Statement to the Victorian Civil and Administrative Appeals Tribunal
Planning and Environment List: VCAT REFERENCE NOS. P481/2014 & P623/2014
From: Alison H Teese, Lochinver Farm, 245 Baringhup Road, Carisbrook 3464
M: 0418 642314; E [email protected].
Ms Teese has lived and farmed locally at Moolort near Carisbrook for 35 years and her
statement draws on not just her local experiences but also local land managers, mainly from
farm families who are still active in practical environmental works, particularly revegetation
on their own properties and roadsides. Her wider experience is listed at the end of this
Statement.
This is an evaluation of some measures proposed by Focus CDS to meet the key amenity and
environmental issues to be considered in the development of a new broiler farm. This
evaluation will reference the two existing broiler farms within the area operated by the same
company Grandview Poultry, as they inform us about the features of the new proposal.
In this Statement, those farms referred are to as Unit 1 and Unit 2 and the proposed farm
subject to this VCAT hearing as Unit 3.
This evaluation will particularly considers two elements of the Code of Broiler Farms 2009
Code Element 1 (E1): Location, Siting and Size and
Element 4 (E4): Landscaping.
These two elements will be examined and evaluated against the key Objectives and Standards
outlined in the Code.
A discussion about revegetation on the Moolort Plains will be included with particular
reference to the David Holmgren’s work on Trees for the Treeless Plains a Revegetation
Manual for the Volcanic Landscapes of Central Victoria .
Unit 1 is located in Rodborough Road and Unit 2 on the corner of Rodborough Road and
Clarkes Road has been operating since October 2012.
Unit 3 is located at 141 Clarke’s Road, Strathlea. There are similarities between the proposal for Unit 3 and Units 1 and 2, so it is important to look at how Units1 and 2 are located and
function within the landscape. Unit 3 is located to the south of Unit 2 on Clarkes Road.
They are located in the east-south part Moolort Plains and are in the Cairn Curran Water
Catchment. The Moolort Plains are a gently undulating volcanic plain, a northern extension
of the Victorian Volcanic Plains. The rainfall varies from over 550 mm in the south to more
than 450mm in the north, it can be highly variable from year to year. It experiences a summer
drought and very cold winters with frosts and exposure to winds, known locally as pleurisy
plains.
See Moolort Plains Topography in appendix.
This area is considered to have high value landscapes with the long vistas to the east, north
and west particularly to the south from the Pyrenees Highway, the visual values of the Plains
landscape were not considered under threat. This is now in question with the building of Unit
1 and 2 broiler farms on these open gentle plains.
This aerial photo of Unit 2 shows the sweeping vistas to the south, now dominated by broiler
sheds. Taken January 2014
The Central Goldfields Shire Heritage Review Stage 1 - Rowe and Jacobs 2005 lists both
Moolort and Middle Creek as important cultural landscapes, quote
4.4 Cultural Landscapes (Low Priority)
It is recommended that the cultural landscapes identified in the previous heritage studies be
further assessed and where necessary objectives and policies prepared for inclusion on the
Central Goldfields Shire Planning Scheme.
These cultural landscapes are at:
- Goldsborough (identified in Shire of Bet Bet Conservation Study).
Dunolly-Burnt Creek Valley (identified in Talbot & Clunes Study).
- Craigie & Majorca (identified in the Shire of Tullaroop Study Stage 1).
- Middle Creek (identified in the Shire of Tullaroop Study Stage 1).
- Moolort (identified in the Shire of Tullaroop Study Stage 1).
- Timor (identified in the Shire of Tullaroop Study Stage 1).
At the March 2014 Central Goldfields Shire Council Meeting, it was agreed to undertake
more work on the Heritage Study. Progressing of these earlier recommendations will take on
more importance now that the Broiler Farms Unit 1 and 2 have been constructed.
Comments on topography and location in the broad Moolort landscape
The Units are located on the ridgeline at height 260 m between the incised valleys of Joyce’s
Creek to the east and Middle Creek to the west and north. Steep scarps lead down to the
valley of the Creeks, the valley floors are much lower 230 m near to the high water level of
Cairn Curran Reservoir .
Revegetation of the Volcanic Plains at Moolort – a brief time line.
