community concerns to Government

We have done this mainly through public fora (Middle Beach, NormanvilLe, Port Vincent and West Beach to date) on the broad theme of `Get to Know Your Gulf' ; and through our newsletter `Blue Swimmer' which circulates to Councils and several hundred individual and corporate associates.

We are also compiling a book in the Royal Society of South Australia series, with the working title `Natural History of Gulf St Vincent . We have just been notified of an NHT grant to publish a booklet on protecting Gulf St Vincent, directed particularly to the school children who are doing marine studies at the several schools around the State which offer that option .

It may appear that our aims mirror those of the recently established Natural Resource Management Boards. We support the NRM concept and believe we have good relations with the boards that surround the Gulf.

We would point out that basing NRM districts essentially on land topography means that their boundaries dissect the two major Gulfs in South Australia. We take this to be an unintended outcome of the NRM initiative . The ̀ Friends' seeks to promote the principles of integrated natural resource management in Gulf St Vincent, and believe similar principles should apply in Spencer Gulf.

We would point out that the application of the NRM legislation (and the provision for Catchment Water Management Boards that preceded it) does not require NRM boards to achieve performance criteria at the coast of a kind that would ensure protection of the marine environment. For example, catchment managers have not been required to bring water at the end of a catchment to acceptable quality criteria before it enters the marine environment .

As an obvious example, inshore waters of the Adelaide metro beaches consistently fail to meet the physical quality criteria for children to swim, through much of summer.

We note that the Environment Resources and Development Committee is to investigate and report on the impacts of coastal development in South Australia, with particular reference to:

1

adequacy of planning legislation and guidelines

2

visual impact

3

built form

4

environmental impact

5

ownership of coastal land

6

preservation of coastal land

7 infrastructure

Our comments focus on experience in Gulf St Vincent, but are placed in context for the entire State, and nationally, where appropriate .

The ̀ Friends' is aware of general public disquiet with coastal development around Gulf St Vincent. In 2005 we sought comments from the about 70 local people who attended one of our fora at Port Vincent . There was no list of issues to respond to - comments were entirely open .

Most of the audience responded . Half of the responses mentioned major issues with the Development Act 1993 and performance of local government. The next group of issues could be classified as to do with information and awareness, then came a cluster of concerns on vegetation management on land and in the sea, then management of freshwater through its entire local cycle.

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The problem with information and awareness was that people are suspicious of much of the information routinely placed before them concerning local development. Their instincts, and unfortunate experience, tell them that they are likely to be given an artificially glowing picture of benefits of each development, with minimal information on potential risks to help them make a personal assessment of the proposal . The unfortunate conclusion is that they are as suspicious of the information that comes from all levels of government as they are of the unashamedly promotional material put out by developers, whose motives and interests at least can be identified directly.

These responses encapsulate what we see as the overall problem . The statute law generally is well founded, and capable of delivering good development. Links are identified with associated Acts in ways that should see development property co-ordinated and integrated . The problems that the community perceive come about through poor process including poor communication .

We would like to refer to two national policy issues before coming to the Committee's special terms of reference. These are housing policy and water policy .

Housing policy

Macquarie University's Department of Economics studies the factors that affect house prices in the long term across Australia. A recent survey (Economic Record 81 August 2005 S961103) from 1970 to 2003, shows that real house prices are determined significantly and positively by real disposable income and the consumer price index . Major negative determinants are unemployment rate, real mortgage rates, equity prices and the housing stock.

One intuitive observation is that the market responds faster to rising prices than to failing prices .

The practical effect of this is that supposed incentives for house building by state and local government simply add perturbations around the tong-run relationship . However, those perturbations invite short term speculation and poor planning process, which is exacerbated in the case of coastal development by its natural premium value .

The ̀ Friends' has no argument with home ownership per se . Our members are homeowners/ mortgage holders reflecting the general population . We point out that speculative runs, with developers trying to persuade councils to `fast track' planning (read - ignore prudent planning process) provides no long term benefit to communities or even the investors in those communities, but will leave the community with continuing environmental costs .

