Growing Green

An Environmental Management Plan for Melbourne’s parks, gardens and recreational facilities

COALITION OF RESIDENTS ASSOCIATIONS’ SUBMISSION

GENERAL COMMENTS

Growing Green is an important statement of commitment to the future sustainable management of Melbourne’s parks, gardens, open space and recreational facilities. As a statement of general principle, much of its content is highly supportable. However, there is a concern that the policy is stated at a level of abstraction which leaves most of the hard issues unaddressed. These hard issues concern (1) the competing uses of the parks; (2) the potentially controversial relationship between the past and future character of public open spaces; and (3) the potential conflict between the preservation of important heritage assets and best practice ‘sustainability’.

Policy Context

Increasing the greening and environmental sustainability of the City of Melbourne is strongly supported in many of Council’s existing policies and plans[1], which incorporate the principles in their objectives and recommendations. Current draft policies[2] area also relevant to the matters addressed in Growing Green by providing relevant information on the needs and projected needs of residents and visitors to the municipality, the important role of parks, gardens and public open space for the amenity of people and their well-being, health and community building, and the importance of protecting heritage landscapes and streetscapes. Another relevant document is the People and Spaces Strategy of Parks Victoria.

In the Overview, it would be expected that there would be a background information section, similar to the draft Recreation and Leisure Strategy and the Social Planning Framework in which reference is made to the increased number of residents, the shift in need for building local neighbourhood spaces and linkages rather than for capital city purposes, the need for more inclusive and accessible activities for all (particularly children, youth and the aged) and the high priority given to parks and gardens for recreation and leisure by respondents in an MCC community survey.

We recommend that Growing Green acknowledge and cite the above Council policy and other documents, clearly establish the relationships of the new document with the existing documents and build on these policies as they relate to the management of public open space. We further recommend that a section providing the conceptual context for the plan should be included.

Heritage

The municipality has a magnificent legacy of 19th century parks, gardens and streetscapes. As Growing Green recognises, these need celebration, but also specific attention. The original purposes of gardens (such as the Botanic Gardens) to inform people about exotic flowers and trees from all parts of the world and to provide wonderful passive green leisure spaces (such as the Fitzroy Gardens), based on European norms, remain relevant today. The 19th century streetscapes have rows of European trees (e.g. elms, planes) which provide welcome summer shade and are consistent with the European ambience of their built form context.

The majority of the Growing Green principles are inherently at odds with the high maintenance requirements of exotic species and extensive grassed areas, and there is a danger that their application will promote inappropriate plantings and modifications in heritage open spaces. This is already evident in street-tree substitutions and new plantings, especially those which occurred in the 1970s when native species were newly in vogue; but the problem is ongoing. Park furniture, kerbing, signage and pathways are also important heritage components.

We recommend that, before the management principles in Growing Green are adopted universally, all public open spaces in the municipality be reviewed for their heritage significance and that a separate management regimen for appropriate planting and protection of parks and other open spaces of heritage significance be developed. In our view, it is important that European species are recognised for their significance as plantings in heritage precincts.

Biodiversity

The range of the City of Melbourne’s biodiversity includes 19^th century parks and gardens with predominantly exotic landscapes, pockets of remnant indigenous vegetation and extensive mixed species street and reserves plantings. It is important that these components of Melbourne’s biodiversity are recognised and that promotion of biodiversity is not restricted to indigenous species only. It is also important that the two themes of Biodiversity and a Green and Leafy City are better integrated in Growing Green and that the Council’s planned Biodiversity Strategy is closely aligned with the Growing Green document.

We recommend that the Growing Green document reflects a more comprehensive understanding of the issue of biodiversity and its complexity in the municipality and that the principles in Growing Green are closely aligned with those in Council’s planned Biodiversity Strategy.

Themes and conflicts between them

The format of Growing Green is in six themes, comprising a general list of key directions, objectives, strategies and actions with desired outcomes and measures for environmental, social and economic indicators. These components need to be more tightly related, so that each objective, strategy and action is matched to the indicators. This could be achieved using a single tabular form where the indicators are shown alongside the actions.

Further, both the order of the themes and the boundaries between them is queried. An alternative order might lead with the community needs, heritage, green and leafy city, biodiversity, resources and waste. This order would give priority to the purpose and use of public open space before considering the management of the space itself.

More critically, by formulating policy under separate headings, Growing Green does not address the very real issues of potential and actual conflict between the themes. For instance, Royal Park has heritage significance, remnant indigenous vegetation sites, passive recreation use, public institutional use (Zoo) and major sporting use (Hockey & Netball Stadium). The conflicts between these competing uses have been continuous and increasing over the years and are unresolved. This conflict is characteristic of most of the major parklands. While the Master Plan for each of the parks attempts to balance competing pressures, the full implementation of the Master Plans is some way off.