This tracks some of the experience gained by the land managers of the Moolort rural and
farming community on revegetation in this northern area of the Victorian Volcanic Plains, as
a central part of the and Loddon Campaspe Catchments.
The history was related to efforts to modify the open wind swept landscapes in the early
1900s with shelter belts, often Eucalypt cladocalyx, sugar gum and exotics, it began with
plantings to protect homestead and work areas to improve the environment on farms. These
plantings have had a spectrum of success and failure over time.
This was followed by demonstration sites for farm forestry in the early 1980s. In the mid1970s, concern was developing around dryland salinity at Moolort and plantings were
undertaken on the recharge areas of Boundary Gully located to the north and of Long
Swamp, located to the north west of Units 1 and 2.
Alison served on the SALT, Salting Action Liaison Team, comprised of both government and
community people from 1979, this lead to the formation of Project Branchout. More farms
became involved revegetation during the 1980s and 1990s. .
Project Branchout - The Loddon Campaspe Revegetation Project in the early 1980s was
formed to encourage revegetation across the Loddon Campaspe Region landscape targeted to
conservation outcomes, focused on both dryland and irrigation salinity. It was a $1 M Project
established on private farmland and road sides including sites on the Moolort Plains,
demonstrated revegetation on over 70 different sites.
There was parallel work at Moolort, as an informal farm trees group, which became in 1989,
the Moolort Landcare Group It undertook a series of studies to support and coordinate the on
ground works. There is over 25 years of active innovative environmental work in this
Moolort Plains landscape. This year, the group plans to produce an interactive map of this
work which will be used for strategic planning on a landscape scale.
The response to these revegetation trials was that the growth of trees and shrubs did not
always meet the hopes of local farmers as to providing the dense shelter belts to slow winds.
Trees did not grow to expected heights and densities yet did provide biodiversity, habitat and
visual interest and some shelter for livestock. While trees could be established in good years
of rainfall on the well-drained red soils more readily than the poorly drained grey cracking
clay soils, they were stunted and thin compared to tree growth in higher rainfall areas to the
south and on the sedimentary derived landscapes to the east and west.
Trees grew more easily on drainage lines which overcame the annual water shortages and in
the sheltered fertile valleys of Tullaroop Creek and Joyce’s Creek. Mixtures of species were
used of indigenous woodland trees to the region, particularly of adjacent land types, so grey
box, yellow box, yellow gum and some work with bulokes and sheokes as well as shrubs.
Project Branchout commissioned David Holmgren to produce the design manual Trees on
the Treeless Plains - A Revegetation Manual for the Volcanic Landscapes of Central
Victoria.
Holmgren’s analysis of the six factors for silvicultural (tree growing) was based in each land
component. These factors of moisture availability, site and soil drainage, effective root
volume, soil fertility, shelter and frost freedom were rated and combined to suggest
revegetation strategies. This informed the land managers of the constraints to tree growing
and suggested strategies to overcome them.
The local farming community were most interested in the design of effective shelterbelts,
Holmgren’s work guided our thinking to try much wider belts than the traditional 2 or 3 rows
to deal with the survival requirements of the trees and shrubs in wind swept and fluctuating
temperature environments and the low moisture limited environments, suited to annual crops
and pastures but not to woody vegetation establishment.
Traditional narrow 2 rows with shrub and trees, 2013, probably planted in mid 1980s.
Northern Moolort Plains.
Holmgren understood that farmers were reluctant to devote wide belts for multi-purpose
shelter belts and particularly suggested roadsides be used for plantings with wider areas being
used. However he encouraged farmers to think in terms of wider plantings of the double
wedge design for better long term results 5, 7 and 9 row plantings.
A wider plantation, say 40 meters of mixed species which would continue to be proactively
managed with thinning, pruning, coppicing would have more impact on the windy
landscapes. While the Moolort Landcare Group has wide environmental interests, the group’s objectives are simple, plant the high recharge hills (which are the volcanic cones), protect the
streams and wetlands and sustainably farm the land in between.
The Moolort members trialled some of these and see some examples from Holmgren
designed shelterbelt plantings illustrated here.
Revegetation moved to direct seeding establishment and protection of remnants and wetlands
and during the harsh long dry, conditions of the 2000 to 2010 period, few new tree paddock
plantings were attempted.