Examples of such costs along the Adelaide coast follow from the pattern of housing. Houses now cover areas that previously were part of the natural dynamics of the coast ; the dunes .

Because we no longer have flexibility to allow natural interaction of water and sand, the state is committed to apparently interminable relocation of sand artificially to maintain beaches for public use . The problem comes not from public use of the beach, but from private encroachment on the dunes . We submit that the planning system should prevent any further building on such lands, and that existing buildings should be levied to pay the costs of `engineering' the coast to compensate for their presence .

The ̀ Living Coast strategy 2004' and the beach management strategy 2005-2025 both show substantial costs of stabilising the metropolitan coast, with no (permanent' fix. We understand that there is a steady loss of sand from the total metropolitan sand `budget', and that other sources will be required to make up the difference - starting with supply from Mt Compass .

There seems limited scope to improve the technology to manage sand movement along this coast . Effectiveness of the `sand shifter' on trial is reduced when it encounters drift seagrass or algae, and its actual operations reduce amenity with noise, physical disturbance and exclusion of the public . It is marginally better, however, than convoys of large trucks taking sand from north to south . It is not clear how much of the cost savings projected in the management strategy might be realised.

Other problems for the metropolitan coastal area, going back several years, came from the urbanisation of the area immediately behind the dune system . When water, retained as it had been for millennia before European settlement, started to flood houses, the `solution' was not to stop building houses on the tow lands, but to cut through the coastal dunes . That action has lead to much of the toss of water quality on the actual beaches, because natural rain - now known by the pejorative `stormwaters' - runs quickly, in large quantities, direct to sea, carrying with it heavy loads of silt and contaminants.

Not that that has been a lasting solution to the urban flooding problem, and we see a proposal for an urban authority focussed on the bad effects of a bad decision - flash flooding - rather than on good management, which would treat the rain as a potential resource and manage it as such, with every expectation that the flooding problems would be solved in the process .

We observe that the proposal for a dedicated stormwater authority comes after several years of operations of Catchment Water Management Boards, which appear not to have alleviated the problem of flooding, even though those boards were comfortably funded from all ratepayers .

Another long-term cost from speculation in coastal land is shown by the `Glenetg Harbour', which was intended to create a Gleneig that is quite mythical, disregarding the unfortunate but well recorded history of attempts to create an anchorage for small craft in the Patawatonga. The current `GLenelg Harbour' was proposed only a few years after the 1986 publication of Ronald Parsons'

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`Southern Passages', a history sponsored by the Department of Marine and Harbors, which noted that the first attempt to do this, at significant public cost, just on a century earlier, had survived only a few days after completion, before a storm wrecked the works, and Mr Rymill's yacht . Yet the `Harbour' was dug, to promote a particular development. The capital value of berths there creates headlines in the Real Estate and Investment Supplements of the newspapers, but the rest of the community will bear the cost of perpetual dredging to maintain this `harbour' .

Had the costs of maintaining this myth been apportioned as a rate or levy on the apartments around it, and the berths within it, at least the public would not be carrying that cost. It is more likely that the entire ill-advised venture would not have proceeded as it did, without impeding the steady accretion of higher density living, if that is what the local council wanted in its long term plan .

A particular case is development of marinas .

Marinas partly confound the old saying - attributed to Will Rogers amongst others - about buying land as an investment because `they' are not making any more of it . Marinas essentially seek to `make' more of that desirable, premium price, waterfront land .

Again, the ̀ Friends' has no objection to marinas, provided they are built on sound planning and environmental principles .

