10
Mar
2021

A Rejection of the Ocean Reef Marina Business Plan

HOA ORM Business Plan March 2021

Dear CEO

This business plan is an onerous economic burden and liability that we want you to reject on behalf of our community, and all ratepayers and taxpayers.

You have never divulged the total extent of environmental destruction this marina housing estate would cause. The business plan only assesses the potential liability from altering the sand flow around the breakwall.

The Tonkin Government in 1972 proclaimed Marmion Marine Park to stop the continued coastal development because the local impacts of dredging and blasting are not in fact local, but widespread with future cost implications.

Today with our better understanding of these environmental implications we know the coastal processes can never be accurately predicted. Numerous coastal development projects in WA, although EPA approved have demonstrated how unintended environmental consequences place a massive financial burden on tax and ratepayers. We should not be building on the coast and a reef. 

What has not been provided as ratepayers is a fully disclosed financial justification and risk assessment for the whole of the development, land and marine and what the lost opportunities are for the parcel of land being sold for only $1.

Irreplaceable Assets

The business plan does not fully realise what we are losing or put a dollar value on the environmental and social losses you expect us to incur:

  • The picturesque cliff backed beaches;
  • World class snorkelling reef;
  • Two surf breaks;
  • richest abalone reef;
  • habitat for birds and animals;
  • Scenic shared path;
  • our cultural identity;
  • fossilized rocks that are an analogue of climate change.

These are all irreplaceable assets for Joondalup, attract tourists and keep us local.

Timeline

The marina was described as BushForever 325 but in 2000 it was classified as Class A Reserve for conservation.

  • Your City of Joondalup Biodiversity Plan says Joondalup has over-cleared. You signed an international treaty in 2008 as a global city to protect biodiversity. 
  • The Coast adapt program[1] is a federal initiative that considers climate change assessing the potential inputs and consequences of coastal developments. The City are aware that the CHRMAP has identified the development area and adjacent zones as at risk from inundation due to sea level rise/ storm surge events. Although claims are made that environmental cell-based studies have been conducted, it’s clear that the level of investigation warranted for this project has not been engaged.
  • We are witnessing the destruction of what we love in Joondalup. We are extremely disappointed by the misdirection and marketing ploys used by council and its associated partners (Development WA).
  • Users of the coast at Ocean Reef were consulted in 2018 on how we valued the coast and how you should manage it for us. The community said in the Coastal Values survey that we wanted the coast for recreation over development. 
  • You let DevelopmentWA continue with this development. The community said no in 2002 but you went ahead planning for a marina until a survey was crafted for the result you wanted.

The roads and public open space that City of Joondalup are having to maintain at the marina development is barely sufficient for the approximate 3000 new residents of the canal housing development (ORM) but you are asking all ratepayers to bear the cost. For the next decade there will be little in the way of rates so revenue to slightly offset the maintenance costs are from other streams; namely parking fees and increased rents for local clubs.

Costs and Revenues

This business plan relies on a five-fold increase in rent from two community clubs, Ocean Reef Sea Sports Club (ORSSC), and Returned Services (RSL) It’s assumed that Whitfords Sea Rescue as a DFES entity will also be a tenant and be required to accept this level of rent increase.

ORSSC will be relocated away from the water to near Ocean Reef Drive. How is this club anticipated to grow with the same number of boat ramps and a location away from the water?

The second stream of revenue is carparking. The mayor and majority of councillors did not know the current state of carparking fees at Hilary’s boat harbour or the present Ocean Reef boat harbour. City of Joondalup said that boat trailer parking will now be controlled by the marina manager, Department of Transport, not City of Joondalup. So where will most carparking fees come from, fines?

A further $4.5million has to be spent on public open space infrastructure including parking meters before revenue flows from parking fees. Are ratepayers expecting a rate increase for this? How can you honestly expect to Activate this location if you charge for car parking Please note, paid parking at both Hilary’s and Ocean reef today is ONLY for boat trailer parking. If normal car parking fees were introduced at Hilarys the already strained addressable market for business there would be further strained.

You have spent $5.5million already on plans and studies for the development. You did not have to include this in the BP which you haven’t, but this is a deliberate misrepresentation of the true financial cost and would see a breakeven point well beyond the 2054 envisaged. No commercial business would be able to “ignore” and extinguish this cost, it was rate payer’s money spent on a range of very expensive consultants, it can’t simply be written off.