We recommend that a strategic Municipal Public Open Space Master Plan be prepared, which addresses the overall provision of public open space within the municipality and the dominant purpose and objectives of each public open space area, to ensure an appropriate matrix of open spaces serving particular uses and an appropriate balance in what is available to individual communities as well as recognising heritage, environmental and other key principles.

As a starting point, Growing Green should include a list and map of the existing major municipal parks, gardens, reserves, waterways and other public open spaces. An overview of public open space in each neighbourhood, a discussion of current and future demographics, inclusion of objectives for open spaces from, for example, master plans and local area plans, should be included. The strategic review of public open space in the municipality should then follow, with appropriate community consultation.

Amenity and neighbourhood diversity

Given the increasing numbers of residents living throughout the municipality and the increasing density of development, passive recreational space is an urgent priority. Sporting and other events should be located where they are least intrusive. All neighbourhoods, including the CBD, should include some appropriate greening, especially during the summer months. Hard space, which the document calls “green” in inverted commas, may serve a variety of needs such as relieving urban density and giving access to sunlight, but it is important to the health and amenity of city neighbourhoods that, generally speaking, green means trees, grasses, shrubs and flowers.

We recommend that a “Growing Green” community reference group be established to guide the proposed review of public open spaces, assess the need for additional public open space, recommend priorities for the implementation of the strategy and seek proactively ways to resource the implementation. The group would be constituted of community representatives, users and experts, and chaired by the Environment, Community and Cultural Development Committee chair with a Council officer for project management. It would be expected that the group would be an ongoing entity and report regularly to the ECCD Committee.

Parks and parking

Currently there are many conflict sites where large numbers of cars are parked on parklands to the frustration of people wishing to use the parklands for passive recreation purposes (e.g., Royal Park, Princes Park and Yarra Park) and importantly, to the detriment of the viability and longevity of the vegetation in the parks. We are concerned that the commitment in the Council’s Parks Policy has been watered down in the Growing Green document – to reducing car parking only on grassed areas. We consider that the commitment should be strengthened to rationalise car parking in parkland and eliminate car parking within specified time frames, and, at the same time, proactively promoting public transport alternatives.

A related parking/green space conflict is median parking in many neighbourhoods in the municipality, particularly in mixed use areas. This negative amenity impact on existing and potential green space has been recognised in the Carlton 2010 local area plan. Again promotion of public transport alternatives for access and proactive introduction of median plantations is needed to achieve sustainability outcomes.

We recommend that, in the short term, Council policy against parking in parkland (including the commitment in Growing Green) be strengthened to focus on rationalisation and elimination of car parking in parkland with specific time frames set and associated with promotion of public transport alternatives. Parking in street medians also needs rationalisation as an important greening measure.

Parks and Events

We are concerned at Growing Green’s concentration on parks as “events venues”, their “capacity” for holding events, and cost structures for reinstatement, etc. There is an urgent need to review the environmental sustainability of events, especially major annual events staged in parkland, by detailed monitoring and analysis.

We recommend that detailed monitoring and analysis of the impacts of “events” impacts on parkland be undertaken and made public. The Municipal Public Open Space Review recommended above could be asked to receive the monitoring reports and recommend the feasibility and appropriate use of public open spaces including types of events, hours of operation and costs and whether such uses should be located more appropriately on non-parkland sites.

Definitions

The Growing Green document uses generalist and specific terminology, sometimes interchangeably. The terms: gardens, parks, reserves, parkland(s), public open space require explicit definition. The function and purposes of each of these terms need clarification. Our preference is for the use of the more general term ‘public open space’ to be used in the document, with the term gardens, parks and reserves to be used when specific reference is required. Other terms that need definition in the document are indigenous, native, exotic, biodiversity and environmental sustainability.

Timeframes

The community is increasingly aware and supportive of greening and environmental sustainability. The Growing Green document therefore should place targets and timeframes for the proposed actions – otherwise the 50-year timeframe of the plan could be seen to render them ineffectual in increasing the greening and environmental sustainability of our City. Inclusion of an Implementation section for each theme would facilitate this.

Funding

We have been disappointed in the amount of funds available for “greening” the municipality and note that the amount has been declining as a proportion of the Capital works budget. For several years there has been about $100K for streetscape improvements in each of the four former Wards. This amount is totally insufficient for the scale of greening envisaged in Growing Green and for the envisaged increased population.

We recommend that a proactive strategy for developing a substantial Greening Fund for the purposes of implementing Growing Green be developed. Suggestions include (1) reviewing the policy being applied to, and the use made of developer public open space contributions under the Subdivision Act 1988; (2) advocating a change in the definition of public open space to include streetscape greening so that developers’ monetary payments in lieu of public open space contributions could also be considered for that purpose; and (3) advocating to State Government that the Park Levy municipal ratepayers pay with their water rates be spent on public open space within the municipality. We are opposed to the increasing reliance on commercial events and private functions in public open spaces.