Across South Australia there are examples of marinas which have been built with minimal environmental impact . Assessing environmental impact should start with modelling the changes that a marina might cause in local water movement. Local universities have built up expertise in such work, supported by consultants who have trained in those institutions . Thus modelling can conveniently be interactive - the objective not being just to describe the effects of a proposal, but to adjust the proposal so that it provides the desired development with minimal problems with circulation or impacts on biological systems. We would assume that that would be an objective of the marina developer, but that is not always obvious in the outcome.

The construction phase can have substantial environmental impact. South Australian marine engineering and works contractors have developed local methods of dredging and land shaping that are highly cost effective, meet the letter of the EPA guidelines, and in some cases have bettered the water quality criteria that those guidelines were designed to produce . There are other marinas for which ̀ planning', at best, was made up as they went along . It would be a pity if more marinas were allowed to develop in that way, particularly as the technology is local and proven to give a good environmental outcome.

Water policy

At present, the Adelaide metro coast suffers far too much from the change in water flow across the plains since European settlement . The change has been from retention, infiltration and steady percolation of clear freshwaters to the coast either through the dunes or via wetlands and along what is now the Port Rive, to the rapid delivery of large quantities of contaminated water direct to the coast through artificial channels, including the Torrens `breakout' .

It is now well established that this has damaged the first several hundred metres of coastal waters and reduced the amenity of the metro beaches . The contaminated flow from rainfall over the Adelaide catchments is boosted by flow from water treatment plants which carry further flow derived from the River Murray, so the total outflow to the coast is much greater than before European settlement.

But this is a symptom of a deeply compromised water management. When various groups try to make a case for better treatment of all this water they are told that there is little or no financial incentive to do the works .

If water were property priced - and we have had a policy outline for the Murray Darting system at least since 1981 in Alan Randall's

Property entitlements and pricing policies for a maturing water economy (in The Australian Journal of Agricultural Economics v. 25, #3 pp . 195-220) then we would retain and reuse much more treated sewage effluent, and we would have a sound economic case to retain and use the rainfall over Adelaide . It has been the experience of the `Friends' that, for

all the promotion of the concept of using the rainfall over Adelaide to

supply Adelaide, when it comes to each specific proposal for a retention basin, or truly effective catchment management to produce useable water, local and state government both demonstrate that without the prospect of real and immediate profits, alternative land uses will be favoured, and probably will prevail . Those uses, if they include high density building, add to the problem of greater runoff, accelerated flow and, usually, greater contamination .

Outside metropolitan Adelaide, there are different problems with supply of freshwaters and treatment of wastewaters. Respondents to our country fora remark that new beach houses have much greater demand for water than the `shacks' they usually replace . Coupled with increasing demand for beach houses, this is likely to increase at least the seasonal peaks of demand for freshwater. The solution being proposed more frequently is desalination of sea water . At first sight, this is an attractive option, and still may be. However, desalination on this scale is not without problems. The assumption seems to be that it is environmentally benign - the plant will just be `putting back what it took out of the sea' . In fact, the chemical composition of the brines from desatinators can be quite different from the mix of salts in the sea. Add extra compounds necessary to prevent build up of biological films in the plant, or otherwise to promote its operation, and the effluent can be noxious to local marine life .

Finally, high seasonal peaks of freshwater flows from housing redevelopments and caravan parks/camping grounds can make it quite difficult to operate some of the `common effluent' systems which have been installed or proposed for these areas, or they can simply overflow, delivering nutrient-rich (and bacteria rich) water to the local beach and coast .

To turn to the specific terms of the inquiry -

1

adequacy of planning legislation and guidelines

2

visual impact

3

built form

4

environmental impact

5

ownership of coastal land

6

preservation of coastal land

7 infrastructure

adequacy of [planning legislation and guidelines

Our members and respondents believe that the core planning legislation is adequate . Their concerns with its application include -

(a)

It is difficult for a local authority to use planning provisions to retrieve and restore old problem areas, even where that authority has the will or inclination to do so . For example, parts of the metro coast suffer from bad decisions of many years ago, but there is little scope to manage development to try to ameliorate those problems. Neither is there scope to raise local funds to assist in ameliorating such problems. There are imaginative but proven ways to fund proper urban renewal, which are included in the equivalent of planning legislation overseas . Local government finance arrangements already allow scope for local rates or levies to support schemes to ameliorate recent environmental bad judgement, but it still seems easier for local councils to `cry poor' and try to shift the costs up to state or federal government .

