Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Tuesday, 13 March 2018

Manager Parks Planning Parks Victona Level10, 535 Bourke St Melbourne VIC 3000

To whom it may concern,

Re: Warmambool Beach Training Support Submission

As an owner of horse/s trained in Warmambool, the opportunities beach training presents as well as the relaxed country em11ronment the d1stnct has to offer is the key reason why I Will continue to support the continuation of horse training in the region.

If this opportunity was not available, the opportunities for these horses would become limited. thus there would be potential for them to retire from racing all together. This would have huge effect on the local horse trainers, horse numbers would decrease as well as taking away the opportunity for any return to continue to fund future horses to be trained in the region.

The opportunity to tra1n horses on Levy's Beach and the dunes is critical for the ongomg success of horse training in Warmambool which I am fully supportive of.

Regards. Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Submission template for Draft Belfast Coastal Reserve Management Plan About you:

Your name:

Your Organisation (if relevant): ______

Postcode: ______

Email or Postal address:

THIS SUBMISSION IS: □ CONFIDENTIAL □x NOT CONFIDENTIAL Date: 5//02/2017______

Your Comments: Please Note – The following information will be made publically available. Main reason for interest: (such as local resident, visitor to parks, tourism operator, environmental interest, business operator, education interest, scientific interest) We enjoy walking our dog on the beach. We understand the damage that dogs can do to fauna if uncontrolled and in sensitive areas are happy to walk with our dog on a leash. To block our dog from the coastal area is unnecessary . We have enough trouble enjoying the wilderness with our canine friend as we are also blocked from most national parks. We especially enjoy Port Fairy and surrounds because this is not at present the case!

How often do you or your organisation use the reserve? □x Daily □ Weekly □ Monthly □ A couple of times a year □ Rarely □ Never

How do you or your organisation mainly use the reserve? □ Walking or running □x Dog walking □x Using the beach (swimming and surfing) □ Horse riding □ Horse training □ Volunteering □ Camping □ Hunng □ Fishing/boang □x Picnicking □ Birdwatching □ Socialising □ Other (please specify): ______

Which part(s) of the reserve do you or your organisation most frequently use? □x West of Killarney (Port Fairy side) □ Between Killarney and Big Baldy □ East of Big Baldy (Warrnambool side) □ Not sure

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

About the vision- Belfast Coastal Reserve, 15 years from now…:

How supportive are you of the vision for the Belfast Coastal Reserve? □ Very supportive □ Supportive □x Not sure/Don’t know □ Unsupportive □ Very supportive

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Key management theme #1: Cultural landscape and living heritage

How supportive are you of the strategies for ‘Cultural landscape and living heritage’ included in the draft management plan?

□x Very supportive □ Supportive □ Not sure/Don’t know □ Unsupporve □ Very supporve

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Key management theme #2: Healthy Country

How supportive are you of the strategies for ‘Healthy Country’ included in the draft management plan?

□ Very supportive □ Supporve □ Not sure/Don’t know □x Unsupportive □ Very supporve

He banning of dogs on leads is unnecessary

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Key management theme #3: Recreation and use

How supportive are you of the strategies for ‘Recreation and use’ included in the draft management plan?

□ Very supporve □ Supporve □ Not sure/Don’t know □x Unsupportive □ Very supporve

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Key management theme #4: Managing in partnership

How supportive are you of the strategies for ‘Managing in partnership’ included in the draft management plan?

□x Very supportive □ Supporve □ Not sure/Don’t know □ Unsupporve □ Very supporve

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Key management theme #5: Research and monitoring

How supportive are you of the strategies for ‘Research and monitoring’ included in the draft management plan?

□ x Very supportive □ Supporve □ Not sure/Don’t know □ Unsupporve □ Very supporve

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Wednesday, 5 September 2018

Manager Parks Planning Parks Victoria Level 10, 535 Bourke St Melbourne VIC 3000

To whom it may concern,

Re: Warrnambool Beach Training Support Submission

As an owner of horses trained in Warrnambool the beach training presents as the main reason Leg injuries and bone injuries are reduced by training on the beach rather than firm turf tracks . The region of Warrnambool is blessed with such beaches.

If this opportunity was not available, the opportunities for these horses would become limited, thus there would be potential for them to be or retire from racing all together. This would have huge effect on the local horse trainers, horse numbers would decrease as well as taking away the opportunity for any return to continue to fund future horses to be trained in the region.

The opportunity to train horses on Levy’s Beach and the dunes is critical for the ongoing success of horse training in Warrnambool which I am fully supportive of. Please take the time to fully understand the impact of removing this privilege of access to the beach.

Regards,

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Tuesday, 13 March 2018

Manager Parks Planning Parks Victoria Level10, 535 Bourke St Melbourne VIC 3000

To whom it may concern,

Re: Warrnambool Beach Training Support Submission

)wns two horses trained in Warrnambool, the opportunities beach training presents as well as the relaxed country environment the district has to offer is the key reason why I will continue to support the continuation of horse training in the region.

we have found that the horses do not excel to their potential as quickly as horses that are trained on the beaches of Warrnambool.

If this opportunity was not available, the opportunities for our horses would have become limited, thus the only other option would have been for our horses to retire from racing all together. The loss of the ability to train horses on the beaches of Warrnambool would have huge effect on the local horse trainers, horse numbers would decrease as well as taking away the opportunity for any return to continue to fund future horses to be trained in the region.

The opportunity to train horses on Levy's Beach and the dunes is critical for the ongoing success of horse training in Warrnambool which I am fully supportive of. Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Tuesday, 13 March 2018

Manager Parks Planning Parks Victoria Level 10, 535 Bourke St Melbourne VIC 3000

To whom it may concern,

Re: Warrnambool Beach Training Support Submission

that owns a horse trained in Warrnambool, the opportunities beach training presents as well as the relaxed country environment the district has to offer is the key reason why I will continue to support the continuation of horse training in the region.

It was with no hesitation that we transferred our horse to Warrnambool and he has excelled due to beach training.

If this opportunity was not available, the opportunities for this horse would have become limited, thus the only other option would have been for our horse to retire from racing all together. The loss of the ability to train horses on the beaches of Warrnambool would have huge effect on the local horse trainers, horse numbers would decrease as well as taking away the opportunity for any return to continue to fund future horses to be trained in the region.

The opportunity to train horses on Levy's Beach and the dunes is critical for the ongoing success of horse training in Warrnambool which I am fully supportive of.

Regar.Qs, Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Manager Parks Planning Parks Victoria Level 10, 535 Bourke St Melbourne VIC 3000

To whom it may concern,

Re: Warrnambool Beach Training Support Submission

owner of horses trained in Warrnambool, the opportunities beach training presents as well as the relaxed country environment the district has to offer is the key reason why I will continue to support the continuation of horse training in the region.

The opportunity to train horses on Levy’s Beach and the dunes is critical for the ongoing success of horse training in Warrnambool which I am fully supportive of.

Regards,

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Manager Parks Planning Parks Victoria Level 10, 535 Bourke St Melbourne VIC 3000

To whom it may concern,

Re: Warrnambool Beach Training Support Submission

As an owner of horse/s trained in Warrnambool, the opportunities beach training presents as well as the relaxed country environment the district has to offer is the key reason why I will continue to support the continuation of horse training in the region.

I only send my horses to Warrnambool because of the beaches.

The opportunity to train horses on Levy’s Beach and the dunes is critical for the ongoing success of horse training in Warrnambool which I am fully supportive of.

Regards,

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Windsurfing Victoria, Inc. 221 Esplanade West, Port Melbourne, Vic 3207 Reg No. A0049214P ABN 59 441 540 713

13 March 2018

Parks Victoria RE: Belfast Coastal Reserve Management Plan

Dear Sir or Madam,

A number of our fellow windsurfers have approached Windsurfing Victoria (the State body representing the sport of Windsurfing) and the Australian Windsurfing Association (the National body), with regards to the proposed restriction of windsurfing in the Belfast Lough and Rutledge’s Cutting areas. As described in the draft Belfast Coastal Reserve Management Plan issued by Parks Victoria.

In respect of Belfast Lough and Rutledge’s Cutting areas, as with the other well used windsurfing areas, we request (as per the Marine Safety Act 2010) ‘Equity of access’ is used as the key principle in defining this area’s future usage and that the draft plan be re-assessed so that windsurfing is not restricted in these areas. We also suggest the local windsurfing community, with support from Windsurfing Victoria, work closely with Parks Victoria on future planning and potential changes to ensure all water users and environments are managed appropriately.

We are aware that Australian Windsurfing Association has already made contact and is in communications with Parks Victoria about this matter. We would like to extend this communication to directly include Windsurfing Victoria.

Over the past years Windsurfing Victoria has worked closely with Parks Victoria. This includes developing strategies and safe locations for our beginner windsurfers to progress in their beloved sport (i.e. ‘Shared Watersports Zones’). Additionally we have worked together with Parks Victoria and continue to cooperate with regard to the Port Philip Bay boating and non-boating zones.

Thanks in advance for your support and open communications regarding this issue and request.

Best Regards

Windsurfing Victoria Inc Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

COMMENTS ON BELFAST COASTAL RESERVE DRAFT MANAGEMENT PLAN

The decision whether to restrict beach access appears to have already been made.

*. Towilla Way walking track to the beach already has a “No Beach Access” sign installed.

*. Gormans Lane walking track to the beach is already wired up with a no access sign (beach end).

This appears to make the effort of writing a submission rather pointless!

However, a few quick points regarding the PROPOSED CONSERVATION ZONE AREA.

1. The use of the beach in the proposed conservation zone is minimal (e.g. 0-4 groups/individuals per km at most at any time) but is extremely important to those who go there, especially locals.

The sandy track to the beach at Towilla Way only occupies less than 1/17000th of the reserve area (less than 0.006%) so should not cause too much worry overall!

2. During gales 2 or 3 times a year, waves up to 1 metre high hit the dunes at the top of the beach causing natural erosion as sand collapses onto the beach. Wind is always shifting sand around and tends to rebuild the base of the dunes in between times. All this makes any human use of this beach totally insignificant by comparison!

3. The track at the rear of the dunes (road reserve) has also been closed off. This should be reopened to provide an alternate route for horses instead of the beach and for walkers when the beach is too windy and unpleasant. The quick regeneration of this track shows that previous use did not cause any permanent damage.

4. Dogs can be an occasional nuisance, but few and far between, with most people using a lead while they are walking their dog on the beach. Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

5. Horses : If they are banned from the beach, it is unfair to locals who enjoy the occasional ride on the beach. They do not seem to be a problem to other beach users. If zoning allows for horses, then use will increase due to publicity.

Therefore best to leave things as they are on this stretch of beach. Don’t specify a change of zoning.

6. To quote from your Draft Management Plan

The natural values of the coastal landscape have been maintained and enhanced. The impacts of pest plants and animals have been progressively reduced through coordinated programs with agencies and neighbouring landholders. Native plants and animals are flourishing and significant rare and threatened species are recovering. The area continues to provide important habitat and refuge for native species, particularly threatened migratory birds that breed and feed here. Sound decision making is assisting to moderate the impacts of erosion and climate change

Things seem to be thriving under the present system.

Therefore, rather than trying to change the present management by creating an unnecessarily restrictive “Conservation Zone” here, the Department’s effort should be put in at places where there is a real need for controls and ”enhancement”.

12th March 2018 Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

12th March, 2018

SUBMISSION TO BELFAST COASTAL RESERVE DRAFT MANAGEMENT PLAN

Friends of the Hooded Plover, Breamlea is pleased to have the opportunity to provide a submission to the above-mentioned Draft Plan.

We believe that we bring to the discussion experiences which closely match those of the Belfast Coastal Reserve, as our own environment contains similar high conservation values and geomorphology of our foreshore.

Breamlea is located between Torquay in the west and Barwon heads in the east. The coast of Breamlea is formed of high sand dunes that create a ridge at the back of the beach from near Point Impossible to the lava flows at Black Rock. The dunes have been formed from the cementation of old wind blown sands with calcium carbonate from shell fragments within the sands. The saltmarsh that borders Thompsons Creek to the north of the township is relatively untouched and so is important for its vegetation communities and as a roosting area for many species of indigenous birds, including the Orange-bellied parrot.

We have Hooded Plover pairs from Point Impossible to Black Rock and as volunteers of the Friends of the Hooded Plover, Breamlea, we have been monitoring these pairs since the formation of our group under Birdlife Australia’s Beach-Nesting Birds Project. This is a species for which we have personally invested hundreds of volunteer hours to protect, and in so doing, assist local, state and federal governments in threatened species management. Our beaches also host migratory shorebirds such as the Red-necked Stint, Ruddy Turnstones and Double-banded Plovers, as well as local species like the Red-capped Plover.

It has been crucial to have a management plan for this threatened species within our region. The City of Greater Geelong (CoGG) has developed a ‘Conservation Action Plan’ for the Hooded Plover which covers beaches under their management from Point Lonsdale to Thompsons Creek estuary (approx. 25 km of surf beaches). This plan outlines goals and targets to be met.

Both Friends of the Hooded Plover groups - Bellarine and Breamlea - work closely with the City of Greater Geelong to achieve these goals as we recognise that bottom- up efforts have to be met by top-down support in order to achieve long-term sustainable use of the coast and to give wildlife the chance to survive and thrive in heavily impacted areas.

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

The strategies in this plan include a permanent ‘no dogs’ section of the beach, ‘dogs on leash’ during the Hooded Plover breeding season and ‘no horses’(recreational or commercial) on the beach or in the dunes at all times. There is no vehicle access and no camping, dune boarding or boot camp training in the dunes. A high emphasis on educating the public through the media, training on Hooded Plover protection for by- laws officers and organisations such as surf schools, as well as beach signage and fencing. CoGG has also developed a Dogs on Beaches card-sized pamphlet- to fit in your wallet- conveying the all year-round beaches rules for dogs (on or off-leash, or no dogs) and the details of the seasonal controls of dogs throughout the year.

These actions have made a significant difference to Hooded Plover species recovery within our area, with the number of breeding pairs under the municipality having doubled over the past 8 years.

Through our connection with Birdlife Australia, The Friends of the Hooded Plover, Breamlea is aware that the Belfast Coastal Reserve site is a particularly critical habitat for the Eastern Hooded Plover, containing 12% of the Victorian population, 2.5% of the Eastern subspecies. In addition, it is one of five priority locations for Orange- bellied Parrots, plus internationally significant habitat for Sanderling and Sharp-tailed Sandpiper, and nationally significant habitat for Ruddy Turnstones and Double- banded Plovers. We all work together across the species range and regularly come together with the volunteers from Warrnambool to Port Fairy to share ideas and work toward recovery of the species as a team who want to change the trajectory of the species at the population level. Everyone’s local actions are amounting to change for this species, in line with the Threatened Species Strategy.

When BirdLife reviewed the breeding success in the Reserve, they found 44% of sites had not produced Hooded Plover fledglings in 5 breeding seasons of monitoring. Sites were under extreme pressure from horses, dogs off-leash and even illegal vehicles, as well as weeds and foxes. The narrow, rocky beaches are subject to high pressure from horses and dogs which are squeezed into this narrow zone. This area happens to contain one of the densest populations of Hooded Plovers known.

We are highly supportive of the Belfast Coastal Reserve Draft Management’s approach to set aside the highest value section of the Reserve as a Conservation Zone, with a focus on protecting the habitat values and minimising disturbance to breeding birds and roosting and foraging migratory shorebirds.

We are particularly supportive of the proposed Conservation Reserve being free of high impact threats including hunting, off-road vehicles, dogs, horses, camping, and dune boarding. Our own experience of CoGG’s resolve to not allow these types of activities, convinces us that not only should such strategies be put in place, but that these regulations must be enforced.

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

We also understand that the geomorphology of the coast within the Conservation Zone consists of many rocky embayments, small headlands and a narrow beach that then opens out in to the estuary at Rutledges Cutting. Horses on the upper beach along these narrow beaches and the cutting across each headland at the multiple ‘pinch’ points has been well documented through the Hooded Plover monitoring program. Avoiding critical breeding habitat cannot be successfully achieved in this particular beach morphology. This is a similar case with our Breamlea beaches. We have volcanic rocky headlands on several sections of our beaches and an estuary at the western end near Point Impossible, that also cause ‘pinch points’. That is why our council has enacted a ‘no horses’ policy of our beaches.

We do not support commercial horse training in the Reserve, including permitting this activity within the Conservation Zone. There are extreme risks to threatened species, habitat, cultural heritage sites, and public safety. Hooded Plovers cannot co-exist with commercial racehorse training because it churns up the sand, disturbs the chicks and nesting birds, crushes eggs and damages protective nest fencing. We understand that an alternative sand track and pool was built in 2017, and several trainers are using the sandy soil in their paddocks. Many racehorse trainers across the country do not have access to beach and dune environments, yet through other training methods, have proven results. The racing industry and state government is primarily using one example of the Melbourne Cup winner, Prince of Penzance being trained on the beaches of Warrnambool. This is overinflating the situation. Trainers will still achieve the results they desire for their horses but it does not have to be on the beach where there is so much to lose. Access to these fragile environments is not a prerequisite for success.

We are alarmed to see that the state government plans to reward the commercial racehorse trainers by giving them a licence to continue, and allowing a major increase of up to 250+ racehorses per day along the beaches. Under the draft management plan, the length of beaches available to racehorse training would be increased by 250% (from 2 km to 5 km). That represents 25% of the Reserve’s beaches with nothing in the plan to stop future expansion or to review compliance and impacts. It even recommends racehorse training within the Conservation Zone at Rutledge’s Cutting, which is at odds with the recommendation of the Conservation Zone.

This draft coastal management plan for the Belfast Coastal Reserve suggests reversing a cap on racehorses numbers put in place in 2016. Just 12 months earlier a factsheet produced by the state government acknowledged the rapid increase in horse numbers. The draft management plan itself recognises that it fails to reduce risks to high conservation zones. Such a situation must not be allowed to happen.

We strongly support the goals and strategies within the chapter of the Draft Plan including maintenance of geological features, recognising Traditional Owner and community connections to it, ensuring cultural landscape values are protected in heritage management, and establishing partnerships with Traditional Owners to protect and conserve heritage features. Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

The traditional owners of the land at Breamlea are the Wathaurong people and protection of the cultural sites within the dunes, which include significant middens, as well as wetland sites, is outlined in the ‘Breamlea Foreshore Masterplan and Management Plan’.

The City of Greater Geelong, along with community groups, work closely with the traditional owners to ensure this protection. We therefore support the right for the Gundijmarra people to protect their cultural heritage and to be directly involved in guiding the management of the Belfast Coastal Reserve.

We would like to advocate for Emergency Beach Number signs (yellow triangles mounted on posts) to access points for the safety of beach users and volunteers in the Reserve. These are extensively used on our beaches to denote nesting sites and to assist volunteers. These have also been used over the years to locate injured beach- users and wildlife.

We do not support the current 5 and 10 year reviews of implementation of the Plan. This is too long a timeframe for threatened species likely to be impacted by the Plan. A one to two yearly review cycle is required.

We urge a coordinated management approach to the Reserve which would enable efficiencies in program delivery and is supported by consistent land status and regulations. However, the plan recommends retaining the fragmented management across the City of Warrnambool, Moyne Shire Council and Parks Victoria and leaving the Reserve under the Crown Lands (Reserves) Act. Due to its significant environmental, threatened species and cultural heritage values, consideration should therefore be given to the Reserve becoming a park under the National Parks Act, as recommended by the Victorian National Parks Association. Thank you for providing the opportunity to engage in this process. A Reserve with such local, statewide, national and international significance to several species and groups of birds is of importance to all members of the community. As members of a Friends of the Hooded Plover group, we especially recognise that decisions made through the process will impact on our efforts to protect this nationally threatened species.

Friends of the Hooded Plover, Breamlea

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Belfast Coastal Reserve Plan 2018- Windsurfing and Kitesurfing in Belfast Lough

Submitted by

I wish to outline my disappointment at the banning of non powered vessels (in particular- windsurfers) on Belfast Lough. every time I visit, if the wind is up, I will find a place to windsurf…. and more often than not, the place I end up at is The Lough. I must outline, that at the time I access the Lough, I am one of a handful of windsurfer/ kitesurfers. There is no one else out using the waterway at the times we are on the water…this is because the conditions aren’t conducive to other pursuits (eg too windy for pleasure craft, fishing or rowing)

It’s fair to say The Lough is an intriguing and unique place to windsurf. It’s not exactly the finest of water quality but windsurfers can be incredibly hardy people! It’s quite shallow which makes it safe for beginners. The other safe element is that it is an enclosed waterway which provides a place to sail when the wind is offshore and the ocean conditions are too dangerous. But most importantly the low-surrounding terrain creates a situation where there is “clean air”. Other lakes in the area are mainly volcanic craters, with high surround hills, which create swirling wind patterns. These create their own challenges but are generally quite terrible for windsurfing.

In the Management Plan, I fail to understand the logic of allowing motorised vessels but not passive watercraft. Wind powered craft are less environmentally damaging than powered craft and have very little affect on the waterway. Under the proposed Plan, motorised boating (including Jet Ski’s) will be permitted; with a 5-knot speed limit within 200m from shore. The Lough is 700m wide and 1800m long, that means that in some places there will be a 400m “speed strip” where motorised vessels can noisily travel in close proximity to each other at over 100 kmh….and yet passive windcraft are banned…would someone in Parks Victoria please explain that logic to me???

The nature of windsurfing and the people that windsurf should be taken into consideration. In general, windsurfing people are environmentally conscious- since we depend on certain environmental conditions to pursue our passion. We are connected to the places that we sail, and we leave very little footprints on the areas that we sail. Many of us are experienced water men and women- we have been on the water all of our lives, and have a broad understanding of wind and environment conditions.

Most of the time, our sport is “invisible”. We venture out in conditions where the wind is howling, sometimes it’s raining, cold- most people are bunkered down inside!! Most importantly, I have found that the majority of windsurfers have a healthy respect for other water users and tend to keep to themselves and not obstruct/ interfere with other water activities.

March 2018

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Submission template for Draft Belfast Coastal Reserve Management Plan About you:

Your name;

Your Organisation (if relevant): ______

Postcode: ____3280______

Email or Postal address: 3280______

THIS SUBMISSION IS: □ CONFIDENTIAL x□ NOT CONFIDENTIAL Date: 5/2/18______

How often do you or your organisation use the reserve? □ Daily x□ Weekly □ Monthly □ A couple of times a year □ Rarely □ Never

How do you or your organisation mainly use the reserve? □ Walking or running x□ Dog walking □ Using the beach (swimming and surfing) □ Horse riding □ Horse training □ Volunteering □ Camping □ Hunting □ Fishing/boating □ Picnicking □ Birdwatching □ Socialising □ Other (please specify): ______

Which part(s) of the reserve do you or your organisation most frequently use? □ West of Killarney (Port Fairy side) x□ Between Killarney and Big Baldy □ East of Big Baldy (Warrnambool side) □ Not sure

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

About the vision- Belfast Coastal Reserve, 15 years from now…:

How supportive are you of the vision for the Belfast Coastal Reserve? □ Very supportive □ Supportive x□ Not sure/Don’t know □ Unsupportive □ Very supportive

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Key management theme #1: Cultural landscape and living heritage

How supportive are you of the strategies for ‘Cultural landscape and living heritage’ included in the draft management plan?

□ Very supportive □ Supportive □ Not sure/Don’t know □ Unsupportive □ Very supportive

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Key management theme #2: Healthy Country

How supportive are you of the strategies for ‘Healthy Country’ included in the draft management plan?

□ Very supportive □ Supportive □ Not sure/Don’t know □ Unsupportive □ Very supportive

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Key management theme #3: Recreation and use

How supportive are you of the strategies for ‘Recreation and use’ included in the draft management plan?

□ Very supportive □ Supportive □ Not sure/Don’t know x□ Unsupportive □ Very supportive

I am writing this as a submission to the Belfast Management Draft Plan. I am very concerned and do not agree that the section of beach from Killarney to Big Baldy should be deemed to exclude dogs. I am a beach user on a regular basis and walk my dog which was leash free until recently when the signs were changed. I understand the need for environmental conservation. However, there is a large area of beach to be considered and a small area that needs conservation mainly the Hooded Plover in this area. When I walked this beach this morning , I was the only user on the beach at the far end of the Gorman’s Lane carpark, which is often the case anytime I use this area. I walked West one kilometre up the beach. In this area there is one 70m x 10m picket star fenced off area with signs for the Hooded Plover. A few bits of rope attached to some pickets. My questions are; Why close the entire part of the beach to dogs for small pockets of conservation area? (The conservation effort to these plovers looks very haphazard with only star pickets and a few signs, there is no protection between these pickets.) Why if they are so important to protect is the effort to protect them so minimal? Why does the beach need to be closed to dogs for the entire year when the birds breed from August to March as stated in the plan? I would like to see data that explains the number of users to the area, how many of them are dog users, and how many and what type of damage do dogs do to this environment. What is the exact number of birds in the past compared to now? To me, it seems that a very small percentage of incidences does not warrant the closure of the area to dogs. In the draft plan, it describes dog behaviour as; leaving excrement, uncontrolled roaming and aggressive behaviour, these behaviours can occur in any environment not just at this location. I believe most dog owners are responsible and control their dogs, it may be a few rogue owners that set a bad example for the rest of us. I disagree with the Belfast Management Draft Plan to exclude dogs from Killarney to Big Baldy. I believe careful consideration is needed in regard to the small conservation requirement and the recreation use for dogs on this part of the beach. I believe a balance can be met for that of conservation and for a leash free beach for dogs.

(I had submitted this as a letter and then I found this template.)

Key management theme #4: Managing in partnership

How supportive are you of the strategies for ‘Managing in partnership’ included in the draft management plan?

□ Very supportive □ Supportive □ Not sure/Don’t know □ Unsupportive □ Very supportive Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Key management theme #5: Research and monitoring

How supportive are you of the strategies for ‘Research and monitoring’ included in the draft management plan?

□ Very supportive □ Supportive □ Not sure/Don’t know □ Unsupportive □ Very supportive Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Submission template for Draft Belfast Coastal Reserve Management Plan About you:

Your name:

Your Organisation (if relevant):

Postcode: 3280

Email or Postal address:

THIS SUBMISSION IS: □ NOT CONFIDENTIAL Date: 12/3/2018

Recreation and use: Windsurfing, Kitesurfing, surfing

How often do you or your organisation use the reserve? □ Daily

How do you or your organisation mainly use the reserve? □ Walking or running □ Dog walking □ Using the beach (swimming and surfing) □ Horse riding □ Horse training □ Volunteering □ Camping □ Hunting □ Fishing/boating □ Picnicking □ Birdwatching □ Socialising □ Other (please specify): windsurfing Kitesurfing ,surfing

Which part(s) of the reserve do you or your organisation most frequently use? □ West of Killarney (Port Fairy side) □ Between Killarney and Big Baldy

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

About the vision- Belfast Coastal Reserve, 15 years from now…:

How supportive are you of the vision for the Belfast Coastal Reserve? □ Very unsupportive

Key management theme #1: Cultural landscape and living heritage

How supportive are you of the strategies for ‘Cultural landscape and living heritage’ included in the draft management plan?

□ Very unsupportive

Key management theme #2: Healthy Country

How supportive are you of the strategies for ‘Healthy Country’ included in the draft management plan?

Very unsupportive

Key management theme #3: Recreation and use

How supportive are you of the strategies for ‘Recreation and use’ included in the draft management plan?

□ Very unsupportive

Addressed to the Conservation area (dark green) in the draft plan.

The Belfast coastal reserve should be designated as Conservation and Recreation zone (light green on Parks Vic map. This plan has an underlying presumption that conservation can only be successfully carried out if an area is locked up and regulated. i.e. close it up, throw away the key, stop peoples’ recreational activities and fine people who dare trespass. This notion of conservation suggests only Parks Vic can be trusted to conserve our environment and people who want to use the reserve cannot be trusted. Parks Vic has very limited human and financial resources. There is a waste of additional resources when people who live in the area, who care and use the environment are sidelined from the conservation process. The group , Southwest Windsurfers and Kitersurfers fulfil the role of friends to the Belfast Lock and Rutledges Cutting. We collect and dispose of rubbish, both in the waterway and the surrounds. We would inform appropriate authorities if inappropriate or illegal activities are carried out. We are a free resource that provides continuous and effective environmental oversight.

I support the right for others to responsibly enjoy their animals in the Reserve. The presence of recreational horses and responsible dog walkers in the reserve has an effective conservation purpose. They collect rubbish and ensure other users are responsibly using Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

and caring for “their backyard”. Inappropriate use or illegal activity in the reserve is challenged or reported and their coverage of the reserve is continuous and covers the breadth of the reserve. This is a much greater and more sustained environment protection than can be carried out by Parks Vic. The idea of locking up vast areas of the reserve seem contrary to good environmental management. These locked up areas become sanctuaries for vermin i.e. feral cats and foxes. Effective control of these pests becomes almost impossible. Baiting is generally ineffective and cannot be responsibly carried out near areas of population. Shooting has too many dangers and does not seem acceptable to the public. The locking up of a major part (dark green conservation zone) of the Belfast Coastal Reserve necessitates that dogs and recreational horses must use the small, designated recreation area between Killarney beach boat ramp and Golfies beach, This will causes massive problems. Parks vic has now put different user groups in direct conflict with each other. Many families with young children use Killarney beach because it has flat water and is safe. Under Parks Vic plan, this small beach now can have dogs off leash during summer before 9am and after 6 pm. On hot days, many families will be on the beach at this time. After Easter and until Christmas dogs can be off leash at any time. The area west of Killarney beach boat ramp carpark to Golfies beach will now have a markedly increased presence of dogs on leash all year round, a concentration of recreational horses and large numbers of beach walkers. This is in addition to the racehorses being exercised on the beach at Golfies in big numbers between dawn and 10am. This is an accident or conflict just waiting to happen. It seems Parks Vic has also tried to save bird habitat in the dark green conservation zone but at the expenses of bird habitat in the Recreation Zone. Data has been provided to Parks Vic in the document “Managing the Hooded Plover in Victoria: A site by site assessment of threats and prioritisation of management investment on Parks Victoria managed land. Dr Grainne Maguire, Dr Meghan Cullen and Renee Mead”. This data states that hooded Plover breeding in the area from Warrnambool to Yambuk is double that of breeding in isolated areas such as Discovery Bay where there is little human contact. The major threats to the Hooded Plovers are sea, wind, foredune alteration, gulls, ravens, foxes etc. comprising around 85% of the total threat to the Hooded Plover. The overall horse threat is measured at 0.77% of all threats and dogs 3.6% compared with Foxes at 6.9%. Natural threats are not reduced by changing the Belfast Reserve to a Conservation zone (dark green on Map) This plan seems to have been formulated from elsewhere by people who have little idea of the Belfast coastal reserve and its user groups. The data suggests that the current arrangements for Belfast reserve are successful and do not need to change. To me the obvious solution to the problem is to make the entire Belfast Coastal Reserve a Conservation and Recreation zone (light green colour). This utilises the local user groups as trusted assets and partners to assist in the conservation and maintenance of the reserve. This spreads out user groups with much a lower density and avoids possible conflict. Any environmental impact of recreational horse or dogs are minimised due to being spread out over a large area. Having people use all areas of the reserve assists in discouraging vermin to remain in close proximity to nesting birds and other native species.

25/2/2018

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Key management theme #4: Managing in partnership

How supportive are you of the strategies for ‘Managing in partnership’ included in the draft management plan?

□ Very unsupportive

Key management theme #5: Research and monitoring

How supportive are you of the strategies for ‘Research and monitoring’ included in the draft management plan?

□ Very unsupportive Comments: (Your submission can be as short or long as you wish. Put comments under relevant headings corresponding to plan sections or strategies, noting page and paragraph numbers. Attach more pages if required).

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Submission template for Draft Belfast Coastal Reserve Management Plan About you:

Your name:

Your Organisation (if relevant):

Postcode: 3280

Email or Postal address:

THIS SUBMISSION IS: □ NOT CONFIDENTIAL Date: 12/3/2018

Recreation and use: Windsurfing , Kitesurfing, surfing

How often do you or your organisation use the reserve? □ Daily

Which part(s) of the reserve do you or your organisation most frequently use? □ West of Killarney (Port Fairy side) □ Between Killarney and Big Baldy

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

About the vision- Belfast Coastal Reserve, 15 years from now…:

How supportive are you of the vision for the Belfast Coastal Reserve? □ Very unsupportive

Key management theme #1: Cultural landscape and living heritage

How supportive are you of the strategies for ‘Cultural landscape and living heritage’ included in the draft management plan?

□ Very unsupportive

Key management theme #2: Healthy Country

How supportive are you of the strategies for ‘Healthy Country’ included in the draft management plan?

Very unsupportive

Key management theme #3: Recreation and use

How supportive are you of the strategies for ‘Recreation and use’ included in the draft management plan?

□ Very unsupportive

Addressed to: Page 59 Recreation and Use: Stated Goal. The Basin, Pelicans and Towilla Way beaches will support recreational activities which are managed to reduce their impact on natural and cultural values.

Access to Pelicans (Long Reef), Towilla Way and Gormans Lane

It has been a mainstay of my physical and mental wellbeing. We are a diverse group of people of all ages who have chosen to live in the Port Fairy/Warrnambool area because of its proximity and access to the ocean. Many of us meet on a daily basis to participate in many water activities in the Belfast Coastal Reserve. We surf mainly at Golfies and the Cutting; we windsurf and kitesurf in the ocean, the Belfast Lough and Rutledges Cutting (saltwater swamp). We Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

snorkel and scuba dive at the Basin (access from Towilla Way and Gormans Lane) and the Long Reef (called Pelicans on Parks Vic. map) with access via a marked primary track from the Basin road to Pelicans. The current draft management plan seeks to create a conservation zone all along the Armstrong Bay beaches in South West Victoria. This conservation zone will have a huge, detrimental impact on our recreational choices, now and into the future, due to restriction of access to waterways. These beach accesses are primary tracks that should remain open. These give access to the ocean and consequently support our recreational activities of snorkelling and Scuba diving. Access to Pelicans (Long reef) has always been available from a primary track accessed from a small carpark located off the Basin road. This path is still reasonably well defined with some parts having duckboards covering sandy areas. The car park used to have approximately five parks that was generally sufficient for the usage. This carpark has now been partially overgrown with coastal wattle, not native to this area, and marram grass. This has reduced parking capacity. This path is important to Scuba Divers, Snorkelers with heavy equipment to carry, as it is the closest direct path to the Long Reef. Access along the beach from the Basin carpark or Killarney boat ramp carpark is a considerably longer distance. This is an existing primary track. It does not have high usage but its continued existence does provide support for the goal stated above. Having a single defined track does reduce impact on the environment. Our group are also Scuba Divers. We are happy to assist Parks Vic. to clear vegetation that has grown over the carpark area. The access tracks to the beach from Gormans Lane and Towilla Way also provide access to the ocean for snorkelling and scuba diving. This access is vital as we often have heavy gear to carry. These tracks have limited use from people participating in diving activities but have greater usage from recreational horse and dog walkers. These primary access tracks should be maintained.

Addressed to page 57: Golfies will continue to be a key site for active recreation providing for a variety of uses including walking, horse and dog exercise, beach fishing and surfing. Reposition of the carpark further inland ….separate parking for horse floats and general public.

Golfies has been used for decades by anglers, surfers, swimmers, families, dog walkers, windsurfers and kite boarders. It is an important access to this “wilder” beach area. Many users carry heavy equipment such as fishing tackle, surfboards, windsurfing and kitesurfing gear and picnic gear. It is also a great spot for people to relax and is important for the mental health of the many user groups. Golfies car park’s main attraction is its proximity to the ocean. Users have a parking place with direct viewing of the sea. Consequently, Golfies carpark should remain in its present location for recreational users. The main wear and tear on this car park has occurred recently and has been caused by commercial horse trainers. If commercial horse riding is relocated to the proposed location at Levis Beach, horse floats will not use this carpark and it can remain in its present position as it has for decades.

Golfies carpark should remain in its present location for recreational users.

Key management theme #4: Managing in partnership

How supportive are you of the strategies for ‘Managing in partnership’ included in the draft management plan?

□ Very unsupportive Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Key management theme #5: Research and monitoring

How supportive are you of the strategies for ‘Research and monitoring’ included in the draft management plan?

