Surfers Appreciating Natural Environment (SANE) is a local, community-based environmental group that has worked on restoration of coastal cliff top flora at Bells Beach for just over twenty years. We are mindful of our reliance and inter-connectedness to other like-minded groups across Torquay and Jan Juc. Needless to say, it is the determined longitudinal efforts by many within this community that have successfully recreated contiguous habitat over large sections of our coastline. Without these groups doing what they do, Torquay and Jan Juc would be a much poorer place to live. Jan Juc Creek has an important role to play as a connecting coast to hinterland wildlife corridor. It is with this in mind that the SANE committee raises our concerns about the water harvesting proposal for Jan Juc Creek.


The Royal Automobile Club of Victoria (RACV) is planning to develop and upgrade the Torquay golf course. As part of this development they wish to harvest stormwater generated by the impervious areas associated with adjacent residential development.
The RACV contracted Aecom Pty Ltd, consulting engineers, to prepare the design and Alluvium Consulting to assess the potential environmental impacts on Jan Juc Creek. AECOM provided advice to Alluvium on the ecological impacts.

Concerns: (For the remainder of this submission, original report information from Alluvium and Aecom is shown in black with SANE comments shown underneath in red.)

Alluvium was engaged to review the work undertaken by Aecom but with the specific purpose of providing a position on the impact on the environmental values of the Jan Juc creek and estuary.
Whilst the opening statements suggest a study of the environmental values of Jan Juc Creek and Estuary, the actual study area is limited from Duffields Road to the coast, thereby excluding the creek west of Duffields Road.

These changes from urbanisation have a detrimental impact on receiving waterways. The water quality is often poor and commonly has high loads of nitrogen, phosphorus and toxicants.
Whilst this generalized statement may be true, there is no factual data in the report that relates directly to Jan Juc Creek. It would be fair to say that many assumptions have been made based on generic information within the report.

Through this assessment we found that the instream lower part of the Jan Juc creek and its estuary largely to be degraded with poor environmental values.
As made clear in the peer review reports, whilst Aecom suggest the lower part of the creek to be degraded with poor environmental values, they do not back this up with any aquatic, amphibian, bird life, mammal or invertebrate studies. The report also fails to state that there is an active community-lead group; namely the Friends of Jan Juc Creek that is intensely engaged in restoring the area to its highest possible ecological value. Furthermore, that FoJJC are one of just a number of interconnected community groups across Torquay and Jan Juc that are collectively resolved to restoring the ecological values throughout the area. Indeed, Torquay and Jan Juc have a long history of success in this regard. Therefore, rather than limiting the options available to the community and Jan Juc Creek; the correct response by all concerned should be to maximize community aspirations; not undermine them.

Urbanisation can have both positive and negative effects on riparian vegetation depending on the condition of the waterway prior to development. If prior to urbanisation the waterway was located on a rural property with poor stock management, then the flora richness and longitudinal connectivity is likely to have been highly compromised. In these cases, urbanisation can actually result in substantial revegetation activities, producing a net vegetation gain for the waterway. At the other end of the scale where urbanisation is introduced to more pristine environments weed invasion is common and likely to decrease the value of the vegetation on the waterway.
For the most part, urbanisation in towns such as Torquay has displaced rural agricultural landuse with both positive and negative impacts on the vegetation community.
The comments regarding vegetation (as shown here within the Aecom report) are so general and vague as to be meaningless.
As areas become more urbanized there are often a number of impacts on the value of the natural environment. These include changes in the natural vegetation community such as species composition and weed invasion. Although such changes may be significant from an environmental perspective, the public will not necessarily perceive the changes as affecting aesthetics.
As areas become more urbanized, there is generally greater public interest in the open space areas and a corresponding pressure to maintain aesthetics of the waterway environment. This normally means that the public expects actions such as increased grass cutting, maintenance of formalised recreational paths, and maintenance of areas of revegetation.
The SANE committee agrees that the public expects revegetated areas to be maintained. There is also a high appreciation of the natural environment for many people that live here- hence the large number of community groups in our area that are dedicated to this aspect.

Environmental values of the lower Jan Juc creek and its estuary
Due to the degradation of the site there are no threatened species noted as being recorded in the Jan Juc creek and its estuary, but a Biosis report (2007:2008) did identify several matters of ecological significance.

Aecom : Vegetation and Habitat:
With the exception of the coastal scrub, the majority of the site has been substantially modified, and is dominated by opportunistic exotic and native species. These modified areas may provide habitat for numerous exotic and common native fauna, however, they are considered unlikely to provide high quality habitat for rare or significant native species which may be present in the area.
The coastal scrub is likely to support medium to high quality habitat for a number of native fauna including a range of reptiles, amphibians, small mammals and birds.
Threatened Species:
No evidence of threatened species or the Coastal Moonah Woodland Community was recorded on the site during the site inspection.
The SANE committee is pleased to see there are several matters of ecological significance that need to be noted within the RACV proposal. Therefore, given that the Jan Juc Creek is a public asset with agreed matters of ecological significance, the SANE committee feels emphasis should be with giving the community the best chance to further its ecological restoration goals and indeed, link up with the high values associated with the coastal scrub at the mouth of the creek.  SANE also notes AECOM’s observations about there not being any Coastal Moonah Woodland Community- which is ironic because reinstating that vegetation unit is precisely what the FoJJCk is on about. It is also one of the vegetation units SANE has been working on for over twenty years. Our belief and experience is there is every reason to be optimistic about restoring most of the former ecological values associated with this vegetation unit.

SANE also notes the concerns outlined by the two peer review reports.  These reports are alarming and raise issues about the veracity of many points made in the original documents.  The issue of catchment volumes being a case in point:
 “Whilst the collection of stormwater for irrigation has merit, this scheme, as proposed, has not demonstrated sufficiently that it will not have a negative impact on the values of Jan Juc Creek and its Estuary. No detailed analysis on the overall catchment characteristics or seasonality of flows has been presented and, whilst the harvesting may be favourable for a proportion of the flows, it is not evident over the whole range of flows. To claim that the scheme will have a benefit, without thoroughly investigating the overall catchment hydrology or values, is misleading.” (Water Technology Pty Ltd, page 9.)

Finally, SANE members are very much aware of the general lack of rain to keep fairways and greens in good condition over the last twelve years in this region.  This is all part and parcel of the ongoing evidence for Climate Change which predicts further ongoing declines in the future. Indeed, within this area the problem has become so common that many golf courses have looked to alternative forms of water security. To that end, SANE is advised that the Portarlington, Anglesea, Thirteenth Beach, Barwon Heads and THE SANDS golf clubs all use recycled water purchased in an ongoing arrangement from Barwon Water.  Curlewis Golf Club is also in the process of doing something similar by installing its own waste water treatment plant to clean untreated water from Barwon Water’s sewer line.
In all cases, the water gained from Barwon Water guarantees supply all year round in all weather conditions. The same cannot be said for the water harvesting proposal by the RACV from Jan Juc Creek.

Thankyou for taking the time to read our concerns. We understand that the RACV will be as concerned as we are to make sure there are no adverse environmental outcomes from this project. We look forward to your reply.


Graeme Stockton
(on behalf of the SANE executive)