Some of this could be a problem deriving from having so many small councils in one metropolitan area .

The city of Brisbane has been able to ameliorate its urban flooding problems over the last 30 years, partly through being a single local government for an entire greater metropolis .

(b)

Review of local plans tends to tag behind trends in development which are not likely to deliver good outcomes overall.

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(c)

There is deep suspicion of use of overriding powers - such as s 46 of the Development Act 1993 - for specific `developments' . The outcome of such development, for example at Glenelg, is not good.

(d)

Many of our members and respondents remark that we are losing coastal `character' in recent developments . Many high-rise buildings show little sympathy with the coast, nor do they use the coastal environment to their advantage . For example, buildings routinely are fully air-conditioned, lack shading for windows, have no practical rainwater storage or solar power or heating systems.

(e)

Our members and respondents are uneasy about what they see as the steady alienation of public uses of the coast. For example, the opposition to coastal walkways supposedly based on particular residents' fears that they will be used for illegal purposes, or otherwise deprive them of privacy or amenity. Gradual exclusion of public uses allows gradual encroachment onto the foredunes and even the beach .

2

visual impact

(a)

Our country contacts give this a high rating for concern . Their case is that the visual attraction of much of the coast depends on land forms and vegetation . Both can be disturbed by housing development, and exacerbated by the design of many new houses (multi story, reflective surface treatments, odd geometric forms) and by the compulsion of new residents to maximise their water views by removing vegetation . This is a common problem around the country . Councils in the greater Sydney area use `shaming banners' across gaps which appear mysteriously in vegetation around Sydney Harbour but just happen to coincide with a new or markedly redeveloped house site, which may represent $5-10 million in current expenditure .

(b)

Against this concern, we are also aware that many of our members are involved actively in caring for, and regenerating, coastal vegetation along metro Adelaide (e.g . dunes) or along the country coasts. We understand that the general provisions for land for such work are considered adequate, and the coastal setback in many new land developments seems to be accepted by a majority of residents .

Volunteering is a particular mindset, difficult to create by bureaucratic methods . Governments can assist volunteer work by helping to remove impediments. Most of those impediments have involved availability of insurance, clarity over legal liability and similar legal elements outside the planning system . Our observation is that the mix of planning, land and catchment management legislation has minimal impediments to volunteer work, and the volunteer sector seems active and healthy in South Australia.

(c)

Other comments on visual impact follow from the remarks on coastal building character above . Active promotion of truly sustainable architecture through the existing planning system should help restore more sympathetic views across settled stretches of coast .

3

built form

We believe that appropriate built form should be promoted through not having artificial stimulants to housing development but by requiring new buildings at least to minimise their environmental demand. There should be a system for environmentally inappropriate building to be levied to pay the costs of its demands on the environment, including demands generated by the local urban form . Such levies could be reduced as those buildings were redeveloped to reduce their demand on the environment .

4

environmental impact

(a)

Particular environmental impacts are associated with industrial developments around the coast . These can be categorised as for power generation, water supply and effluent disposal, boating and shipping.

It is unlikely that Gulf St Vincent will be a source of tidal or wave power, but the maritime coasts offer significant opportunities for this . Planning legislation and process should allow for predicted forms of wave or tidal power generation . Wave power generators are being tested in other parts of the world which use the principles of coastal `blowholes' to drive turbines. The main structure is fixed on land, within the tidal range . Air is compressed by waves building up to the shore, and that air drives a turbine . Such machinery would be difficult to integrate into settled areas for obvious reasons.