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Submission template for Draft Belfast Coastal Reserve Management Plan About you:

Your name:

Your Organisation (if relevant): ______

Postcode:

Email or Postal address:

THIS SUBMISSION IS: □ NOT CONFIDENTIAL Date: 5/3/2018

Recreation and use: Windsurfing , Kitesurfing, surfing

How often do you or your organisation use the reserve? □ Weekly

How do you or your organisation mainly use the reserve? □ Other (please specify): windsurfing Kitesurfing ,surfing

Which part(s) of the reserve do you or your organisation most frequently use? □ West of Killarney (Port Fairy side) □ Between Killarney and Big Baldy

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

About the vision- Belfast Coastal Reserve, 15 years from now…:

How supportive are you of the vision for the Belfast Coastal Reserve? □ Very unsupportive

Key management theme #1: Cultural landscape and living heritage

How supportive are you of the strategies for ‘Cultural landscape and living heritage’ included in the draft management plan?

□ Very unsupportive

Key management theme #2: Healthy Country

How supportive are you of the strategies for ‘Healthy Country’ included in the draft management plan?

Very unsupportive

Key management theme #3: Recreation and use

How supportive are you of the strategies for ‘Recreation and use’ included in the draft management plan?

□ Very unsupportive

Put your submission here and upload to park Vic site at https://engage.vic.gov.au/belfast

I’ve been Windsurfing in the Port fairy area and the Lough provides us with the only safe spot to teach and encourage learners as well as sail in strong northerlies where the alternative would be to risk being blown out to sea. Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

I do not understand why windsurfing has been singled out for exclusion over other forms of water sports including those that involve motorised engines. Windsurfing is an incredibly low impact activity and my presumption is this exclusion is perhaps a clerical error in its exclusion.

We do not damage the local environment, we represent virtually no threat to any wildlife.

Key management theme #4: Managing in partnership

How supportive are you of the strategies for ‘Managing in partnership’ included in the draft management plan?

□ Very unsupportive

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Key management theme #5: Research and monitoring

How supportive are you of the strategies for ‘Research and monitoring’ included in the draft management plan?

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Belfast Coast Management Plan: - Individual Survey Submission

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Do you believe that the current use of the reserve that allows for both Recreation and Conservation should continue?

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2 Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

From: Sent: Tuesday, 6 March 2018 2:08 PM To: ParkPlanMailbox; Cc: @wv.org.au Subject: Belfast CR Enquiry

Categories: Red Category

Dear

Thanks for your response and comments.

We do understand from previous experience plus the research we have already undertaken that this plan is in draft, and that all comments and feedback will be considered in reviewing and preparing the final management plan.

Prior to the draft proposal submission date we seek specific confirmation re: a) Is it correct that Parks Vic (as per Draft proposal) proposes the banning of windsurf activity on the Belfast Lough ? b) Is it correct that Parks Vic (as per Draft proposal) proposes the use of powerboats/jetski/PWC on the Belfast Lough ?

If both of these are correct (as indicated by the draft planning proposal) this would seem clearly illogical, and at apparent odds to a number of Parks Vic objectives, as well as the interests of our windsurf community. Obviously, in this case, and to ensure our position is not taken lightly, we would prepare a more extensive submission etc ahead of the draft response deadline 16 March. (now less than 10 days away)

Should it be simply an oversight in planning proposal documentation, descriptive terminology or similar (which, considering the apparent illogicality of this proposal we have grounds to believe it may be ??), then we would be pleased to have confirmation so that we can all relax and make more efficient use of everyone’s valuable time and resources.

I understand potentially affected users have already sought the involvement of Victorian Government MPs etc, in this matter - perfect if required, but potentially embarrassing should it turn out to be not as Parks Vic intended.

Unusual though this request may be, we hope the logic in resolving this promptly is reasonable and apparent.

Alternatively, should you or any of your staff wish to discuss this situation or any aspect of the draft, I would be pleased to hear from them by email or phone .

With Thanks and Best Regards

Australian Windsurfing Association www.windsurfing.org Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

From: @parks.vic.gov.au] On Behalf Of ParkPlanMailbox Sent: Tuesday, 6 March 2018 12:59 PM To: @wv.org.au Subject: RE: Belfast CR Enquiry

Dear

Apologies for the late response. The plan is currently in draft and your comments in regards to how the surfing community uses the Lough will be taken into consideration in reviewing and preparing the final management plan. regards

Park Planning Team I Parks Victoria Phone 13 1963 Email: [email protected] Level 10, 535 Bourke Street, Melbourne VIC 3000 www.parks.vic.gov.au

From: Sent: Friday, 2 March 2018 1:47 PM To: ParkPlanMailbox Cc: @wv.org.au Subject: RE: Belfast CR Enquiry

Dear Parks Victoria,

Understanding it may take some moderate amount of time to investigate and clarify as per below, however as would be normal commercial good practice, it would be appreciated if receipt of the below email, together with an estimate of reply time, could be provided. Thank you.

With Best Regards

Australian Windsurfing Association www.windsurfing.org

From: Sent: Tuesday, 27 February 2018 1:48 PM To: '[email protected]' Cc: @wv.org.au' Subject: Belfast CR Enquiry

Re : Parks Victoria Belfast Coastal Reserve Draft Management Plan

Dear Planning Committee,

Having reviewed the Draft Coastal Reserve Draft Management Plan as per the details and downloads Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018 available via engage.vic.gov.au/Belfast, it has come to our attention that it would appear Parks Victoria would propose to restrict windsurfing as an approved activity within Belfast Lough.

On behalf of our members, Australian Windsurfing Association, Inc and Windsurfing Victoria Inc seek initial clarification of this matter, as the possibility exists that it may simply be a planning or draft oversight or omission.

Belfast Lough has been a frequently used safe haven for local and visiting windsurfers seeking alternative water access in prevailing, strong offshore Northerly winds for over 30 years, with no known incidents, accidents or environmental impact attributed to this usage.

Whilst we appreciate the basics of environmental protection, conservation and user safety, any restriction being proposed or introduced restricting windsurf access to this waterway would seem at logical odds to the apparent draft approval of the use of the area for powered boating, including jetski/PWC use(??)

Please kindly confirm promptly if the Draft Management Plan intention is to restrict future or ongoing windsurf access to Belfast Lough.

With Best Regards

Australian Windsurfing Association www.windsurfing.org

DISCLAIMER *********************************** This message and any files transmitted with it are intended only for the addressee. This message may contain confidential or privileged information. If you are not the addressee of this message you must not read, copy, distribute this information or take an action in reliance on it. If you have received this message in error you are requested to immediately contact the sender or Parks Victoria at [email protected] and delete the original and any copies of this message and any files transmitted with it. The views expressed in this message are those of the individual sender, except where the sender has the authority and specifically states them to be the views of Parks Victoria. Parks Victoria accepts no liability for any damage caused in the transmission, receipt or opening of this message and any files transmitted with it.

*********************************** Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Belfast Coastal Reserve Draft Management Plan Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

The Victorian National Parks Association has prepared this submission guide and provided dot points (in blue text) for each of the chapters to help with your submission. As for the ticks, we’ll leave that to you should you wish to use them.

Draft Belfast Coastal Reserve Management Plan About you:

Your name:

Your Organisation (if relevant):

Postcode:

Email or Postal address:

THIS SUBMISSION IS: □ CONFIDENTIAL X NOT CONFIDENTIAL Date: 10/3/2018

Your Comments: Please Note – The following information will be made publically available.

Main reason for interest: I am submitting feedback to the plan because I have an environmental interest in the area and the conservation of the threatened hooded plover population. I am also fundamentally opposed to horse and dog racing. A decision to allow horse racing on these beaches would be to put money before the environment - I hope the department makes the right decision and gives the hooded plover population a fighting chance at survival. Please see detailed feedback below:

• There are many good elements in the draft coastal management plan that I wholeheartedly support: cultural heritage protection; joint management; education and interpretation; monitoring and research; rationalisation and closure of inappropriate beach access; dog control. But it remains deeply flawed because of its complicity in entrenching and expanding the use of the reserve by commercial racehorse trainers.

• Under the plan, commercial racehorse training would rapidly expand to multiple beaches and in sand dunes, with devastating effects for the nationally threatened hooded plovers—the reserve is its most important breeding area in the state according to the plan—other coastal wildlife and the safety and enjoyment of mum, dad and the kids, anglers, surfers and other beachgoers.

• The length of beaches available to racehorse training would, under the plan, be increased by 250% (from 2 km to 5 km) and the number of horses by 400% (from 65 to 256 each day). That represents 25% of the reserve’s beaches, with nothing in the plan to stop future expansion.

• The draft plan would allow racehorses back into 750 metres of fragile dunes behind Levy’s Beach and at Hoon Hill, where in the past they have caused severe dune erosion. The plan even recommends racehorse training within the Conservation Zone at Rutledge’s Cutting. That is inexcusable.

• Many times, the draft plan refers to damage caused by racehorses but fails to explain how increasing the area available to them by 250% will mitigate these impacts. Worse still, the plan’s risk assessment reveals that management won’t make any difference. Before management, the risk to Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

coastal dune vegetation, cultural heritage, resident and migratory shorebirds from racehorse training is rated ‘Extreme’. After management is introduced? The rating remains—Extreme!

• Ever since the uninvited invasion by racehorses in 2015, their training has been mismanaged, with numerous breaches of licensing conditions, public safety put at risk and taxpayers footing the bill for costly Parks Victoria surveillance and infrastructure upgrades. Expanding the number of training beaches will simply make that worse.

• By entrenching and expanding commercial horse training the plan is a relic of past coastal mismanagement and inappropriate use.

Executive summary (pages v-viii)

• The draft plan claims on page vi of the executive summary that it is consistent with the ‘existing strategies and guidelines of relevant governing bodies’. This is simply not true. It is inconsistent with the:

o original and ongoing purpose of the reserve which aims to conserve coastal wildlife and cultural heritage, and support passive recreation and public education

o Victorian Coastal Strategy, which urges that coastal dune and beach systems be protected from damage and that any uses should be coastal dependent, which means they can only be carried out along the coast. Commercial racehorse training is clearly not one of those

o City of Warrnambool’s planning scheme: the Levy’s Beach to Hoon Hill area is covered by a Public Conservation and Resource Zone, which lists the uses that are allowed with or without a permit. Any uses not listed are prohibited. Commercial racehorse training is not listed so should be prohibited.

About the vision- Belfast Coastal Reserve, 15 years from now…: (page 7)

How supportive are you of the vision for the Belfast Coastal Reserve? □ Very supportive X Supportive □ Not sure/Don’t know □ Unsupportive □ Very supportive

Comments:

• The vision encapsulates much of what I wish to see in the future for the Belfast Coastal Reserve except for the reference to ‘horse riding’: “The location, timing and intensity of activities such as horse riding has been managed to avoid conflicts between uses, and to reduce the risk of damage to the environment and cultural sites”. The softer term of ‘horse riding’ deflects from the extreme risk and existing damage to wildlife, culture and passive recreation from commercial racehorse training in the reserve. The term ‘horse riding’ should be removed from this statement and commercial racehorse training removed from the Belfast Coastal Reserve. Throughout the rest of the plan there are 24 references to the impacts that horses have on the reserve’s natural, cultural and recreational values. More on this under Key Management Theme #2 Healthy Country.

Key management theme #1: Cultural landscape and living heritage (pages 13-24)

How supportive are you of the strategies for ‘Cultural landscape and living heritage’ included in the draft management plan?

□ Very supportive X Supportive □ Not sure/Don’t know Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

□ Unsupportive □ Very Unsupportive

Comments:

• I strongly support the goals and strategies within this chapter of the draft plan including maintenance of geological features, recognising Traditional Owner and community connections to it, ensuring cultural landscape values are protected in heritage management, and establishing partnerships with Traditional Owners to protect and conserve heritage features. However, one of the strategies—'Work with users and community groups to reduce impacts from both authorised and illegal access on the fragile coastal dune systems’—is expecting too much from community groups to act as delivery partners when those groups will witness daily the extreme damage to sand dunes and beach habitats from commercial racehorse training which, under the plan, will have ‘authorised access’. The goals and strategies also ignore the extreme risk to cultural heritage from commercial racehorse training.

Key management theme #2: Healthy Country (pages 28-42)

How supportive are you of the strategies for ‘Healthy Country’ included in the draft management plan?

□ Very supportive □ Supportive X Not sure/Don’t know □ Unsupportive □ Very Unsupportive

Comments:

• This chapter reveals the draft plan’s underlying contradictions regarding commercial racehorse training. On page 29, the draft plan admits that the extreme risk to coastal habitats, cultural heritage and resident and migratory wildlife from commercial racehorse training will remain so even following management action. This fundamental contradiction in the draft plan will undermine the achievement of the very good goals and strategies in this chapter. The goals to which I give strong support include maintaining and enhancing habitats, reducing the impact of pest species and visitors, better management of marine, lake and swamp habitats, minimising the fire risk and building resilience to climate change.

• It is very pleasing to see one of the strategies under this goal including water management of the Belfast Lough, which until now was not considered as part of the Belfast Coastal Reserve. But the strategy is vague, only referring to maintaining its aquatic values. This needs to be more articulate and refer to water quality, water levels and habitat protection, especially the strong management of motor boats and jet skis, which in the shallow waters can significantly impact on shallow-water habitats and birdlife. Jet skis should be banned from the lough and broader reserve.

• Reducing threats and impacts are a commonly used measure to build resilience to climate change within natural systems. Horses have the most impact in the reserve, especially with regard to dune vegetation and stability. Sea-level rise may reduce the width of beaches and intensify the impacts of racehorses on that habitat. The best way to build resilience is to get the racehorses out.

Key management theme #3: Recreation and use (pages 45-69)

How supportive are you of the strategies for ‘Recreation and use’ included in the draft management plan?

□ Very supportive X Supportive □ Not sure/Don’t know □ Unsupportive □ Very Unsupportive

Comments:

• I strongly support many of the goals and strategies that relate to the recreational use of the Belfast Coastal Reserve in this chapter including increased enforcement, better management of vehicular use, dog walking and recreational horse riding, bans on dune boarding, hunting and off-road vehicles, reducing risks and improving safety, improving information, interpretation and education, and developing tourism Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

partnerships, marketing and promotion. But without the removal of commercial racehorse training, these goals will not be achieved.

• A far more honest heading for this chapter would be ‘Recreational and commercial use’. Too often the plan seeks to confuse recreational riding and commercial racehorse training or to downplay the intensity and impacts of the commercial activity, continually referring to the training as a ‘licensed’ or ‘authorised’ use to convey that it is not negotiable, it cannot be restricted or removed. By including it within a chapter mainly on ‘recreation’, it again tries to downplay the highly commercial and intensive nature of racehorse training.

• The draft plan recommends strict controls on where and how recreational uses are to be managed in the future, whereas commercial racehorse training will be expanded. That doesn’t make sense. • In the introduction to this chapter, the draft plan states, with my underlining: Riding of horses for recreational or commercial purposes was viewed as a threat to dune health, cultural heritage, shorebirds and public safety, especially if riders did not comply with regulations, codes of conduct or licence conditions. This suggests that the community is mainly concerned about impacts that occur when commercial racehorse training doesn’t follow the rules. But as the risk assessment table reveals on page 29, even with rules, management will not mitigate the extreme risk from commercial racehorse training.

• Jet skis should not be allowed in reserve waters, including Belfast Lough, because of their disturbance to wildlife and other recreational users, and damage to shallow water habitats.

• Dogs should not be allowed off-leash from 1 August to 30 November at Killarney Beach, coinciding with the first part of the hooded plover breeding season.

• It is ludicrous to consider renaming Hoon Hill to ‘improve expectations on visitor behaviour’ when those same visitors will witness racehorses and their riders ‘hooning’ up and down the dunes of the hill. • Section 6.5 of this chapter is titled ‘Authorised uses’, code for commercial racehorse training. Much of the emphasis in this section is the regional economic importance of the racing industry as justification for the damage that it is causing and will continue to cause if it remains in the Belfast Coastal Reserve. But in a September 2013 report prepared for the Victorian racing industry by consultants IER, it was revealed that the racing industry generates $75 million gross value added in the Western District, which includes Warrnambool but also a number of other racing clubs at Casterton, Coleraine, Hamilton, Terang, Camperdown Mortlake, Penshurst and Dunkeld. The report also reveals that 40% of statewide gross value added for horse racing is from gambling, which takes money out of the community. If applied to the Western District, $30million of the gross value added would be from gambling, which leaves $45million shared across all of the region’s clubs.

• This is tiny relative to other sectors in the regional economy. Most jobs are provided by the healthcare and social assistance, retail and accommodation and food services sectors. Tourism generates more than half of Warrnambool’s total economic output of $3.3billion. Except for the May Racing Carnival being mentioned in a dot point in an event strategy, the racing industry in Warrnambool is ignored in the Warrnambool Economic Development and Investment Strategy 2015-2020 prepared by the Coty of Warrnambool.

• It appears that the main reason for justifying a huge expansion in commercial racehorse training is ‘due to community interest’ and so the ‘plan sets out an approach for horse training that balances support for the racing industry, equity of access for all trainers and ensuring adequate protection for cultural and natural values’. The consultation carried out by Parks Victoria confirmed the serious concerns the community had about commercial racehorse training, but that is now being referred to as ‘community interest’ that justifies the racing industry’s use of the reserve. It sounds ludicrous and it is.

• I strongly condemn the goal under this section of the chapter—Authorised uses of the Reserve are managed to minimise the effect on values and visitors—with regards to commercial racehorse training as it is incompatible with the goals of the plan and the purposes of the reserve.

Key management theme #4: Managing in partnership (pages 71-75)

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

How supportive are you of the strategies for ‘Managing in partnership’ included in the draft management plan?

□ Very supportive X Supportive □ Not sure/Don’t know □ Unsupportive □ Very Unsupportive

Comments:

• I strongly support the first goal in this chapter: Coordinated management of the Reserve enables efficiencies in program delivery and is supported by consistent land status and regulations. But I cannot support the strategies that aim to achieve it. The plan recommends retaining the fragmented management across the City of Warrnambool, Moyne Shire Council and Parks Victoria and leaving the reserve under the Crown Lands (Reserves) Act. The reserve should become a park under the National Parks Act.

• I also strongly support goals to ensure that Traditional Owners caring for their Country is an integral part of the reserve’s management and that community skills, knowledge and assistance provide stewardship and help in that management. However, if commercial racehorse training is retained inside the reserve, all of their efforts would be to nought.

Key management theme #5: Research and monitoring (page 77-79)

How supportive are you of the strategies for ‘Research and monitoring’ included in the draft management plan?

X Very supportive □ Supportive □ Not sure/Don’t know □ Unsupportive □ Very Unsupportive

Comments:

• I strongly support this chapter’s goal and strategies and the indicators to be used to evaluate the effectiveness of the management plan. However, the plan fails to explain how it will lower the extreme risk presented by commercial racehorse training revealed in the table on page 29. That table proves that it cannot and so commercial racehorse training should be removed from the reserve.

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Addressed to specific issues. Prohibition of Windsurfing Kitesurfing and Surfing on the Belfast Lough and Rutledge’s Cutting (saltwater swamp).

He uses the Belfast Lough and Rutledge’s Cutting on a small number of occasions per year. He uses them if the waves in the Ocean are too big or too choppy or if there is an offshore wind that is too dangerous to go into the Ocean. Both the Lough and Cutting are only waist deep so this adds to his safety. I notice that Parks Vic motto is “healthy parks healthy people”. It certainly gives me great peace of mind to know that has two safe venues to windsurf. The physical exercise of Windsurfing is great for his flexibility and mobility. It also improves Brian's mental health and wellbeing as he returns home in a content state of mind. I feel assured that all is well when he uses the Lough or Cutting. Surely this fits Parks Vic motto? I notice that Boating, Jetsking and Yachting are allowed on these places but Windsurfing is not. This doesn't make sense. Windsurfing and Kitesurfing on the Belfast Lough and Rutledge’s Cutting are very passive activities with no environmental effect. The Lough and the Cutting are not used frequently and then only by a small number of enthusiasts. Windsurfers and Kitesurfers do not clash with other user groups on the Lough or Cutting, as they are usually the only water user group on the Lough or cutting. They also keep these areas clean as they collect rubbish and care for the surrounds. Surely, Parks Vic should embrace this major positive effect.

I hope that Parks Vic amend the draft plan to allow windsurfing and Kitesurfing on the Belfast Lough and Rutledge’s Cutting. Both groups do not have a negative effect on the environment.

09th March 2018

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Submission template for Draft Belfast Coastal Reserve Management Plan About you:

Your name: ______

Your Organisation (if relevant): ______

Postcode: ______

Email or Postal address: ______

THIS SUBMISSION IS: □ NOT CONFIDENTIAL Date: 5/3/2018

Recreation and use: Windsurfing , Kitesurfing, surfing

How often do you or your organisation use the reserve? □ Daily □ Weekly Which ever is appropriate for you

Which part(s) of the reserve do you or your organisation most frequently use? □ West of Killarney (Port Fairy side) □ Between Killarney and Big Baldy

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

About the vision- Belfast Coastal Reserve, 15 years from now…:

How supportive are you of the vision for the Belfast Coastal Reserve? □ Very unsupportive

Key management theme #1: Cultural landscape and living heritage

How supportive are you of the strategies for ‘Cultural landscape and living heritage’ included in the draft management plan?

□ Very unsupportive

Key management theme #2: Healthy Country

How supportive are you of the strategies for ‘Healthy Country’ included in the draft management plan?

Very unsupportive

Key management theme #3: Recreation and use

How supportive are you of the strategies for ‘Recreation and use’ included in the draft management plan?

□ Very unsupportive

Put your submission here and upload to park Vic site at https://engage.vic.gov.au/belfast

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Key management theme #4: Managing in partnership

How supportive are you of the strategies for ‘Managing in partnership’ included in the draft management plan?

□ Very unsupportive

Key management theme #5: Research and monitoring

How supportive are you of the strategies for ‘Research and monitoring’ included in the draft management plan?

□ Very unsupportive Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Belfast Coast Management Plan: - Individual Survey Submission

Name:

Email Address:

Post Code: 3280

Is this submission to be treated as Confidential: No

How often do you use the Reserve: Weekly

How do you get to the Reserve: .. Walk, Drive, Ride a Bike, Ride a Horse

By car or by car with float attached.

• walking with dogs • recreational horse riding • socialising • family walks • photographing the scenery • swimming • snorkelling

How important is it to you to be able to continue these activities within the entire Reserve?

This is very important to me, I have been using the Reserve My leisurely visits to the Reserve keeps me healthy and happy and gives me a good sense of balance.

Which part of the Reserve do you use most frequently:

Killarney Beach No. 3

West of Killarney Beach to Port Fairy No. 4

East of Killarney Beach to The Cutting No. 1

West of The Cutting towards Warrnambool No. 2

What is your area of interest (For Example: Conservation, Recreational, Cultural, With Animals – Horses or Dogs)? Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

My main interest is riding my horse leisurely and walking my dog with friends who bring theirs as well, so it is for both personal fitness and the fitness and happiness of my horse and dog, when friends come with me, it becomes a social outing, a very important outlet to ensure good mental health in the community.

Is there a specific change that you want made to the Draft Proposal?

Yes. I would like to see the green zone that is marked for a conservation zone to be changed to a light green zone to be a recreational conservation area.

This proposed area for conservation (east of the Cutting to the boat ramp at Killarney) is where I usually walk or ride, being banned from this area is discriminatory and an unnecessary move. I put my dogs on a leash when we are approaching a fenced off plover nesting area and I walk at the water’s edge so I am very conscious of not disturbing the wildlife especially the nesting plovers. I also do keep an eye open on wandering plover babies as naturally they do not stay within the roped areas, I keep my dogs on the leash if I see baby chicks wandering away.

This is not a highly visited area and usually it is deserted. However when I do come across other dog walkers, they usually follow my example and also leash their dogs during plover breeding season.

I think dogs should not be banned but I do agree that during plover season, they should be on a leash when nearing plover nesting areas.

I also do not wish to see recreational horses banned from this area. Once again, when I ride it is usually deserted, even in high summer. When I do meet others on foot, I ensure that I am mindful that I approach at a walk and do not go into trot until a good distance away from them. I halt if necessary.

I am educated as far as plover breeding habits and feeding habits and am extremely careful to always ride below the high water mark and access the beach at designated tracks. I do not ride in the deep sand at the bottom of the dunes to ensure that I do not disturb any wildlife or cause any erosion.

The plan is not a well thought out. One cannot go on a long ride as there is no alternate access to ride on past the conservation zone. The only option is to ride from Warrnambool to Baldy Hill and return. You cannot ride on as there are no tracks or roads other than the Princess Highway to Killarney.

According to the plan, there will be congestion and over-use of the areas where recreational riders would be allowed. There will also be increased risks with likely accidents due to the recreational horses becoming unruly and over excited when thrown in with racehorses being worked.

Also carparks are presently very small, with more car parks set to be closed off, this will increase the burden on the existing car parks. This will also add to frustration and potential personal blow ups amongst BCR users. Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

There will also be increased incidents involving dogs and horses.

There will also be discord due to the frustration of the congestion between all the beach goers who have different hobbies and needs, these would come to a head at times unbalancing harmony.

There have been people against horses on the beach for a very long time even before the controversial big-name trainers started training their racehorses. Unfortunately some people seem to confuse recreational horses with racehorses, the two sports are vastly different.

This discord is not the vision of Parks Victoria, the slogan “Healthy Parks Healthy People” would be inflammatory and contradictory.

How important is the Cultural Heritage of the Reserve to you?

I think it is important to acknowledge the culture of the first Australians and respect their heritage sites.

How important is protection of the Natural Environment and Bird life to you?

This is very important to me. It is a great privilege to witness first hand all the different and numbers of birds and be a good caretaker of this environment to make sure it stays pristine for everyone to enjoy, not only for us but for those yet to come. I always stop and pick up plastic and other rubbish and remove it from the beach when I walk. When I ride I am very much in awe of the nature around me and am fortunate to be able to be part of nature, more so when I am riding than walking, the birds at times do not even take off when you approach, some walk and form half a circle around us while I go past slowly by, the birds seem to trust you more when you are sitting on a horse. Eagles seem to accompany me flying above me and my horse, not bothered at all by our presence.

When I leave the car park, I ensure that I have picked up any manure and leave the car park in the way I found it, or in a better state than I found it as I usually pick up any rubbish left behind by others.

How important is the ability to enjoy recreation activities to you?

Very important.

We are fortunate to be able to drive only a short distance to find ourselves walking on a quiet deserted beach, such as The Cutting or The Basin, even in the middle of Summer. Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

a favourite track of mine was blocked off by Parks Victoria. This track runs through the sand dunes the whole length of the area from The Cutting to the Basin. This track has a long history and has been in use for over 100 years with little change. This is in important track as at times storms throw logs and big rocks blocking the access from Gormans Lane, but the track enabled me to walk or ride on towards my destination towards Killarney. The other direction at times in winter the tides are so high, they lap the bottom of the dunes, so the track going east enabled me to keep riding towards my destination towards Levy’s Beach in Warrnambool. I also liked to walk with my dogs on this tracks as well.

I object strongly to the fencing off of this much loved track by the local community and all those who come to walk, ride, cycle, fish and so on.

A discussion with a respected traditional owner when I asked him if he objected to my using the track, commented that blocking it was unnecessary and he did not object to my riding on it. He thought that a common sense approach would be to create a detour around an area if it was “getting down a bit”.

Can Parks please take this advice from this well-known respected traditional owner and reinstate our right of passage and take the fences down?

Also I would have thought it sensible to leave it open as it is a way of by passing the beach where the plover nesting areas during breeding season.

I think that with less human presence and with the track getting overgrown, would encourage the population growth of animals that would not be welcome in the Reserve so close to important shore bird nesting areas such as foxes, wild cats, snakes and other undesirable predators. Surely in time these predators will make a significant impact on reducing the plover numbers. Eagles and other predatory flight birds will also not be able to find their prey as easily with the thick growth, I think this would also increase the population of any pests and snakes too.

Back to recreation, with the blocking of this important track and now the proposed ban of horses and dogs on the beach

Walking and riding in this area is very special to me. I would like to keep on doing this.

Is your Personal Health and Wellbeing associated with your use of the Reserve? If so in what way.

Yes, walking and riding (and photographing the landscape and wildlife) brings me great joy and satisfaction. It gives me a feeling that all is well in my world. It is relaxing and calming while keeping the body fit. Good for mental health as well as keeping physical fit and healthy.

I enjoy the remoteness and feeling of being away from it all

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

I also enjoy my encounters with other users of the Reserve, if I am riding, people usually smile and wave and at times people especially with children, want to stop and pat my horse.

If I am walking with my dog and meet other dog walkers, it is the same, usually a stop and a chat and let the dogs socialise before we keep going.

Do you believe that the current use of the reserve that allows for both Recreation and Conservation should continue?

Yes I do.

I think everything should continue the way it is. It has already been made a reserve to look after flora and fauna, aboriginal sites and promote recreational activities.

I think recreational activities should continue throughout the WHOLE reserve, I think directing certain activities and lumping everyone in a smaller area will be problematic for the environment, the wildlife and also cause friction between users which will end up deterring some people from continuing doing what they love.

By allowing horses and dogs throughout the whole reserve , the impact will be spread thinner which will be much better for the Reserve’s health, conservation and recovery.

I have ridden in the company of the local hobby trainers as well. We have a good relationship with each other and we show respect for one another too. They have always been courteous to myself and to my friends when riding out together.

If you believe dogs and horses should be banned – which areas should they be banned from?

I DO NOT think that horses and dogs should be banned at all from anywhere.

I think that education is key in preventing damage to the Reserve’s environment and wildlife. Educating the horse riding community to stay on the designated paths and beach access points, riding below the high water mark and approaching bird nesting areas at a walk and to halt if necessary and not increase speed until the rider is at a safe distance away. Also to approach other beach users with the same courtesy.

As far as dogs are concerned, educating the public about dog control and keeping dogs on leashes when nearing plover nesting areas during plover breeding season is sensible.

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

This education can be via social media, television ads, visiting schools and kindergartens, pony clubs and horse riding clubs, dog clubs and also having an information booth at key beach access points with give-aways of leashes and brochures.

Do you wish to add any further comments? Yes.

• Closing tracks and car parks will not be in line with the Draft Submission visionary slogan “Healthy parks healthy people”. These tracks have been in use for over 100 years and are important for the users to keep doing what they do to keep healthy. Closing access and carparks would make it difficult for the users to get out and enjoy what they do.

• Pollution in the shape of plastics, ropes, broken bottles and other materials washed in to the beaches are picked up and taken away by the users of the beaches, especially by the residents who live here. This ensures the beaches remain in a clean and pristine condition and avoid potential mishaps with the wildlife being entrapped or consuming the rubbish.

• In 2012 WTHRC put in a submission to Parks Victoria (DSE) to be allowed to organise club rides in National Parks and Reserves in south west Victoria. Permission was formally given to the club to do so.

An example of a club ride:

Members and day guest riders would usually meet at Killarney where we park out floats and ride out, either to the east or to the west depending on the tide and beach conditions. We did this at peak summer times with many regular beach goers on the beach and also during and near plover breeding sites. We did this under the guidance of Parks officers during the ride organisation and at times a Parks officer would attend our musters on the day if they wished.

At the end of our ride, we would return to Killarney and enjoy a social bbq lunch with our members and friends of the club. At times other park users would join in, either for a chat or to meet the horses. This always generated a feeling of goodwill not just for our club members but for the whole community at the camping grounds and on the beach.

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Club rides are organised well ahead of time, with permissions sought from the land owners/managers, in this case from Moyne Shire and Parks Victoria. The guidelines and Athra’s code of conduct is strictly adhered to both during the planning phase and the riding phase.

As per the regulations, there is always a pre-ride done to have an approximate expected time of the ride, track and beach conditions, lunch spots and any hazards that might be encountered on the day, plover nesting sites noted too. Members are notified of the ride with a formal Ride Notice and members rsvp to register their attendance with the ride planner. On the day, there is a muster which is an on-site meeting between the ride planner, trail boss, stewards (1 steward appointed to 10 riders), first aid, ride leader and drag rider. The planner, trail boss and stewards are all accredited with Athra and all ride personnel carry walkie talkies, mobile phones and a light first aid kit for both humans and horses. For extra visibility, these personnel also wear a high visibility vest.

At the end of the ride, the ride personnel and riders meet again for a post ride meeting where any incidents are noted, recorded and signed.

All members of WTHRC pledge to obey the club’s code of conduct on their membership form. Every member has a membership card with their name and membership number which they must present if they are asked to provide identification. The code of conduct expects members to take care and respect the environment at all times. It also stipulates rules to ensure the ride is as safe as possible. Groups are kept to a manageable 20 riders at a time.

Both the landowner and hosts are covered by Athra’s insurer and members enjoy 24/7 insurance whether they are riding with the club or not.

Despite riding in high season with many people enjoying the beach at Killarney and riding past plover nesting sites, we never had an issue. We showed respect to one and all at all times.

On behalf of WTHRC, I respectfully ask Parks to include WTHRC as a historic user of the BCR . We have been granted permission formally to hold club rides in the BCR and other national parks and areas under the control of Parks since 2012.

(I can provide documentation of our initial submission in 2012 and a letter from Parks giving us approval to use the BCR for our club rides.) We would like the same privileges as those given to the historical local trainers.

Our club is a small and friendly group that welcomes new members and day members at all times.

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

It is important for horse recreation that we retain as many tracks and beach as possible. It would be a travesty to many horse owners if this privilege is taken away from them. Recreation riding (pleasure riding/trail riding) is a very pleasurable way to enjoy exercise both for the horse and for the rider. Riding is good for both the mind and the body, enjoying nature from the back of a horse is a very special recreational activity especially when you are surrounded by the sounds of the sea, the wind and the birds. Riding keeps people active, fit and healthy.

Impact on the environment is very low due to the mainly slow pace therefore hoof impact is light, especially when walking below the high water mark.

For a read of the Athra Code of Conduct please go to http://www.athra.com.au/2014-03-29-07-34-49/athra- code-of-conduct.html

“The ATHRA Code of Conduct, specifically the Environmental Rules, has evolved and grown since the Code was first drafted. The Environmental Rules have been formulated after consultation with staff from Park Victoria, and other experts in the environmental field, and after research on many of the topics.

I am personally aware of the introduction of ATHRA's Guide to Combatting Phytophthora, prepared by ATHRA.” and ATHRA

I would like Parks to replace the area painted with the dark green with the light green for zoning as “conservational recreation” to ensure that flora and fauna is protected, aboriginal sights are protected and recreational activities for all can continue. (See Map 5, Recreational Horse Access).

I would like Parks to replace the area with the dark green with the light green for zoning as “conservational recreation” and put in the following text:

“Dogs on leash during plover breeding season when approaching plover nesting sites”.

Referring to seasons in Victoria is unfair and unreasonable due to the changeable weather conditions from day to day in a Victorian summer. (See Map 4, Dog Access).

Page 7, para 2 Vision Healthy Parks Healthy People –

This draft plan is a contradiction to the slogan “Healthy Parks Healthy People”. If the plan goes ahead, many BCR users would be detrimentally affected, potentially resulting in the opposite to the slogan.

• “Healthy Parks” there is no proof or science to warrant the notion that if horses and dogs are removed from the area marked as dark green, that the park will be any healthier. Given that plover numbers are Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

the strongest in the state and given that there is a large number of other shore birds on the beaches despite having dogs and horses in the reserve, suggests that it is quite healthy now.

In fact, if the reserve is turned into a park, I would question as to how healthy it would be with an increased number of foxes, feral cats, roaming lone dogs from the neighbourhood, increased snake population and the forever increase of the marram grass would point to the reverse.

• “Healthy People” slashing access points, closing car parks, banning outings that families have with their dogs and their horses, will deter people from taking part in recreational activities.

Vii Summary page

“Horse riding can impact dune health, cultural heritage, public safety and disturb beach-nesting birds. It is critical that the most significant areas for shorebird breeding are protected from disturbances including those from dogs and horses. “

I have gone into discussion in the submission already and I reiterate that as long as horse riding is done in a responsible and conscientious way does not have any impact whatsoever. In my experience and in my observation of those whom I ride with and also see riding, stick to the main access tracks to get to the beach from the designated car parks, do not come across cultural heritage on these tracks or on the beach, always approach the public in a walking pace or stop our horses if necessary to let others go by, certainly do not go anywhere near nesting areas as the nesting places are roped off and in the dry deep sand under the dunes so it is an incorrect accusation and assumption that recreational riding causes an impact.