This Holmgren Design is on a favourable site in a sheltered northern property on the Moolort
Plains. It is a double wedge 7 row belt planted in mid 1980s. It is unlikely that this result
would be gained near Units 1, 2 and 3 because of unfavourable soil and climate conditions.
Code of Broiler Practice 2009, what does the local experience bring to implementing the
Code.The Objectives of E 1 is to ensure the location and size of the broiler farm and the
siting of the broiler sheds avoid adverse impacts on the visual quality of the landscape.
In Section 4 of the Code Issue 5. Visual amenity, says While broiler sheds, like other
agricultural buildings are an acceptable part of the rural landscape, the construction of
several sheds may significantly alter the character of the landscape.- page 13 of the Code .
If the Code states that several sheds can significantly alter the character of the landscape, then
it stands that the 16 sheds already constructed have already significantly altered the Character
of the Moolort Plains landscape.
The gentle rolling plains open agricultural landscape around the southern Moolort Plains is
now dominated by sheds constructed for Units 1 and 2. This brings us to compare the scale
the shed construction for Unit 3 and with farm sheds in surrounding agricultural operations
The size of each shed for Unit 3 is 17.37 m wide and 172.00 m long by 3 m wall height and
roof ridge lines at 4.3 m, the floor area of approximately 3000 sq m. There are proposed with
the design of Unit 3, two lots of 4 sheds, aligned east-west making a total of 8 sheds, giving a
total floor area of 24,000 sq m.
To compare with the large broiler farm sheds compared to a very large farm shed on Moolort
Plains, we look at this image of the nearby shed immediately west of Unit 3. The shed is in
the bottom left foreground, it is to be noted that the scale of the broiler sheds is far in excess
of the largest agricultural shed adjacent.
Photo is taken from the south in January 2014.
This is regarded as the largest farm shed near Joyce’s Creek. The broiler farm shed base shed
area of 24,000 sq m is of the order 25 times the size of a big Moolort farm shed required to
carry on agriculture in the Moolort area.
However taking into account the ground area defined by the Unit 3 plans to be enclosed by a
vegetation screening, the area is about 450 m long by 146.0 m wide which covers 65,814 sq
m or 6.5 hectare. Unit 3 would occupy around 7.00 hectare without considering the
proposed dam. This is a very large area to be screened from the surrounding roads and the
Joyce’s Creek Valley. An additional 12 silos, approximately 9 m height would be seen on
high part of landscape too. It is unlikely that the best managed revegetation landscaping will
screen the silos.
The Standard E1 S1 is Amenity Protection; to comply should incorporate the following
approved measures
Approved Measure E1 M1.3 – asks that prevailing meteorological and topographical
features are taken into account. For example, how did Focus CDS account for these key
features in determining adequate separation from sensitive uses, in addition to the separation
distance requirements. Has Focus CDS assumed it is enough to apply minimums only to
protect sensitive uses?
E1 M1.4 Unit 2 the boundary setback has not met the objectives of E1, to the west it does
not meet the minimum of 100 m boundary setback, it has been reduced to less than 80 m.
Will Focus CDS ask for this again for Unit 3 Construction?
This location of siting again on a highly visible ridgeline hardly meets E1 S1Amenity
Protection and relates to the demonstrated ongoing reduced amenity accentuating the odour
impacts and the impacts on visual amenity over the life of Units 1 and 2.
Standard E1 S3 Protecting the visual quality of the landscape.
Approved measure E1 M3. is Existing ridgeline vegetation is maintained to avoid breaking
the ridgeline silhouette. This measure was not shown to be complied with again for Unit 3 .
The original ridgeline vegetation according to EVC mapping was a plains grasslands with
vegetation no taller than 1 m. The present ridgeline vegetation is agricultural annual crops
and pasture no taller than 1 m. The development of Unit 2 broke this ridge line and the
proposed Unit 3 would break the ridgeline silhouette again. Note the attached Moolort
Contour Map.
Focus CDS does not demonstrate that this ridgeline silhouette has not been broken or how
buildings and works are sited to account the special topography of the site and to account for
views from public roads, to minimise their visual impact on the landscapes. Indeed the
business name of the Units is a Grandview Poultry; is this related to the location of the Units?