The Gulf coast already is used for wind power generation . This has had problems with local acceptance . Likely future wind power sites must be indicated in local plans.

We have mentioned possible impacts of desalination plants, and, separately, of potential problems with disposal of wastewater in areas where new housing, or extensively redeveloped shack settlement, increases seasonal peaks of wastewater production . Solutions to this include provision for reuse at least of grey water and acceptance in planning of more appropriate disposal of wastes, including the many `dry' systems now proven .

Industrial discharges around the Gulf - and the entire coast of South Australia - have been documented since the Marine Environment Protection Act 1993. That Act required that all industrial discharges to marine waters be brought to a condition where they did not infringe water quality criteria within a period `not in any event' to exceed 8 years from the commencement of that Act .

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Effectively, that period finished in 2001, but the requirements of that Act, even as continued in the Environment Protection Act, were not met .

So, although Adelaide households subscribed what was initially identified as an environmental levy to pay for effective sewage treatment (and which was rounded into fees when the corporate structure of the former Engineering and Water Supply Department changed, but no longer identified separately in billing) ratepayers did not receive the outcome they were promised.

Similar tack of resolve meant that other discharges, such as that from the Pendce soda ash plant, which actually used part of the river to complete its industrial process cycle, continue to pollute . It is difficult to make any further recommendation on these discharges . If administration is able simply not to comply with the clear direction of an Act, and not be censured in any way by the Parliament that passed the bills for that Act, we are at a loss to know what else to recommend in a democracy under the Westminster system

Boating and shipping will have a range of impacts. Even if there are no special structures built to accommodate vessels, swing moorings too readily destroy seagrasses, and should be replaced by lower impact methods .

We are aware that the EPA is seeking to improve management of wastewaters on boats in all South Australian waters.

Boats and ships are also sources either of invasive pest species from fouling or bilge and ballast waters, or they may be sources of persistent toxins in the antifoulants used to suppress these organisms.

It is unavoidable that most antifoulants will have to be toxic to be effective. We have the example of tributyltin, now being phased out, but can expect that other generations of antifoutants will affect non-target species .

Invasive pest species, on land and in the water, have potential at least to reduce amenity greatly, and at worst to inflict economic damage on coastal areas . Port Adelaide already has an almost continuous `red tide' of toxic algae, sustained by the nutrient loads from water treatment and the Penrice industrial process which releases tonnes of available nitrogen to the river from the ammonia used in the Solvay Process.

Any other anchorage around South Australia is likely to receive marine pests of some kind ; studies show a simple correlation between number of vessel movements from other ports and the probability of an introduction .

A significant impact from shipping comes from dredging and related engineering works . A recent bad example was the deepening of the channel to Outer Harbour to accommodate vessels rated as `Post Panamax' . The ̀ Friends' did not object to the actual works, but were deeply disappointed to see that Flinders Ports was allowed to ignore accepted international environmental standards for such work.

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International standards are contained in what is known as the London Dumping Convention . The ̀ 1996 Protocol' to that Convention made it subject to internationally recognised procedures for waste assessment and management, on the principle that potential wastes should be assessed for use, and portions that could not be used should be further assessed to minimise their quantity and mitigate their environmental impacts, including choosing appropriate areas for disposal .

Australia is a signatory of the London Convention and its Protocol . Those instruments are mirrored in the South Australian Environment Protection (Sea Dumping) Act 1984 . That Act has now been on the books for 22 years, has been regularly updated, but has never commenced . To cover that gap, the Marine Environment Protection Act included a policy which applied the principles of the Convention to proposals to dredge material in South Australia . That policy, in turn, applied controls to the dredging process and management of material dredged . Until recently, that policy had been applied to dredging in South Australia . Local contractors refined methods and adapted to local conditions to meet the criteria . During most local works water quality was much better than criterion values, and there was negligible environmental impact, but all this experience was ignored for the Outer Harbour channel.