The same goes with dogs, dog owners including myself stick to the main beach access from the carparks therefore not affecting dune health, do not come across cultural heritage sites on these tracks or on the beach, my dogs and those of others’ I have met have never been a menace to anything let alone humans, and importantly do not go near nesting areas as they are not allowed to and are leashed when approaching nesting areas. Therefore this statement is discriminatory from all points. It is like saying everyone who will drive a car will speed, cause damage on purpose, be a menace to everyone, will disobey the rules. It is like saying everyone who will have a drink will be a drunkard, a nuisance, a menace, a danger to society. People are people, most will do the right thing and it is wrong to assume that everyone riding their horse on the beach and walking their dog on the beach will do the wrong thing. It is terrible form and terribly ignorant and arrogant to attack paint all people with this slur.

Vii Recreation and Use

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

“Other key directions include creating a more inviting visitor experience by providing sustainable, rationalised access and facilities; developing on-site interpretation on the Reserve’s values and risks to enhance visitor experience and safety; and improving promotion of the values of the Belfast Coastal Reserve and the recreational opportunities it offers.”

The point here I would like to make is that this sentiment is faulty in that the change will not make a more inviting visitor experience at all. It has already sustainable rationalised access points that have been in place with not much marked change in well over 100 years as noted and informed by the original land holder who subdivided. Regarding visitor experiences and risks, the plan will actually be putting more visitors at risk by condensing the area of the Reserve into sectioned zones of recreational and conservation, and conservation. The light green zones showing recreation and conservation zones will have the added pressure of more usage by different users, so you have a smaller area with an increased number of people, this in itself will make the zone an unsafe place to be at times. This will surely change the habits of people and the areas will not be as open and friendly and inviting as they are now.

Page 3, para 1.6 “A range of community engagement opportunities took place from March 2017 through to September 2017 with an online project page including interactive map, surveys, public events, semi-structured interviews, targeted stakeholder workshops and site visits, consultation with Gunditjmara and Eastern Maar Traditional Owners. In total more than 230 people were engaged. The website received approximately 800 views, with 77 online surveys submitted and 54 comments added to the interactive map. Participants were dispersed across the south west region, with the majority from Port Fairy and Warrnambool.”

In my view, a total of 77 submitted surveys and a time line of 6 months obviously was not an adequate basis for the present draft to be drawn on.

With a population of Warrnambool standing at about 35,000, Koroit 1380, Port Fairy 2560, plus a large scattered population of Killarney and surrounding smaller towns and many farmers in the shire within a short drive of the BCR, a total of only 230 people engaged is not an adequate number to draw on for such a life changing law to be playing with. With recreational riders in the district being represented by Warrnambool Trail Horse Riders Club (WTHRC), Casterton & District Trail Horse Riders Club, Smythesdale Trail Horse Riders Club, Forrest Horse Riding Club, Mount Leura Riding Club and Limestone Coast Club, how many members of these clubs were involved in your survey and engaged? Outside these clubs, there are many pony clubs in the district as well as other adult riding clubs who often go to the beaches for a ride (maybe a yearly occurrence) and also many individual horse riders who go riding who are not affiliated with a club go to the beach.

I personally attended one of the information sessions in 2017 and also submitted and I was told at all times by Parks and others that recreational riders will not be affected in the decision to ban horses, that only race horses were targeted. Also there was never any mention of dog bans.

How many of the 230 people engaged were recreational riders? On what basis and whose opinion was the assumption made in the summary that recreational riders damage dunes, aboriginal sites, threaten people’s safety and disturb nests? Surely these were either theories or assumptions made by people with a bias.

Also recreational riders were not adequately engaged as the draft was not targeting recreational riders but it was aimed at horse racing only so there was a false sense of security for recreational riders.

3.1 Conservation Zone

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

“This usually involves ensuring recreation is low key and dispersed with small-scale or no facilities.”

Unfortunately this zone chosen includes the township of Killarney, which is smack in the middle.

Its residents have purchased their properties here exactly for the lifestyle choices that were on offer to them. They access the beach via Towilla Way which was included in the subdivision especially for them to access the beach. It also includes important access points for everyone, fishermen, beach goers, recreational riders and others to access the beach on tracks that have been used over 100 years with minimal change other than the change that the sea itself would cause. This includes the access and carparks of Gorman Lane and the access to the Basin, two very important areas for recreational purposes for everyone in the south west.

Page 41, Chp 5 Health Country

“The protection of vulnerable fauna such as Hooded Plover will require reducing threats to these species through controls on the key impacting activities of dogs, horses and people”.

The BCR has one of the most significant numbers of the hooded plover in the State, this is despite horses and dogs on the beach. The threat to the plover from horses is 0.77% and the threat from dogs is 3.26%, see Table 1 - Managing the hooded plover in Victoria (2014) Parks Victoria.

Reducing these threats will not wipe off the other threats, and given that the natural threats to the plover amount to approx. 85% (including the major threat of tides), banning dogs and horses will not take away the natural threats.

Page 35 Key Threats to the Hooded Plover Breeding Success

“Horses. Horses can trample eggs or run over a chick or adult bird, particularly when riding above the high-tide mark or in dunes. Horses also leave craters in the sand that make chick navigation across the beach difficult. Chicks can become trapped in hoof craters if they are deep enough, leading to death from predation, trampling, dehydration or starvation”

I would suggest that this is pure theory. “horses can trample eggs” But do they? If yes, it would be an extremely rare occurrence with such a low % of maybes that it could not be measured.

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

“horses leave craters in the sand” Yes until the tide comes in and washes the footprint away evening the sand again. The tide comes in every 6 hours and with a breeding pair of about 1 per kilometre, the chance of a chick falling into a horse print is just a theory and could not be measured statistically either. Who made this up? Even a beetle can slowly make its way out of a hole in the sand, it is hard to believe that a plover chick could not.

“vehicles” since vehicles, trail bikes and four wheeler bikes are illegal in the BCR yet quite a common occurrence, banning horses and dogs is not going to make any difference to the ecology and to the numbers of fauna. The illegal vehicles, trail bikes and four wheelers will still continue illegally.

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

From: Sent: Thursday, 15 March 2018 7:09 PM To: ParkPlanMailbox Subject: Belfast CR Enquiry

Good Evening. I submitted on behalf of Warrnambool Trail Horse Riders Club already however I neglected to make an important point. At one of our meetings in around 2012, we invited from Parks and from a local birdgroup to come and speak at a club meeting. educated our members about plovers and their breeding habits and taught us how to identify them on the beach. and also told us to be mindful and to ride as close to the water's edge as possible to avoid distrubing the birds. We have always done so and we slow to a walk when we are nearing a plover nesting site. also talked about keeping dogs on leashes when approaching plover nesting sites to ensure that dogs do not disturb the birds. We acknowledged our thanks with a donation on behalf of the club to the bird group to help them buy materials needed for roping off nesting sites. We also offered our assistance on the beach to help out. As a club, we are always mindful that we do the right thng. We appreciated and coming to the meeting to educate us to ensure we were all on the same page. Thank you. I hope this can be added to my comments in the WTHRC submission.

WTHRC Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Belfast Coast N1anagement Plan: - Individual Subrr•ission I Survey Name: - Signature_

Email Address: - Post Code:-

AgeRange =--~~4~------·------

Gender : · \<= <

lsthissub~issiontobetreatedasConfidential =~~~~~~~~~~-~~~~~~~~~~-

How do you Get to the Reserve: •• W'alk, Drive, Ride a Bike, Ride a Horse

- - ··-- What do you mainly use the ReseNe for: For example: Bird watchi Swim min surfing, kitesurfi windsurfing, snorkelling, horse ridinJg dog walking, ishing, boating, campi family time at the beach with or without a pet)

How important is it to you to be ablE! to continue these activities within the e11tire Reserve?

-~::::::L.::=+--...!..l-.!-.!..~...a....."'!1c1o:\ r\- ':2 an

Which part of the Reserve do you us1e most frequently:

West of Killarney Beach to Port Fairy ' ---~~----~-~------~---

East of Killarney Beach to The CuttinJg. __....______~------~--~----

1 Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

What is your area of Interest (For Example: ConSeNation, Recreational, Cultural, With Animals- Horses or Dogs)

Is there a specific change that you want made to the Draft Proposal. ~ ee , q ()d t

How important is protection of the Natural Environment and Bird life to you

How important is the ability to enjoy recreation activities to you r+or1t areas +haf-

ord •

Is your Personal Health and Wellbeing associated with your use of the Reserve? If so in what way.

Do you believe that the current use of the reserve that allows for both Recreation and Conservation should continue?

If you believe dogs and horses should be banned- which areas should they be banned from:

2 Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Manager Parks Planning Parks Victoria Level 10, 535 Bourke St Melbourne VIC 3000

To whom it may concern,

Re: Warrnambool Beach Training Support Submission

the Beach/Ocean environment has been vital for their fitness and well being. the Therapeutic benefits of the Ocean are immeasurable. These benefits have also been enjoyed by our and many others horses over the years whether it be treating Back, Join, Muscle or feet issues.

The opportunity to train horses on Levy’s Beach and the dunes is critical for the ongoing success of horse training in Warrnambool which I am fully supportive of.

Regards,

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Addressed to specific issues. Prohibition of Windsurfing Kitesurfing and Surfing on the Belfast Lough and Rutledge’s Cutting (saltwater swamp).

He uses the Belfast Lough and Rutledge’s Cutting on a small number of occasions per year. will use them if the waves in the Ocean are too big or too choppy or if there is an offshore wind that is too dangerous to go into the Ocean. Both the Lough and Cutting are only waist deep so this adds to his safety. I notice that Parks Vic motto is “healthy parks healthy people”. It certainly gives me great peace of mind to know that has two safe venues to windsurf. The physical exercise of Windsurfing is great for his flexibility and mobility. It also improves mental health and wellbeing as he returns home in a content state of mind. I feel assured that all is well when he uses the Lough or Cutting. Surely this fits Parks Vic motto??? I notice that Boating, Jetsking and Yachting are allowed on these places but Windsurfing is not. How does that make any sense?? Windsurfing and Kitesurfing on the Belfast Lough and Rutledge’s Cutting are very passive activities with no environmental effect. The Lough and the Cutting are not used frequently and then only by a small number of enthusiasts. Windsurfers and Kitesurfers do not clash with other user groups on the Lough or Cutting, as they are usually the only water user group on the Lough or cutting. They also keep these areas clean as they collect rubbish and care for the surrounds. Surely, Parks Vic should embrace this major positive effect.

I hope that Parks Vic amend the draft plan to allow windsurfing and Kitesurfing on the Belfast Lough and Rutledge’s Cutting. Both groups do not have a negative effect on the environment.

Date 4/3/2018

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Belfast Coast Maha2ement Plan: -Individual Submission I Survey

Name:

Signature: ......

Email Address:

Post Code:

Age Range : 75......

Gender : Male......

Is this submission to be treated as Confidential:

Not confidential......

How often do you use the Reserve :

Mostly in winter, about every 3 weeks ...... : ......

How do you Get to the Reserve: .. Walk, Drive, Ride a Bike, Ride a Hors

Drive, as I need to carry windsurfing gear.

What do you mainly use the Reserve for: {For example: Bird watching, Swimming, surfing, kitesurfing, windsurfing, snorkelling, horse riding, dog walking, fishing, boating, camping, family time at the beach with or without a pet)

windsurfing

How important is it to you to be able to continue these activities within the entire Reserve?

Paramount

1 Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Which part of the Reserve do you use most frequently?

West Killarney Beach (Belfast Lough)

Killarney Beach......

West of Killarney Beach to Port Fairy ......

East of Killarney Beach to The Cutting······················································································································

West of The Cutting towards Warmambool......

What is your area of interest (For Example: Conservation, Recreational, Cultural, With Animals- Horses or Dogs)

Recreation - windsurfing

Is there a specific change that you want made to the Draft Proposal.

Dark green to the light green proposal.

How important is the Cultural Heritage of the Reserve to you?......

It is important If there is any cultural heritage to the Belfast Lough.

How important is protection of the Natural Environment and Bird life to you

Important.

How important is the ability to enjoy recreation activities to you?

I value my recreational activity as it my only form of exercise and valuable to my self-esteem and I wish to maintain my windsurfing fora longtime to come. The Iough is my only chance to do so as the only other venues that are safe for me are drive to Lake George or to Geelong (Point Henry) which are prohibitive as it would be a return journey with no time for enjoyment.

Is your Personal Health and Wellbeing associated with your use of the Reserve? If so in what way. 2 Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Windsurfing is my only choice of recreation as it is in my humble opinion "age preserving" and great exercise, authorities permitting, remain so for a number of years to come.

Do you believe that the current use ofthe reserve that allows for both Recreation and Conservation should continue?------

I do believe that it should continue as the users of the reserve from my observance are very conscious of caring for the coast. To deny their access would be a shame as they are the ones that have cared and I am sure have kept it in the pristine condition that it is. This point should not be ignored.

Conservation is paramount and I do believe that most users of this area are fully aware of this, however we do have a problem with over enthusiast endangered bird protectors causing grief with the people that are innocently enjoying our coast. They need to be educated in public relations as their behaviour will cause and will encourage aggressive reaction.

If you believe dogs and horses should be banned -which areas should they be banned from:

Dogs should not be banned if they are kept on a leach. Heavy fines should be in place if dogs are not restrained and not looked after sanitarily. Horses I am not able to comment but do understand the situation in the sand dunes. seems to have it all covered and willing to endorse his well thought out proposal.

Do you wish to add any further comments? ......

My comment is that I am quite perplexed that wind/kite surfing are listed to be disallowed on the Belfast Lough. This is the safest venue for our activity in the area. To be forced onto the ocean for me is fraught with danger. During most part of the year the wind direction is west to south west which means that the area that is able to be windsurfed is golfies (Mills Reef) which is highly dangerous for myself being unable to handle such ferocious conditions. My only safe place is the Iough which has been for and fail to understand that I or any others of like mind would damage or disturb any of the wild life. In fact, 3 Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

I am very conscious of keeping a distance from any birdlife and maintaining and safe guarding the area. It would be on record that I have reported to the Moyne Shire, debris such as animal carcases and building rubble dumped at the landing strip entrance at the Iough. When walking around the town and the environs I am continually picking up rubbish.

I do question the amount of thought and wisdom that has gone into this proposal as It apparently allows jet skis at any speed and other craft capable of doing much greater damage and disturbance than a very small windsurfing and kite surfing craft. Ifthis proposal is passed then number of us will be forced to travel (lake George or Gee long /Point Henry} to pursue our much-loved sport.l would have to cease windsurfing as it is too dangerous to travel a day return and to have time to enjoy the purpose of the trip.

When I was investigating the area where is there a place to windsurf? The Iough was the recommendation. As with many others I have spoken to also have been attracted to this part of the world which, with the departments plan, will seriously disrupt and massively (without any exaggerat.ion} effect their lifestyle.

4 Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Manager Parks Planning, Parks Victoria Level 10, 535 Bourke St Melbourne VIC 3000

Dear Sir/Madam, SUBMISSION - BELFAST COASTAL DRAFT MANAGEMENT PLAN

I wish to submit opinion on a number of key items outlined in the management plan. We enjoy recreation in this reserve and have a respect and love of the natural environment.

1. Dogs on beaches. – I generally support the recommendations with respect to dogs. It is of upmost importance to protect the bird and animal life in this area. In particular the hooded plover nesting sites need protection. Volunteers put in countless hours to protect this bird only to see dog owners allow dogs to run through these areas. I frequent the beach area a lot, maybe every second day. Each time I am there I see this happening. On many occasions I see a particular dog owner that has 4 or 5 large hunting dogs, they get let off lead at the basin and they charge around, through fenced areas. Many of the dog owners are well intentioned, however totally oblivious to what their dogs are doing, despite the signs. Accordingly I believe the recommendations are fairly sound, and you need to stick to your guns despite the pressure that will inevitable come to bare from disgruntled dog owners as they become aware of the proposal. Education and signage alone will not work.

2. Recreational horses – Within the allowable conservation and recreation zones this activity should be tightly controlled via a permit system with a slew of conditions. Walking only, hard sand only, etc etc. I have seen horsemen charging about bareback riding, horses riding at speed up through the soft sand where the plovers nest, the list goes on . Without tight restrictions the danger and destructive impact is too great.

3. Local trainers- I do not agree with local trainers continuing to use these areas. When incorrect practices are occurring it is prudent to terminate them as soon as possible. If local historical trainers are to be allowed it is important that it be defined carefully to prevent bigger operators slipping in through a loop hole. Walking and swimming only, no cantering/galloping. There should also be provision to phase out this activity in say 2 or 3 years to give these trainers time to accept this as a reality of the modern world, and make alternative arrangements.

4. Killarney beach – Allowing any horse training speed work is madness at this location. This is an extremely popular family beach totally incompatible with galloping/cantering horses in every respect. The valid arguments have all been presented numerous times already.

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

5. Basin boat ramp – This standard of this facility is quite in line with its usage. It is a difficult access which limits its usage to small craft ( tinnies and kayaks) which are appropriate for this site. Upgrading access will see larger craft trying to launch and the associated problems, getting bogged etc on the beach etc.

6. Commercial Race Horse Training – I think it is obvious to 90% of people in the community that this activity is totally incompatible with the reserve in all respects, all valid arguments have been presented. I suspect the authors of the report also are well aware of this and are making these proposals under sufferance. It seems obvious that political pressure from the racing industry, via the racing minister are the reason for this ridiculous situation. I expect that the general consensus is that the “consultation” in this area is a complete farce as the decisions have been made behind closed doors, made by the environment minister to appease the racing minister. I expect that the consultation process showed an overwhelming support for the ceasing of this damaging commercial activity within the fragile reserve. I would like to see the statistics around this item collated and openly presented to prove the transparency of the process. I think the mishandling of this item, which is the catalyst for the management plan casts a bad light on the whole process and leaves people with a feeling of helplessness and betrayal. It must be recognised that many local people have put in countless hours revegetating this area, protecting birds, looking after the environment. To these people the proposal to allow commercial horse training in the reserve is a slap in the face, and a cause for them to lose faith and give up these activities.

Yours Sincerely,

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Belfast Coast Management Plan: - Individual Survey Submission

Name:

Signature

Email Address:

Post Code:

Age Range: Adult

Gender: Female

Is this submission to be treated as Confidential: no

How often do you use the Reserve: weekly

How do you Get to the Reserve: .. Walk, Drive, Ride a Bike, Ride a Horse

Drive

Horse riding,

How important is it to you to be able to continue these activities within the entire Reserve?

Very important it is a great relaxation activity for me and my family

Which part of the Reserve do you use most frequently:

Killarney Beach We use all areas

West of Killarney Beach to Port Fairy

East of Killarney Beach to The Cutting

West of The Cutting towards Warrnambool

What is your area of interest (For Example: Conservation, Recreational, Cultural, With Animals – Horses or Dogs)

With animals - horses

Is there a specific change that you want made to the Draft Proposal.

Leave the access as it is – let us continue to enjoy our beautiful beach as we have been doing Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

How important is the Cultural Heritage of the Reserve to you?

Protection of any cultural heritage is important but not at the deferment of the local community and beach users

How important is protection of the Natural Environment and Bird life to you

What’s the point of having some great natural environment if no one can use or access it???

How important is the ability to enjoy recreation activities to you

We consider riding on the beach a privilege and a unique experience. We share our great resource with international visitors, and greatly value the family time we have riding at the beach

Is your Personal Health and Wellbeing associated with your use of the Reserve? If so in what way.

I consider riding at the beach a very relaxing active which enhances our family time and well being

Do you believe that the current use of the reserve that allows for both Recreation and Conservation should continue?

YES

Recreational Activities should be allowed throughout the Whole Reserve

If you believe dogs and horses should be banned – which areas should they be banned from:

None

Do you wish to add any further comments:

Leave us and our beach alone

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Belfast Coast Management Plan: - Individual Submission I Survey

Name:

Signature __

Email Address:

Post Code : ______3k8:':Q__ . ______------

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How often do you use the Reserve : ...... e'/~~ ------.(Cftn. ~}:-......

How do you Get to the Reserve: .. Walk, Drive, Ride a Bike, Ride a Horse

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How important is it to you to be able to continue these activities within the entire Reserve? · ··· -- -~e.- ~ ---······\ .W\ ..~ .b.Q. :\:: ......

Which part of the Reserve do you use most frequently:

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West of The Cutting towards Warrnambool ...... Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

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Parks Victoria Level 10, 535 Bourke Street Melbourne Victoria 3000.

Dear

BELFAST COASTAL RESERVE – MANAGEMENT PLAN

This is a further submission from ATHRA, the Australian Trail Horse Riders Association, regarding a draft management plan for the Belfast Coastal Reserve, (BCR). ATHRA is the peak body representing recreational trail horse riders in Australia. ATHRA advocates for recreational horse riding at all levels of government. While a large proportion of leisure horse riders do not belong to clubs or organisations such as ATHRA, as a national body we have over 100 affiliated clubs Australia wide. Our philosophy regarding riding on public lands, is based on environmental respect, user group co-operation and compromise.

Cultural heritage and the natural environment contribute to the pleasure of horse riding activities. Indeed, being quietly and safely on a recreational riding outing lends itself to observing and enjoying these aspects of public lands. Recreational horse riding is not intense in pace or volume, as the draft plan implies. Indeed, it is compatible with environmental protection. This is especially so when riders comply with regulations and codes of conduct.

Trail horses’ presence is passive, relatively non-damaging and environmentally aware, (there are 16 environmental rules in our ATHRA Code of Conduct). Such activity needs space, it is not contained within a small paddock or arena, like some riding activities, but uses open trails and bushland, sandy stretches and beach.

You would already have received submissions about the health and social benefits of leisure horse riding, a much- needed recreational activity for many Victorians whose lower exercise levels have been identified as a Victorian Government health priority. As ATHRA stated in its first submission, the numbers of trail horses, the pace at which they are ridden, and the mindful attitudes of their riders, in general cannot be compared with the commercial ‘drive’ of race horse activities.

Yet, according to the draft plan, commercial horse riding tour operators and race horse trainers will be allowed into areas where recreational horses will not be allowed, on the basis that there will be licence conditions imposed on the first two groups. Surely, with recreational riders being in much smaller numbers, and riding there at lesser frequencies, the same conditions can be imposed on trail riders as well?

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Yes, we understand that there can be vocal, strident opposition to horses in fragile areas, but why are recreational users being treated as ‘sacrificial lambs’ while those horse activities which have a commercial rather than recreational basis are granted privilege?

ATHRA urges ParksVic to amend the draft plan, acknowledging a strong difference between commercial race horse training and leisurely, recreational horse riding. That there is not a commercial or political drive behind trail horse riding does not mean that these horse riders’ interests should be sacrificed. Timing and number restrictions proposed for race horse trainers in certain zones which propose to exclude trail riders, could apply equally to those riders.

At a minimum and in the spirit of compromise and justice, ATHRA suggests that ParksVic consider a trial period which treats recreational riders equally with commercial horse operations. We are confident that there are articulate, informed and committed recreational riders in the area who can advise on such a trial in the BCR.

Yours sincerely

8 March 2018. Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Belfast Coast Management Plan: - Individual Submission / Survey

Name:

Signature

Email Address:

Post Code :3280

Age Range : 39

Gender : female

Is this submission to be treated as Confidential : no

How often do you use the Reserve :weekly

How do you Get to the Reserve: .. Walk, Drive, Ride a Bike, Ride a Horse

Drive

Horse riding and dog walking

How important is it to you to be able to continue these activities within the entire Reserve?

Very important... It's a safe place to take horse riding without worrying about traffic etc

Which part of the Reserve do you use most frequently:

Killarney Beach

West of Killarney Beach to Port Fairy.... Yes

East of Killarney Beach to The Cutting yes Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

West of The Cutting towards Warrnambool yes

What is your area of interest (For Example: Conservation, Recreational, Cultural, With Animals – Horses or Dogs)

Horse riding and dog walking

Is there a specific change that you want made to the Draft Proposal.

I would like horse ring and dog walking to continue to be allowed

How important is the Cultural Heritage of the Reserve to you? Very important

How important is protection of the Natural Environment and Bird life to you

Very important

How important is the ability to enjoy recreation activities to you

Extremely important

Is your Personal Health and Wellbeing associated with your use of the Reserve? If so in what way.

Horse riding is a very important weekly part of my life and it's so peaceful and safe to ride in the Reserve. If it's banned myself and alot of other Recreational horse riders will be very disappointed and it will be sadly missed

Do you believe that the current use of the reserve that allows for both Recreation and Conservation should continue?

Yes

I believe Recreational use should be allowed in the whole Reserve

If you believe dogs and horses should be banned – which areas should they be banned from:

Do you wish to add any further comments: Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Submission to Parks Victoria regarding the Belfast Coastal Reserve Draft Coastal Management Plan January 2018 by

Thanks for the opportunity to make this submission and thanks for the work that has gone into the Draft Management Plan.

and consider the natural settings and landscapes as one of the best things about living in the South West. frequent the Belfast Coastal Reserve on a regular basis throughout the year. We love to walk on the beaches and So you could say that I am pre-disposed to attributing very high value to the ‘scenic beauty, biodiversity and cultural heritage’ of the Reserve. At the same time I am aware that the competing uses and users of the Reserve must be considered and that is ultimately the point of this consulting exercise and submission process.

It is great to see that a comprehensive plan for the ongoing management of the Reserve will soon be in place and it is clear to me that the contents of the Draft Plan provides all the information that one needs to decide how we should allow the Reserve to be used. Of course the opposing groups that we see today lobbying for support of their view feeds into the whole mix. I will try to present my view in a rational and coherent manner.

I think it is true to say that a management plan specific to the Reserve in this current day is very timely. The Reserve has been accessed by all those wanting to in the manner they generally wish to over many years and this has effectively resulted in a sense of entitlement within the many different users of the Reserve. There exists a local culture (and perhaps this is a national phenomenon) if you like that does not necessarily equate to the general population attributing value to what remains of our natural ‘wild’ places, ecosystems and landscapes. And this situation has and continues to lead to the degrading of what is described as the ‘significant values’ of the Reserve.

The question we need to ask ourselves is, if a proportion of a community doesn’t value biodiversity above its own wants and needs and therefore sanctions activities that damage what we see as a place’s ‘significant values’ then is that a reason to actually sanction those activities within a management plan? Governing bodies and authorities presumably have as part of their duty of care, or governance remit, a responsibility to adopt a plan that does truly focus “…on protecting and enhancing the outstanding cultural and natural values of the Belfast Coastal Reserve while allowing for recreation and use compatible with the protection of those values.”

As ‘very little land in the Reserve retains its original vegetation….’ it is even more important to retain and enhance what is left by adopting management practices that exclude incompatible recreational and commercial activities from the reserve.

Too often the generation of any given day looks at the natural world within the context of the new, known or experienced baseline. What I mean by the ‘new baseline’ is that the attributes of a natural space before any significant human impact occurred is not even known or recognised. That is, what has already been lost is not considered. This is a dangerous approach or position to be in because the community is at risk of believing that the remaining or existing natural world can be further exploited with minimal impact. Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

I believe that the risk of negative impacts on already diminished and degraded environments and ecosystems should preclude activities that are not low impact or passive. I have a sense of unease that a commercial activity such as horse training could be allow ed in essentially what is or w hat should be considered a conservation area. This unease exists because horse training on the beaches of the Belfast Coastal Reserve does pose risk to the significant values of the Reserve.

Any management plan adopted for the Belfast Coastal Reserve needs to adhere to the main purpose ofthe Reserve' s existence in the f irst place w hich is conservation and relatively passive recreation. The draft plan looks like it could make a significant improvement to the Reserve in terms of its significant values, how ever this w ill entail ongoing community education and engagement. This w ill involve a greater presence of Parks Victoria staff and others on the ground.

In short I say, keep the draft plan minus the horse training.

Kind Regards, Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

6 March 2018

Belfast Coastal Reserve Draft Management Plan Invited Feedback Manager Parks Planning Parks Victoria LevellO, 535 Bourke Street MELBOURNE VIC 3000

Dear Sir,

In the last I have seen Warrnambool expand as a training centre to the vast industry it is today for one reason- Warrnambool's beach access.

Warrnambool trained horses have a superior record to those trained elsewhere. That is generally credited to their access to training on the sand and in the salt water.

If you want to kill an industry, deny them the access. What has been built up over decades can be wiped out overnight

You should listen long and hard to industry participants ... not professional agitators.

I remain, Yours faithfully, Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Submission template for Draft Belfast Coastal Reserve Management Plan About you:

Your name:

Your Organisation (if relevant): ______

Postcode: ____3280______

Email or Postal address:

THIS SUBMISSION IS: □ CONFIDENTIAL □x NOT CONFIDENTIAL Date: 5th March 2018______

How often do you or your organisation use the reserve? □ Daily □ Weekly x Monthly □ A couple of times a year □ Rarely □ Never

How do you or your organisation mainly use the reserve? x Walking or running x Dog walking □ Using the beach (swimming and surfing) □ Horse riding □ Horse training □ Volunteering □ Camping □ Hunting □ Fishing/boating x Picnicking □ Birdwatching □ Socialising □ Other (please specify): ______

Which part(s) of the reserve do you or your organisation most frequently use? □ West of Killarney (Port Fairy side) x Between Killarney and Big Baldy □ East of Big Baldy (Warrnambool side) □ Not sure

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

About the vision- Belfast Coastal Reserve, 15 years from now…:

How supportive are you of the vision for the Belfast Coastal Reserve? x Very supportive □ Supportive □ Not sure/Don’t know □ Unsupportive □ Very supportive

The Vision at 2.1 is very rosy and attractive. I especially like the emphasis on “wild feel” in the third paragraph.

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Key management theme #1: Cultural landscape and living heritage

How supportive are you of the strategies for ‘Cultural landscape and living heritage’ included in the draft management plan?

X Very supportive □ Supportive □ Not sure/Don’t know □ Unsupportive □ Very supportive

I am very interested in the goals p 19 for educating visitors as well as locals to the history of the area. I take many overseas visitors around the area. There is sadly a diminishing amount of information at Tower Hill, which used to have a better display of the Aboriginal history; it is now merely a small amount of sad artefacts with a possum cloak lying in a heap on a chair with very little explanation. To reach this one has to walk through all the racks and shelves of garish souvenirs. Budj Bim had a great deal of press coverage last year but is not well-signposted from the road coming south from Heywood. The site itself was well done, (when we found it) but we had difficulty making phone contact with the people who organise the tours. Goals on p 23 should be implemented and information available at local tourist offices. I note p22 that Gunditjmarra Owners are NOT supportive of racehorse training . I agree - race horses should be trained at separate facilities with their own purpose built sand tracks . Riding galloping race horses is not what I expect in the Reserve.

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Key management theme #2: Healthy Country

How supportive are you of the strategies for ‘Healthy Country’ included in the draft management plan?

□ Very supportive □ Supportive □ Not sure/Don’t know □ Unsupportive □ Very supportive

Comments: (Your submission can be as short or long as you wish. Put comments under relevant headings corresponding to plan sections or strategies, noting page and paragraph numbers. Attach more pages if required). P27 “Primary objective of conservation” Conservation altogether is a difficult task. I think it is impossible to conserve a landscape which now has an ever increasing population living nearby which needs recreation and exercise and is encouraged for the sake of its health and wellbeing to be active. It is impossible to turn back time , reality must be addressed.

I note that the “public land “ pv of Executive summary is only 20km long or is it 18km as described in p 46? The coastline of Australia as far as I can find out varies between 39, 000 km or 25,000 depending on where one looks. The Reserve area is therefore not a large proportion of the Australian coastline but it is so near and accessible from Port Fairy and Warrnambool, that it seems mean-spirited and impracticable to limit access to average visitors many of whom own dogs.

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Key management theme #3: Recreation and use

How supportive are you of the strategies for ‘Recreation and use’ included in the draft management plan?

□ Very supportive □ Supportive □ Not sure/Don’t know x Unsupportive □ Very supportive

As a frequent beach walker with my well-managed , controlled dog I should like to be able to walk with her off lead , under voice control as I do now, keeping her under voice control and walking along the shoreline and allowing her to swim in the sea. This area is easily reached by parking at the boat ramp car park and could be shown on a detailed map there.

I am happy NOT to take her west towards the Killarney campsite, out of respect for campers and families there, or in the dunes or off tracks. This would be in accordance with p47 6.2 paragraph 2 “wild feel”. I have heard someone say that this part of Victoria is “close to heaven”. A quote from a London dweller.

Therefore I do not agree with p53 Goal . This could be modified. If this were done as I suggest above and this area “off leash” allowed and publicised, dog owners would be less liable to sneak into more precious parts with ill-intent.

I agree with recreational horse riding and licenced commercial riding but NOT race horses at all, as per Goal on p53. Goal on p64 should therefore not be followed, no race horses. They should be trained away from recreational beaches with families , children etc.. Despite the success of local trainers, surely the risk of an accident with a member of the public precludes the presence of such large, powerful race horses anywhere near ordinary people?

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Key management theme #4: Managing in partnership

How supportive are you of the strategies for ‘Managing in partnership’ included in the draft management plan?

□ Very supportive x Supportive □ Not sure/Don’t know □ Unsupportive □ Very supportive

Comments: (Your submission can be as short or long as you wish. Put comments under relevant headings corresponding to plan sections or strategies, noting page and paragraph numbers. Attach more pages if required). Co-ordinated management seems sensible and to be encouraged as described in goals on p 72 and 73. Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Key management theme #5: Research and monitoring

How supportive are you of the strategies for ‘Research and monitoring’ included in the draft management plan?

□ Very supportive □ x Supportive □ Not sure/Don’t know □ Unsupportive □ Very supportive

Comments: (Your submission can be as short or long as you wish. Put comments under relevant headings corresponding to plan sections or strategies, noting page and paragraph numbers. Attach more pages if required). Research and honest monitoring is a sensible plan, especially involving school students. Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Belfast Coastal Reserve Draft Management Plan Submission

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Draft Belfast Coastal Reserve Management Plan About you:

Your name:

Your Organisation (if relevant):

Postcode: 3280

Email or Postal address:

THIS SUBMISSION IS: □ CONFIDENTIAL □ NOT CONFIDENTIAL Date: 5 March 2018

Your Comments: Please Note – The following information will be made publically available.

Main reason for interest: (such as local resident, visitor to parks, tourism operator, environmental interest, business operator, education interest, scientific interest)

How often do you or your organisation use the reserve? □ Daily □ Weekly □ Monthly □ A couple of times a year □ Rarely □ Never

Which part(s) of the reserve do you or your organisation most frequently use? □ West of Killarney (Port Fairy side) □ Between Killarney and Big Baldy □ East of Big Baldy (Warrnambool side) □ Not sure

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

General comments

• Many times, the draft plan refers to damage caused by racehorses but fails to explain how increasing the area available to them by 250% will mitigate these impacts. Worse still, the plan’s risk assessment reveals that management won’t make any difference. Before management, the risk to coastal dune vegetation, cultural heritage, resident and migratory shorebirds from racehorse training is rated ‘Extreme’. After management is introduced? The rating remains—Extreme!

• By entrenching and expanding commercial horse training the plan is a relic of past coastal mismanagement and inappropriate use.

Executive summary (pages v-viii)

o original and ongoing purpose of the reserve which aims to conserve coastal wildlife and cultural heritage, and support passive recreation and public education

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

About the vision- Belfast Coastal Reserve, 15 years from now…: (page 7)

How supportive are you of the vision for the Belfast Coastal Reserve? □ Very supportive □ Supportive □ Not sure/Don’t know □ Unsupportive □ Very unsupportive

Comments about the vision for Belfast Coastal Reserve

The vision encapsulates much of what I wish to see in the future for the Belfast Coastal Reserve except for the reference to ‘horse riding’: “The location, timing and intensity of activities such as horse riding has been managed to avoid conflicts between uses, and to reduce the risk of damage to the environment and cultural sites”. The softer term of ‘horse riding’ deflects from the extreme risk and existing damage to wildlife, culture and passive recreation from commercial racehorse training in the reserve.