Is so called because the broiler farms get a grand view or because the public roads get a grand
view of the broiler farms?
It is to be emphasised that all Units, existing and proposed , are inappropriately sited on the
high and exposed ridgeline of altitude 262 m between Middle Creek and Joyce’s Creek, they
are highly visible in the area, do not nestle into the landscape and can be seen for long
distances. The Units are highly visible in the Strathlea Valley of Joyce’s Creek in the east.
Further, Focus CDS do not show how the location and siting of these Units demonstrate how
to minimise the impacts on visual amenity, maybe Focus assumes that the measures will be
effective without site and location analysis.
The siting of Unit 1 and 2 does not ensure that the visual impact of the sheds is minimised,
these sheds can be seen from up to
· 7.5 kilometers to the south –west,
5.76 kilometers to the north west and
for a distance of 6.4 kilometers along the Pyrenees Highway B180 to the north .
See Road map of M Lewis which shows where the proposed broiler sheds will be
visible from.
The roads include
Pyrenees highway
Strathlea Road
Rodborough Road
Clarkes Road
Hurns Road
O’Callaghan’s Road
Nicholls Bridge Road
Salagaris Road
Cotswold Road
Smeaton Road
Baringhup-Moolort Road
Shiells Lane.
This makes for a substantial impact on the visual quality of the landscape. Note that this
includes a major regional highway, the Pyrenees Highway B180 that stretches from
Castlemaine to Ararat.
·
·
·
Map showing visibility of existing sheds from highways and local roads.
Note the red stars indicate Grandview Unit 1 and 2 are visible.
Is the landscaping of Units 1 and 2 going to integrate the broiler farm into the surrounding
landscape?
It is difficult the preserve the visual quality of any landscape with the landscaping planned.
A 10 m wide three rows of shrubs and trees to protect from the impact of large industrial size
complexes in this landscape is not of the right scale. The attempts, so far, at screening with
native plants demonstrate this clearly.
As this ridge is a natural open crop and grassland where even local trees and shrubs do not
grow well and certainly not to the heights required for screening of greater than 8 m.
The soil types have not been described by Focus CDS for the Unit 3 Shed Site, where
vegetation for landscaping is expected to be established. The soil is most likely to be fertile
cracking basalt derived soils either dark grey prone to seasonal waterlogging or freely
draining red loamy soils or a mosaic of these type of soils, described in the Moolort Landcare
Common Soils Report 1993
Soil types will be a critical part of assessing the suitability of plants suggested in the
landscape plan as plant growth both woody and herbaceous is strongly influenced by soil
type. These soils make for difficult tree growth.
While, the cracking clay soils derived from basalt make excellent soils for cropping and
pasture growth with short annual growing periods, as outlined in Moolort Soils report, but
they are very difficult for woody species like trees and shrubs. These clay soils expand and
contract, with drying and wetting, making for difficult growth conditions for perennial
vegetation. Tree and shrub root systems are effectively root pruned by this movement
resulting in difficulty of establishment and then if established, resulting in stunted tree
growth, compared to nearby favourable land in the Goldfields.
The Victorian Volcanic Plain bioregion offers descriptions of Ecological Vegetation
Communities EVCs which are relevant to the site of all Units, see attached.
EVC 132_61: Heavier Soils Plains Grassland – treeless vegetation less than 1 m tall see
attached
EVC 132_62: Lighter –soils Plains Grassland – treeless vegetation less than 1 m tall, but
have originally contained scattered woody plant see attached.
It is to be noted that this is consistent with the 1853 Selwyn Map attached which shows the
Unit 1, 2 and 3 sites as clear of timber, consistent with first settler Alfred Joyce’s original first hand records which describe this area comparing the kangaroo grass waving in the wind
to the appearance of a wheat crop.
This is unlike higher rainfall areas such as Gippsland where vegetation was cleared for
agriculture. It is understood that woody vegetation was restricted perhaps with silver
banksia, scattered Allocasuarina verticillata (drooping sheoke ) to the north on better drained
soils, bursaria and tree violet, scattered and Eucalyptus camaldulensis river red gum around
some of the swamps and along the valley of Joyce’s Creek.
The attached Moolort Land Systems shows the pattern of different land types near Moolort.