The result has been that dredged material is now being found by trawlers on fishing grounds outside the supposed dump site . The inshore waters along metropolitan Adelaide received exceptional quantities of silt which will now recirculate through those waters for several years, reducing available light to seagrass beds and retarding growth of surviving grasses . That turbidity also detracts greatly from the simple amenity of the beaches; their suitability for small children to swim or have any other contact recreation beyond paddling depth .

We hope that this was a single aberration, triggered by publicity on the supposed urgency of having this channel deepened before the channel through Port Phillip Bay could be deepened. Unfortunately, other developers are entitled to cite this as a precedent for their own exemption from the policy .

Much of the process that allowed, even promoted, these works to be done without environmental controls is of the kind identified in the 1989 paper by Hoehn and Randall `Too many projects pass the benefit cost test' (American Economic Review 79(3) 544-551) . We had thought that the essential message of that work had been absorbed by government agencies around the world. That message is that projects tend to be considered individually . All possible benefits are attributed to each project in turn, but tested against only the costs of that project. In fact, benefits usually are created through linked projects, but it is still common practice for writers of proposals to use the flawed `benefit/cost' ratio given by assessing all benefits against costs of one project, not against the sum of costs of contributing projects.

We submit that proponents find this an effective way to seek special consideration because many of the agencies which should apply rigorous assessment methodology to their proposal are more likely to be advocates for the kind of development they propose, and readily accept and promote generous benefit/cost ratios rather than checking that they are justified.

Our disappointment was compounded because, at the request of the then peak industry, bodies (Chamber of Mines and Energy and Chamber of Commerce and Industry) the policy had been drafted in a form that essentially said that any applicant who could show that their works would be consistent with the policy would receive automatic approval . That was the experience with major dredging around South Australia from 1993 to 2004. The applicants for the Outer Harbour project then virtually said `Thank you, we will take that rapid approval, and would you just please waive the environmental conditions anyway .'

A final irony is that South Australian consultants have been employed in the environmental assessment of the Port Phillip Bay project. Good practice in Victoria has generated income for South Australia, even as South Australian authorities were waiving similar environmental assessment here.

5

ownership of coastal land

Two major indenture Acts virtually vest ownership of some coastal lands in `The Broken Proprietary Company' in Spencer Gulf and in the Mobil Oil Refinery in Gulf St Vincent. The ̀ BHP' Indenture Act of 1937 has allowed that company to alter coastal land to a remarkable extent ; in fact, to create new coastal land almost as it wished. The Oil Refinery (Hundred of Noarlunga) Indenture Act 1958 includes right to occupy the foreshore and a strip of coastal waters. This actually has had the effect of protecting much of that foreshore from the cumulative minor impacts of large numbers of human visitors . The shore is not pristine, but it has been protected from some impacts . If any future government truly is prepared to follow through on its stated determination to resume the refinery site, any new development should preserve that coast .

We cannot identify any other Acts which establish significant coastal land tenure through indentures . We do note that occupation of parts of the Port River by Penrice, appears not to have been authorised by any specific legislation, yet for a long time that company was not prevented from effectively alienating what should have been public lands and amenities with its steady deposit of caustic wastes into the river, back to the bank. Neither are we aware of any similar authorisation for Penrice to shift that waste further out to sea when several times it accumulated to the stage where it interfered with shipping, and their chemical processing ; that is, when they were `fouling their own nest' .

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Aquaculture

The legislation promoting aquacutture has introduced a way of alienating coastal land and the submerged lands of the Gulfs, otherwise the property of the Minister of Marine, that is different from most other land tenure in South Australia.

Gulf St Vincent has been tested for more than 40 years, but apparently is not an attractive area for fish farming . The few experiments with oyster growing in Gulf St Vincent have gradually faded .

This is not to say there will not be applicants for sites in this Gulf . If that happens, the local public will learn how limited is their opportunity to respond in the same way as they can to commercial or industrial development fully on land.