The term ‘horse riding’ should be removed from this statement and commercial racehorse training removed from the Belfast Coastal Reserve. Throughout the rest of the plan there are 24 references to the impacts that horses have on the reserve’s natural, cultural and recreational values. More on this under Key Management Theme #2 Healthy Country.

Key management theme #1: Cultural landscape and living heritage (pages 13-24)

How supportive are you of the strategies for ‘Cultural landscape and living heritage’ included in the draft management plan?

□ Very supportive □ Supportive + □ Unsupportive = □ Partially Supportive □ Not sure/Don’t know □ Very Unsupportive

Comments: I strongly support the goals and strategies within this chapter of the draft plan including maintenance of geological features, recognising Traditional Owner and community connections to it, ensuring cultural landscape values are protected in heritage management, and establishing partnerships with Traditional Owners to protect and conserve heritage features.

However, one of the strategies—'Work with users and community groups to reduce impacts from both authorised and illegal access on the fragile coastal dune systems’—is expecting too much from community groups to act as delivery partners when those groups will witness daily the extreme damage to sand dunes and beach habitats from commercial racehorse training which, under the plan, will have ‘authorised access’. The goals and strategies also ignore the extreme risk to cultural heritage from commercial racehorse training.

Key management theme #2: Healthy Country (pages 28-42)

How supportive are you of the strategies for ‘Healthy Country’ included in the draft management plan?

□ Very supportive □ Supportive + □ Unsupportive = □ Partially Supportive □ Not sure/Don’t know □ Very Unsupportive

Comments:

• This chapter reveals the draft plan’s underlying contradictions regarding commercial racehorse training. On page 29, the draft plan admits that the extreme risk to coastal habitats, cultural heritage and resident and migratory wildlife from commercial racehorse training will remain so even following management action. This fundamental contradiction in the draft plan will undermine the achievement Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

of the very good goals and strategies in this chapter. The goals to which I give strong support include maintaining and enhancing habitats, reducing the impact of pest species and visitors, better management of marine, lake and swamp habitats, minimising the fire risk and building resilience to climate change.

Key management theme #3: Recreation and use (pages 45-69)

How supportive are you of the strategies for ‘Recreation and use’ included in the draft management plan?

□ Very supportive □ Supportive + □ Unsupportive = □ Partially Supportive □ Not sure/Don’t know □ Very Unsupportive

Comments:

• I strongly support many of the goals and strategies that relate to the recreational use of the Belfast Coastal Reserve in this chapter including increased enforcement, better management of vehicular use, dog walking and recreational horse riding, bans on dune boarding, hunting and off-road vehicles, reducing risks and improving safety, improving information, interpretation and education, and developing tourism partnerships, marketing and promotion. But without the removal of commercial racehorse training, these goals will not be achieved.

• The draft plan recommends strict controls on where and how recreational uses are to be managed in the future, whereas commercial racehorse training will be expanded. That doesn’t make sense.

• In the introduction to this chapter, the draft plan states, with my underlining: Riding of horses for recreational or commercial purposes was viewed as a threat to dune health, cultural heritage, shorebirds and public safety, especially if riders did not comply with regulations, codes of conduct or licence conditions. This suggests that the community is mainly concerned about impacts that occur when commercial racehorse training doesn’t follow the rules. But as the risk assessment table reveals on page 29, even with rules, management will not mitigate the extreme risk from commercial racehorse training.

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

• Jet skis should not be allowed in reserve waters, including Belfast Lough, because of their disturbance to wildlife and other recreational users, and damage to shallow water habitats.

• Dogs should not be allowed off-leash from 1 August to 30 November at Killarney Beach, coinciding with the first part of the hooded plover breeding season.

• Section 6.5 of this chapter is titled ‘Authorised uses’, code for commercial racehorse training. Much of the emphasis in this section is the regional economic importance of the racing industry as justification for the damage that it is causing and will continue to cause if it remains in the Belfast Coastal Reserve. But in a September 2013 report prepared for the Victorian racing industry by consultants IER, it was revealed that the racing industry generates $75 million gross value added in the Western District, which includes Warrnambool but also a number of other racing clubs at Casterton, Coleraine, Hamilton, Terang, Camperdown Mortlake, Penshurst and Dunkeld. The report also reveals that 40% of statewide gross value added for horse racing is from gambling, which takes money out of the community. If applied to the Western District, $30million of the gross value added would be from gambling, which leaves $45million shared across all of the region’s clubs.

Key management theme #4: Managing in partnership (pages 71-75)

How supportive are you of the strategies for ‘Managing in partnership’ included in the draft management plan?

□ Very supportive □ Supportive + □ Unsupportive = □ Partially Supportive □ Not sure/Don’t know □ Very Unsupportive

Comments:

• I strongly support the first goal in this chapter: Coordinated management of the Reserve enables efficiencies in program delivery and is supported by consistent land status and regulations. But I cannot support the strategies that aim to achieve it. The plan recommends retaining the fragmented management across the City of Warrnambool, Moyne Shire Council and Parks Victoria and leaving the Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

reserve under the Crown Lands (Reserves) Act. The reserve should become a park under the National Parks Act.

Key management theme #5: Research and monitoring (page 77-79)

How supportive are you of the strategies for ‘Research and monitoring’ included in the draft management plan?

□ Very supportive □ Supportive + □ Unsupportive = □ Partially Supportive □ Not sure/Don’t know □ Very Unsupportive

Comments:

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Friends of the Bay of Islands Coastal Park response to the Belfast Coastal Reserve Draft Coastal Management Plan 2018

conservation zone We have been participating in the recovery of the endangered beach bird, the Hooded Plover, since our formation in 1994. This bird lives only on the beaches, and South Western Victoria beaches are well documented in being critical sites. Belfast Coastal Reserve contains 12 % of the Victorian breeding population. This is a significant number for their survival. “There are 28 breeding sites within the proposed conservation zone”, (Birdlife data personal communication). We have supported the B.C.R.A.G., sharing ideas and will continue to work towards the recovery of this species. We wish to support the proposed conservation zone to be dog and horse free, to lift the pressure on all birds, plants and invertebrates who live and breed only on this section of beach.

conservation and recreation zone Commercial horse training is NOT recreational horse riding. With regard to the conservation and recreation zone area deemed we are adamant that commercial horse training is not compatible with conservation and/or recreation. Horses will cause/do cause erosion “significant impacts occur after only low levels of horse use”(Phillips and Newsome, 2001) 1. The Licence Racehorse Access map fails to point to Killarney main beach being used as a commercial training facility. As in the Managing Belfast Coastal Reserve Draft Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Management Plan summary activities P6 within the purposed zone allows horse training at Killarney Beach but on map 6 it is shown as historical. This is very confusing to whether horse training is proposed or not for this area. Commercial horse training is a multi million dollar industry and has no right to ignore and destroy the coastal conservation values. It is not compatible and the racing industry can afford other facilities ie. the new sand track at Warrnambool built in 2017. We believe that this industry will survive handsomely with out training on beaches within Belfast Coastal Reserve. The photo of a horse and the Double Banded Plovers on page 8 of the Belfast Coastal Reserve Draft Coastal Reserve Management Plan is very deceiving as it shows the race horse walking on wet hard sand but in reality the horses (personal observation have been training on the soft and hard sand plus the sand dunes, which is destroying the Hooded Plovers nesting sites and causing erosion. As your draft plan has stated of commercial horse training “horse riding can impact dune health, cultural heritage, public safety and disturb beach nesting birds”(page vii executive summary Belfast Coastal Reserve Draft Coastal Management Plan) and therefore it follows that it is not compatible with the conservation values of the Reserve.

As a Friends group of a local park, we know how underfunded Parks Victoria are and have no confidence that this plan will be managed adequately.

1.N.Phillips & D. Newstone, 2001 Pacific Conservation Biology 7(4) 256-273. Understanding the impacts of recreationa in Australia protected areaa: Quantifying damage caused by horse riding in D’Entrcaste- CSRIO publishing.

Friends of the Bay of Islands Coastal Park. Peterborough. 3270. Victoria. Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Submission template for Draft Belfast Coastal Reserve Management Plan About you:

Your name:

Your Organisation (if relevant): group______

Postcode: ___3280______

Email or Postal address:

______

THIS SUBMISSION IS: □X NOT CONFIDENTIAL Date: 5/3/2018

Recreation and use: Windsurfing , Kitesurfing, surfing

How often do you or your organisation use the reserve? □X Daily □X Weekly Which ever is appropriate for you

How do you or your organisation mainly use the reserve? □ Walking or running □ Dog walking □ Using the beach (swimming and surfing) □ Horse riding □ Horse training □ Volunteering □ Camping □ Hunting □ Fishing/boating □ Picnicking □ Birdwatching □X Socialising □X Other (please specify): windsurfing Kitesurfing ,surfing

Which part(s) of the reserve do you or your organisation most frequently use? □X West of Killarney (Port Fairy side) □ Between Killarney and Big Baldy

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

About the vision- Belfast Coastal Reserve, 15 years from now…:

How supportive are you of the vision for the Belfast Coastal Reserve? □ Very unsupportive

Key management theme #1: Cultural landscape and living heritage

How supportive are you of the strategies for ‘Cultural landscape and living heritage’ included in the draft management plan?

□ Very unsupportive

Key management theme #2: Healthy Country

How supportive are you of the strategies for ‘Healthy Country’ included in the draft management plan?

Very unsupportive

Key management theme #3: Recreation and use

How supportive are you of the strategies for ‘Recreation and use’ included in the draft management plan?

□X Very unsupportive

have been using the Belfast Coastal Reserve primarily to be close to the water and windsurfing/surfing opportunities. of the “South West Windsurfers and Kiters”, I and many others are very regular users of the Belfast Loch, East Beach, Mills Reef and the Cutting. We also scuba dive and snorkel the Basin and Long Reef. As it stands at the moment, the current proposed plan will mean that I and others will be Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

restricted severely in my choice of recreational activities. In relation to the banning of Windsurfing and Kite Surfing on the Belfast Lough and the cutting, I fail to see any data available to show that the above activities will have a negative impact in the Belfast reserve. (I also fail to see how it is possible to surf on flat water.) Windsurfing on the Lough is a pollution free, quiet passive activity, requiring no fuel or possibility of spillage and no noise. On windy days there are a small group of enthusiasts enjoying wind/kite surfing and generally stay in the middle part of the Lough where it is deepest away from the muddy edges. Birds are not disturbed as they always move to the edges or completely away when the wind gets up. When the wind dies down the wind and kite surfers do not use the water. Birdlife can be seen in all parts of the Lough during calm conditions so there is no impact.

In terms of conflict with the public, it is zero. Both the Lough and Cutting are rarely used by any other user groups because we are out there on the water in windy conditions which are generally unappealing to other users.

It is interesting that in table 6.1 Page 54, motorised boating, which includes jet skis, is permitted in the Belfast Loch, yet windsurfing and kitesurfing are not. Non-motorised boating (canoes, kayaks rowing skulls, paddleboards etc. are permitted. On Rutledges Cutting, non-motorised boating is permitted. Kite surfing and Windsurfing are non- motorised sports yet are subject to prohibition in Section 6. This means that I can ride my loud fuel dependant jet ski at 100 kmh across the Lough yet I cannot ride my wind surfer or kite board. I hope this is merely an oversight.

Both the Cutting and the Lough are very valuable locations in terms of providing a space for learners and older people who are interested in these water sports to experience them in a safe and satisfactory way. Wind conditions at times do not make ocean sailing an appropriate option so the Lough and Cutting are opted for. The closest locations that would have the same conditions would be Geelong

It should also be noted that the users of these waterways help keep the environment clean. We often pick up rubbish from the water, around the entrance to the Lough and near the airstrip because we care about the area and collectively do our bit for conservation.

The Southwest Windsurfers and Kiters also believe that the Belfast Lough and Rutledge’s Cutting are environmentally different to Kelly’s swamp. The Lough and The Cutting are brackish and highly modified. Kelly’s swamp is fresh water and heavily reeded, consequently is not suitable for windsurfing and kitesurfing.

In summary, windsurfers and kite-surfers are opposed to the Belfast Reserve Plan and do not believe it is not appropriate to treat all wetlands and estuaries the same under the plan. Windsurfers and kite-surfers cannot see Parks Victoria’s justification to change from the current permitted use of the Lough as we have zero environmental impact.

Key management theme #4: Managing in partnership

How supportive are you of the strategies for ‘Managing in partnership’ included in the draft management plan? Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

□ Very unsupportive

Key management theme #5: Research and monitoring

How supportive are you of the strategies for ‘Research and monitoring’ included in the draft management plan?

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Belfast Coast Management Plan: - Individual Submission by

Name:

Email Address:

Post Code:

Age Range: 24

Gender: Female

Is this submission to be treated as Confidential: NO

I am down at the beach (between Gormans Road and the Basin) at least 4 times a week.

I mainly walk, ride a bike, or ride my horse to the beach.

I enjoy the following recreational pursuits – riding my horse, paddle boarding, swimming, running, snorkelling.

It is extremely important to be able to continue to use the beach with my horse. I have ridden my horse on the beach As I am older I believe it is important to have healthy passive recreation activities and the beach allow me to do just that. Going for long rides on the beach is extremely important. I will often ride from the Basin over to near Levies. I always ride along the water’s edge where the sand is a lot harder. I am extremely respectful of the environment.

I believe that it is extremely important for everyone around here to be able to continue doing the same activities with their dogs and also the horse riders that ride along the beach.

I mainly frequent the following parts of the area:

I rarely go to Killarney Beach. I usually go from the Basin over to past the Cutting (past Gormans Road)

My main area of interest is recreational horse riding and paddleboarding.

I disagree with the conservation zone as it will prevent me from participating in the recreation activity that I love – riding my horse.

It make sense to me to remove the Dark Green – Conservation Zone and Replace it with a Light Green Conservation Zone

I see the cultural heritage as important, however most of the burial sites and middens have been covered by the sand.

The birdlife is important to me; however I believe that the current situation of management is appropriate.

I have seen a few foxes on the beach early in the morning and towards the evening. They are disturbed when they see me. The birds do not seem to worry about me – mostly because I walk along the water’s edge.

There is a lot of erosion on the beach – I have noticed the sand dunes. I believe the beaches however are much cleaner; this is because the people usually pick up the rubbish and take it home with them. Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

The Beach is extremely important to me for recreation. It is extremely important for me to be able to ride my horse along the beach. It is extremely important for my health and wellbeing.

Most of the people I see down the beach walk their dogs. A few, mainly women ride horses.

I believe that the current use of the reserve that allows for both Recreation and Conservation should continue.

I believe that Recreational Activities should be allowed throughout the Whole Reserve. Dogs and Horses should be allowed in all areas of the beaches – from Port Fairy to Warrnambool. I believe it is very important for the local community to be able to walk their dog and ride their horse along the beaches from Port Fairy through to Warrnambool.

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Belfast Coastal Reserve Draft Coastal Management Plan Submission

I am grateful for the opportunity to make a submission on the draft plan which, in my view, represents a pivotal moment in the history of this reserve and its preservation for generations to come. While this reserve has been in place since 1870 and falls under the protection of several pieces of federal and state legislation, the reality is that much of it has long suffered from neglect, wilful damage through illegal trail-bike riding, four- wheel driving and rubbish dumping, and commercial activities that would not be considered appropriate today, such as the sand mining operation and nearby rendering plant.

This plan gives us an opportunity to set things right and to – again - prioritise the preservation of the remote and wild parts of this reserve; to protect the vulnerable ecology; to acknowledge and protect its rich indigenous heritage; and to permit soft recreational activities in those areas that have been classed as suitable for recreational use.

I strongly support the majority of the plan, as it clearly identifies the damage that has been done in the past, acknowledges the ecological and cultural significance of this area and sets out meaningful and practical steps for it to be further protected.

But then we come to the proposal for large-scale, commercial racehorse training.

This proposal, within the context of the overall report that emphasises further protection, stands out like the proverbial sore thumb. Indeed it is so at odds with the aims of the draft management plan that I can almost see the anxious author/s trying to work out how to incorporate the words “commercial racehorse training” into a plan that has two very clear zones: recreational and conservation. Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

On any measure, commercial racehorse training is not recreational. It is also not an act of conservation.

Put simply, there is no place for commercial racehorse training in a reserve that is designated for recreation and conservation.

For the sake of brevity, I have condensed my strong opposition to allow the reserve to be used for commercial racehorse training into 10 main points that are detailed below:

1. At least 54 species of "conservation significance" live there, including five listed as critically endangered, 10 listed as endangered, 20 as vulnerable, and 16 listed as threatened. (p86-87). In particular, the area is a feeding area for the critically endangered Orange Bellied Parrot that is now on the verge of extinction in the wild and the area, as I am sure will be explored in other submissions, is one of two major breeding sites for the Hooded Plover.

2. According to the draft report’s own risk assessment (p29), there will be a negative impact on these species. Not “perhaps” or “maybe”: there will be a negative impact that reduces their chances of thriving or even surviving. Of the six areas included in the risk assessment, the impact of horses on habitat degradation is listed as extreme in three of the six categories.

3. The draft report makes it clear that the traditional owners of this country do not support racehorse training in the reserve. (p22, p64) Further, the report acknowledges the cultural surveys in the area are either incomplete or out of date (p20). These two facts alone should see a ban on all commercial racehorse training in the reserve.

4. The Cultural Heritage Management Plan prepared for Racing Victoria concluded that racehorse training at Levy’s Beach will cause erosion and damage to Aboriginal cultural heritage in this area and that any artefacts will have to be removed and stored before it begins* (p64). Again, this fact alone should see a ban on all commercial racehorse training at Levy’s Beach. To even contemplate such a move in contemporary times is incomprehensible to me and, in my view, offensive to indigenous owners.

5. Horse training will cause erosion. Not perhaps or maybe: it will. There has been limited research into the impact of horse training on beaches in Australia, but three research papers that focus on this aspect and are referred to in the ‘Reference’ section of the draft report all conclude that horses contribute to erosion.* Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

6. Every coastal plan for this area in the past 40 years has emphasised the need for more protection, not less. This includes the Warrnambool City Council’s own Warrnambool Coastal Management Plan, signed off just four years ago in 2013, that identifies Levy’s Beach as part of a ‘Wild Coast Precinct’ and a “wildlife corridor and biological hotspot”. As such, it recommends passive and nature based recreational opportunities. In this report, there is no mention of commercial racehorse training in this zone.**

7. It ignores the Land Conservation Council framework that was set down for this area in 1978 in anticipation of the reserve coming under increased pressures. As a result of the LCC, the majority of public land in the area was officially set aside in 1979 as a conservation reserve. As outlined in the draft report, the LCC emphasises low-impact recreation, conservation and protection. (p83)

8. There are no numbers on exactly how many racehorses would use the most sensitive areas of Levy’s Point, Golfies and Rutledge’s Cutting (p63-64), but the Warrnambool Racing Club has indicated up to 260 a week in the Levy’s Beach dune area and 120 a day at so-called “Hoon Hill”. Such numbers confirm the intention to pursue commercial racehorse training on an industrial scale.

9. Local action groups have recorded numerous breaches by those using this reserve in the recent past for commercial racehorse training, despite assurances that it would be carefully monitored. The expectation that Parks Victoria officers will rigorously monitor commercial racehorse training (p62) into the future is therefore not met with great confidence. The question also remains as to why Parks Victoria staff and resources should be allocated to monitoring a commercial venture and not toward the further protection of this reserve.

10. There is no doubt about the economic importance of the racehorse industry to Warrnambool and beyond, but the figures contained in the draft report confirm that the local racing industry was thriving before the influx of racehorses on to local beaches. The 2014 figures (p63) reveal the industry generated $97 million for the local economy and employed more than 950 people fulltime. The huge increase in the number of commercial racehorses on local beaches followed the 2015 Melbourne Cup and the success of Pirates of Penzance, trained by Darren Weir. It is my understanding that is responsible for the majority of horses that now train on the local beaches and there is a fear that if this activity is no longer permitted, he will withdraw from Warrnambool. My response is that the racehorse industry has been robust in Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Warrnambool for many years and its future should not depend on the decisions of a single trainer who is already expanding his operations elsewhere; that a $1.2 million sand track, half-funded by taxpayers, has been built at the Warrnambool Racecourse to accommodate sand training; and that no single industry – be it racehorse training, rendering, or sand mining – should be given access to what is one of the last remaining vestiges of wild, yet accessible, coastline in south-west Victoria, for commercial gain.

Notes:

* Part of the summary from the 2001 study of horse riding in D’Entrecasteaux National Park, WA (Phillips, N., Newsome, D): “Horse riding altered plant species composition, increased the area of bare ground and decreased height and cover of vegetation. Significant impacts occurred after only low levels of horse use. The findings indicate the need for a database on horse riding impact in Australia so that, where horse riding is allowed, impacts can be properly assessed and effectively managed.” http://www.publish.csiro.au/pc/PC020256

** https://www.warrnambool.vic.gov.au/sites/warrnambool.vic.gov.au/files/documents/co uncil/plans strategies/coastal%20plan.pdf (p20)

This ends my submission.

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Belfast Coast Management Plan: - Individual Survey Submission

Name:

Email Address:

Post Code: 3283

Age Range: 22

Gender: Male

Is this submission to be treated as Confidential: No

How often do you use the Reserve: 2 - 3 x per week – and more if the surf is working

How do you Get to the Reserve: .. Mainly - Walk, Drive, Ride a Bike, Ride a Horse

Ride a bike, Walk, Drive a car.

I mainly surf . I have surfed at The Cutting, Front Porch, Pelicans, Golfies, East Beach.

I snorkel at The Basin, and Paddleboard out to Front Porch.

I enjoy riding the horse along the beach, and I used to take the dogs down to Gormans Road.

I do sprint training on the beach for football training.

How important is it to you to be able to continue these activities within the entire Reserve?

Extremely important - It is the way of life down here. A lot of people mainly use the beach for these type of activities (maybe not sprint training). A lot of my friends may bring their dog down to the beach – mainly in the summer months. For most of the year though, the weather is pretty rough and the tides are up – so you have to know the beach to know when you can walk along it ok.

I believe that it is extremely important for everyone around here to be able to continue doing the same activities with their dogs and also the horse riders that ride along the beach.

Which part of the Reserve do you use most frequently:

Killarney Beach – Hardly Ever – no need to add to the numbers of the holiday makers.

West of Killarney Beach to Port Fairy – Mainly for - Surfing at East Beach and Golfies

East of Killarney Beach to The Cutting – Mainly for - Horse Riding, Surfing, Paddle boarding, walking my dog, snorkelling, fishing

West of The Cutting towards Warrnambool Hardly ever – no need

What is your area of interest (For Example: Conservation, Recreational, Cultural, With Animals – Horses or Dogs)

I like to surf. And I like to be able to take my dog down to the beach. Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Is there a specific change that you want made to the Draft Proposal.

Yes; I don’t like not being able to take my dog or my family to take our horse down to the beach. I want the Dark Green Zone – Conservation Zone to be deleted and replace sith a Recreation-Conservation (light green zone).

How important is the Cultural Heritage of the Reserve to you? - Ok – I like the idea of having middens down at the beach.

How important is protection of the Natural Environment and Bird life to you:

The beach environment has improved over the years. There used to be a lot of rubbish around – but now because we pick the rubbish up there is hardly any. The sand dunes have been washed away a fair bit. There are heaps of birds around – and I like to see the plovers. (now that I know what to look for). I don’t like the tracks in the sand dunes being closed off – there is no reason for it. The marram grass is ridiculous. It has taken over. I see a few foxes down there in the evenings – they are usually just hunting on the sand at the base of the sand dunes. – I don’t think the bait is working – because I have seen more this year than ever.

How important is the ability to enjoy recreation activities to you

Really important. I see the need for passive recreation to be an important part of society.

The health and fitness of the society is extremely important. People need to be motivated to exercise, and therefore lifestyle activities such as walking with a dog, or riding a horse is extremely important.

This is what happens on the Killarney beaches – most people walk their dogs down at the beaches. I also see a few people ride their horses. It is a fantastic resource for the community and should not be taken away from them.

Is your Personal Health and Wellbeing associated with your use of the Reserve? If so in what way.

Absolutely. It is really important to me. I am down there a lot. I love it – it relaxes me and keeps me fit.

Do you believe that the current use of the reserve that allows for both Recreation and Conservation should continue?

YES absolutely it needs to allow for all the activities that are now down there. Especially dogs and horses.

Dogs and Horses should be allowed in all areas of the beaches – from Port Fairy to Warrnambool.

If you believe dogs and horses should be banned – which areas should they be banned from:

I do not believe they should be banned.

Do you wish to add any further comments: I think the beach should stay as they are. I think dogs and horses should be allowed at the beaches at all times. I think the commercial race horses should be controlled to ensure they don’t break the rules. I think that the car park at golfies needs to be better organised, because the horse trucks in the car park take up most of the room. Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Submission template for Draft Belfast Coastal Reserve Management Plan About you:

Your name:

Your Organisation (if relevant):

Postcode: 3280

Email or Postal address:

THIS SUBMISSION IS: □ NOT CONFIDENTIAL Date: 1 march 2018

Local Resident: Recreation use- Windsurfing, Kitesurfing ,surfing Scuba diving, walking on beach

How often do you or your organisation use the reserve? □ Daily

Which part(s) of the reserve do you or your organisation most frequently use? □ West of Killarney (Port Fairy side) □ Between Killarney and Big Baldy

About the vision- Belfast Coastal Reserve, 15 years from now…:

How supportive are you of the vision for the Belfast Coastal Reserve? □ Very unsupportive

Key management theme #1: Cultural landscape and living heritage

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

How supportive are you of the strategies for ‘Cultural landscape and living heritage’ included in the draft management plan? □ Very unsupportive

Key management theme #2: Healthy Country

How supportive are you of the strategies for ‘Healthy Country’ included in the draft management plan?

□ Very unsupportive

Key management theme #3: Recreation and use

How supportive are you of the strategies for ‘Recreation and use’ included in the draft management plan? □ Very unsupportive

Submission to Belfast Coastal Reserve Draft Management plan by I have been using the Belfast Coastal Reserve for . It has been a mainstay of my physical and mental wellbeing.

We are a diverse group of people of all ages who have chosen to live in the Port Fairy/Warrnambool area because of its proximity and access to the ocean. Many of us meet on a daily basis to participate in many water activities in the Belfast Coastal Reserve. We surf mainly at Golfies and the Cutting; we windsurf and kitesurf in the ocean, the Belfast Lough and Rutledges Cutting (saltwater swamp). We snorkel and scuba dive at the Basin (access from Towilla Way and Gormans Lane) and the Long Reef (called Pelicans on Parks Vic. map) with access via a marked primary track from the Basin road to Pelicans. The current draft management plan seeks to create a conservation zone all along the Armstrong Bay beaches in South West Victoria. This conservation zone will have a huge, detrimental impact on our recreational choices, now and into the future, due to restriction of access to waterways. This conservation zone will exclude me, the members of our group and the vast majority of people in the South West of Victoria from a historical recreational reserve, which has served as the life blood of the society and community groups in the municipality.

Addressed to specific issues. Prohibition of Windsurfing Kitesurfing and Surfing on the Belfast Lough and Rutledges Cutting (saltwater swamp). Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

I have not included surfing here as it is not possible to surf on flat water.

In the draft plan under Section 6 Recreation and Use, there is no mention or data on Windsurfing or Kitesurfing as having any negative influence in the Belfast Reserve, yet these groups are prohibited from the Belfast Lough and Rutledges Cutting (saltwater swamp). In table 6.1 Page 54, motorised boating, which includes jet skis, is permitted in the Belfast Lough, yet windsurfing and kitesurfing are not. Non-motorised boating (canoes, kayaks rowing skulls, paddleboards etc. are permitted. On Rutledges Cutting, non-motorised boating is permitted. Where is the data to support the prohibition of Windsurfing and Kitesurfing, that in reality are non- motorised sports?

Windsurfing and Kitesurfing on the Belfast Lough and Rutledges Cutting are very passive activities with zero ecological effect. The Lough and the Cutting are not used frequently and then only by a small number of enthusiasts. We access the Belfast Lough (see Map 1) from the 20-metre wide public right of way that serves as access to the Port Fairy airport. The Belfast Lough and the Rutledges Cutting are geographically special places for windsurfers and kitesurfers. Both are shallow. The surrounds are flat without any tall vegetation. This gives a “clean” constant wind. The closest places that replicate these conditions are Point Henry, Geelong (200 km East) and Lake George, Beachport (300km west)

The Belfast Lough is used as it is a place of safety. We teach learners in the shallow water away from Ocean waves. The Lough and Rutledges Cutting are occasionally used when the wind is northerly and sailing on the Ocean is too dangerous due, to offshore winds. They sail infrequently and this is a safe place for them to sail. Due to the length of the fin on a windsurf board we can only sail in a small area in the middle of the Lough and cannot access the shallow mud flats. This means that we do not affect any birds or nesting places.

Some other points to note under the draft plan: • The Lough and the Cutting are not undisturbed pristine areas. They have been highly modified over the years. Both have old fencing in parts and are very muddy. The biggest environmental impact on the Belfast Lough and Rutledges Cutting is the nutrient inflow and rubbish from agricultural activities further up in the Moyne river catchment. Windsurfers and Kitesurfers have no detrimental effect on these places.

• The Lough is approximately 700m wide and 1800m long. Under the draft plan it is permissible to ride up and down the middle of the Lough on a jet ski at 90 km/hr, as it would be over 200m from shore. In comparison, a windsurfer is an engine free, noise-free, relatively slow craft.

• There is an airport runway adjacent to the shore that is approximately 1 km long. There are frequent fixed wing and helicopter scenic flights operating from this airport over summer. No mention has been made of stopping this. Yet this has a much greater impact on the environment than a kitesurfer or windsurfer.

• Boating (non-motorised) is permitted. Rowing skulls, canoes, kayaks, paddleboards, all with a low draft, could disturb the shallow waters at the Lough’s edge. However, due to the length of a windsurf board fin windsurfers can only sail in a small area in Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

the middle of the Lough and cannot access the shallow mud flats. This causes zero disturbance.

• A great deal of rubbish floats down the Moyne River and into the Lough. Our group pulls this to shore and responsibly disposes of it. We often pick up rubbish that is dumped on the road access beside the airport. We care for the Lough and do not leave an ecological footprint. Under the new plan, who will be responsible for cleaning up rubbish in the Lough if we are excluded? As friends of the Lough, we fulfil a very useful conservation purpose.

• Both the Lough and Cutting are rarely used by any other user groups, especially when our usage is during windy conditions that is generally unappealing to other users. Consequently, our usage has zero conflict with other users or the public.

• Rutledges Cutting and saltwater swamp (see Map 2) is a body of water usually closed off from the Ocean and generally containing little water. It is a highly modified area. It has been dredged, graded, and modified for agricultural means. During times of flood (winter mainly) much of the water flows out onto private agricultural land and is beyond the boundaries of the Belfast coastal reserve. It is subject to considerable nutrient inflow and rubbish from surrounding farmland. On page 59, the draft plan for Rutledges Cutting mistakenly assumes it has a similar ecology to Kellys Swamp, is always open to the sea and, consequently, is a nursery area for fish and a refuge for birds. This is not the case. Rutledges Cutting is landlocked, brackish and closer in ecology to that of Belfast Lough. Occasionally, Kitesurfers and Windsurfers use this area when a northerly wind blows and the area is in flood. The water then spreads way out beyond the Belfast coastal reserves boundary over flat agricultural land. This means this area can only be used infrequently. The ecological impact on the reserve is zero, especially when compared to the permitted agricultural activities. Currently, the draft plan permits non-motorised craft in the Rutledges Cutting. I would propose that windsurfing and kitesurfing are included in the permitted activities on Rutledges Cutting.

• Kellys swamp should be considered as environmentally different to the Belfast Lough and Rutledges Cutting. Kellys swamp is a fresh water, heavily reeded bird habitat. Consequently, it is not appropriate for windsurfing and kitesurfing to be allowed on Kellys swamp.

• we are willing to engage with Parks Victoria on any issue related to use and management of the Belfast Lough and the Cutting.

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Map 1: Showing the approximate small area of Belfast Lough used for Kitesurfing and Windsurfing.

Map 2: Showing approximate small area of Rutledges Cutting used for Kitesurfing and Windsurfing. Notice red box showing area of Rutledges Cutting mostly closed off to ocean.

Summary Windsurfing and Kitesurfing have zero ecological impact on Belfast Lough and Rutledges Cutting and are ecologically sustainable recreational activities. They do not have any documented, detrimental environmental impact on these waterways. These recreational activities are determined solely by prevailing wind and weather conditions. This means infrequent use. The safety and long term health implications of Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

removing such places of recreational activity will have an impact on the safety of inexperienced, novice and elderly users. These activities should be supported for many reasons, including the health and well-being of the people who engage in them. I hope the prohibition of these outdoor recreations in the Belfast Lough and Rutledges Cutting is an oversight in the plan, otherwise it cannot be justified. Proposal I would propose that windsurfing and kitesurfing are included in the permitted activities on the Belfast Lough and Rutledges Cutting

Regards

Key management theme #4: Managing in partnership

How supportive are you of the strategies for ‘Managing in partnership’ included in the draft management plan?

□ Very unsupportive

Key management theme #5: Research and monitoring

How supportive are you of the strategies for ‘Research and monitoring’ included in the draft management plan?

□ Very unsupportive

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Manager Parks Planning Parks Victoria Level 10, 535 Bourke St Melbourne VIC 3000

To whom it may concern,

Re: Warrnambool Beach Training Support Submission

As an owner of horses trained in Warrnambool, the opportunities beach training presents as well as the relaxed country environment the district has to offer is the key reason why I will continue to support the continuation of horse training in the region.

It is excellent to be able to be involved in local horses as we get more opportunities to see them train and run in the region. If the use of beaches were restricted, this might not be the case.

The opportunity to train horses on Levy’s Beach and the dunes is critical for the ongoing success of horse training in Warrnambool which I am fully supportive of.

Regards,

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Manager Parks Planning Parks Victoria Level 10, 535 Bourke St Melbourne VIC 3000

To whom it may concern,

Re: Warrnambool Beach Training Support Submission

As a current member of the Warrnambool Racing Club, this letter is written to provide my support to the continuation of Beach training in Warrnambool.

I am very proud of the fact we have the beaches to offer this unique horse training opportunity, this for certain provides significant positive economic benefits to our local community, and employs many passionate people.

it would be sad to see the cessation of beach training for these wonderful race horses. Not being able to work on the soft sandy surface could affect the stability of some horses that need a softer surface to train on and swimming is an excellent form of exercise for horses.

What we have is unique and something our community is proud of, as a result I am fully supportive of the continuation of horse training on our local beaches.

Regards,

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Drainage: Since the completion of the Pt Fairy to Warrnambool Rail Trail in 2012 Kelty's Swamp & t e neighbouring wet lands have increasingly retained water for longer periods of time in ct still holding water today, which in years prior to the permanent causeway being constru ed wo ld be dry by mid February unless there had been very heavy summer rains which has not been th case this year.

ThiS we believe this is being caused by the height of the Rail Trail causeway. There has for many years been a sand track across what is know as "Rooney's Swamp" (the causeway) hi h would wash away every year in high floods when the banks of the Merri River burst & flowed onto h wetlands. The causeway was built by the Mayne Shire to allow Run dells Trail Rides other horse riders access to the now '(The Belfast Coastal Reserve'' It was constructed with heavy limestone with only 6 culverts in 1 section & completely blocking the government drain {fea ured on the Parks Victoria Map date 1 September 2016) Map attached. Which I have noticed doesnlt feature on t maps in the draft plan information booklet. The 6 culverts have completely silted over in 6 yrs & the drain is now barely visible in sect1ons which is preventing any water to escape back into the river from beyond that section of Swamp. In turn every year our wetlands are becoming Increasingly flooded & less productive as farm land and "Kelly's Swamp" in increasing in size ~------~

We are seeking to have the causeway & drain cleared to allow the flow of water to return to prior 2012 when the Rail Trail was constructed.

Weed Control: - -

Sadlyit. was the NRE employees in the early 90's whom placed the boxthorn on tracks to prohibit 4x4 vehicles & motorbikes.