From the Selwyn Map 1853 showing location of Unit Broiler Sheds.
Further north of Units 1, 2 and 3 is an area of Moolort Plains where the vegetation was more
of an open plains grassy woodland, with Eucalypt microcarpa (grey box) and Allocasuarina
luehmannii, widely spaced .
Plains Grassy Woodland EVC was the most extensive vegetation type in this bioregion, but
there was a diversity of other EVCs including relatively large numbers of small wetlands.
The woodlands were characterised by low density tree cover, scattered shrubs and a diverse
and rich herbaceous layer often dominated by Kangaroo Grass.
Extract from Comment –Focus CDS did not analyse the potential for proposed landscaping
measures to shield the proposed broiler farm from intruding into the landscape. Rather, Focus
assumed that such measures would work effectively.
Element 4 (E4) Landscaping , the objective is to ensure landscaping is used to minimise the
visual impact of broiler sheds and litter storage areas, further reduce the risk of adverse
impacts from light and dust on nearby sensitive uses and protect, manage and enhance on
farm native vegetation and biodiversity.
Standard E4 S1 Landscaping
Landscaping provides substantial visual screening from roads, public areas, nearby sensitive
uses not associated with the broiler farm:
Integrates the farm into the surrounding landscape; and provides adequate access and
clearance around the sheds.
The Code states To comply with the standard, applicants should incorporate the following
measures into their development proposal.
Approved measure E4 M1.1 Screening
The landscape plan provides for dense vegetation and planting along frontages to public
roads and other highly exposed site boundaries to provide screening of the broiler farm
buildings, structures and handling areas.
What have we observed from Units 1 and 2 – while the choice of species for tree planting
species used in the landscape plantings is not known, the plantings do not seem to have the
capacity to screen these Units from the surrounding roads and nearby sensitive uses. The
Units are located on sites where planted trees and shrubs do not grow very tall or have the
density of foliage to provide adequate screening of the rooves, shed walls and 12 silos over
8.5 m tall.
Approved measure E4 M1.2 Species Mix
The landscape plan incorporates a mix of trees and large shrubs to ensure effective upper
level and lower level screenings of the farm.
Comment: The applicant supplied a planting list with the initial permit application which
listed species totally unsuited to the 500mm rainfall Victorian volcanic plains of Moolort and
since then a reference to the local EVC for species, has not yet supplied adequate information
on the mix, how they will be established and managed. If the species selection relates to the
local EVCs described earlier, the choices are limited to herbs and grasses less than a meter
tall.
Approved measure E4 M1.3
As far as possible, the landscape plan retains existing trees, particularly native vegetation,
and a mix of native and local indigenous plant species that blend into the landscape.
Comment the site for unit 3 has been used for agriculture since the 1830s, being plains
grassland extensively modified with grazing and cropping. On the Joyce’s Creek section if
the property a Joint project on Riparian Restoration Demonstration site exists on the subject
land.
There is no discussion about the new landowners continuing to cooperate.
There is no reference to revegetation challenges offered by Focus CDS in this volcanic
landscape and it seems to be assumed that trees and shrubs will grow to the heights required
to provide screening, the local experience is different. This has been discussed separately.
Approved measure E4 M1.4 Mounds
Mounds to a height of approximately 2 m are used if the combination of natural topography
and tree planting cannot effectively screen a broiler farm.
Soil from shed excavation, stormwater drains and farm dams may be suitable for
constructing these mounds.
Is this being considered as a measure to screen Unit 3?
Approved measure E4 M1.5
Plantings and vegetation are located no closer than 20 m from the perimeter of the broiler
sheds to ensure adequate shed ventilation, minimise vermin habitats, and provide adequate
shed access and fire-fighting protection.
It is noted that the landscape design layout plantings suggested are to be less than the
prescribed 20 meters from the southern wall and not more than 3 rows around the broiler
shed farm..
Approved measure E4 M1.6
Unpaved areas around sheds are grassed to prevent soil erosion and minimise the heat load
on the buildings through radiation from bare ground.
This is an important environmental management measure. Is this to be done and if so at what
cost?
Approved measure E4 M1.7
Ground surfaces that are exposed to erosion are stabilised with ground cover planting or
other means to minimise erosion.