6

preservation of coastal land

(a)

Probably the major threat to the integrity of coastal land in Gulf St Vincent is the steadily increasing impact of the human population of greater Adelaide . The impact is insidious, coming as it does in small increments. The solution will include control of human activity in fragile areas .

As an example, a current development proposal for Port Wakefield seeks to attract an extra population that may be several times the current local count. The attraction for those people will include opportunities to use and enjoy the marine environment. Activities with high physical impacts could include wash and propellor gouging from power boats, dragging boats across shallows, digging bait on banks and wetlands, and random walking across samphires and similarly fragile lands.

We assume the developers do not want activities that will reduce the very features that would make the area attractive to house buyers, but the controls will be in the hands of a mix of local government, NRM boards, parks and fishery agencies, and the need will be for them to be anticipatory, and well integrated . We do not question the competence of any of those agencies, but hope that the methods they apply conduce to good behaviour, even to restoration of some areas already showing impact, rather than simple proscription of particular kinds of behaviour, with the attendant difficulty of getting compliance .

(b)

As almost a counterpoint to this kind of impact, a surprising number of the audience at a forum at Port Vincent expressed concern for the glacial erratics on the beach near the marina there. This is encouraging evidence that local people are concerned for such geological sites, although not sure how to protect them .

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7 infrastructure

We have nominated housing and water as areas where defective national policy causes unnecessary impacts on the coast. The patent defects in national energy policy also cause unnecessary impacts on particular parts of the coastal environment. The major impact is from thermal power stations. Already the load on the Port River from 3 power stations exceeds capacity during peak of summer, which is also the time when demand peaks for air conditioning . Assuming climate change raises ambient temperatures in that river, there will be less capacity to meet current peaks in demand, yet the station at Pelican Point was approved quite recently, apparently as part of an arrangement to `second guess' moves to a sensible national generating policy .

Part of the fault seems to lie with poor integration of what should be national moves to true efficiency - rather than self-defeating interstate rivalry - with the planning system .

The State government does appear to be inclined to an efficient mix of sources of electricity, including from renewable sources. We would hope that trend continues to the point where it produces real benefits by reducing thermal loads on confined coastal waters .

Submission

The notice of inquiry said `Committee is interested in determining if an overarching coastal development plan for South Australia would assist councils and if this would help provide consistency in coastal planning .'

Our concern would be that such a process could take many years to complete, but would still tend to lowest common denominator requirements . It would not overcome the misuse of s46 of the Development Act 1993, particularly the disregard for Regulation 63 on prescribing criteria for development handled under that section of the Act .

We would maintain our case for better integration of natural resource management of the two major gulfs in South Australia, consistent with the principles underlying the [and NRM Boards. We accept that this would involve those land boards having to be more accountable for effects of their works and plans at their coastal boundary.

The solution to the problems with S46 development appears to tie in accountability in Parliament, but it would be helped by effective communication on the true implications of proposals to be dealt with under that section of the Act .

The Friends of Gulf St Vincent would prefer more commitment to the requirements of extant legislation for the environment. We would also like to see more commitment to national and state policies for water, energy and sustainability so that the scope for unintended or unsustainable environmental impacts because of pointless state `rivalries' and similar flaws in application was reduced . The measure of sound national policy is that it produces good local outcomes.

Environmentally appropriate housing, in all its implications, can be promoted through extant legislation, and amendments to local plans . Principles for this include requiring each new housing development to be completed to minimise environmental demand . Existing housing or other urban settlement can be levied to ameliorate earlier impacts. Local plans can be quite prescriptive on energy and water efficiency, with consequent aesthetic benefits .

We are prepared to expand on any of these points for the Committee .

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Ian Kirkegaard Secretary

`Friends of Gulf St Vincent' 8 Severn Street

GILBERTON SA 5081 telephone (08) 8269 3928

e-mail ianrk@iprimus.com .au