Vermin· rt------~------~~~------~r~ We realise there has for several ...... _~_,.,.,..,..~ v a been programs to bait foxes but unfortunately the pro1ram has not been a success as the numbers would still be at a high if I ceased level. Rabbits when bur owing clos or under the fences.

4x4 Vehicl · s & Motor Bikes:

r ca in& 1reat deal of damage to the vegetation in the reserve ...... witne sed first hand large 4x4 vehicles purposely driving into wet areas on h ~--~~------~ With he1r only Intention being to bog the vehicle. Ther re usual y s v I ...... __--~------h c pr orm1n1 hi x r is at time with the winner being the vehicle that can achi v th pth. Th rd pi c on th Mahogany Wal ins Track h opped th v hi I in om w~h d h 4x4 ~--~~----~--~ ~--====~~====~~------~~==~--~ Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Submission template for Draft Belfast Coastal Reserve Management Plan

About you:

Your name:

Your Organisation (if relevant): ______

Postcode:

Email or Postal address:

THIS SUBMISSION IS: □ CONFIDENTIAL x NOT CONFIDENTIAL Date: 27/02/18

Your Comments:

Please Note – The following information will be made publically available. Main reason for interest: (such as local resident, visitor to parks, tourism operator, environmental interest, business operator, education interest, scientific interest)

Environmental interest

How often do you or your organisation use the reserve? □ Daily □ Weekly □ Monthly □ A couple of times a year x Rarely □ Never

How do you or your organisation mainly use the reserve? □ Walking or running □ Dog walking □ Using the beach (swimming and surfing) □ Horse riding □ Horse training □ Volunteering □ Camping □ Hunting □ Fishing/boating □ Picnicking x Birdwatching □ Socialising □ Other (please specify): ______

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

About the vision- Belfast Coastal Reserve, 15 years from now…:

How supportive are you of the vision for the Belfast Coastal Reserve? □ Very supportive x Supportive □ Not sure/Don’t know □ Unsupportive □ Very supportive

• I largely support the Vision statement, with the exception of the inclusion of “horse riding”. Given the sensitivity of this coastal Reserve, its value to birds which are highly prone to disturbance and with highly camouflaged eggs and chicks, it would be more appropriate to avoid specifying horse riding in the vision for the Reserve’s future.

Key management theme #1: Cultural landscape and living heritage

How supportive are you of the strategies for ‘Cultural landscape and living heritage’ included in the draft management plan?

x Very supportive □ Supportive □ Not sure/Don’t know □ Unsupportive □ Very supportive

Key management theme #2: Healthy Country

How supportive are you of the strategies for ‘Healthy Country’ included in the draft management plan?

□ Very supportive □ Supportive □ Not sure/Don’t know x Unsupportive □ Very supportive

• I strongly support a Conservation Zone and believe it should be required and prohibit dogs, horses and vehicles. The reserve is home to over 50 species listed as threatened and has been identified as a Key Biodiversity Area. A conservation zone will reduce the impact of dogs and horses on Hooded Plover and key migratory shorebird sites. • I strongly support the strategy to “protect Hooded Plover nests and chicks from trampling through erection of temporary fencing and signage around individual breeding sites across the Reserve (following best practice protocols)” and to “undertake targeted Hooded Plover nest monitoring…use monitoring results to inform/adapt management of visitor activity”. • I strongly support the goals and strategies to maintain and enhance habitats, reduce the impact of pest species and visitors, better manage marine, lake and swamp habitats, and to build resilience to climate change • This chapter reveals the draft plan s underlying contradictions regarding commercial racehorse training. On page 29, the draft plan admits that the extreme risk to coastal habitats, cultural heritage and resident and migratory wildlife from commercial racehorse training will remain so even following management action. This fundamental contradiction in the draft plan will undermine the achievement of the goals and strategies in this chapter. • I strongly oppose a conservation zone that allows commercial racehorse training

Key management theme #3: Recreation and use

How supportive are you of the strategies for ‘Recreation and use’ included in the draft management plan?

□ Very supportive x mainly Supportive □ Not sure/Don’t know □ Unsupportive □ Very supportive

I strongly support many of the goals and strategies that relate to the recreational use of the Belfast Coastal Reserve including increased enforcement, better management of vehicular use, dog walking and recreational horse riding, bans on dune boarding, hunting and off-road vehicles, reducing risks and improving safety, improving information, interpretation and education, and developing tourism partnerships, marketing and promotion. But without the removal of commercial racehorse training, these goals will not be achieved.

Licensed Horse Training

I do not support access for commercial racehorse training.

The draft plan recommends strict controls on where and how recreational uses are to be managed in the future, whereas commercial racehorse training will be expanded. This does not make sense. Table 6.1 Summary of activities proposes that commercial horse training will be allowed within the CONSERVATION ZONE at Rutledges Cutting. This is inexcusable and contradicts the vision for the Reserve and the EXTREME assessment of risk that this activity poses to key values of the Reserve.

I do not support and strongly condemn permits for horse training at Golfies, Rutledges Cutting or Hoon Hill/Levys beach.

I support the statement “close the beach to horse training and riding groups when Hooded Plover nests extend onto narrow sections of beach…or when climatic conditions or tidal conditions make access unsuitable”.

Dog Walking

I strongly support prohibition of dogs in the proposed CONSERVATION ZONE as this will also allow for greater fox control to occur within this area, as currently baiting cannot occur adjacent to any walking tracks where dogs may be walked on-leash.

I strongly support the plan's identification of a designated 'off-leash dog beach' on page 49. Providing locals and visitors with a designated beach to enjoy with their dogs provides an alternative to the high value CONSERVATION ZONE where dogs will directly negatively impact the breeding of multiple species of beach-nesting birds, and disturb large flocks of roosting and foraging migratory shorebirds.

I also strongly advocate for the creation of a more inviting dog walker experience and facilities for dog walkers through the old vehicle track that runs between the Golf course access and the Killarney campground. If a circuit walk for dog walkers was created here, with a walk that included on-leash time on the beach and then a walk that returned via the old track on the dune, it would take pressure off the CONSERVATION ZONE, and would provide dog walkers with a more attractive alternative.

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Key management theme #4: Managing in partnership

How supportive are you of the strategies for ‘Managing in partnership’ included in the draft management plan?

□ Very supportive x mostly Supportive □ Not sure/Don’t know □ Unsupportive □ Very supportive

I strongly support the first goal in this chapter:Coordinated management of the Reserve enables efficiencies in program delivery and is supported by consistent landstatus and regulations. But I cannot support the strategies that aim to achieve it. The plan recommends retaining the fragmented management across the City ofWarrnambool, Moyne Shire Council and Parks Victoria and leaving the reserve under the Crown Land s (Reserves) Act.The reserve should become a park under the National Parks Act. • I do not supportthe current 5 and 10 year reviews of implementation of the plan. These are too long a time frame for threatened species likely to be impacted by the plan. A one to two yearly review cycle is required.

Key management theme #5: Research and monitoring

How supportive are you of the strategies for ‘Research and monitoring’ included in the draft management plan?

□ Very supportive X Supportive □ Not sure/Don’t know □ Unsupportive □ Very supportive

I strongly support this chapter’s goal and strategies and the indicators to be used to evaluate the effectiveness of the management plan. However, the plan fails to explain how it will lower the extreme risk presented by commercial racehorse training revealed in the table on page 29. That table proves that it cannot and so commercial racehorse training should be removed from the reserve.

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Belfast Coastal Reserve Draft Management Plan

Community Feedback

From –

27/02/2018

Submission below is Not Confidential (my private details above are Confidential)

Key Management Theme #2: Healthy Country

 I strongly support a Conservation Zone and believe it should be required and prohibit dogs, horses and vehicles. The reserve is home to over 50 species listed as threatened and has been identified as a Key Biodiversity Area. A conservation zone will reduce the impact of dogs and horses on Hooded Plover and key migratory shorebird sites.  I strongly support the strategy to “protect Hooded Plover nests and chicks from trampling through erection of temporary fencing and signage around individual breeding sites across the Reserve (following best practice protocols)” and to “undertake targeted Hooded Plover nest monitoring…use monitoring results to inform/adapt management of visitor activity”.  I strongly support the goals and strategies to maintain and enhance habitats, reduce the impact of pest species and visitors, better manage marine, lake and swamp habitats, and to build resilience to climate change.  This chapter reveals the draft plan’s underlying contradictions regarding commercial racehorse training. On page 29, the draft plan admits that the extreme risk to coastal habitats, cultural heritage and resident and migratory wildlife from commercial racehorse training will remain so even following management action. This fundamental contradiction in the draft plan will undermine the achievement of the goals and strategies in this chapter.

Key Management Theme #3: Recreation and Use

 I strongly support many of the goals and strategies that relate to the recreational use of the Belfast Coastal Reserve including increased enforcement, better management of vehicular use, dog walking and recreational horse riding, bans on dune boarding, hunting and off-road vehicles, reducing risks and improving safety, improving information, interpretation and education, and developing tourism partnerships, marketing and promotion. But without the removal of commercial racehorse training, these goals will not be achieved.

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Licensed Horse Training

• I do not supp01t access for commercial racehorse training. • The draft plan recommends strict controls on where and how recreational uses are to be managed in the future, whereas commercial racehorse training will be expanded. This does not make sense. Table 6.1 Summaty of activities proposes that commercial horse training will be allowed within the CONSERVATION ZONE at Rutledges Cutting. This is inexcusable and contradicts the vision for the Resetve and the EXTREME assessment of risk that this activity poses to key values of the Resetve. • I do not supp01t and strongly condemn pemlits for horse trailing at Golfies, Rutledges Cutting or Hoon Hill/Levys beach. I supp01t the statement "close the beach to horse training and riding groups when Hooded Plover nests extend onto narrow sections of beach ... or when climatic conditions or tidal conditions make access unsuitable".

Dog Walking

• I strongly suppmt prohibition of dogs in the proposed CONSERVATION ZONE as this will also allow for greater fox control to occur within this area, as currently baiting cannot occur adjacent to any walking tracks where dogs may be walked on leash. • I strongly suppmt the plan's identification of a designated 'off-leash dog beach' on page 49. Providing locals and visitors with a designated beach to enjoy with their dogs provides an altemative to the high value CONSERVATION ZONE where dogs will directly negatively impact the breeding of multiple species of beach-nesting birds, and distmb large flocks of roosting and foraging migrat01y shorebirds. • I also strongly advocate for the creation of a more inviting dog walker experience and facilities for dog walkers through the old vehicle track that tuns between the Golf course access and the Killamey campground. If a circuit walk for dog walkers was created here, with a walk that included on-leash time on the beach and then a walk that retumed via the old track on the dune, it would take pressure off the CONSERVATION ZONE, and would provide dog walkers with a more attractive altemative.

Thank you

Sincerely,

27/02/2018 Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Submission on Belfast Coastal Reserve Draft Coastal Management Plan Jan 2018

Thank you for the opportunity to comment on this plan .

have spent many hours at Killarney Beach and surrounds fishing ,snorkelling and walking my dog .

I have great concerns about the impact of the plan on recreation in this area .

The main concern of this plan seems to focus on the shore bird life which is quite appropriate but disproportionate to the other recreational pursuits in this area .

I wish to address two main areas in the report — dogs and their control and horses .

1.Horse riding

Rundells’ riding school has been doing day treks at the Eastern end of the reserve for some years under a strict management system with no riding above the high tide mark except at designated access points. Having experienced these rides myself I know they stick by the rules and have a limited impact on the shore .

Racing thoroughbreds on the beaches is another matter . The report talks about “historic” horse training on the beaches but I have only noticed the huge increase of racehorse activity .over the last 6 years. Prior to that the occasional racehorse came to the beach mainly to wade to treat injuries for which there is good medical evidence . More recent experience has been of flat out galloping ABOVE the high water mark chopping up and compacting sand and destroying habitat as well as being a danger to other beach goers .The beach is now used as a de facto race track which of course is cheaper than the all weather Warrnambool track . This is akin to allowing formula 1 cars to practise on the freeway while other traffic is around.

The car parks are unsuitable for the horse floats and although trainers are required to pick up manure the car park ends up smelling of horse shit and urine giving the flies a field day Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

The racing industry is said to bring so much money in to the city —perhaps allow the

council to pay for a sand track to be built at the race course and let’s see how the

ratepayers value that . I doubt if council would be in favour but the beach seems to be fair

game but not for other users .The concerns expressed for the birdlife do not seem too

apparent when racehorses are mentioned and state and local vested interest must be

behind this .

I am not against racing and training of horses but NOT ON THE BEACH.

As regards riding on the beach for recreation rather than professional training I think it is

appropriate providing reasonable control and behaviour and riding below the high water

mark as in Rundell’s guidelines

2. Dogs

A lot is written in the report concerning dogs .As the report notes there is VERY limited

access to the beach for dog owners in Warrnambool .Further limitation of access to the

beach I believe is detrimental to tourism and to local people who exercise their dogs and

improve their own health in doing so .

The proposed access for dogs on leads is limited by the summer closure and dog walkers

are likely to be run over by racehorses in the two areas .Not exactly relaxing !!.If it is

decided dogs must be on leads this will greatly reduce the impact on birdlife so why the

green zone ??

Conclusion

A very disappointing document for recreation and possibly the thin end of the wedge

reducing access to the beach .The green zone may be up graded in future to NO access

to the public in the name of conservation of the hooded plover . This was not the original

vision for the coastal reserve

Signed

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Submission template for Draft Belfast Coastal Reserve Management Plan About you:

Your name: ______

Your Organisation (if relevant): ______

Postcode: ______

Email or Postal address: ______

THIS SUBMISSION IS: □ CONFIDENTIAL □ NOT CONFIDENTIAL Date: ______

How often do you or your organisation use the reserve? □ Daily □ Weekly □ Monthly □ A couple of times a year □ Rarely □ Never

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

About the vision- Belfast Coastal Reserve, 15 years from now…:

How supportive are you of the vision for the Belfast Coastal Reserve? □ Very supportive □ Supportive □ Not sure/Don’t know □ Unsupportive □ Very supportive

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Key management theme #1: Cultural landscape and living heritage

How supportive are you of the strategies for ‘Cultural landscape and living heritage’ included in the draft management plan?

□ Very supportive □ Supportive □ Not sure/Don’t know □ Unsupportive □ Very supportive

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Key management theme #2: Healthy Country

How supportive are you of the strategies for ‘Healthy Country’ included in the draft management plan?

□ Very supportive □ Supportive □ Not sure/Don’t know □ Unsupportive □ Very supportive

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Key management theme #3: Recreation and use

How supportive are you of the strategies for ‘Recreation and use’ included in the draft management plan?

□ Very supportive □ Supportive □ Not sure/Don’t know □ Unsupportive □ Very supportive

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Key management theme #4: Managing in partnership

How supportive are you of the strategies for ‘Managing in partnership’ included in the draft management plan?

□ Very supportive □ Supportive □ Not sure/Don’t know □ Unsupportive □ Very supportive

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Key management theme #5: Research and monitoring

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

How supportive are you of the strategies for ‘Research and monitoring’ included in the draft management plan?

□ Very supportive □ Supportive □ Not sure/Don’t know □ Unsupportive □ Very supportive

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

5th February 2018

Dear Sir/Madam,

I am writing this as a submission to the Belfast Management Draft Plan. I am very concerned and do not agree that the section of beach from Killarney to Big Baldy should be deemed to exclude dogs.

I am a beach user off Gorman’s Lane, on a regular basis and walk my dog which was leash free until recently when the signs were changed. I understand the need for environmental conservation. However, there is a large area of beach to be considered and a small area that needs conservation mainly the Hooded Plover in this area.

When I walked this beach this morning , I was the only user on the beach at the far end of the Gorman’s Lane carpark, which is often the case anytime I use this area. I walked West one kilometre up the beach. In this area there is one 70m x 10m picket star fenced off area with signs for the Hooded Plover. A few bits of rope attached to some pickets. My questions are; Why close the entire part of the beach to dogs for small pockets of conservation area? (The conservation effort to these plovers looks very haphazard with only star pickets and a few signs, there is no protection between these pickets.) Why if they are so important to protect is the effort to protect them so minimal? Why does the beach need to be closed to dogs for the entire year when the birds breed from August to March as stated in the plan?

I would like to see data that explains the number of users to the area, how many of them are dog users, and how many and what type of damage do dogs do to this environment. What is the exact number of birds in the past compared to now? To me, it seems that a very small percentage of incidences does not warrant the closure of the area to dogs. In the draft plan, it describes dog behaviour as; leaving excrement, uncontrolled roaming and aggressive behaviour, these behaviours can occur in any environment not just at this location. I believe most dog owners are responsible and control their dogs, it may be a few rogue owners that set a bad example for the rest of us.

I disagree with the Belfast Management Draft Plan to exclude dogs from Killarney to Big Baldy. I believe careful consideration is needed in regard to the small conservation requirement and the recreation use for dogs on this part of the beach. I believe a balance can be met for that of conservation and for a leash free beach for dogs.

Regards

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Response to Draft Belfast Coastal Reserve Management Plan

To Whom it may concern.

If, to quote your own plan “Belfast Coastal Reserve is an important cultural landscape on Victoria’s south-west coastline, recognised for its scenic beauty, environmental attributes and cultural significance,” why would you put it at risk?

It is with grave concern and a heavy heart that I submit this response. I have been an active participant in the protection of Australia’s beautiful and fragile shore birds, especially the Hooded Plovers along the beaches of Port fairy and surrounds Birdlife Australia and Moyne shire Council to help the birds survive their first weeks from the laying of eggs to fledging. visitors from all over the world who have shown an interest in what we do and how the birds live. I have always found these conversations to be positive and they highlight a very important fact. Port Fairy and the surrounding beaches, which include those mentioned in the Belfast Coastal Reserve Management Plan, are the main attraction for the visitor. People come to our coastline for its raw beauty. This is a raw beauty referenced in your plan. To quote, “Belfast Coastal Reserve is an important cultural landscape on Victoria’s south-west coastline, recognised for its scenic beauty, environmental attributes and cultural significance.” Why then would you put it at risk?

I have always agreed with the notion of getting the balance right. However, there can be no balance between “enjoying walking, bird-watching, fishing, swimming, dog-walking, picnicking and nature study,” and commercial horse training. No matter what you say, the two things cannot go together. You may claim that the horses can train at designated times, for example, early morning and the bird watching etc can happen afterwards but what will be left of the beach will hardly be worth a look. This is like saying that horses can train on the MCG between Christmas day and Boxing Day and then the cricketers can have it for the Boxing Day test. It sounds a fair split but the damage done by the horses will render the test unplayable and so it goes for the walkers, picnickers, nature students and bird watchers and the fragile ecosystem that supports a myriad of wildlife.

The basic tenets of your plan are at odds with each other. Commercial horse training has no place on our beaches especially those deemed “Conservation and Recreation Zones”. To walk the beaches with horses galloping up and down is not pleasant and nor is it safe. Your plan places the safety of beachgoers at risk. Are you going to accept that responsibility? What plans have you for monitoring the beaches when these two competing forces collide? AND THEY WILL!!!

The two things are mutually exclusive. They are a contradiction. You must decide. The future of our great southwest lies in its beauty and the tourism that it attracts. Allow the commercial trainers, horses to take over, and you will ruin the beaches for once and all and you will ruin the jobs that rely on those who visit the southwest to enjoy its rugged and raw beauty.

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

RE: Personl request to reject the current "Belfst Costl Reserve Drft Mngement Plnʼ nd mke mendments before finlising the ‘Belfst Costl Mngement Pln.ʼ

As locl resident nd user of the Armstrong By beches I wish to submit my forml objection to the Belfst Costl Reserve Drft Mngement Pln.

I strongly object to the extent of the Conservtion Zone nd its inherent exclusion of dogs on leds nd recretionl horse riders from the beches.

I recommend tht the proposl be mended to be more inclusive nd sustinble. I urge for sustinble pproch tht will include benefits for ll community stkeholders nd will provide blnce between the socil nd environmentl needs of the re.

I sk tht the Belfst Costl Reserve Drft Mngement Pln be mended for finlistion by chnging the Drk Green Zone: Conservtion Are, to Light Green Zone: Conservtion/ Recretion Are, to llow me, nd mny other citizens, to continue to enjoy the freedom of the beches in our community with our nimls.

The conservtion zone will essentilly exclude me nd the vst mjority of people in the South West of Victori from historicl recretionl reserve which hs served s the life blood of the community in the municiplity.

The intention of Prks Victori to crete conservtion zone long the Armstrong By beches in South West Victori will hve detrimentl impct on my helth, wellbeing nd lifestyle choices, now nd into the future.

My life nd lifestyle choices will be significntly diminished nd my ttitude to the re will be permnently ffected. Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

If I m excluded from entering the bech nywhere long the “Conservtion Zone,” I will be forced to drive my cr to wlk my dog in n incresingly smller re reserved for dog wlking which will crete congestion nd ssocited problems.

I sk tht you give this letter your thoughtful considertion nd note my objections nd suggestions when finlising the mngement pln bsed on feedbck from our community nd current stkeholders.

Thnk you for your time.

Kind Regrds,

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

RE: Submission and Personal request to reject the current "Belfast Coastal Reserve Draft Management Plan’ and make amendments before finalising the ‘Belfast Coastal Management Plan.’

As a local resident and user of the Armstrong Bay beaches I wish to submit my formal objection to the Belfast Coastal Reserve Draft Management Plan.

I strongly object to the extent of the Conservation Zone and its inherent exclusion of dogs on leads and recreational horse riders from the beaches.

I recommend that the proposal be amended to be more inclusive and sustainable. I urge for a sustainable approach that will include benefits for all community stakeholders and will provide a balance between the social and environmental needs of the area.

I ask that the Belfast Coastal Reserve Draft Management Plan be amended for finalisation by changing the Dark Green Zone: Conservation Area, to a Light Green Zone: Conservation/ Recreation Area, to allow me, and many other citizens, to continue to enjoy the freedom of the beaches in our community with our animals.

The conservation zone will essentially exclude me and the vast majority of people in the South West of Victoria from a historical recreational reserve which has served as the life blood of the community in the municipality.

The intention of Parks Victoria to create a conservation zone along the Armstrong Bay beaches in South West Victoria will have a detrimental impact on my health, wellbeing and lifestyle choices, now and into the future. My life and lifestyle choices will be significantly diminished and my attitude to the area will be permanently affected.

If I am excluded from entering the beach anywhere along the “Conservation Zone,” I will be forced to drive my car to walk my dog in an increasingly smaller area reserved for dog walking which will create congestion and associated problems.

I ask that you give this letter your thoughtful consideration and note my objections and suggestions when finalising the management plan based on feedback from our community and current stakeholders.

Thank you for your time.

Kind Regards,

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

SUBMISSION TO PARKS VICTORIA – Title: Do Not Disturb

From: Ratepayer:

SUBJECT: Belfast Coastal Reserve Management Plan – to include commercial race horse training POSITION: I ask Parks Victoria not to put their name to this destruction. BEACHES ARE NOT SUITABLE PLACES FOR HORSES – THEY WRECK IT:

o No number of horses is allowable. They trash the beach. Horses need dedicated facilities. o Undisturbed environments are valuable to Australia and to people from all over the world. o Commercial interests are robbing all of us of natural undisturbed environments. - Immediate solutions are required - dedicated facilities for horse activity - Synthetic surfaces for horse activity; avoid disturbing the beaches at all cost. Horses leave the beach trashed. Main entrance to the Killarney beach looking westward. Main entrance to the Killarney beach looking eastwards.

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

BEACHES ARE NOT SUITABLE PLACES FOR HORSES – THEY WRECK IT Killarney beach main entrance looking eastward - after horse training

Killarney beach main entrance a) looking west b) looking east c) looking straight ahead

a b c

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

BELFAST COASTAL RESERVE Warrnambool Field Naturalists Club Submission on the Draft Coastal Management Plan

1. The park planning process and the genuine community engagement sought by Parks Victoria is to be commended. 2. The establishment of conservation only zones is to be commended. However, there is “historical use” of horses noted in Ruttledge’s Cutting and horses are thus permitted in this conservation zone where there is significant risk to shorebirds. If dogs are banned from conservation zones then we strongly argue so should horses be banned. We also challenge the use of horses being termed “historical”; the LCC report for the area lists 4WD and other vehicles as demaging the area but not horses. 3. Both resident and migratory shorebirds must be considered as they feed and rest on the shoreline where horses are allowed. Migratory shorebirds use both wetlands and beaches in the Reserve and should be protected under our obligations to international treaties. 4. Coastal dune scrub is threatened and fast disappearing. Page 30: “… research has shown that low levels of horse trampling can cause a significant reduction in vegetation height with fewer species found on trampled sites (Dyring 1990). The rate of soil stress is dependent on the amount of horse trampling and characteristics of soils, however, structurally unstable deposits such as dunes are more readily impacted by this process (Phillips and Newsome 2002). Deluca et al. (2001) and Wilson and Seeny (2009) determined that horses caused the greater degree of trail erosion as they loosen soils to a greater degree than hikers and motorcyclists, due to their relative weight and high exerted ground pressure. Sand dunes sensitivity to disturbance can lead to loss of habitat, reduced seed sources an increased risk of dune erosion by storms.” Horses also enhance the spread of weeds through their droppings. We argue these are arguments for excluding horses from the entire Belfast Coastal Reserve, but especially from the conservation zones. 5. Managing vehicle access using gates and other infrastructure is welcome. Keeping tracks to a minimum is good for vegetation and dune stability as well as for wetland habitat conservation. 6. p. viii l 3 “complimentary” surely should be “complementary”? 7. p. 29 key threats and words on the maps are difficult to read. 8. The Club applauds the importance placed on research and monitoring and urges continuation of the successful Research Partners scheme to undertake paid research projects on behalf of Parks Victoria, using a partnership model. The Club also welcomes the strategy to “support and encourage citizen science research and monitoring to fill key knowledge gaps and inform Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

management decisions” (p. 79). The Club would welcome the opportunity to undertake long-term monitoring of natural resources such as vegetation and wildlife at sites considered important by Parks Victoria. The Club and other like-minded organisations can provide the long-term input that is so difficult for government organisations normally to provide commitment and resources. 9. The Club believes any commercial horse training licence fees for use of the Reserve should be allocated directly to (or collected by) Parks Victoria so that funds can be invested in maintenance of the Coastal Reserve, especially rectifying damage caused by horses. 10. The costal ecosystem typical of Belfast Coastal Reserve is under threat across Australia and it is imperative it be conserved in our local area for the enjoyment by future generations. We need to be aware that the shifting baseline syndrome operates in these contexts - each new generation perceiving the environment they first know as ‘natural’. The diminution of ecosystem integrity over time is regarded as natural as each generation regards the state of the ecosystem they encounter as a child as “natural”. 11. Parks Victoria should be the management agency for the whole area instead of local governments having responsibility for intervening sections. 12. On page 79 there is also a strategy to engage with Traditional Owners to “research and document Aboriginal cultural values”. This is commendable and supported by the Club. The same strategy also goes on to say “… and apply traditional ecological knowledge and land management practices.” Care and diplomacy will be required if such recommendations are in conflict with those obtained by modern scientific evidence. This will not always be the case and we would hope that in most instances, the recommendations will be in alignment. However, our experience suggests that sometimes either a) local knowledge on past ecological practices has been lost and those questioned might feel obliged to provide an unsubstantiated opinion, or b) non-Traditional Owners from Indigenous groups located elsewhere provide inputs that also are in conflict with best practice for long term ecological health of the ecosystems under consideration, but that may well be appropriate for different environmental contexts.

Approved by the Committee of the Warrnambool Field Naturalists Club. [email protected] Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

- Feb 11 2018 – Submission in response to the Parks Victoria Report: Managing the Hooded Plover in Victoria: A site by site assessment of threats and prioritisation of management investment on Parks Victoria managed land.

I make a few brief observations on the Parks Victoria report noted above. All quotes are extracts from the report.

These comments are in addition to comments on the Draft Belfast Coastal Management Plan made in January 2018 which has been distributed and is included at the end of this document (See Appendix 1).

Breeding success “..if the population (Hooded Plovers) relied on breeding success of pairs in isolated or inaccessible sites then fecundity would only be half of what was achieved with Management” Exec. Summary P7.

Simplifying this statement indicates that the hooded plover, if left to fend for itself in the natural environment, without man-made improvements, annoyances or ‘threats’, has a breeding rate of half of the rate than when they are nesting in community accessible sites in close proximity to high population densities and related activities.

This is both a paradoxical call to arms for Parks Victoria (look we can make a difference) and an artificial (unnatural) support of a bird population that clearly cannot breed effectively when left alone. naturally. This either must the ‘natural’ condition or recent climate or other ‘natural’ variation has made the current conditions unsuitable. This needs scientific comment and/or further research.

Management Given the increased ‘regulatory’ suggestions to tighten control on people-based activity in the very areas where the breeding rate is double that of ‘in the wild’, it seems that the Science actually suggests we should continue the current management regime and class the overall management framework as being sufficient and successful.

“..Warrnambool to Yambuk had an increase of 69% in the number of hooded plovers recorded (2011 study)” P18.

This increase within the monitored areas (not the inaccessible or remote) further supports the argument that additional regulation may not be required.

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

The current Parks management framework has recorded an increase in numbers in the face of the extensive list of human related ‘threats’. More recent declines in numbers may not be statistically significant. In order to class the population outcomes as successful or unsuccessful then there must be a clear Parks Victoria Belfast target for Hooded plover population within a specific time frame. It would be useful if the both target and the evidential support was made public. Given the natural low fecundity rates reported, then low may actually be the norm and additional ‘management’ unnecessary.

Natural Environment “The factors driving the presence of Hooded Plovers on the Victorian coast were: 98% Reef, 92% foredune and 89% dune” P27.

Since the reef is only affected by sea levels the statistic reinforces the observation that the destruction of the foredune through the misguided ‘stabilisation’ program has had a dramatic effect on a primary breeding site of the Hooded Plover, since the foredune’s have all but disappeared and the ‘flat’ beach is subject to inundation and wind action it is highly likely, that without intervention, the successful breeding rates will fall. Ignoring the past ‘conservation’ mistakes the report suggests that the rising sea-levels (perhaps this should read the subsiding beach levels due to Dune stabilisation) could be combated by:

“Raising seaward side nest sites on rocky berms with artificial platforms of tractor tyres and sandbags” P157

Which clearly does nothing to improve the environment (I am sure there are plenty of spare tyres to line the dune cliffs) or assist the reversion to the ‘natural’ environment that many conservation groups are trying to achieve.

Bird Numbers There are “2.9 birds (hooded plovers) per kilometre from Warrnambool to Portland” P31. and “There are 52 birds in the Belfast zone which is 9% of the total population and 12% of the parks managed population” P35.

It is worth considering the above bird densities of around 1 breeding pair per kilometre. Given that the fecundity is 50% less in non-managed areas it would make more economic sense to collect the birds and relocate them to a smaller area that is isolated and lends itself to more effective management and focused research. A special conservation and research zone that is not near population centres but has the primary factors required for breeding success.

The actual outcome appears to favour increasing the: allocation of rangers, restriction of tourists, blocking off kilometres of beaches to any access at all, putting tyres on the beach, building berms, removing marram grass for tens of kilometres, creating new regulations, issuing permits and generally causing community disruption and angst.

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

It should be noted that if the birds are nesting where there are all these human ‘threats’, then they may have selected their nesting sites based on ‘homing’ instinct (previous familiarity) or environmental preference, if this is so then we may be deliberately increasing nesting density in high traffic areas because that is where we like to ‘manage’, thus inadvertently creating an escalating non-productive community conflict.

Threats Many Tables in the document are misleading. The report focuses on human related ‘Threats’ as though they are the major threats to the Hooded Plover, it appears for convenience that most of the statistics exclude the actual major threats of sea, wind, foredune, gulls, ravens etc comprising around 85% of the total threat to the Hooded Plover (See Table 1 - Appendix 1) and, instead, simply include selected people related threats. As an example, the overall horse threat is measured at 0.77% of all threats (op cit), in Table 11, P76, Belfast Horses are noted as 17% and dogs off-lead as 19% of observed threats (ignoring natural threats). Compounding this confusion Table 13 P78 Belfast lists horses as 66% and dogs off-lead as 32% in terms of the ‘main threats’ (ignoring both natural events and general recreation). This type of presentation does nothing to assist in the understanding of the real threats to Hooded Plovers.

This (mis) use of statistics may cause the general reader to incorrectly conclude that horses are 66% of the total threat to Hooded Plovers in the Belfast region, an almost 100-fold exaggeration. In the cases of horses and dogs this type of presentation incorrectly focuses management attention on factors that will have little influence on breeding outcomes but are easier to regulate.

The report also appears to harbour a self-fulfilling prophesy, many of the observations in the report only occur where the beach is easily accessible and people are prevalent and thus, the measurements of threats and breeding successes are highly localised and may not be relevant to overall breeding rates. Particularly the ‘natural’ breeding rates. Additional Regulations In terms of the suggested horse related regulations to be applied by Parks Victoria, P.157:

1. Horse Permit required: Support. for large groups or events, not applicable for small numbers. 2. No access to Narrow beaches: Not Support. this varies markedly over the seasons and years and will result in an impossible to regulate context or extensive community disobedience if permanent bans are suggested. It should be left to community guidelines and be restricted for large groups or events. 3. No riding if over 35C or 49kph of wind: Not Support. No real science here. Not relevant and unnecessary. 4. Only at low tide and not within an hour of high tide: Not Support. Although the intent is understood, the tides are 6 hourly, many tides are high-lows and low-highs. The window of opportunity will in fact be one hour either side of the low tide hour, effectively 3 hours per day. This actual beach area available varies depending on surf conditions. Tide, wind and low/high pressure systems. This is not science based and not the basis for banning access. 5. Walking within 100m of fences: Support. given the beach is less than 100 metres wide then this is walking controlled by fences erected by the conservation groups. Will create difficulties but a reasonable guideline. Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

6. Riding on the water’s edge: Support. where possible this is the normal recreational horse riding strategy. 7. No riding in dunes: Not Support. On the basis it creates dune erosion? maybe this would actually be desirable in the foredune to remove the ‘stabilising’ marram grass. The track erosion is minimal and ensures access tracks in the dune system to support OHS. Not really supportable on existing tracks ie. from back dunes to access beach. Could be supported to restrict new tracks. 8. No dogs: Not Supported. Once again unenforceable and unnecessary, this is the largest non- natural threat but not large overall. Lot of community participation. On leash rules OK.

Summary On balance some lateral thinking is required to build Hooded Plover numbers, the community should be aware of the targets and the ways to assist. Given that non-natural management in a non-natural environment appears to give the Hooded Plovers the greatest chance of breeding success, then relocation to a highly managed small, restricted, but isolated area would be the most cost-effective solution.

Other solutions may have success but result in increased regulation and community exclusion.

If the restricted remote management strategy is not possible (because of logistical difficulties in management) then Recreational Horse groups and dogs on leashes should follow reasonable guidelines to minimise threat, with larger and commercial horse groups requiring a permit. Commercial horse riding permits should be subject to schedules and maximum numbers in terms of horse concurrency during beach access.

In summary: 1. Do add permits for commercial and large groups. 2. Do let recreational users continue as current with additional education and permanent signage. 3. Do not block existing dune tracks that provide access to the beach. 4. Do not promote stabilisation of the fore dune areas. 5. Do not ban controlled dog walking or rec horse use to any beach area between Warrnambool and Port Fairy. 6. Do consider relocation of birds in high use areas to more isolated locations with focused management.

Thanks for your consideration.

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Appendix 1 – Draft Coastal Management Plan Comments

Prepared in Jan 2018. Main ref: Comments on draft Belfast Coastal Reserve – Draft Coastal Management Plan – Jan 2018

Ref Page III

Native Flora and environment Although ‘enhancing the scenic beauty’ is one clear objective (but not a science based goal) of this plan, It is recognised that the current flora and environment are not original

yet the discourse is about preserving the ‘native vegetation’ and ‘priority habitats’.

Page vii

Threat The paper then draws the inference that the threat to the ‘native vegetation’ is ‘people, dogs and horses’ which need ‘controls’.

Page vii.