The studies for the breakwall that you have commissioned for the EPA assessment are insufficient for ratepayers to bare the liability for the uncertainty building a huge breakwall will cause, and the cost it will impose to maintain. Surely the land transfer should include these cost considerations and provide money for future remediation.

The length of time this marina will take to construct and the lack of any proven or validated demand for pens is concerning. The likelihood is that a small number of pens (possibly around 50) could be constructed to attract early lessees. Unfortunately, until hundreds of pens are occupied commercial marina services, including lifters and fuel bowsers, won’t be cost justified. This will mean that the small number of penned vessels and the early stages of little or no residences constructed will make this location a nightmare for security and anti-social behaviour falling on council and DOT to run 24×7 security operations. Where are these costs in the business plan?

Mullaloo Beach and Sand Migration

We are particularly concerned of the impact to Mullaloo Beach with the Beenyup wastewater outfall hitting the huge breakwall and directing the pollution on to this beach and into the marina entrance.

We are concerned of the altered sand flow, the changed wave action and rips at Mullaloo Beach if protective rock groynes have to be constructed. Where in the business plan is an allowance for remediation cost?

We are concerned that the expected loss of sand from the beach on the northern side of the breakwall where inundation from the sea was expected to almost reach Resolute Way in 90 years, this was the prediction before a breakwall was going in, but the protective vegetation and sand dunes have now been removed for the development. Has the cost of active retreat management been factored in this business plan?

Environmental Risk Factors

There are very few marinas you can swim in. But this marina has Australia’s 6th worst nutrient polluted waste water outfall with the first diffuser only 300-400m from a huge breakwall. How will a polluted ocean pool and little public open space effect carparking revenue for the city? This risk has not been considered in the business plan.

Where is the ongoing data and analysis for the nutrient pollution of the groundwater outflow into the marina over and above the small number of bore samples taken? This will have a major effect on water quality in the marina as DevlopmentWA expected this polluted fresh water to flush the marina.

Why aren’t the associated remedial costs in this business plan? Removing native vegetation and landscaping with lawn will exacerbate this problem.

The 2019 -2020 Watercorp sampling at Beenyup wastewater outfall showed 2 days of chorophyll levels above acceptable. With predictions of increasing water temperature, less diffusion for the Beenyup wastewater because of an enormous breakwall, we may not be able to swim at Mullaloo beach on the hottest days let alone the marina. It is easy to ban swimming but the sea life can’t escape as we have seen in Cockburn Sound with algal blooms. Are there remedial costs in this business plan?

Are we to lose our fishing ground to algal blooms also? This risk should have been considered in a risk analysis in the business plan.

The huge breakwall will be built on the 43 year old Beenyup outfall pipe. Watercorp have said it is your responsibility not to damage it. This is a huge liability we do not want to accept with even the best studies which we don’t think have been done, cannot predict what might happen here. Why has this risk not been assessed and predicted costs published in the business plan as a scenario?

A disservice to ratepayers

In 2002 you wanted a commercial return on your investment for buying 45acres at Ocean Reef for $500,000 in 1979. This business plan should be cost neutral, we insist on a land sale price to realise this and reduce our burden for decades to come. It is a disservice to ratepayers to sell 11+ha for $1.

This development has been marketed as world class and vibrant. Please explain to the public how it is world class and vibrant as the lack of risk and cost benefit analysis shows it to be an economic liability and possibly a world class folly. This “blue sky” marketing may well have deceived the public into allowing the marina construction and placing an onerous economic burden on ratepayers and taxpayers.

We are concerned that City of Joondalup (CoJ) have proceeded with this development unaware that the consults for the Environmental Protection Agency, commissioned with our money said there would be total destruction of the richest abalone reef and all bottom living marine live inside the marina, 70m around the breakwall and 500m of the abalone reef to the north.

We are concerned that you have allowed DevelopmentWA to clear land, construct roads with an access permit only and no business plan prior to now for public scrutiny, a reckless act against the best interests of your ratepayers.

Lastly it is disappointing you pay your respects to traditional owners past and present but you are condoning the desecration of the best remaining example of their traditional way of coastal living and mobility, tribal hunting and gathering grounds, ceremonial and sacred coastal limestone cliffs just because it did not have a registered site on it. If we are to preserve the Aboriginal culture, we need to preserve Ocean Reef.

We request that the City engage an external independent financial consultant with expertise and experience in marina and reclaimed land developments, to undertake a peer review of the Business Plan with the results made available to the public as part of the Business Plan consultation process.


[1] https://coastadapt.com.au/about-coastadapt