This is an important environmental management measure. Is this to be done and if so at what
cost?
Approved measure E4 M1.8 outlines Bond Arrangements. These would be regarded as a
minimum not as all that was required to meet the objective of E4
This Bond Arrangement is an important measure in the Code to ensure compliance with the
objectives and landscaping standards, it was not used for Units 1 and 2, and needs to be
applied if Unit 3 is to be constructed. This will cover both the completion of the landscaping
works and their ongoing maintenance. It needs to consider the long life of the site being 40 to
50 years.
The permit approval requires the establishment of a landscape performance bond, to ensure
effective implementation of a landscape plan approved by the responsible authority. This
plan includes a reasonably detailed estimate of the quantity and types of materials, watering
equipment, plants and other inputs required. The amount of the bond provides an incentive
for the broiler farm operator to fully implement the landscape plan and maintain the
vegetation during the establishment period.
The bond arrangement is based on:
• a quote that the permit applicant obtains from a reputable landscape business to implement
the landscape plan, with sufficient detail to identify the costs of materials, plants and labour
• the responsible authority’s verification of the quote, based on its experience
• application of a 25 per cent margin of the verified quote for unforeseen costs – that is, the
total bond equals the cost of the quotation plus a 25 per cent margin
• a bank guarantee for the total amount of the bond to be lodged with the responsible authority
• a time limit for landscape works to be completed
• release of 85 per cent of the bond when landscape works are completed to the
satisfaction of the responsible authority
• retention of 15 per cent of the bond by the responsible authority as a maintenance bond
for three years
• inspection by the responsible authority at the end of the three-year maintenance period,
and release of the maintenance bond if the landscaping has been maintained to the
satisfaction of the responsible authority
• if the landscaping has not been satisfactorily maintained, the maintenance bond amount
is used by the responsible authority to restore the landscaping to the required standards.
Conclusion
Key requirements of the Code of Broiler Practice 2009, an incorporated document into the
Victorian Planning Provisions and all planning schemes are not complied with and are
mandatory for the establishment of all new broiler farms and expansions in Victoria.
Resources : –
Victorian Code for Broiler Farms 2009 – Department of Primary Industries 2009
Trees for the Treeless Plains, A Revegetation Manual for the Volcanic Landscapes of Central
Victoria by – David Holmgren 1993
Common Soils within the Moolort Landcare Group, prepared by Emma Bryant and Mal
Lorimer Centre for Land Protection Research 1993
EVC/Bioregion Benchmarks for Vegetation Quality Assessment - Department of
Sustainability and Environment.
North Central Native Vegetation Plan 2005 © North Central Catchment Management
Authority 2005
A Homestead History being reminiscences and letters of Alfred Joyce, of Plaistow and
Norwood, Port Phillip, 1834-1864; ed G F James
Experience of Ms Alison H Teese
Convenor of Moolort Landcare Group, 1989 and member to date.
Member of Moolort Plains Wetlands Project Working Group 2012 – 13
North Central Catchment Management Authority, Deputy Chair, 2003 - 2006
Victorian Catchment Management Council, Member, 1997 – 2006 and related Committees
Ministerial Victorian Second Generation Landcare Taskforce - Member, 2000 – 2002.
Central Highlands Water, Non- Executive Director from 2001 – 2010.
Victorian Planning Panel, Sessional Member 1988 - 1999.
Implementation Panel for the Box-Ironbark Forests Parks, 2002 - 03
Panel for Community Consultation for the West Victorian Regional Forest Agreement RFA –
2000 – 01
Vic. Bushcare Reference Group, Chair 1997 – 2003 – priority setting in Bushcare.
NHT Australian Landcare Council, Community Member, 1997 – 2004.
NHT Council for Sustainable Vegetation Management, 1997 – 2001.
Land Conservation Council of Vic, 1987 – 1994, Member with expertise in soil conservation
Member, Management Committee of Project Branchout, the Loddon Campaspe Revegetation
Project 1979 – 1989 – a fore runner of landcare and CMAs
Salting Action Liaison Team – 1979 – 1984 Member
Council Member, Vic. College of Agriculture & Horticulture, 1983 – 1988.
Appendices: 1 Selwyn Map 1853