The conflation of dogs and horses incorrectly suggests that research provides evidence that they should be treated in a similar way because they have similar effects on the environment. This is not correct:

a. Uncontrolled dogs have the largest effect on nesting birds (4%) and general disruption as noted in the research (see Table below) b. Horses are never uncontrolled and have a minimal impact on nesting birds (research) (0.77%) c. Recreational horse numbers are small… perhaps averaging 2-4 horses at any one time, in groups of 2- 3 spread over 5-10 kms, mainly on weekends. Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

d. Commercial and local trainers are increasing and the catalyst of the report and should be the focus of the recommendations. Recreational riders should remain outside of controls except where people are affected ie. Killarney main beach in summer.

Table 1 - Managing the hooded plover in Victoria (2014) Parks Victoria

General Observations Horses 1. The theme of the Report continues with ‘horses’ affecting ‘dune health, Cultural heritage, public safety and disturbing birds’ P45. Only one element of which applies to riding on the beach (that is, disturbing birds). Using the research in the Table above, the greatest impact relates to storm surges and high tides (25%) followed by fox (7%), People (6%) and dogs (3%). Further down the list is recreational horses (0.8%). That is 99.2% of all hooded plover breeding failures are likely to have nothing to do with recreational horse riding. 2. In terms of horses and consequential erosion, there could be an argument made that horse trails in the back dune are more lasting, even if narrowly contained. There is no argument through evidence which supports the restriction of recreational horse riding on the most dynamic of coastal environments, the sea shore, beach and foredune. Conservation and mitigation 3. As an aside, the nature of the word conservation is to imply the preservation of ‘things’ as they are in a point in time eg. A building. This concept cannot be applied to the shore-dune ecosystem, it is clearly dynamic and not subject to conservation in any real sense. Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

4. The research offered within the report supports this view, that the beach-dune ecosystem is ‘Dynamic and resilient’, and that the impact of the ocean will increase as sea level rises. Despite this, the statement that we should increase resources and controls to protect the ‘fragile coastal dune system’ is made even though it is at odds with the Science. 5. We will have great difficulty applying conservation concepts to a ‘dynamic and resilient’ natural system. We cannot continue to talk about controlling dune and beach erosion when that is the natural condition of a dynamic ecosystem. 6. The draft talks about ‘mitigating the effects of storm surges’ by stabilising the dunes P.41, repeating the errors of the past and knowingly generating dune ‘cliffs’ through ‘stabilisation’. This actually prevents the natural movement of the sand dunes thus limiting the growth of shore bird habitat for breeding (the fore dune is the preferred nesting habitat for the hooded plover, not the flat beach). Status-quo and history 7. In terms of conserving the status quo, or bringing the environment back to some past imagined wilderness (perhaps, it should be noted that the sea level has been rising since the last ice age, 40,000 years ago). The first Australians claim occupation during the same period indicating that most of the evidence would be under water, and it is likely with global warming that the areas under consideration will also disappear within 50 years. Yet the substantive conclusion is that recreational horse riding is a: ‘risk to middens’, manure should be removed (surely only in the parking areas), hoof prints filled in (not worth a real comment) and horses should stop disturbing birds. Risks classes 8. The ‘risk chart’ combines recreational horses and uncontrolled dogs as though they have the same effect, both labelled as ‘extreme’. This is not evidence based and not supported by the research. The effect of the ocean/wind is ‘extreme’ everything else is relatively minor (including dogs). The dynamic environment 9. Despite noting the ‘dynamic nature of the dune system’, the paradoxical efforts to ‘stabilise and conserve’ is focused on ‘eroded dunes’ surely the natural outcome of dynamism. 10. The use of phrases like ‘prevent erosion’ and ‘natural regeneration’ is really code for plant spinifex grass instead of marram grass, both to bring back the native vegetation (unnaturally) and to unmercifully (for the shore birds) stabilise the dunes and create a vertical retreat in the face of the ocean rather than the natural slope of the fore dune, the preferred habitat of the hooded plover. 11. The conflict embedded in this proposal is actual a war on nature and refers to ’rising sea levels… higher storm surges’ P40 with estimated retreat of the beach in the last 150 years of 0.1-0.3 metres per year (more in the next 150 years) either way that suggests a retreat of 15-45 metres, wider than the current beach in many places. Again, planting spinifex grass, picking up manure and preventing hoof prints, is unlikely to have the desired effect. Community Recreation 12. Re-interating the statement that dogs are the ‘biggest threats off the leash’ to plovers and shore birds, but unfortunately the owners of the same are the largest user community group and most difficult to control. Recreational riders are more obvious, a smaller group (almost sparse) and easy to control but with minimal comparative impact. It appears rec riders (and Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

local trainers) have been lumped with dogs and large commercial racing to appear ‘even handed’ rather than having any real evidence base. 13. The suggestion that there is a competition between ‘people, vehicles, dogs and horses’ P46 simply ignores that fact that these are all people pressures and it is a question of scale. 14. The case study P50 contained in the report does link the restriction of un-controlled dogs to the improved breeding success of plovers, no such study can make the same claim for controlled horses. 15. Attributing ‘one of the most significant impacts – disturbance of shore birds’ to recreational horses has no evidence base and it is an incorrect extension of the uncontrolled dog cohort to horses. Regulation and consequences 16. The report notes that erosion has been caused on the high dune by the surfers looking at the surf at carpark 2 in the cutting P59, and thus the proposed action will be to remove and level the mid-dune to create a viewing platform. There is little evidence that surfers caused any erosion and it should be noted that the ‘top of the dune’ location is the favourite site for the coast care members monitoring horse activity. The report continues to draw the incorrect conclusion that loss of marram grass is somehow detrimental to the dynamic dune system. 17. Lastly, leaving open the concept ‘closing the beach’ to all horse activity when the conditions demand pre-supposes that a select group will make the call and the hooded plover will benefit (both of which pre-suppose we know both the cause and the outcome of hooded plover success or failure). This may ultimately create even more dissention and avoidance of the ‘controls’. Summary In summary recreational horse riders should be permitted to use the beach in small groups (as they have historically done for a period much longer than local horse trainers), large groups (more than 4 and less than 20) of recreational riders should require a permit and belong to an association, such as ATHRA, at least an association that has acceptable insurance, environmental and behavioural codes and a certification process for organisers.

Jan 2018.

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

29 March 2018

Manager, Park Planning Parks Victoria Level 10, 535 Bourke Street Melbourne BY EMAIL [email protected]

Dear Sir/Madam,

BELFAST COASTAL RESERVE DRAFT COASTAL MANAGEMENT PLAN

Warrnambool City Council welcomes the opportunity to provide the following feedback to the draft Belfast Coastal Reserve Coastal Management Plan (January 2018). The plan was considered at Councils Ordinary Meeting of 5 March 2018; please find enclosed copy of the Meeting Minutes. Council resolved:

1. That Council provide in-principal support to the proposed management directions for the Belfast Coastal Reserve Draft Management Plan; and 2. That a submission be prepared and lodged with the Department of Environment, Land, Water and Planning prior to the closing date of 16 March 2018; and 3. That the State Government provides a report that gives a response to all of the issues that were raised in the consultation so that the community understands the decision making process.

Council understands the Belfast Coastal Reserve Draft Management Plan outlines proposed management directions for the Reserve over a 15 year time-frame that seeks to find a balance between the environmental, cultural, social and economic values of the reserve and the variety of user groups. The Coastal Management Plan also identifies associated challenges and risks and provides strategies and actions for management.

The Belfast Coastal Reserve is currently under an array of management arrangements which would benefit from strategic and coordinated direction for the future management of the Reserve.

The area that relates to Warrnambool City Council extends along the coast from Levy’s Beach to the City’s western most municipal boundary with Moyne Shire Council. Warrnambool City Council is currently the delegated land manager for an area in the subject Reserve totalling approximately 176 hectares, approximately 8% of the Reserve’s total planning area of approximately 2,260 hectares. This may be a relatively small percentage however there are significant and complex land management recommendations within this area.

The land management strategies outlined in the plan will require a significant capital investment and ongoing recurrent expenditure to ensure that the objectives of the plan can be meet. Council requests that the report make clear who is expected to fund the initial Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

capital uplift and where the ongoing recurrent resource capacity will be funded from. Warrnambool City Council needs to make it very clear that it does not intend nor does it have the financial capacity to fund or implement any of the activities for which it has been identified as either the responsible authority or as a delivery partner. On this basis we ask that the state government very clearly articulate in the plan the proposed funding model that will support each agencies responsibilities.

There is opportunity for the draft Belfast Coastal Reserve Coastal Management Plan to be aligned with the Guidelines for the Preparation of Coastal Management Plans (DELWP, September 2017). An overall observation of the draft plan is in regards to consolidating the detail to ensure the plan is succinct and clear to all readers; in particular the vision should be concise and provide a clear vision for the Belfast Coastal Reserve.

The proposed management directions of the Belfast Coastal Reserve Draft Management Plan are considered to have brought together and acknowledged the relationship that Traditional owners have with the area, various agencies, user groups, activities and environmental features of the reserve and provides a framework that enables a balanced management approach. However Council requests a report on the submissions received to the draft plan and how any revised Coastal Management Plan responds to submissions and community consultation.

Having regard to the above requests for alteration, Council provides in-principle support to the proposed management directions for the Belfast Coastal Reserve Draft Management Plan.

If you have any queries on Council's submission, please contact

Yours sincerely Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Wednesday, 14 March 2018

Manager Parks Planning Parks Victoria Level 10, 535 Bourke St Melbourne VIC 3000

To whom it may concern,

Re: Warrnambool Beach Training Support Submission

As a part owner of a horse trained in Warmambool, I support the continuation of horse training on the beaches in the region. This is primarily due to the opportunity that beach training presents, as well as the relaxed country environment in the Warrnambool district.

The success of Prince of Penzance in the Melbourne Cup is testimony to the benefits of beach training.

I see many tourists who enjoy the opportunity to see horses training on the beach, with a flow on financial benefit to the area.

If beach training was not available, the opportunities for these horses would become limited, and potentially they would retire from racing altogether. This would have a negative impact on the local horse trainers - horse numbers would decrease as well as taking away the opportunity for any financial return to continue to fund future horses to be trained in the region .

The opportunity to train norses on Levy's Beach and the dunes is critical for the ongoing success of horse training in Warrnambool, of which I am fully supportive.

Regards, Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

BELFAST COASTAL RESERVE DRAFT COASTAL MANAGEMENT PLAN, JANUARY 2018

Personal submission from:

While I support the bulk of the plan - limiting areas for dogs, horses, motorcycles, off-road driving, duck shooting and the declaration of a Conservation Zone, I cannot agree with any recommendation which allows racehorse training in the Reserve, particularly at Rutledge's Cutting in the so-called CONSERVATION zone. I believe the regulations should be made even tighter than those in the Draft Plan - no racehorse training and severely limited areas for recreational riding and on-leash dogs (not off-leash and definitely not in the Conservation Zone.)

The Belfast Coastal Reserve provides habitat for several species of threatened birds, such as orange-bellied parrot, hooded plover and Australasian bittern. Populations of migratory shorebirds (sanderlings, sandpipers, double-banded plovers and ruddy turnstones) also use the Reserve. It is a declared site of national and international significance for some of these birds. In other coastal areas authorities are tightening regulations to preserve the habitat for these threatened species. Why should Belfast Coastal Reserve be different?

Racing is an industry and while it does bring some wealth to the local economy, it is no match for the year-round tourist trade, which could expand even further if the area's natural attractions were highlighted. There are many other local industries of greater economic value that employ people year-round, but we do not let them set up business on the beach or in other environmentally sensitive areas and we cannot justify allowing this one industry to threaten the survival of already endangered species in one of the few areas of natural landscape left in this district. Gundijmarra people are against racehorse training in the Reserve due to the risk of damage to Aboriginal cultural heritage. The recommendations on race-horse training in the Draft Management Plan contradict the "vision for the Reserve as providing a 'wild feel', a place to appreciate and connect to nature" (p.47). They also seem to contradict one of its key management outcomes for natural values as listed on p.27 - i.e. "the protection of vulnerable fauna such as Hooded Plover will require reducing threats to these species through controls on the key impacting activities of dogs, horses and people."

Section 6: I strongly support the provision of extra information and interpretation signage to explain to visitors and locals just how special this areas is, though I fail to see how we can achieve the goal "Visitors appreciate, understand and care for the values of the Belfast Coastal Reserve" (p.67) while we allow racehorses to be thundering past them on our beaches.

Section 7: I strongly support coordinated management of the Reserve - preferably for the reserve to be managed as a whole by one authority, with input from stakeholders (municipal government, recreation organisations, conservation groups, indigenous communities), rather than the fragmented management as at present. I would support the Reserve being declared a National Park.

Section 8: I strongly support on-going research and monitoring.

Unless there is a substantial government investment in extra rangers and maintenance staff I do not see how these recommendations and those on weed and vermin control, and the effective policing of restrictions of racehorses, recreational horseriding, off-road vehicles, on- and off-leash dogs can be effectively carried out. Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Manager Parks Planning Parks Victoria Level 10, 535 Bourke St Melbourne VIC 3000

To whom it may concern,

Re: Warrnambool Beach Training Support Submission

As a current member of the Victorian Racing Industry, this letter is written to provide mine and the Club’s support for the continuation of Beach training in Warrnambool, particularly at Levy’s Beach and Hoon Hill.

I am a proud participant of what is a $2.8 billion industry in this State and of the fact that training on the beaches along the Belfast Costal Reserve, and Lady Bay, provides significant positive economic benefits to the South West community.

The flow on effect of restricting horse access on the beaches is significant to our industry. Restricting access to beaches will result in a large number of training operations relocating, potentially interstate, essentially diminishing the number of trainers in the region. The flow on effect of this is significant. This will see a huge impact on the economic benefit racing brings to the region, including the lucrative May Carnival. The May Warrnambool Carnival alone delivers over $90 million in economic benefit to the region every year. The thoroughbred industry, including the Warrnambool Racing Club employs hundreds of local residents, who would ultimately be out of work if the industry was to be this significantly affected. The flow on effect is also significant to industry suppliers, Veterinary, farriers and alike also likely to suffer from a reduction in the Warrnambool region.

By having the sand and salt water available to a large number of horses trained in the area it also reduces the impact on our grass training tracks across the state and reduces the risk of injury through better track management. Having beach access is a major rehabilitation tool for trainers and ultimately provides the thoroughbred with an alternative method of training than the effects training on a track may have (reduces concussion).

What we have is unique and something our community is proud of, as a result I am fully supportive of the continuation of horse training on our local beaches.

Regards,

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Werribee Racing Club

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Manager Parks Planning Parks Victoria Level 10, 535 Bourke St Melbourne VIC 3000

To whom it may concern,

Re: Warrnambool Beach Training Support Submission

As a current member of the Warrnambool Racing Club, this letter is written to provide my support to the continuation of Beach training in Warrnambool, the Belfast Coastal Reserve, Killarney Beach and along the East Beach Port Fairy.

We are extremely fortunate to have the beaches that provide this unique horse training opportunity, which indeed provides significant positive economic, social and recreational benefits to our local community, and employs many passionate and very skilled people.

I’ve enjoyed using the East Beach from Port Fairy to Mills Reef for walking, swimming and surfing. During that time I’ve shared the area with racehorses and recreational horses without any detrimental impact. In fact along with the vast majority of people I’ve enjoyed the experience of the presence of the horses in this environment.

Through this involvement I’m acutely aware of the importance of beach access for the racehorses so that owners have confidence to continue to own horses trained in the area which then supports the sustainability of employment and enormous economic benefit the racing industry contributes to the local community.

What we have is unique and something our community is proud of which has existed for many many years, in fact decades. As a result I am fully supportive of the continuation of horse training on our local beaches.

Yours sincerely,

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Tuesday, 13 March 2018

Manager Parks Planning Parks Victoria Level 10, 535 Bourke St Melbourne VIC 3000

To whom it may concern,

Re: Warrnambool Beach Training Support Submission

I. A critical part of that training is conducted regularly on Levy's Beach to ensure the ongoing health, development and strength of our horse.

are also a small part in contributing to the overall success and health of the racing industry itself as well as its many supporting industries.

As an owner of a horse trained in Warmambool, the opportunities beach training presents as well as the relaxed country environment the district has to offer is the key reason why I will continue to support the continuation of horse training in the region.

The opportunity to train horses on Levy's Beach and the dunes is critical for the ongoing success of horse training in Warrnambool which I am fully supportive of.

Regards, Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

The Manager

Parks Planning

Parks Victoria 1st March 2018

Level 10, 535 Bourke Street

Melbourne, Vic. 3000

Dear Sir/Madam, Re: Belfast Coastal Reserve.

This is our submission in response to the Draft Management Plan, dated January, 2018.

We support the need for a ‘Belfast Coastal Management Plan’ and submit that the entire ‘Belfast Coastal Reserve’ be a ‘Conservation and Recreation Zone’ with no area dedicated only as a ‘Conservation Zone’. We have detailed our guidelines for use of this ‘Conservation and Recreation Zone’ at the end of this submission.

Page (v) of the Draft Plan states that the ‘The Belfast Coastal Reserve protects a narrow section of land backed by flat open farmland, creating a sense of remoteness from nearby Warrnambool and Port Fairy’. This is inaccurate, incomplete and misleading. The Belfast Coastal Reserve also directly backs onto the Towilla Way residential estate and the Draft Management Plan makes no reference to this, nor does § 6.4 (page 59) of the Draft Plan define if the Towilla Way beach access path is, or is not, a ‘secondary’ path that will be ‘rationalised’.

Towilla Way Landowners have a Section 173 Agreement with the Moyne Shire Council to ensure ‘Pedestrian access to the Beach’. Moyne Shire acknowledges their obligations under this section 173 agreement in a written response to resident’s questions in February 2018. The Belfast Coastal Reserve Management Plan should specifically enshrine the Towilla Way beach access path for pedestrian access and ensure that it is maintained as a safe pedestrian passage to the beach and that it meets fire and vermin prevention standards.

We regret that Parks Victoria have not taken the opportunity to clarify this issue of Towilla Way pedestrian beach access during the ‘consultation’ period. We approached the Parks Victoria Officer, , at the advertised meeting at Sackville Street, Port Fairy, and we have written to, and emailed, the Manager, Parks Planning, at Parks Victoria. Despite these requests we have not received written confirmation that Parks Victoria will not attempt to close the Towilla Way pedestrian beach access path.

As Parks Victoria is the responsible authority, we submit that Parks Victoria undertake as part of the Belfast Coastal Management Plan, and in co-operation with adjoining land owners, an effective rabbit and fox eradication program from the dunes. The current explosion in the rabbit population is causing Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

erosion in the dunes and adjoining properties and is providing food for the foxes which are destroying Hooded Plover and wading bird populations within the Belfast Coastal Reserve.

We highly value the sense of remoteness of the Armstrong Bay beaches and expect that an effective Belfast Coastal Management Plan will maintain this special quality. However we submit that the Area marked in dark green as ‘Conservation Zone’ in ‘Map 3 Access and Visitor Facilities’ of the Draft Coastal Management Plan should be rezoned as a ‘Conservation and Recreation Zone’.

We submit that within this extended ‘Conservation and Recreation Zone’ the following restrictions should be defined, displayed and enforced on dog, horse and vehicular access and that our other recommendations below also be added to the Belfast Coastal Management Plan.

Summary of requested inclusions in the Belfast Coastal Reserve Management Plan. 1. Continued pedestrian beach access from Towilla Way. 2. Ongoing maintenance of the Towilla Way beach access path by Parks Victoria. 3. Effective vermin control of rabbits and foxes in the sand dunes by Parks Victoria. 4. Effective signs and penalties be displayed at all beach access points. 5. The ‘Conservation Zone’ in ‘Map 3, Access and Visitor Facilities’ the Draft Coastal Management Plan should be rezoned as a ‘Conservation and Recreation Zone’. 6. Access for dogs on leashes be allowed throughout the Belfast Coastal Reserve. 7. No dogs be allowed off leashes anywhere within the Belfast Coastal Reserve. 8. No race horse training be allowed anywhere within the Belfast Coastal Reserve. 9. Recreational horses may only be ridden at walking pace, in groups of 4 or less below the high water mark with beach access limited to Gorman’s Lane, the Basin, Spookies and Golfies. 10. Unauthorised access of dogs, horses and all vehicles be effectively policed. 11. A consultative committee comprising residents, other interested parties, Moyne Shire and Parks Victoria be established to monitor the effectiveness of the Belfast Coastal Management Plan. The consultative committee meetings should be open to the public as observers and the committee will openly report annually to the responsible minister and the public on agreed key performance indicators. 12. Vehicle management structures be put in place at the Basin to effectively prevent vehicles and motor bikes driving East along the beach at both high and low tide. 13. The Management Plan acknowledges dune erosion by wave action and incorporates plans to minimise the impact of wave erosion on the Belfast Coastal Reserve. 14. The Belfast Coastal Management Plan ensures that Parks Victoria will use its best endeavours to protect the migratory beach wading birds within the Coastal Reserve, whilst allowing the defined, and controlled, recreational activities listed above.

We trust this submission will be carefully considered and taken into account before the final Belfast Coastal Management Plan is presented to the responsible Minister.

Yours Faithfully

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Tuesday, 13 March 2018

Manager Parks Planning Parks Victoria Level 10, 535 Bourke St Melbourne VIC 3000

To whom it may concern,

Re: Warrnambool Beach Training Support Submission

Our horse has benefited enormously from being able to train on occasions at the beach

The opportunity to train horses on Levy's Beach and the dunes is critical for the ongoing success of horse training in Warrnambool which I am fully supportive of.

Reaards. Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

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Manager Parks Planning Parks Victoria Level 10, 535 Bourke St Melbourne VIC 3000

To whom it may concern,

Re: Warrnambool Beach Training Support Submission

I base my decision to have them trained out of Warrnambool 100% on the use of the beach The horses have a longer racing life, and much less injuries If this access to the beach in question is no longer available, I would definitely relocate my horses

Please do not take your decision lightly, keep in mind when my horses are running at Warrnambool, Think about the on flow affect to Warrnambool and all the people who are employed in the racing game also

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

18 February 2018

Manager Parks Planning, Parks Victoria Level10, 535 Bourke Street Melbourne Vic 3000

Re: Belfast Coastal Plan.

To whom it may concern,

I write on behalf of with land holdings fronting t he coasta l reserve at Tower Hill. We have all utilized the beach at Rutledge's cutting and the Basin for many years to exercise our horses in a respectful manner.

We note that we are privy to a submission by SWOTRA for the proposed use of Rutledge's Cutting by a limited numbers of small trainers which we are in agreeance with however we believe we have further claims than those based away from Rutledge's Cutting and that the final plan should reflect this.

. we request minimal use of the beach at Rutledge's Cutting and the Basin (maximum of 2 horses per day per trainer) on a year round basis. This would equate to a maximum of 8 horses per day however given our normal activity would be less than this. The beach is absolutely essential to us from 1 April t hrough to 30 October Having access to bo·th beaches would allow us to spread our use minimizing any impact upon the environment. We also request beach use from first light to last light allowing us to keep a healthy distance from nesting birds by utilizing low tides.

we also request access from the Gorman's Road car park as the ride to t he Rutledge Cutting car park is along the road verge and close to traffic.

We are aware of the Hooded Plovers nesting habits and agree to ride at the water's edge and to walk past any fenced nesting areas. Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

We note that we have a long history of successful co-existence with the limited number of other beach users.

Yours sincerely Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

From: Sent: Wednesday, 14 March 2018 3:59 PM To: ParkPlanMailbox Cc: Subject: Beach training support

Categories: Red Category

To the manager parks and planning, Parks Victoria.

I am writing as an owner of horses that are currently trained in the Warrnambool area . The ongoing success of the training facilities in this region are strongly linked to the ability for the trainers to use the beach. have wonderful memories of watching the horses on the beach In the early hours. Warrnambool is a country region and unfortunately country areas are consistently losing a lot of business to larger metropolitan areas. If horses were not permitted to use the beach in this region I believe a lot of training facilities would close. Warrnambool has always been synonymous with horse racing and has a strong tradition which includes the training of thoroughbreds on the beach in the dunes. Having the ability to train horses on the dunes at Levy’s beach is vital for the success of horse training in this country region. It saddens me that the voice of a few can be louder than the thoughts of the majority. Yours truly,

Sent from my iPhone Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Manager Parks Planning Parks Victoria Level 10, 535 Bourke St Melbourne VIC 3000

To whom it may concern,

Re: Warrnambool Beach Training Support Submission

I have seen first-hand what benefits can be gained from training them in soft sand and walking and swimming them in a protected bay area!

The horse had bad knees and would break down whilst in training with normal trackwork.

and still loving training and racing in the dunes and at the beach, always eager to get on the float

What a great atmosphere/community to involved with !

A big part of our continued support within the industry relies on what we see as an ideal way to train horses in a setting that is beneficial to the horse and local community.

The opportunity to train horses on Levy’s Beach and the dunes is critical for the ongoing success of horse training in Warrnambool which I am fully supportive of.

Regards and yours sincerely,

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Friday, 9 March 2018

Manager Parks Planning Parks Victoria Level 10, 535 Bourke St Melbourne VIC 3000

To whom it may concern,

Re: Warrnambool Beach Training Support Submission

Beach training not only provides therapeutic effects from the water but also aids rehabilitation and recovery for joint and soft tissue problems that horses may have. If this opportunity was not available, the opportunities for many horses would become limited, thus there would be potential for them to retire from racing all together. This would have a huge effect on the local horse trainers; horse numbers would decrease as well as taking away the opportunity for any return to continue to fund future horses to be trained in the region.

The opportunity to train horses on Levy’s Beach and the dunes is critical for the ongoing success of horse training in Warrnambool, which I am fully supportive of.

Yours sincerely,

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Manager Parks Planning Parks Victoria Level 10, 535 Bourke St Melbourne VIC 3000

To whom it may concern,

Re: Warrnambool Beach Training Support Submission

The opportunity to train horses on Levy’s Beach and the dunes is critical for the ongoing success of horse training in Warrnambool which I am fully supportive of.

Regards,

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Manager Parks Planning Parks Victoria Level 10, 535 Bourke St Melbourne VIC 3000

To whom it may concern,

Re: Warrnambool Beach Training Support Submission

This would never have been possible if not for the facilities of the Warrnambool Beach, he may very well been retired and lost to the racing game.

The opportunity to train horses on Levy’s Beach and the dunes is critical for the ongoing success of horse training in Warrnambool which I am fully supportive of.

Regards,

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

~ Surfrider Foundation Surf Coast Branch SURFRIDER Torquay, Vic. 3228 FOUNDATION [email protected] SURF COAST BRANCH

1 20 h March, 2018

The Manager, Park Planning, Parks Victoria, LevellO, 535 Bourke Street Melbourne, VIC 3000,

By Email: [email protected]

Belfast Coastal Reserve Management Plan Surfrider Foundation Surf Coast Branch Submission

On behalf of our members and supporters we make the following submission. Whilst we are not based in close proximity to the Belfast Coastal Reserve (the Reserve), we have an active interest in coastal management across Victoria. Many of our members visit the area and we were asked by concerned locals to examine the proposed draft Plan and provide input to ensure the proper management of the Reserve.

Our primary concern is the survival of the threatened Hooded Plover and other vulnerable species that use these beaches, noting that t he Belfast Coastal Reserve has the highest density of Hooded Plover nesting pairs in Victoria. We are also concerned about access to the beaches and amenity of surfers and beach lovers being affected by the use by the commercial race horse trainers and other recreational activities such as illegal trail bikes and Four Wheel Drives.

We comment as follows.

1. General

As stated in the Plan, the majority of public land in the Reserve was set aside for protection of the coastline, to be managed for conservation, education and compatible recreation. We support much of what the Plan aims to achieve in order to achieve these objectives. However, commercial activities, in particular horse training, clearly do not fit within those purposes.

We note the strong support in the previous stage of the consultation for horse training to be banned and believe that needs to be better reflected in the final plan.

The draft Plan lists many threatened, endangered or vulnerable species as occurring in the area. We believe that allowing race horses to train in such an area is entirely inconsistent with the conservation purposes ofthe Reserve and reflects a double standard. The threats from horses is mentioned repeatedly throughout the document butt he plan seems to go out of its way not only to accommodate them, but to extend the area of reserve they are able to utilise.

We don't have an issue with the original recreational training that was happening before the commercial racehorse trainers arrived in recent years, but allowing a special interest group to train there, at odds with the aims of the Reserve does not appear to be sound management.

Surfider Foundation Suri Coast Branch March 2018 Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Horses are not an animal endemic to our beaches, and have been shown to have serious impacts on soils and vegetation. Racehorses in particular are part of an industry created by a special interest group and should be trained on tracks created for/by that group. We understand there are training facilities at the Warrnambool Racing Club constructed recently at great expense to taxpayers. That is where horses should be trained if they require resistance t raining.

Restricting horses to the water's edge and a particular time of t he days might sound like a condition that protects shore nesting birds but at high tide, (which occurs at a different time each day), during spring tides and large seas, the water's edge will be at the back of the beach at the base of the dunes where the birds are nesting. Hooded Plovers feed at the water's edge so it is simply inevitable that the two activities will be in conflict. Newly hatched Hooded Plover chicks have to find feed for themselves and this can occur at the water's edge. As the draft Plan states, chicks can become trapped in hoof prints in the sand which can be quite deep.

2. Planning Issues

The Coastal Management Act 1995 requires that a Coastal Management Plan be consistent with and give effect to the Victorian Coastal Strategy (VCS). any relevant Coastal Action Plan and any relevant coastal recommendation. It is therefore concerning that the draft Plan proposes racehorse training activities which appear wholly inconsistent with these statutory documents.

For example, the Warrnambool Coastal Action Plan 1999 has a number of objectives that appear to not be reflected by commercial horse training within its area of management, as follows: 1. To conserve natural and historic features of local, regional and national significance. The high number of Hooded Plovers at risk in this Reserve make it a National issue under the EPBC Act.

2. To enhance the quality of life for local residents. Safety and amenity concerns will impact upon residents and visitors.

3. The community's enjoyment of the natural resources of the coast will not be compromised by the planning of the city. Part 5.2.1 To protect environmental values. Recommendation No.4 Designate a Hooded Plover Protection Zone operational during the breeding season from August to March. Dog's access to beach areas in the zone is prohibited during breeding season. Since this CAP has been written, the incidence of horses on the beaches has risen sharply and we suggest that horses should also be excluded from the above mentioned protection zone.

Part 5. 7.2. To ensure sites of indigenous cultural significance are identified and appropriately protected. There are aboriginal middens and other culturally significant sites located in the dunes.

Part 5. 7. 6. To provide for animal exercise areas on the beach that do not impact on the amenity of the area for non-animal owners. This objective should not be limited to impacts on people but to other species that use the BCR.

We are similarly concerned with glaring inconsistencies between this activity and the intent of the VCS, Western Regional Coastal Plan and the originallCC recommendations on which the reserve purposes are based.

The beaches within the BCR are covered by an Environmental Significance Overlay in both the Moyne Shire and Warrnambool City Planning Schemes, though different provisions apply in each. The Moyne Shire Council provisions are the stronger of the two as follows: • Environmental Objective To Be Achieved: "To protect and enhance flora and fauna habitat of the coast.... " and • "To protect and enhance the stability and environmental quality ofsand dunes...... " and • "To encourage development including infrastructure to locate away from the sea...... ".

2 Surfider Foundation Surf Coast Branch March 2018 Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

• Decision Guidelines: " ..... consider as appropriate: The availability of alternative land suitable jar the proposed development away from the coast...... " and • "Potential threats to the quality, life cycle processes or functioning ofaquatic and terrestrial ecosystems or native plant and animal species" and • "Whether the proposal protects and avoids the loss of indigenous native vegetation particularly sensitive coastal and foreshore vegetation, in particular heath-lands, dune vegetation, saltmarshes and sedges from clearing, pollution, grazing and trampling" and • 'the need for an agreement or a covenant on title to protect significant habitat and whether this should be a condition of any permit" and • "...... the intent of minimising any visual impact, including views from the water or ocean".

All of the above objectives and statements of intent are manifestly at odds with the commercial training of racehorses on the beaches. While we would prefer no horses on beaches, we are able to support a compromise of very low-key and small-scale responsible recreational horse training similar to what has occurred on some beaches for a long time. However, with commercial training proposed to occur on such a scale, how would the average beach user know the difference between the two? We believe all horse training on BCR beaches and within the dunes should be banned as discussed below.

3. Management Zones

At present the plan allows 'historical horse training' in the Conservation Zone at Rutledges Cutting. This appears to be a double standard and we believe this should be removed.

You are aware that Hooded Plovers nest in both the Conservation Zone and the Conservation and Recreation Zone, (refer image below). We support the banning of horses in the Conservat ion Area but we believe the whole Reserve needs to be a Hooded Plover Sanctuary between the start of nesting until when chicks have fledged. At all other times adopt the current plan except for the historic site at Rutledge's Cutting which should be removed.

J ..

Image 1: Nesting Hooded Plover at Golfies Beach (within the Conservation & Recreation Zone) 2nd Jan 2017

We are supportive of the measures to restrict dogs from the Conservation Zone and to have dogs on leash in the Conservation and Recreation Zone. The presence of dogs and how they are controlled by their owners needs to be monitored during the nesting season.

3 Surfider Foundation Surf Coast Branch March 2018 Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

4. Safety

We have concerns about safety of the public when multiple horses are galloping along the beaches at the same time as they are being used by surfers, walkers, fishers, swimmers, sun bakers and other beach lovers. If commercial horse training proceeds permanently, we are concerned with regard to occupational health and safety issues where beaches and dunes might be considered places of work. It might raises issues of who would be liable should a member of the public be injured as a result of race horse training activities.

Will it be practical for trainers to have to keep slowing their horses down every time they are required to observe the 20m distance from other users of the beach, not to mention critically endangered birdl ife? How far up the beach will horses encroach at high tide when passing each other between the water and high water mark? Who will realistically enforce these things?

It should be noted t hat the City of Onkaparinga (south of Adelaide) say that a safe speed is walking pace within SO metres of other beach users http://www.onkaparingacity.com/custom/files/docs/horses on beaches. pdf

5. Licenses

We were very disappointed with the reactive decision for licenses to be issued during the consultation phase before the management plan was finalised. In our opinion, once the licenses exist the chance of removing the horse trainers is reduced.

We are very concerned at the Minister's Order enabling the creation of licences in November 2016. This order implies that there are "special conditions" making the granting of licences reasonable and appropriate. We are unable to find any such special reasons in this draft Plan or provided as part of the issuing of t hat Order.

We are not supportive of industry self-regulation as proposed and have no confidence that regu lations will be adhered to or any enforcement action taken. There have been many breaches since the temporary licenses were granted. We have observed on 2"d January 2017 trainers clearly violating the intent of the licences by training at The Cutting (refer image below).

Image 2: Illegal horse training at Rutledges Cutting. z nd Jan 2017

The licenses fee does not appear to have any commercial basis, nor does it appear to reflect the ongoing impact of the activity on the reserve. It does not appear sufficient to support proper monitoring or compliance activities. If the cost was substantially higher than using the tracks at the Warrnambool Racing Club it would take pressure off the BCR.

4 Surfider Foundation Surf Coast Branch March 2018 Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Mills Reef (Golfies) has quite a small carpark. With the current license arrangement, it is proving difficult for the everyday users to access the carpark when the special interest group horse trainers are also using it. We note that surfers often seek to access beaches in the morning when winds are more likely to blow offshore and create favourable conditions.

6. Monitoring Despite the recognition of the impact of horses and other recreational activity in the reserve, we are unable to see clear monitoring, reporting or evaluation arrangements for these activities. We believe that these activities require rigorous and independent scrutiny.

We hope that the wishes of the community will be acted upon with revision of the plan to better reflect the original intent of the Belfast Coastal Reserve and remove key areas of conflict. Thank you for the opportunity to provide input into this plan.

Yours sincerely,

The Committee Surfrider Foundation Surf Coast Branch

Protection of Australia's waves and beaches through Conservation, Activism, Research and Education or C.A.R.E. For more information about Surfrider Foundation Surf Coast Branch please go to: https:/ /www. facebook. com/Su rfrid erFounda tionSu rfCoa st For more information about Surfrider Foundation Australia please go to: http://www.surfrider.org.au

5 Surfider Foundation Surf Coast Branch March 2018 Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Submission for Draft Belfast Coastal Reserve Management Plan About you:

Your name: ______

Your Organisation (if relevant): ______

Postcode: 3280______

Email or Postal address:

THIS SUBMISSION IS: □ CONFIDENTIAL □ NOT CONFIDENTIAL Date: March 12 2018

Your Comments: Please Note – The following information will be made publically available. Main reason for interest: Local resident and environmental interest.

How often do you or your organisation use the reserve? □ Daily □ Weekly □ Monthly □ A couple of times a year □ Rarely □ Never

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

About the vision- Belfast Coastal Reserve, 15 years from now…:

How supportive are you of the vision for the Belfast Coastal Reserve? □ Very supportive □ Supportive □ Not sure/Don’t know □ Unsupportive □ Very supportive

Key management theme #1: Cultural landscape and living heritage

How supportive are you of the strategies for ‘Cultural landscape and living heritage’ included in the draft management plan?

□ Very supportive □ Supportive □ Not sure/Don’t know □ Unsupportive □ Very supportive

Key management theme #2: Healthy Country

How supportive are you of the strategies for ‘Healthy Country’ included in the draft management plan?

□ Very supportive □ Supportive □ Not sure/Don’t know □ Unsupportive □ Very supportive

Key management theme #3: Recreation and use

How supportive are you of the strategies for ‘Recreation and use’ included in the draft management plan?

□ Very supportive □ Supportive □ Not sure/Don’t know □ Unsupportive □ Very supportive

My comments are in accord with those of BirdLife Australia and the Victorian National Parks Association.

I am highly supportive of the Draft Management’s approach to set aside the highest value section of the Reserve as a Conservation Zone, with a focus on protecting the habitat values and minimising disturbance to breeding birds and roosting and foraging migratory shorebirds.

I do not support commercial horse training in the reserve. This proposal compromises the critical environmental requirements for this area in the interests of economic gain. There are extreme risks to threatened species, habitat, cultural heritage sites, and public safety. Under the plan, commercial racehorse training would rapidly expand to multiple beaches and in sand dunes, with devastating effects for the nationally threatened hooded plovers—the reserve is its most important breeding area in the state according to the plan— and other coastal wildlife as well the safety and enjoyment of families, anglers, surfers and other beachgoers. The stretch of beaches available to racehorse training would, under the plan, be increased by 250% (from 2 km to 5 km) Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

and the number of horses by 400% (from 65 to 256 each day). That represents 25% of the reserve’s beaches, with nothing in the plan to stop future expansion.

The draft plan would allow racehorses back into 750 metres of fragile dunes behind Levy’s Beach and at Hoon Hill, where in the past they have caused severe dune erosion. The plan even recommends racehorse training within the Conservation Zone at Rutledge’s Cutting. As the most significant area for Hooded Plover nesting, that is inexcusable.

Many times, the draft plan refers to damage caused by racehorses but fails to explain how increasing the area available to them by 250% will mitigate these impacts. Worse still, the plan’s risk assessment reveals that management won’t make any difference. Before management, the risk to coastal dune vegetation, cultural heritage, resident and migratory shorebirds from racehorse training is rated ‘Extreme’. After management is introduced? The rating remains— Extreme!

Key management theme #4: Managing in partnership

How supportive are you of the strategies for ‘Managing in partnership’ included in the draft management plan?

□ Very supportive □ Supportive □ Not sure/Don’t know □ Unsupportive □ Very supportive

Key management theme #5: Research and monitoring

How supportive are you of the strategies for ‘Research and monitoring’ included in the draft management plan?

□ Very supportive □ Supportive □ Not sure/Don’t know □ Unsupportive □ Very supportive

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Thursday, 8 March 2018

Manager Parks Planning Parks Victoria Level10, 535 Bourke St Melbourne VIC 3000

To whom it may concern,

Re: Warmambool Beach Training Support Submission

As a current member of the Warrnambool Racing Club, this letter is written to provide my support to the continuation of Beach training in Warrnambool.

Warrnambool is famous for its beach horse training and it is a very important part of the success of the racing industry in the western district.

What we have is unique and something our community is proud of, as a resu~ I am fully supportive of the continuation of horse training on our local beaches.

Regards, Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Submission template for Draft Belfast Coastal Reserve Management Plan About you:

Your name:

Your Organisation (if relevant): __n/a______

Postcode: _3280______

Email or Postal address:

THIS SUBMISSION IS: □ CONFIDENTIAL □Y NOT CONFIDENTIAL Date: _20/2/18______

How often do you or your organisation use the reserve? □ Daily □Y Weekly □ Monthly □ A couple of times a year □ Rarely □ Never

How do you or your organisation mainly use the reserve? □ Y Walking or running □ Dog walking□ Y Using the beach (swimming and surfing) □ Horse riding □ Horse training □ Volunteering □ Camping □ Hunting □ Fishing/boating □ Y Picnicking □ Y Birdwatching □ Y Socialising □ Y Other (please specify): art- sketching, painting etc__ for example, there is an exhibition of printmaking featuring migratory shorebirds in October 2018.______

Which part(s) of the reserve do you or your organisation most frequently use? □ y West of Killarney (Port Fairy side) □ yBetween Killarney and Big Baldy □ y East of Big Baldy (Warrnambool side) □ Not sure Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

About the vision- Belfast Coastal Reserve, 15 years from now…:

How supportive are you of the vision for the Belfast Coastal Reserve? □ Very supportive □ y Supportive □ Not sure/Don’t know □ Unsupportive □ Very supportive

I don’t believe commercial horse training in ANY form should be allowed in the reserve. It is public land, and no private business of any type should be able to use it in such a way that there MAY be negative impact. I refer you to multiple inputs from BirdLife Australia- regarding the commercial scale of training along any beach/costal environment. Please refer to the letter to the editor of ‘The Standard’ Saturday 12 February, from the Manager of BirdLife Australia’s Hooded Plover conservation project, Grainne Maguire. http://www.standard.net.au/story/5230215/letters-to-the-editor-february-16/?cs=77. I do hope you have attained all past letters to the editor regarding this reserve, and the commercial training of racehorses on our beaches. In particular I recall a letter from BirdLife Australia spelling out reasons for the opinion that any form of frequent use of beach/coastal areas by horses WILL cause destruction, and is not compatible with preservation of any of the bird species needing protection at these sites.

I believe it is impossible for the coastal environment to be maintained (or improved) while allowing large hooved animals to regularly walk/run there. The days of a handful of horses only, using the beach several times a week, are over. Nostalgia for this, and perhaps the association of local beaches with successful horses (eg Melbourne cup and other winners) is not a reason for allowing the practice of commercial training to continue on any coastal areas. There has been a large amount of controversy created by horses training in these areas, and conflicting reports of things that have occurred. There is no doubt that destruction of habitat, and danger to people using the reserve, has occurred. There should be ample evidence of this already submitted during the community consultation process.

I call on the government to take very seriously the threats to the hooded plover and other birds. It is important to note that the critically endangered Orange Bellied Parrot has been found in this region, and important habitat exists there. And that if there is any chance of the allowing commercial scale horse training causing damage to these birds, their habitat, or any other aspect of the environment- it shold NOT be allowed. Not to mention the danger to other users of the Conservation and recreation zoned lands. In any decision making please err on the side of our environment, for the benefit of all of us, rather than for the financial benefit of a few.

These lands are zoned appropriately, and large scale commercial operations in them are not compatable with planning guidelines.

I am very disillusioned by government & local councils, and their ability or desire to do what is best for the environment and public. My experience is that big business/powerful people eventually always get their way. I do not see a sustainable way of having a licencing system that would appropriately control commercial training. I am only submitting this because of the article published in ‘The Standard’ Newspaper Saturday Feb 12, where Minister Lily D’Ambrosis called for submissions to ensure getting the balance right. Her quoted remarks made me think it might be worthwhile to submit.

I don’t see why the commercial racing industry can’t build their own facility that includes sand track/s and swimming pools, specifically set up for horses. For example this could happen in the centre of Warrnambool Race course. Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

If the government proposes to allow commercial horse training- how will the reserve be protected from changes to the licencing system in future that escalate the training volume and areas? I don’t think this is possible.

The Merri Wetlands abut the coastal reserve at Levy’s Beach, and there are seasonal wetlands all along this coastal trough between Warrnambool and Pt Fairy. These wetlands are listed as Nationally Significant, and again- commercial scale horse training is not compatable with these wetlands, or their zoning.

I also want to raise the issue of cultural heritage of the area. One area of the significant wetland areas, close to ‘the cutting’ are known as Tarerer lands, and it is vital these lands are not negatively impacted.

She had found very significant cultural heritage sites which she told me would rival and likely surpass Lake Condah for its significance. She kept the exact location secret, The Minister could get in contact with her for more information if wanted.

I ask that you put the benefit of public conservation and recreation zones to all people, and creatures, above the financial interests of a few. Thank you.

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Key management theme #1: Cultural landscape and living heritage

How supportive are you of the strategies for ‘Cultural landscape and living heritage’ included in the draft management plan?

□ Very supportive □ Supportive □ Not sure/Don’t know □ Unsupportive □ Very supportive

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Key management theme #2: Healthy Country

How supportive are you of the strategies for ‘Healthy Country’ included in the draft management plan?

□ Very supportive □ Supportive □ Not sure/Don’t know □ Unsupportive □ Very supportive

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Key management theme #3: Recreation and use

How supportive are you of the strategies for ‘Recreation and use’ included in the draft management plan?

□ Very supportive □ Supportive □ Not sure/Don’t know □ Unsupportive □ Very supportive

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Key management theme #4: Managing in partnership

How supportive are you of the strategies for ‘Managing in partnership’ included in the draft management plan?

□ Very supportive □ Supportive □ Not sure/Don’t know □ Unsupportive □ Very supportive

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Key management theme #5: Research and monitoring

How supportive are you of the strategies for ‘Research and monitoring’ included in the draft management plan?

□ Very supportive □ Supportive □ Not sure/Don’t know □ Unsupportive □ Very supportive

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Friday, 2 March 2018

Manager Parks Planning Parks Victoria Level10, 535 Bourke St Melbourne VIC 3000

To whom it may concern,

Re: Warrnambool Beach Training Support Submission

As a current member of the Warrnambool Racing Club, this letter is written to provide my support to the continuation of Beach training in Warrnambool.

Proper beach access for horse provides longevity for their careers, better outcomes for riders (it's safer than circular tracks) and provides valuable income for the town employing hundreds of locals.

Warrnambool needs a viable long term plan for the beaches and its training facilities to support its local horse population.

Regards, Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

From: Sent: Friday, 16 March 2018 4:03 PM To: ParkPlanMailbox Subject: Belfast coastal reserve

Categories: Red Category

Thank you for the opportunity to comment on the proposed changes in the draft plan for the Belfast Coastal Reserve.

have regularly used the Armstrong Bay area for exercise and relaxation. We also had two dogs for much of this period who also loved this beach area. During this time it was rare to see more than the occasional other person on the beach when we were there. The people we did see were generally local people or fishermen as the area is quite isolated and does not attract more than a handful of tourists.

For this reason, I find that comparisons with the Mornington Peninsular National Park are somewhat stretched. Mornington Peninsular is very residential and not far from millions of people living in Melbourne proper. It is also a popular tourist destination. For this reason, many of the people using the Mornington Peninsular do not have the vested interest and feeling of “ownership” that the locals in the Belfast Area do.

Last Monday, Labour day Holiday and the final day of the Port Fairy Folk Festival, I walked from Towilla Way Carpark to just past the Basin Access and back. I had my camera and a rubbish bag (as do many of the locals while walking the beach). In a 90 minute walk, in one of the most used areas of the Reserve, I saw two groups of two people (fishermen at the basin and a couple at the Towilla Way beach entrance. I picked up a plastic spoon, 2 napkins and a bottle top at the basin area (nothing at all in the 2km to and from the basin) and saw evidence of 2 horses, a dog and 2-3 people all walking close to the water level (it was low tide). This, I think, represents a typical experience.

The people of the Belfast Coastal Reserve area have looked after this area for years. They have maintained a safe access to the dunes from Towilla Way, have kept a close eye on the wildlife and helped to protect the hooded plover population, have advised the authorities of sick or injured wildlife and have kept the beach immaculately. We have followed directions in relation to control of dogs in hooded plover areas and ridden our horses close to the water level. We have been directly involved in making this area the most successful hooded plover conservation area in Victoria WITHOUT onerous restrictions being placed on our beach usage and lifestyle.

We feel quite insulted by any suggestion that we and our community may be penalised by this government after the very successful and voluntary efforts we have made over many years. We feel that a classification of our area of the reserve would be just as well served with a conservation/recreation classification with a few simple clarifications in relation to dogs on leashes within say 200m of hooded plover nesting areas during nesting season, some restrictions on dune access in sensitive areas, adequate signage and designated tracks through limited areas of the dunes. Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

From: Sent: Tuesday, 13 March 2018 12:21 PM To: ParkPlanMailbox Subject: belfast coastal plan

Categories: Red Category

To Whom it may concern

During that time I have been a keen windsurfer, snorkeler diver and surfer

I have already put in a submission regarding my opposition to the commercial horse trainers being granted permission to use our beaches for their training purposes. My other concern is that access to some of my favourite sections of the coast will be too severely restricted. The current draft management plan seeks to create a conservation zone all along the Armstrong Bay beaches in South West Victoria. This conservation zone will have a huge, detrimental impact on our recreational choices, now and into the future, due to restriction of access to waterways. These beach accesses are primary tracks that should remain open. These give access to the ocean and consequently support our recreational activities of snorkeling and Scuba diving. Access to Pelicans (Long reef) has always been available from a primary track accessed from a small car park located off the Basin road. This path is still reasonably well defined with some parts having duckboards covering sandy areas. The car park used to have approximately five parks that were generally sufficient for the usage. This car park has now been partially overgrown with coastal wattle, not native to this area, and marram grass. This has reduced parking capacity. This path is important to snorkelers in full wet suits carrying weight belts and is the closest direct path to the Long Reef. Access along the beach from the Basin car park or Killarney boat ramp car park is a considerably longer distance. This is an existing primary track. It does not have high usage but its continued existence does provide support for the goal stated above. Having a single defined track does reduce impact on the environment. I am a responsible and law abiding community member and have previously volunteered in helping clean our beaches of rubbish including the recent “nurdles” and would be happy to assist Parks Vic. to clear vegetation that has grown over the car park area. The access tracks to the beach from Gormans Lane and Towilla Way also provide access to the ocean for snorkeling and scuba diving. These tracks have limited use from people participating in diving activities but have greater usage from recreational horse and dog walkers. These primary access tracks should be maintained.

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

From: Sent: Tuesday, 6 March 2018 1:10 PM To: ParkPlanMailbox Subject: Draft Belfast Coastal Reserve Management Plan

Categories: Red Category

Submission template for Draft Belfast Coastal Reserve Management Plan About you: Your name:

Your Organisation (if relevant): ______Postcode: ____3280______Email or Postal address: ______THIS SUBMISSION IS: ? NOT CONFIDENTIAL Date: 7/3/2018 Your Comments: Please Note – The following information will be made publically available. Main reason for interest: (such as local resident, visitor to parks, tourism operator, environmental interest, business operator, education interest, scientific interest) Recreation and use: Windsurfing , Kitesurfing, surfing How often do you or your organisation use the reserve? ? Daily How do you or your organisation mainly use the reserve? ? Walking or running ? Dog walking ? Using the beach (swimming and surfing) ? Horse riding ? Horse training ? Volunteering ? Camping ? Hunting ? Fishing/boating ? Picnicking ? Birdwatching ? Socialising ? Other (please specify): windsurfing, surfing Which part(s) of the reserve do you or your organisation most frequently use? ? West of Killarney (Port Fairy side) ? About the vision- Belfast Coastal Reserve, 15 years from now…: How supportive are you of the vision for the Belfast Coastal Reserve? ? Very unsupportive

During that time I have been a keen windsurfer, diver and surfer

Although I have numerous concerns about the proposed changes I will address the one I see as the most important. I strongly object to the granting of permission for commercial trainers to use our beaches for their horse training. I surf or windsurf in the sea often using the “Golfies” car park as an access point. On average I would use it three to four days a week.

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Problems with commercial horse training. ?? The horses arrive in heavy purpose built trucks that have cracked the natural crust of the car park and the subsequent increase in soft sand has reduced the available parking space to less than half what it was a year ago. ?? The horse truck(s), their support vehicles and the car(s) of supervising parks officers and occasional private monitors or protesters have made it difficult to for the general public to access the car park. ?? The reduced turning circle of the park leads to vehicles being regularly forced to reverse up the car park’s hill posing a high risk of accident with another vehicle entering the area. ?? Horse manure in the car park cannot totally be cleaned up. The remnants of it, horse urine and sweat from washing them down has contributed to an unpleasant odour. Last summer was the worst for flies This could well be related to the increase in horse usage. ?? Golfies is used all year by fishermen, surfers, families, stand up paddle boarders, dog walkers windsurfers and kite boarders. This is a great spot to relax and important for the mental health of many users. There has recently been increased tension and ill feeling between the horse staff and other members of the general public creating stress on both sides. ?? Kites and windsurf sails spook horses. This has occurred both on the beach and in the car park. Mixing this variety of users creates a high risk of injury. ?? The horse riders do not always stay within the limits of their permit. I have personally seen them go beyond their restricted area. Parks officers monitor them. The officers are thus not engaged in more traditional duties. It seems a poor use of their limited resources and budget. ?? The trampling of many horses regularly on a beach will have effects on the environment. There is a whole ecosystem that is being interfered with from the bacteria, worms, sand hoppers, various bird species, and so on up the food chain. It is arrogant and foolish for anyone to say no ill effects will result from this impact on the environment. What I would like to happen If commercial horse racing from the large stables were banned completely there would be no need to make any other changes from what was in place before this proposal was submitted. This would be my preferred option and I believe most locals would be content with this scenario. The worst thing for us as surfers and windsurfers would be for Golfie’s car park to be shut down.

If for some reason the commercial trainers have to be bowed to, then it would be more logical to have only one area to supervise. As mentioned above this would lead to more efficient use of Park’s resources as well as restrict the damage the horses can do to a single area. The Levi’s beach area would be less of a safety concern for the mixing of the general public and the horses. Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

From: Sent: Friday, 9 March 2018 7:47 PM To: ParkPlanMailbox Subject: No to race horses on the beach

Categories: Red Category the Belfast Coastal Reserve: Please stop the commercial use of this reserve, by race horses or any other commercial "entertainment" for humans. Nature is NOT a "resource" and source of "service" to humans.

What will you do when human & business "survival" has been used to justify the destruction of the very viability of our means of basic life?? And our ecosystems collapse? Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Tuesday, 13 March 2018

Manager Parks Planning Parks Victoria Level 10, 535 Bourke St Melbourne VIC 3000

To whom it may concern,

Re: Warrnambool Beach Training Support Submission

The opportunity to train horses on Levy's Beach and the dunes is critical for the ongoing success of horse training in Warrnambool which I fully support.

Regards, Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Wednesday, 14 March 2018

Manager Parks Planning Parks Victoria Level 10, 535 Bourke St Melbourne VIC 3000

To whom it may concern,

Re: Warrnambool Beach Training Support Submission

They are trained by a local trainer and race at the local track. Nothing gives me more pleasure than seeing them swimming at the beach or training on the sand. I also get satisfaction from my contribution to the economy knowing that the ownership fees I pay are being used to employ local trainers, riders, vets and a wide range of people associated with the local racing industry.

The opportunity to train horses on Levy's Beach and the dunes is critical for the ongoing success ofA'lorse trainina in Warrnambool which I am fully supportive of. Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Manager Parks Planning Parks Victoria Level 10, 535 Bourke St Melbourne VIC 3000

To whom it may concern,

Re: Warrnambool Beach Training Support Submission

As a current member of the Warrnambool Racing Club, this letter is written to provide my support to the continuation of Beach training in Warrnambool.

I am very proud of the fact Warrnambool has the beaches to offer this unique horse training opportunity, this for certain provides significant positive economic benefits to the local community, and employs many passionate people.

Warrnambool to enjoy the beaches and the races. The combination of these training activities is a major attraction for Warrnambool and should be continued.

What we have is unique and something the community is proud of, as a result I am fully supportive of the continuation of horse training on local beaches.

Regards,

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

From: Sent: Tuesday, 13 March 2018 4:55 PM To: ParkPlanMailbox Subject: Warrnambool Beach Access for Horses

Categories: Red Category

To Whom it may concern, As an owner of horse/s trained in Warrnambool, the opportunities beach training presents as well as the relaxed country environment the district has to offer is the key reason why I will continue to support the continuation of horse training in the region.

The opportunity to train horses on Levy’s Beach and the dunes is critical for the ongoing success of horse training in Warrnambool which I am fully supportive of.

Regards,

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Wednesday, 14 March 2018

Manager Parks Planning Parks Victoria Level 10, 535 Bourke St Melbourne VIC 3000

To whom it may concern,

Re: Warrnambool Beach Training Support Submission

As an owner of a horse trained in Warrnambool, the opportunities beach training presents as well as the relaxed country environment the district has to offer is the key reason why I will continue to support the continuation of horse training in the region.

If this opportunity was not available, the opportunities for our horse and other horses alike would become limited, thus there would be potential for them to retire from racing all together. This would have huge effect on the local horse trainers, horse numbers would decrease as well as taking away the opportunity for any return to continue to fund future horses to be trained in the region.

The opportunity to train horses on Levy's Beach and the dunes is critical for the ongoing success of horse training in Warrnambool which I am fully supportive of.

ReQards, Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

SUBMISSION FOR THE BELFAST COASTAL RESERVE DRAFT MANAGEMENT PLAN

This draft plan was prepared with a very limited contribution from the local community. Government Departments, the Aboriginal community and the racing industry prepared this draft. Local interests such as the recreational sports groups, the fishing industry, conservation groups, Birds Victoria were not consulted. The obvious aim was to put an emphasis on the racing industry thereby making this draft plan severely compromised. This document has been dressed up as a conservation plan to ‘protect’ this precious coastline. However it is an oxymoron to have a ‘conservation’ area that allows the training of race horses. Even the local child on her pony is not allowed in this area YET race horses are allowed in. The argument that there is an ‘historical’ right to use the beach going back 70 years has a precedent in the high country in North East Victoria where cattle were put out to graze over summer in a very vulnerable landscape. After much protest it was decided that their ‘right’ was now over. Times have changed, our landscape is under greater pressure and we need to take note of that and adapt our practices. That is also the case here. The conservation area to protect our endangered birds, to protect the ancient aboriginal artefacts and heritage is to be applauded, so to have the racing industry pounding those very same beaches from Port Fairy to Warrnambool is a nonsense. We should be promoting the aboriginal history of this area and celebrating it, not dismissing it so carelessly. This could be a tourist drawcard. Arguments on the amount of money the racing industry brings to the South West, and linking it to access to our public beaches is spurious at its best and at its worst downright misleading. If all race horses were banned from our beaches forthwith there would be no measurable difference in the amount of money coming into this area from racing. The racing industry will not shut down if they were banned from our beaches. Other successful race horse trainers such as the have built their own facilities and are hugely successful. Also the taxpayer has contributed to an upgrade of facilities here. Can we get that money back? Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

The recreational use of these beautiful beaches I believe has been underplayed. The tourist industry in Warrnambool and Port Fairy is huge and the amount of money it brings into the district has not been mentioned in this draft. The pleasure visitors and locals get from strolling these beaches, fishing, surfing and walking their dogs is immeasurable. Yet to find race horses coming toward you can be alarming and sometimes distressing. To see horses being loaded into floats and trucks with surfers and dog walkers all in the mix is a recipe for disaster. Our beaches are a public area open to all, and yet here we have a commercial enterprise using our space for commercial gain, with huge possible dire consequences for our endangered birds and the vulnerable dunes in a time of global warming. The restriction of dogs in areas of breeding birds is to be applauded, yet we see this is a year round restriction when the Hooded Plovers are not breeding and the migratory waders have gone, and the orange bellied parrot is in the dunes. Also in winter the tides are higher and the dunes are at their most vulnerable, yet you will allow horses to still pound the beaches at the high tide mark which is often right at the base of the dunes. Above all, who is going to oversee the use of the beaches by the racing industry? It is all very well having restrictions but if they are not policed it is a waste of time. This last summer rules were not observed by some trainers. There have been some unpleasant encounters with angry trainers and dubious hangers-on who feel they have every right to do as they please.

We submit that this draft urgently needs to be re written.

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

GEELONG ENVIR()Nl\riENT COUNCIL Inc. F-\ECEIVEO I 2 1211 I ll El'IIO"'I.: 11-U7 1110 :!llo.525li 1!117. PJIO'I,I I\\:::;~ ' I ( 1)1{1{1 .... 1'0\IH- " ( ~ Ill: I'll KO\: 771.. 1111 \10\ol .. \ ll ...u u. ( 7 MAR 2018 I , \\I I'" ., , · lnn"~'ll' irnllllll'lll.url!.aU F\lo\11: J(l'l' IIIC (~ IIII'Ptlllcl.l'lllll •• \\\\\\-lC ~ MINISTERS OFFICE Geelong Environment Council Letter to Premier Daniel Andrews opposing Racehorse Training on Victorian beaches. Dear Premier, Licence fo r Racehorse Trainng on Belfast and adjacent beache is opposed by the Geclong Environment Council (GEC) for the following reasons ..

The licence for 50 horses to train on a daily basis on the beach results in the vi rtual privatization of public land and the loss of a valued environmental and recreational asset.

The community looks to Government to protect our precious coastline, beaches and dunes from inappropriate use and to protect these areas for conservation values and recreation; the type which does not impact on passive users. Th is decision by DE.l"WP sends a message that our public beaches are avai !able for money for restrictive uses, causing extreme publ ic inconvenience and loss of amenity and environmental damage.

Both the former Land Conservation Counci l and the Western Coastal Board have supported the passive use of th ese beaches for public enjoyment and ecological protection.

It appears to the public that the horses hold priority above that of the threatened Hooded Plovers, known to nest on these beaches and to have suffered several losses of young this season.

Pollution of the water, dunes and tl·.~ soft sands from horse manure and urine is unacceptable and has the potential to change the ecological values of the in-shore areas. The passage of horses through the dunes presents a further hazard to the environment.

We understand that the Warrnambool Racing Club has received significant fu nds for a horse training area. GEC urgently requests that your Government ceases thtllict:uce for training on these beaches which clearly has the potential to destroy one of Victoria's valuable assets. Training must be carried out on a site other than a public beach.

Were the requirements of the Coastal Management Act followed in this application, and was due consideration given to the breeding areas of the Hooded Plover?

Sincerely RECEiVED DEL.WP

for GEC Comm ittee -7 MAR 2J13 MINISTERIAl SERVICES Cc Minister Lily D'Ambrosio

I'RI:\ II 11 t ) ' HI CH: I l·lll'\1'1 K Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Manager Parks Planning Parks Victoria Level 10, 535 Bourke St Melbourne VIC 3000

To whom it may concern,

Re: Warrnambool Beach Training Support Submission

As a current member of the Warrnambool Racing Club, this letter is written to provide my support to the continuation of Beach training in Warrnambool.

When I walk on the beach path in the morning there appears to be no people using the beach, so I am unsure as to why this is an issue in any case.

What we have is unique and something our community is proud of, as a result I am fully supportive of the continuation of horse training on our local beaches.

Regards,

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Thursday, 8 March 2018

Manager Parks Planning Parks Victoria Level 10, 535 Bourke St Melbourne VIC 3000

To whom it may concern,

Re: Warrnambool Beach Training Support Submission

As an owner of horse/strained in Warrnambool, the opportunities beach training presents as well as the relaxed country environment the district has to offer is the key reason why I will continue to support the continuation of horse training in the region.

If this opportunity was not available, the opportunities for these horses would become limited, th•As there would be potential for them to retire from racing all together. This would have huge etfect on the local horse trainers, horse numbers would decrease as well as taking away the Oboortunity for any return to continue to fund future horses to be trained in the region.

ThA nnportunity to train horses on Levy's Beach and the dunes is critical for the ongoing success of horse training in Warrnambool which I am fully supportive of. Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Tuesday, 13 March 2018

Manager Parks Planning Parks Victoria Level 10, 535 Bourke St Melbourne VIC 3000

To whom it may concern,

Re: Warrnambool Beach Training Support Submission

I am a part owner of a horse trainee

I have long believed that training work done on beach sand is particularly good at strengthening and conditioning horse§. The famous running coach, Percy Cerutty, used to train athletes such as Herb Elliot, down at Portsea in the same way!

It is for this reason that I chose a Warrnambool trainer for my horse.

The opportunity to train horses on Levy's Beach and the dunes is critical for the ongoing success of horse training in Warrnambool.

I fear that closing this option down will eventually lead to a gradual reduction in training in the area with an inevitable loss of jobs.

Regards, Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Manager Parks Planning Parks Victoria Level 10, 535 Bourke St Melbourne VIC 3000

To whom it may concern,

Re: Warrnambool Beach Training Support Submission

As an owner of a horse trained please give them access to the beach.

our horse to Warrnambool ONLY because of the beach access

Training in Warrnambool which I am fully supportive of can only be good for Warrnambool

Kind Regards,

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

From: Sent: Monday, 5 March 2018 3:20 PM To: ParkPlanMailbox Subject: Belfast Coastal Reserve Management Plan

Categories: Red Category

To whom it may concern I recently emailed a submission regarding the above plan. Unfortunately, I somehow sent it before I had finished so may I add the following? Dog Walking I strongly support the prohibition of dogs in the Conservation Zone. Whilst I am personally against it, I will support the off-leash dog beach proposal on condition that dogs are still under control. I support the creation of dog walking tracks between golf course access and Killarney campground. I would like to see more education for dog owners such as picking up and disposing correctly of dog droppings and not allowing dogs to pester other people in the reserve. There should be close monitoring as was done in Mornington Peninsular Park and if there is still detrimental effects on Hooded Plovers and other beach nesting birds then dogs should be banned. Key Management Theme #4 Managing in Partnership. I strongly support coordinated management of the reserve however I do not believe it would be efficient to have fragmented management. The reserve should be declared National Park and managed by Parks Victoria. The park should have appropriate funding. The 5 and 10 year reviews are too long a time frame for some of the proposals, they should be one or two year reviews. Key Management Theme #5 Research and Monitoring. I strongly support this chapter with the above comment regarding time frame. I would also point out that there has been sufficient monitoring regarding the damage that horses do and so commercial racehorse training should cease immediately. Thank you for the opportunity to comment Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Re: Belfast Bay Coastal Reserve Draft Management Plan.

The Friends of Shorebirds SE (FoSSE) appreciates the opportunity to make the following comments on the Belfast Coastal Reserve Draft Management Plan.

Although FoSSE is based in the South East of South Australia, the group has been involved in shorebird activities in the Port Fairy area, working with like minded local groups. We also have a connection with Port Fairy as a Hooded Plover which was caught, banded and leg-flagged as a chick near the abalone farm, later moved to the Port MacDonnell area and has successfully bred here.

FoSSE wishes to support the Draft Management Plan’s recommendation to categorise the high value sector of reserve as a Conservation Zone, concentrating on protecting habitat values and minimising disturbance to beach nesting and migratory shorebirds, for which this area is particularly valuable. There are 28 known Hooded Plover, plus numerous Red-capped Plover and Australian Pied Oystercatcher breeding sites within the proposed Conservation Zone, and it is an internationally or nationally significant area for Sanderling, Sharp-tailed Sandpiper, Ruddy Turnstone and Double-banded Plover. In addition, the Reserve is used by ten other threatened species.

Threats faced by beach nesting birds in particular are increasing at an exponential rate. With increasing human population, and more recreational use of our beaches, it is rapidly becoming more and more difficult for these species to successfully breed. Monitoring by BirdLife Australia has shown that the Hooded Plover breeding success rates are failing to maintain the population trajectory over time. Given that the reserve contains the largest population density of breeding Hooded Plover in their entire eastern range it is imperative that all possible efforts be undertaken to increase the breeding success rate. Much effort has been made in other areas to mitigate threats to the species elsewhere, it seems paradoxical that threats such as commercial race horse training, off-leash dogs and trail bikes are allowed to go unabated in this most important area.

It is because of the above that FoSSE is highly critical of the proposal to allow commercial race horse training within the reserve, including the absurd proposal to allow this activity within the Conservation Zone. Throughout the draft plan, reference is made to the significant damage caused by race horse training, however the plan fails to address how this damage will be lessened by massively increasing the available area and horse numbers. The draft plan even allows race horses to use the fragile dune area behind Levy’s Beach and the perhaps appropriately named Hoon Hill, where they have caused significant dune erosion in the past! The draft plan’s Risk Assessment (p. 29) exposes the fact that proposed management plan will not reduce the “extreme” risk (p. 29) posed by this commercial activity. The plan also neglects to list race horse training in the ‘Habitat Protection Strategies’ table (p. 32), even though the plans categorises the threat as “Extreme”. Given that a $1.2 million synthetic sand track is available for commercial horse training it makes no sense to allow this highly damaging commercial activity, which poses extreme risks to habitat, threated species and public safety, to occur within the Conservation Zone or indeed the reserve as a whole.

FoSSE supports the goal of the draft plan to restrict dogs in high value habitat areas. Areas of high conservation value, particularly for beach nesting birds, should be dog and horse free zones. Designating these beaches as dog and horse free zones would still leave 57% of the Reserve available for dogs (both as off-leash and on-leash areas) and recreational horse riding under a permit system. The creation of dog free zones would also allow baiting for fox control to occur, something which cannot be done where dogs are permitted, either on or off-leash. We also support the proposed designated off-leash dog beach (p. 49). The proposal to establish dog on-leash only areas must however must be backed up by sufficient resources to enforce regulations. Studies at other sites where on-leash only regulations exist show that such regulations are generally ignored by most dog walkers.

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

The statement in the draft plan “there are however mixed opinions in the community about the ongoing impact of dogs and horses in the Reserve” is unfortunate. It may be that emotive opinions are mixed; however, all available scientific information proves that dogs and horses do have an adverse impact. This is a fact which is simply undeniable, not an opinion.

The Vision Statement (Belfast Coastal Reserve, 15 years from now) is generally supported, however, the statement that “the location, timing and intensity of activities such as horse riding has been managed to avoid conflicts between uses, and to reduce the risk of damage to the environment and cultural sites” is definitely not supported. Given the sensitive nature of the habitat and the birds within the Reserve, horse riding, and more particularly commercial race horse training, which interestingly is not mentioned in the above statement, does not belong in the reserve. The Vision Statement also refers to “migratory birds that breed and feed here”. Migratory birds do not breed in Australia.

FoSSE believes that is essential that proper zoning and regulation of recreational activities are implemented, that commercial race horse training is ceased, and that sufficient funds be made available to enforce these regulations, alleviate predator impacts and conduct appropriate public education, monitoring and research. With these steps a balance of conservation and recreation can be achieved and a more productive future for the birds of the reserve could be guaranteed.

Friends of Shorebirds SE

8 March 2018

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

From: Sent: Friday, 9 March 2018 12:40 PM To: ParkPlanMailbox Subject: Belfast Coastal Reserve Submission

Categories: Red Category

Draft Belfast Coastal Reserve Management Plan - Postcode: 3088 - Email: THIS SUBMISSION IS: NOT CONFIDENTIAL Date: 09/03/2018 Main reason for interest: Environmental & Conservation interest About the vision- Belfast Coastal Reserve, 15 years from now…: (page 7) How supportive are you of the vision for the Belfast Coastal Reserve? ? Supportive

I am unhappy with the term "horse riding" when in fact the proposal is supportive of "race horse training" - horses cantering at speed through the sand poses extreme risk to wildlife, in particular the threatened Hooded Plover.

Key management theme #1: Cultural landscape and living heritage (pages 13-24) How supportive are you of the strategies for ‘Cultural landscape and living heritage’ included in the draft management plan? ? Supportive

Comments: I am a strong supported of maintaining cultural landscape and living heritage and recognise the value of consultation and management alongside Traditional Owners. However the strategy that requires the community to act as delivery partners protecting the fragile dune systems is unreasonable if commercial racehorse training is provided authorised access to an area rich in Cultural Heritage. Key management theme #2: Healthy Country (pages 28-42) How supportive are you of the strategies for ‘Healthy Country’ included in the draft management plan? ? Supportive Comments: Horses are the largest threat to the native coastal vegetation and the dune stability that it supports. As we continue to see increasing changes in sea levels through climate change, this fragile ecosystem is already under severe threat from climate related changes without compounding the threats by allowing racehorses onto the beaches.

Key management theme #3: Recreation and use (pages 45-69) How supportive are you of the strategies for ‘Recreation and use’ included in the draft management plan? ? Supportive Comments:

I think increased enforcement of appropriate use of the reserve is vital and that includes restriction of vehicular access that destroys micro habitats within the sand systems, no off leash Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018 dog walking unless there is a fenced, designated area, no racehorse access, jet skis in reserve waters and no dune boarding. It is essential that the public are encourage to feel like stakeholders in the valuable reserve and an increase of interpretation signage about its cultural and ecological value will facilitate this. The draft plan recommends strict controls on where and how recreational uses are to be managed in the future, however commercial racehorse training will be expanded? How does this make any sense? In the intro for this chapter "Riding of horses for recreational or commercial purposes was viewed as a threat to dune health, cultural heritage, shorebirds and public safety, especially if riders did not comply with regulations, codes of conduct or licence conditions". This suggests that the community is mainly concerned about impacts that occur when commercial racehorse training doesn’t follow the rules. But as the risk assessment table reveals on page 29, even with rules, management will not mitigate the extreme risk from commercial racehorse training. I strongly condemn the goal under this section of the chapter—Authorised uses of the Reserve are managed to minimise the effect on values and visitors—with regards to commercial racehorse training as it is incompatible with the goals of the plan and the purposes of the reserve.

Key management theme #4: Managing in partnership (pages 71-75) How supportive are you of the strategies for ‘Managing in partnership’ included in the draft management plan? ? Supportive

Comments:

The reserve should become a park under the National Parks Act. We need a coordinated management objective. The plan recommends retaining the fragmented management across the City of Warrnambool, Moyne Shire Council and Parks Victoria and leaving the reserve under the Crown Lands (Reserves) Act.

I also strongly support goals to ensure that Traditional Owners caring for their Country is an integral part of the reserve’s management and that community skills, knowledge and assistance provide stewardship and help in that management. However, if commercial racehorse training is retained inside the reserve, all of their efforts would be to nought. Key management theme #5: Research and monitoring (page 77-79) How supportive are you of the strategies for ‘Research and monitoring’ included in the draft management plan? ? Very supportive

Comments:

Research and monitoring is vital going forward. Many conservation efforts are wasted after the initial investment because of the lack of follow up and its important we are able to measure the effectiveness of the plan through monitoring.However, the plan fails to explain how it will lower the extreme risk presented by commercial racehorse training revealed in the table on page 29. That table proves that it cannot and so commercial racehorse training should be removed from the reserve. Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

From: Sent: Wednesday, 14 March 2018 12:14 PM To: ParkPlanMailbox Subject: Re; Warrnambool Beach Training Support submission

Categories: Red Category

To whom it May Concern,

I am an owner of horses trained at Warrnambool and some of the reasons I was attracted to having these horses trained there was (1) the ideal rural setting with spacious yards, (2) the proximity of the beach for horses who may have leg issues, and the standard of the training provided.

Undoubtedly the high standard of the training is related to 1 and 2 above, in particular the variety provided by exercising and swimming at the beach, and as exemplified by the success in recent years of Warrnambool based trainers, with the flow-on economic effects to the community.

Should the opportunity for trainers to utilise Levy's Beach and the dunes be taken away, I have no doubt that the racing opportunities of a vast number of horses would be removed and these horses would be forced into involuntary retirement, with dramatic reduction in horse numbers, and resultant impact on the Warrnambool community.

In conclusion, I wholeheartedly support retention of the existing training arrangements at Levy's Beach and the dunes, and trust that these will be retained.

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Wednesday, 14 March 2018

Manager Parks Planning Parks Victoria Level 10, 535 Bourke St Melbourne VIC 3000

To whom it may concern,

Re: Warrnambool Beach Training Support Submission

The opportunity to train horses on Levy’s Beach and the dunes is critical for the ongoing success of horse training in Warrnambool which I am fully supportive of.

Regards,

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Tuesday, 13 March 2018

Manager Parks Planning Parks Victoria Level 10, 535 Bourke St Melbourne VIC 3000

To whom it may concern,

Re: Warrnambool Beach Training Support Submission

I truly believe the current environment that is available in Warmambool gives them the best opportunity to show their ability.

The opportunity to train horses on Levy's Beach and the dunes is critical for the ongoing success of horse training in Warrnambool which I am fully supportive of.

Regards, Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Wednesday, 14 March 2018

Manager Parks Planning Parks Victoria Level 10, 535 Bourke St Melbourne VIC 3000

To w hom it may concern,

Re: Warrnambool Beach Training Support Submission

As an owner of horses trained in Warrnambool, the opportunities that beach training presents as well as the relaxed country environment the district has to offer is the key reason why I will continue to support the continuation of horse training in the region.

whose soundness and ability to continue to compete directly relates to the opportunities to be trained in the water and on the beach.

This would also have huge effect on the local horse trainers, horse numbers would decrease as well as taking away the opportunity for any return to continue to fund future horses to be trained in the region.

The opportunity to train horses on Levy's Beach and the dunes is critical for the ongoing success of horse training in Warrnambool which I am fully supportive of.

Yours Sincerely, Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Monday, 5 March 2018

Manager Parks Planning Parks Victoria Level 10, 535 Bourke St Melbourne VIC 3000

To whom it may concern,

Re: Warrnambool Beach Training Support Submission

As a current member of the Warrnambool Racing Club, this letter is written to provide my support to the continuation of Beach training in Warrnambool.

I have enjoyed watching the horses train on the beach when I have been visiting Warrnambool.

What we have is unique and something our community is proud of, as a result I am fully supportive of the continuation of horse training on our local beaches.

Regards,

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Belfast Coast Draft Management Plan Submission by

I have read the Belfast Coastal Reserve Draft Management Plan January 2018 and make the following comments for consideration in the preparation of the Final Management Plan.

My comments are specific to particular sections of the plan. Where appropriate I have lifted sections or words from the plan with the section number and heading and added my comments below the quote. 1.1 About the draft management plan

The Belfast Coastal Reserve Draft Coastal Management Plan is a strategic guide to the management….

The document is inappropriately named – it is not a management plan, it is a strategic guide as stated. While the document does set the overall directions for management it does very little to direct management responses to specific issues.

What needs to be asked is: could I manage the reserve based on the instructions in the document?

I do not think the answer is yes.

I understand that “management plans” are a requirement for areas managed by Parks Victoria but to refer to the current document as a management plan is misleading. I further understand that there is a composite management arrangement for the planning area, which is a problem in itself but probably beyond the scope of the plan to address, so those groups may have other requirements for the document but a management plan should specify management actions – ie what will be done. Not what will be considered, thought about, consulted about or gathered from others if they just happen to do any investigations. As an example in Section 4.4 strategies: Build capacity for the conservation of Aboriginal cultural heritage, site protection and restoration. What is that actually telling the land manager to do? How is that measured? How do you or the public know if that has been achieved (whatever it means).

Good planning should be S.M.A.R.T.

S – Specific

M – measurable

A – attainable

R – Relevant

T – Timely

The plan does not pass this test. Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Solution: Call it a strategy and have the strategy require that specific plans, with aims and actions, be developed for each of the strategies. 2.1 Vision

Para 5: The natural values of the coastal landscape have been maintained and enhanced.

If this is part of the Vision I see no evidence within the document of any attempt to identify and understand the natural values of the planning area. All that seems to be planned is to sort-of manage the stuff that we know about and gather information serendipitously from others, but only if they think of it first.

Where is the leadership in this? What does PV or the other managers want to know about the planning area to ensure it is managed appropriately? As the plan says later in Section 5.2 Marine Ecosystem: Marine habitat mapping has not been conducted for the planning area…….. but there no strategy to indicate that you actually want to know what is being managed? Merely supporting a volunteer group does not cut it and is an abrogation of responsibilities. 3.1 Management zones

I am generally in support of the management zones, and their locations, as proposed with two exceptions:

 Racehorse training is a commercial operation and if it is to be retained (more of that later) it should be within a commercial (or development) zone. Call a spade a spade. It is not recreational.  I think the southern shore of Belfast Lough should be within the Conservation Zone. It is an important samphire area potentially important for Orange-bellied Parrot and is better placed in the Conservation Zone to ensure that potential recreation activities do not encroach on this area 4 Cultural landscape and living heritage

Generally in agreement but again wishy-washy goals with no solid actions. 5.1 Managing coastal ecosystems

We could argue all day about the risk matrix and what sits where but it seems to provide a reasonable basis for management decision making. The problem is that the plan has not responded to the risks as set out. If, as the table indicates, horses provide an extreme risk to coastal dunes and resident and migratory shorebirds even following remedial management actions, why is the plan even considering these uses as appropriate?

While it is noble to have a goal of undertaking invasive weed management through:

 Prioritising treatment of new and emerging weed species infestations e.g. Sicilian Sea-lavender;  Staged control of priority woody invasive weeds e.g. reduce Coast Wattle;  Containing the expansion of Marram Grass. Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

What is the specific, measurable and attainable goal? Reducing infestations by 20%, 50%? Containing Marram Grass – really? Has the infestation been mapped so we know what it will be contained to? How will it be “contained”?

What is the staged control of wattle based on? Zoning; specific sites; roadsides?

There is no direction or even broad guidelines for management as to how to prioritise control measures. Will Warrnambool Council prioritise similar areas to Moyne? 5.2 Managing marine ecosystems

Why is this section even in the plan? The preamble talks about everything except what is happening within the planning area and the goals provide no instruction to find out what is happening within the marine environment other than the establishment of a volunteer group. This is unsatisfactory and no basis for management.

And I have no idea what the following goal means:

 Support an integrated, catchment based approach to improve water quality and reduce both aquatic and marine pest plants and animals, including marine and aquatic mapping, monitoring and research activities to inform management decisions e.g. EstuaryWatch

Not bad when it is not even known what the marine pest plants and animals are or where they are in the planning area. 5.3 Water management

Again, largely waffle except for the reference to the existing Merri Estuary Management Plan. But why not make it a goal or strategy (or whatever) to ensure the existing plan is implemented. At least that would be something concrete for management actions.

Strangely the single goal states: Water levels in the Lower Merri are managed to maintain resilience and aquatic values in the wetlands and estuary.

Good, and feeding off the existing plan, but no mention of the Belfast Lough except as a strategy to maintain its water quality. Why is this not a goal or broaden the goal to include all waterways?

And, how exactly will the water quality in the lough be maintained when it is completely outside the scope of the plan to have any influence on water coming down the Moyne River? 5.4 Fire management

What might be the aim of a planned ecological burn? What is being targeted for both reduction and enhancement? It seems that fuel reduction burns are not proposed (at least it is not stated that they are). So, if ecological burns are a possibility then managers need to know what ecological feature might be targeted and how it could benefit to make any sense of a possible ecological burn. Surely this was discussed and canvassed during the preparation of the draft plan? Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

And what of the risks? A management burn could end up with Coast Wattles germinating all over the place and therefore (presumably) a more intense and costly weed control program following a burn. This has not been included or addressed in the risk matrix, and it should be, to highlight to managers the risks associated with the action. 5.5 Climate change

Great to see it has been thought of but there is nothing in the plan for the management of this issue. The bottom line is that nothing can be done within the reserve for climate change except for the protection of infrastructure, and it seems that that only means car parks and tracks for this reserve.

The goal should just be to protect facilities, the rest is wasted verbage. 6 Recreation and use

Generally pretty happy with this section of the plan. I would suggest however that “Bush walking” includes beach walking which should be added to the “only on designated tracks or on the beach”.

Regarding recreational horses (identified as an extreme risk in the risk matrix even after management), personally I would remove them but I understand that this may not be possible in the current climate. But it would be nice to know, and have it explicitly stated in the plan, that if resident and migratory shore birds are being adversely impacted then recreational horse riding will be banned. The plan needs to take a position – what is more important: shore birds and international agreements (JAMBA, CAMBA) or horses?

The saving grace for recreational riding at this stage would seem to be the low numbers and sporadic impacts as compared with commercial racehorse training. I have further addressed this in Section 6.5 below.

A few comments to consider:

 Why is commercial horse training included in Table 6.1 and mentioned under 6.4 Site Strategies for Golfies; Killarney Beach; Levys beach access; Kellys Swamp Track between Big Baldy and Spookys beach access; and, Rutledges Cutting, Gormans Road carparks number 1, 2 and 3. o It is an Authorised Use (Section 6.5) and not a recreational use.  Rutledges Cutting, Gormans Road carparks number 1, 2 and 3: Permit small numbers of horses training under license at Ruteledges Cutting to provide for local trainers that have historically used the reserve. o What is a small number? This must be specified – it is a management plan for heaven’s sake. o “History” has nothing to do with good management. The fact that things have been done historically does not mean that is appropriate or suited to the current reserve.  Kellys Swamp Track between Big Baldy and Spookys beach access: Licence horse training at Hoon Hill - conditional upon adequate risk management and compliance. Monitor compliance and periodically review conditions of use. o Do I assume this is a typo and it is supposed to refer to recreational horse riding? o What is adequate? o How will adequate be judged or measured? Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

o Compliance with what? o What period for review? This must be specified otherwise it will not be undertaken. I suggest annually. o What are the conditions of use and on what basis would they be altered? 6.5 Authorised uses

Beach training of racehorses

I quote from the plan:

Paragraph 3: The racing industry contributes to the local economy through employment and support to local businesses. Thoroughbred racing in the south west region brings benefit to the local economy. A size and scope study from 2014 revealed that the racing industry generates more than $97 million in the area, employs more than 950 people full time with almost 4,500 involved as employees, volunteers or participants (Warrnambool Racing Club 2016). The 2017 Warrnambool May Carnival injected over $10 million into the local economy, attracting over 30,000 people, of which 68% were attendees from outside the Warrnambool region (Warrnambool Racing Club 2017).

Sophistry at its best! The plan is supposed to be about the proper management of the Belfast Coastal Reserve, not about the grand economic claims of the Warrnambool Racing Club (WRC). The WRC claims are completely irrelevant to the development of a reserve management plan and should be removed from the final plan.

The only purpose I can see in incorporating such specious information is as an attempt to sway readers into supporting a ridiculous proposition. It is a non-sequitur to attempt to link the dollar value of an industry to the management of a coastal reserve. Who do you think is being fooled by these types of statements?

I may be a bit equivocal about recreational horse riding in the reserve but I am completely unequivocal regarding commercial horse training. Commercial race horse training should not be permitted at any location within the reserve or on any other beaches or dunes in the region. It is a commercial operation that has no place within a public reserve.

There is no requirement for a phase out period – they should just go. Given the value of the industry to SW Victoria it would seem they should have no problem in providing purpose built training facilities in a place where there are no conflicts with ecological processes or the “visitor experience”. A little bit on shore birds as it relates to commercial racehorses

A range of wading birds, including the Hooded Plover, use the beaches within the reserve. However, it seems that the complete emphasis has been placed on the nest location of Hooded Plovers with little or no regard to the other components of their habitat or other shore bird species. The birds, including Dotterels, Sanderlings, Sandpipers as well as the Hooded Plover and others gather food from the sandy beaches right down to the low water mark. The area between high-water mark and the ocean is not dead sand with no use other than for horse riding. The Plan pays no heed to the macro-fauna, meio- fauna or micro-fauna that inhabit the sand and, amongst other important ecological functions, provide Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

the food for wading birds. To countenance or encourage the ploughing of the beach daily by commercial racehorses is ecological vandalism and an abrogation of responsibilities under our international bird treaties such as JAMBA and CAMBA.

It is a relatively simple process to record nest locations, put up temporary fences and count eggs and breeding success but this should not be the end of our attempt to protect the species that either permanently or periodically use the beaches. There is no point in providing great protection for a nest when we condemn the hatchlings to starvation due to destruction of their feeding habitat.

That is why I am totally opposed to commercial racehorse riding on the beaches and within the reserve. I do not object to horseracing or those who are involved with it but I do object strongly to a public resource being used for commercial purposes particularly where there is such a demonstrable deleterious impact and risk. The plan recognizes the risk (at least in part) to the shore birds but then does not apply management actions to adequately avoid the risk.

Back to the plan statements….

Goal: Authorised uses of the Reserve are managed to minimise the effect on values and visitors.

The goal should be amended to:

 Authorised uses of the Reserve are managed to avoid or minimise the effect on values and visitors.

Strategies:

 Permit horse training under license at Golfies beach (as shown on Map 6) from dawn to 10am Monday to Friday, with a maximum of 50 horses per day December 1st to March 1st and a maximum of 20 horses per day March 2nd to November 30th. o Delete as totally unacceptable. But at least some numbers were provided.  Permit small numbers of horse training under license at Rutledge’s Cutting and Killarney Beach to provide local trainers that have historically used the reserve. o How many is small numbers? o History has absolutely nothing to do with proper management. o Strategy should be deleted.  Permit horse training under license at Levys beach and Hoon Hill as shown on Map 6. o How many? o What conditions? o Strategy should be deleted.  Licence conditions for racehorse trainers and tour operators to include comprehensive protections for cultural values, natural values and other beach users. Revoke licence for continual levels of non-compliance. o The plan offers nothing to show there is a “comprehensive”, or even a good, understanding of the values so how can comprehensive protection be provided? Empty words. o Revocation of licences for continual levels of non-compliance is not required. One strike and you are out. And what is a continual level? Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

 Review beach nesting bird monitoring results to inform licence conditions e.g. Hooded Plover density and fledgling success as an indicator species. o Good, but where is this going? What are the triggers. If one nest gets stomped is that enough? What happens if no fledglings are recorded? o How often is it reviewed? I assume annually but need to specify. o Indicator of what? It is a resident bird – how does that indicate what is occurring with migratory species?  Close the beach to horse training and riding groups when Hooded Plover nests extend onto narrow sections of beach used for training, or when climatic conditions or tidal conditions make access unsuitable. o So, every high tide rangers will be down at the beach directing horses. Really? Do we really think PV or other managers will be available to suitably manage this?

This last point really summarises the tangles that have been inflicted on management through keeping horses on the beaches. Get rid of the horses and it becomes that much easier – and better – to manage. 6.7 Information, interpretation and education

 Ensure facilities are maintained and ‘fit for use’ and that any new assets comply with Australian standards, Industry standards and building codes and regulations. Upgrade, replace or withdraw from public use those that do not. o What new “assets”? The only “assets” specified in the plan are car parks roads and tracks. If that is what is meant then say it. This would allay fears of other development within the reserve that has not been flagged in the management plan.  Support citizen science programs and increased active use of the Reserve by educational institutions to develop knowledge on the area and inform the education and interpretation program.  What about PV et al actually finding out about the reserve they are managing rather than rely on “citizen science”. 6.8 Tourism partnerships, marketing and promotion

 Provide for tour operator licences in the Reserve that utilise the range of available activities, subject to the protection of native flora, native fauna, built assets, natural features and cultural heritage places.  It is assumed that this would be an Authorised Use and should therefore be included in Section 6.5. 7.1 Coordinated management

 Undertake a 5-year review of implementation of the plan – with reporting against high priority strategies provided by responsible agencies.  There are no high priority strategies in the plan. There are immediate, medium, long-term and as required strategies. Is it assumed that Immediate is the same as high? If not, it needs clarification.  Explore opportunities for consolidation of land management arrangements as they arise.  This should be a High (or immediate) priority. Mixed responsibilities leads to mixed results. Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

8.1 Research and monitoring

Goal: Monitoring and evaluation improves management decisions and techniques through enhanced ecological, cultural and visitor use knowledge.

I do not see a goal here. What I see is a questionable statement. The right things need to be monitored in the right way and then acted upon with the express aim of minimizing adverse impacts and enhancing good outcomes for the identified issue.

 Develop monitoring criteria for key ecological measures, informed by conservation planning and State of the Parks. o Good – but what are the key ecological measures for this reserve? These should not be defined by State of the Parks or other high level governmental reporting instruments but by local conditions and what is happening in Belfast Coastal Reserve. o All the supporting, encouraging, facilitating – why cant the managers lead this and do it?  Use knowledge gained from research to refine management practices e.g. investigations into the effectiveness of invasive species control programs and techniques. o How many times do we need to research weed control and what works? It has been done. It is now time to get on with it. The plan should identify the weeds that are a threat; instruct that they be mapped and priority control areas be defined based on some defensible reasoning (ecological, recreational, whatever) and then measure how effective it was. This is not hard, it just requires taking a position.  Support research into the impacts of climate change on coastal areas and mitigation measures that could be applied in the Reserve. o I really look forward to seeing how this is implemented in the reserve. Summary

In summary, the management plan fails to provide a clear, cohesive and defensible set of management actions. Broad statements do not constitute a management plan. I sincerely hope the final management plan will consider my comments and observations and incorporate specific, measurable, attainable, relevant and timely actions.

The plan should be a working document that identifies the problem/issue, what is known about it issue, what needs to be known about it, the aim of management, specific actions that will be undertaken to achieve the aim and how to know if the aim has been met.

Remove the waffle. It is not judged by the eloquence of the prose but rather the appropriateness of the management aim and the likely effectiveness of the actions in achieving the aim.

Remove the sophistry. This is pretty easy – just talk about the planning area.

Most importantly for this planning area: Remove commercial horse training from the reserve immediately to protect the ecology of the reserve and comply with our international agreements.

I would be happy to discuss my comments with the planning team should that be desired.

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Manager Parks Planning,

Parks Victoria Level 10,

535 Bourke St

Melbourne VIC 3000

11March 2018

Dear Sir/Madam,

Re: Belfast Reserve Draft Management Plan

1. I believe it is essential to clearly delineate areas for dog activity and support the Plan’s designated areas as either no dog, dog on leash or off leash

For several years now I have walked the section of coast from Killarney Beach to Port Fairy organised by Birdlife Australia. This has made me very aware of the importance of this coast for many species of migratory and resident bird species. I have also witnessed first hand the careless attitude of many dog owners toward the roped off hooded plover nesting sites along this section of beach( see below).

Dog running through Hooded Plover nest site on East Beach Port Fairy photo). Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

2. I do not support the use of the Reserve for commercial horse training.

The Victorian Coastal Strategy 2014 makes some important points about commercial activity and infrastructure on the coast:

• P27 Key Issues; Desired Outcomes, point 7. New development, reuse and redevelopment on the coast (a) has a demonstrated need to be located on the coast (b) protects environmentally and culturally significant places • P27 Key Issues; Desired Outcomes, point 9. New private structures that provide no public benefit are not permitted. • P65 Section 3.1 Desired Outcomes point 3. Coastal Crown land is not used for structures unless they provide significant community benefit, and their functionality depends on them being near the water. • P65 Section 3.1 Table. Coastal Crown land location not necessary…..eg Function Centre, community hall, non-maritime industrial plant and storage, non-water based sporting facility

In my view the proposed activity, with its associated tracks is not consistent with these outcomes. The financial viability of Victoria’s racing industry is not affected in any way by banning race horse training in the Reserve. Trainers in many other locations successfully train race horses without access to a beach. As the Plan points out (p63) Warrnambool Race Course has recently (2017) built a sand track for trainers and this is appropriate. The Club could also consider other facilities to aid horse training.

3. I agree with points made by Birdlife Australia about the Draft Plan.

include the following points made by that organisation as part of my submission.

• This Reserve has local, statewide, national and international significance to several species and groups of birds.

• High support for actions taken to mitigate threats and to improve the protection of birds and their habitat within the Reserve.

• High support for 43% of the onshore area to be protected in a CONSERVATION ZONE. This encompasses the area used by the Orange-bellied Parrot, 28 Hooded Plover breeding sites (of 44 sites in total within the Reserve), the largest known winter flocking site for Hooded Plovers, at least 24 red-capped plover breeding sites, 2 pied oystercatcher breeding sites, and major roost and foraging sites for migratory shorebirds including internationally significant sites for Sanderling and Sharp-tailed Sandpiper, nationally significant sites for Ruddy Turnstone and Double-banded Plovers (New Zealand migrant, visits in our autumn/winter months). Rutledges Cutting for example is one of five priority sites in Victoria for the Orange-bellied Parrot (Adams & Purnell 2016). The plan states (page 10), “the conservation zone covers the areas where the highest cultural and environmental values are found. The intention of this zone is to ensure a very strong management emphasis on protection of the environment and identified values. Recreation and nature-based tourism are permitted when managed in a way that is sensitive to the identified values.” • High support for the proposed CONSERVATION ZONE to be free of high impact threats including hunting, off-road vehicles, dogs, horses, camping, and dune boarding.

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

• High support for: Cultural Heritage protection; Joint management; Education and interpretation; M onitoring and research; Rationalisation and closure of inappropriate beach access; Dog control; A permit system for recreational horse riding (in areas w here this is sustainable); Pest animal and w eed control.

• No support for commercial race horse training w ithin the Reserve, including permitting this activity w ithin the CONSERVATION ZONE. Under the draft management plan, the length of beaches available to racehorse training w ould be increased by 250% (from 2 km to 5 km) and the number of horses by 400% (from 65 to 256 each day). That represents 25% of the Reserve' s beaches, w ith nothing in the plan to stop future expansion or to review compliance and impacts of the commercial horse training on the Reserve's natural and visitor values. The draft plan is allow ing racehorses in to 750 metres of fragile dunes behind levy's Beach and at Hoon Hill, w here in t he past they have caused severe dune erosion. The plan even recommends racehorse training within the Conservation Zone at Rutledge' s Cutting. THIS IS INEXCUSABLE AND IT IS INCONGRUENT WITH THE RECOMMENDATIONS OF THE CONSERVATION ZONE.

Throughout the draft plan, damage caused by racehorses is referred to but the plan fails to address how increasing the area available to them by 250% w ill mitigate these impacts. Worse still, the plan' s risk assessment (page 29) reveals that the current proposed management plan won't reduce the threat of this commercial activity. Before management plan implementation, the risk to coastal dune vegetation, cultural heritage, resident and migratory shorebirds from racehorse training is rated EXTREME. After the management plan is put in place, the rating remains EXTREME. In other w ords, no effort has been made to address the threat commercial race horse training poses to mult iple values of the Reserve, including visitor safety, and instead, it has been expanded w ithin t he Reserve.

Since the M inister of Environment granted access to commercial race horse trainers in 2016, there have been numerous breaches of licensing condit ions, high risks to public safety and the channeling of limited resources and state government staff in to surveillance and infrastructure. This has stretched local Parks Victoria and DELWP capacity and taken already limited support and resources away from environment and visitor services. Expanding the number of training beaches w ill make condit ions even harder to monitor and be costly to the local economy and values of the Reserve.

Yours sincerely

3 Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018 Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Manager Parks Planning Parks Victoria Level 10, 535 Bourke St Melbourne VIC 3000

To whom it may concern,

Re: Warrnambool Beach Training Support Submission

there is no doubt that his horses racing career has been significantly prolonged because of the beach environment that Warrnambool provides. Most significantly the ability to take weight off the front knees and fetlocks with dune work, the instant anti-inflammatory benefit provided from the cooling of the ocean immediately following work on the beach.

If this opportunity was not available, the opportunities for horses would become limited, thus there would be potential for them to retire from racing all together. This would have huge effect on the local horse trainers, horse numbers would decrease as well as taking away the opportunity for any return to continue to fund future horses to be trained in the region.

The opportunity to train horses on Levy’s Beach and the dunes is critical for the ongoing success of horses training in Warrnambool, which I am fully supportive of.

Regards,

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

15th March 2018

Manager Parks Planning Parks Victoria Level 10, 535 Bourke St Melbourne VIC 3000

To whom it may concern,

Re: Warrnambool Beach Training Support Submission

I I am somewhat concerned of the intended restrictions proposed in relation to the ongoing training opportunities within the Warrnambool region.

I refer specifically to the proposed restriction or elimination of beach training on Levy's beach and its surrounds.

I believe that the relaxed country environment the district has to offer and the current training facilities are the key reason why the area has such success within the industry and contributes so much to the local economy.

In the event of beach training being reduced or eliminated I would seriously consider the value of continuing in the current situation. This I believe would be of great detriment to not only the industry in the local community but also the local economy as I believe many owners will relocate their horses.

The opportunity to train horses on Levy's Beach and the dunes is critical for the ongoing success of the horse racing industry in Warrnambool which I am fully supportive of.

Reaards. Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

From: Sent: Tuesday, 13 March 2018 1:34 PM To: ParkPlanMailbox Subject: Warrnambool Beach training

Categories: Red Category

Manager Parks Planning Parks Victoria Level 10, 535 Bourke St Melbourne VIC 3000

To whom it may concern, Re: Warrnambool Beach Training Support Submission As an owner of horse/s trained in Warrnambool, the opportunities beach training presents as well as the relaxed country environment the district has to offer is the key reason why I will continue to support the continuation of horse training in the region.

If this opportunity was not available, the opportunities for these horses would become limited, thus there would be potential for them to retire from racing all together. This would have huge effect on the local horse trainers, horse numbers would decrease as well as taking away the opportunity for any return to continue to fund future horses to be trained in the region. The opportunity to train horses on Levy’s Beach and the dunes is critical for the ongoing success of horse training in Warrnambool which I am fully supportive of. Regards,

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Manager Parks Planning Parks Victoria Level 10, 535 Bourke St Melbourne VIC 3000

To whom it may concern,

Re: Warrnambool Beach Training Support Submission

over the yrs have appreciated the beach training. Beach training is beneficial to most horses, particularly those in recovery from any injuries.

The opportunity to train horses on Levy’s Beach and the dunes is critical for the ongoing success of horse training in Warrnambool which I am fully supportive of.

Regards,

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Manager Parks Planning Parks Victoria Level 10, 535 Bourke St Melbourne VIC 3000

To whom it may concern,

Re: Warrnambool Beach Training Support Submission

The opportunity to train horses on Levy’s Beach and the dunes is critical for the ongoing success of horse training in Warrnambool which I am fully supportive of.

Regards,

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

From: Sent: Friday, 9 March 2018 12:14 PM To: ParkPlanMailbox Subject: Submission

Categories: Red Category

I am strongly opposed to the use of Belfast Coastal Reserve for the use of training horses. This is a major threat to numerous endangered bird species that rely on the site. If I want to see horse racing I go to the races. I go to Belfast to see amazing coastal landscapes and intact native ecosystems. Regards,

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

From: Sent: Thursday, 15 March 2018 10:05 AM To: ParkPlanMailbox Subject: horse beach use

Categories: Red Category

To who it may concern. As an owner of a horse trained in Warrnambool,I fully Support the beach training of horses in the area. I have observed horses on the beach and in the water,and they seem to love it.,and cannot See that they are doing any damage to the environment.

Yours truly,

OWNER Sent from Mail for Windows 10 Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Manager Parks Planning Parks Victoria Level 10, 535 Bourke St Melbourne VIC 3000

To whom it may concern,

Re: Warrnambool Beach Training Support Submission

As an owner of horse/s trained in Warrnambool, one of the main reasons I support training in this area is the availability of the beach to help with the welfare of the horses

having the beach as not only a valuable training resource, it enable horses less than sound to fulfil their potential they otherwise may not reach

If this opportunity was not available, the opportunities for these horses would become limited, thus there would be potential for them to retire from racing all together. This would have huge effect on the local horse trainers, horse numbers would decrease as well as taking away the opportunity for any return to continue to fund future horses to be trained in the region. In turn I suspect this would affect employment in and around your area.

The opportunity to train horses on Levy’s Beach and the dunes is critical for the ongoing success of horse training in Warrnambool which I am fully supportive of.

Regards,

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

From: Sent: Tuesday, 13 March 2018 9:33 PM To: ParkPlanMailbox Subject: Warrnambool Beach Training Support Submission

Categories: Red Category

Tuesday 13th March 2018

Manager Parks Planning Parks Victoria Level 10, 535 Bourke St Vic Melbourne Vic 3000

To whom it may concern,

Re: Warrnambool Beach Training Support Submission

I am the owner of a racehorse now trained in Warrnambool for the opportunities beach training presents as well as the relaxed country environment the district has to offer is the key reason why I will continue to support the continuation of horse training in the region.

There are many horses who have limited opportunities and because of beach training have become very successful. The retirement of these horses would have a huge effect on local trainers, horse numbers would decrease as well as taking away the opportunity for any return to continue to fund future horses to be trained in the region. The opportunity to train horses 0n Levy’s Beach and the dunes is critical for the ongoing success of horse training in Warrnambool which I am fully supportive of.

Regards, Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Tuesday, 13 March 2018

Manager Parks Planning Parks Victoria Level 10, 535 Bourke St Melbourne VIC 3000

To whom it may concern,

Re: Warrnambool Beach Training Support Submission

I would quite often walk down to the beach to watch the horses being trained there. I noticed that all the horses using the beach were very happy and healthy so I decided that any horse that I part own will only be trained from the Warrnambool area using these facilities of the beach. I have also noticed that the horses that I am involved in are very sound, fit and healthy.

however, if these beach facilities we no longer available I would look elsewhere to have my horses trained.

It is very hard to attract people into the country towns like Warrnambool so it would be a real shame if this was to happen as other towns are attracting the racing community with great facilities for their horses.

In Summary

If this opportunity was not available, the opportunities for these horses would become limited, thus there would be potential for them to retire from racing all together or to find new trainers with beach facilities. This would have huge effect on the local horse trainers, horse numbers would decrease as well as the effect this would have on the local business community, taking away the opportunity for any return to continue to fund future horses to be trained in the region.

The opportunity to train horses on Levy’s Beach and the dunes is critical for the ongoing success of horse training in Warrnambool which I am fully supportive of. I would look elsewhere for my enjoyment and involvement in horse racing if the beaches were not available for use.

Kind Regards,

Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

From: Sent: Wednesday, 14 March 2018 4:03 PM To: ParkPlanMailbox Cc:

Categories: Red Category

Manager Parks Planning Parks Victoria Level 10,535 Bourke St Melbourne, Vic 3000

Re: Warrnambool Beach Training Support Submission.

Dear Sir/ Madam

I forward you this email as an owner of horses which currently use the Warrnambool beach as part of their training programme. It is clearly my understanding that the beach, as a training facility, is essential for the effective preparation of the horses in order to perform at their optimum. The beach, to my knowledge, not only enhances performance but also assists in the horses general well being.

It is also my belief that the withdrawal of this training facility will have quite a devastating effect on horse trainers who have heavily invested in the area along with diminishing employment opportunities for those working within the stables.

number of times people mentioned the "must do" of visiting the beach in the morning to watch the horses work. We did make the early "trek"to Levy's Beach and thoroughly enjoyed the activity that was taking place. For us both we considered it quite a "tourist attraction" and an experience we shared with our friends and family

In conclusion I ask you to continue giving the many horse trainers of Warrnambool the opportunity to utilise Levy's Beach and the dunes as a training facility. Without this opportunity I believe many training businesses would suffer greatly and this would put their viability in grave doubt.

Thank you for your consideration of this submission.

Yours sincerely Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Tuesday, 13 March 20 8

Manager Parks Planning Parks Victoria Level1 0, 535 Bourke Melboume VIC 3000

To whom it may cone n,

Re: Warrnambool Be ch Training Support Submission

As a part owner of ho e/s trained in Warrnambool I have noticed, the opportunities beach tr ining presents to our horses.We continue to support trainers in the area due to multiple venue raining& results flowing from this, at the various race days (especially Warrnambool Carnival which I would have thought would be advantageous to the economy of the region. Having watched the b ach training I could not see any adverse impacts to landscape or any impact on beach user rather it enhanced the experience of the visit!

If this opportunity was not available, the opportunities for our horses would become limited, thus there may bean ed to reaccess future investment . Further this would have huge effect on the local horse tr iners, horse numbers would decrease as well as taking away the opportunity for any ret rn to continue to fund future horses to be trained in the region.

The opportunity to tr n horses on Levy's Beach and the dunes is critical for the ongoing success of horse traim g in Warrnambool which I am fully supportive of.

Regards, Parks Victoria - Non-Confidential Submissions to Draft Belfast Coastal Reserve Management Plan 2018

Sunday, 4 March 2018

Manager Parks Planning Parks Victoria Level 10, 535 Bourke St Melbourne VIC 3000

To whom it may concern,

Re: Warrnambool Beach Training Support Submission

The opportunity to train horses on Levy's Beach and the dunes is critical for the ongoing success of horse training in Warrnambool which I am fully supportive of.

Regards,