SPECIFIC COMMENTS

[Suggested alterations and additions are underlined. Strategies have been allotted a number according to their order under each theme in the draft document. Wording changes are suggested where it is felt greater clarity and more comprehensive statements are required.]

Theme 1 – Protecting and enhancing biological diversity [page 7]

Melbourne’s green spaces will support increased biodiversity. Natural processes will thrive as a result of …. parklands and the sea and as pollution and other factors that detrimentally affect the processes are addressed.

Exotic vegetation is often favoured … diversity of native birds and animals the vegetation can support. Management, however, is as important as plant choice and this includes control of introduced animals and environmental weeds and addressing pollution.

The range of the City of Melbourne’s biodiversity covers its 19thC parks and gardens with predominantly exotic landscapes, its pockets of remnant indigenous vegetation and its extensive mixed species street and reserves plantings.

The goal is to create a city that has the broadest possible biological diversity in this context.

Objectives

2. An increased range and number of native and other appropriate plants in the city

3. Minimal adverse environmental impact of Council activities on other habitats and ecosystems.

It should be noted that it is not only Council’s activities that should have minimal adverse environmental impacts, given the document’s proposals elsewhere to work with other landowners, agencies, adjoining municipalities, etc.

Where is the justification for just “indigenous” plants – on ecological, biodiversity or heritage grounds? Melbourne no longer reflects its original landscapes, flora and fauna, but that does not mean it cannot increase biodiversity. Biodiversity = biological diversity and includes any diverse mixture of species of insects, birds, plants, animals, and obviously includes exotics and introduced animals. It is not always the specific plant species but the interrelationships with other plants and animals that are critical in increasing biodiversity in a city setting[3].

We would like to see biodiversity addressed on a number of fronts that recognise Melbourne’s original ecological systems, post-settlement heritage and realistic contemporary aspirations in its urban setting.

Objective 1

Strategy (1)

‘Remnant sites’ should be ‘remnant indigenous vegetation sites’ under Strategy and Action and previously under Theme 1’s introduction and key directions.

Action

· Recognise that biodiversity allows for exotic and introduced species as well as native and indigenous.

· ‘The control of weeds and pest plants’ should include ‘pest animals and human impacts’ and not relate only to ‘remnant indigenous vegetation’ areas.

To seek additional sites and to nominate suitable existing open space areas as key sites for increasing biodiversity. The role for ‘greenways’[4] in providing green links/habitat/ biodiversity would also be appropriate here. The Council’s proposed biodiversity strategy and implementation plan cited under Strategy (1) would also be applicable for Action under this additional strategy.

· Expand the range and complexity of plant and tree species, with particular emphasis on promoting viable ecosystems and linkages.

[‘across the city’ treatment is misleading. We do not need a blanket approach that could mean Fitzroy Gardenising Royal Park or vice versa.]

‘To enhance the ecological value of land and waterways’ [so as to also provide greening links]

Action

· Identify sites and implement planting plans to restore river and creek margins and land links.

· Continue to improve water quality through the implementation of storm water strategies and related waste minimisation schemes.

· Control the negative impacts of pest plants and animals (e.g. silver gulls, feral pigeons, common mynas and starlings, foxes) and human impacts.

· Control the negative impacts of soil erosion, instability and other impacts (e.g. land pollution, overshadowing) caused by infrastructure and building developments on waterway banks and land links.

· Preserve existing public open spaces from negative impact from building or other developments, in their role as green areas, through the planning scheme.

[The contribution to heritage and/or landscape values will be enhanced if the Melbourne Planning Scheme establishes buffer zones around parks and gardens, with specific provisions that will foster the retention of sympathetic, human scale developments around the margins of parks and gardens and reverse the trend towards fringing towers.]

To work with other landowners and managers within the City of Melbourne and with other agencies and adjoining municipalities to protect and enhance biodiversity values in the city.

· Develop partnership projects with other agencies such as the Royal Botanic Gardens, Parks Victoria, DNRE, other municipalities.

· Investigate incentives for private developments to provide greening and habitats, including roof top gardens and ‘vertical greening’, where appropriate. [‘Rooftop gardens’ have potential to create overlooking and noise problems in close-built residential areas and are inappropriate in heritage areas unless totally concealed.]

· Encourage CBD building owners to utilise rooftop spaces for greening, accessible open space and recreation facilities.

· Establish replacement programs for significant trees stands and avenues (particularly elms).

· Continue to use regional forums to advocate biodiversity outcomes, … to protect water, air and land quality.

· Involve schools, local communities, public and private organisations* in planting, revegetation, maintenance** and monitoring*** projects.

[*Experience shows such organisations are often keen to be involved in their local area]

[***Outside organisations, e.g. Field Naturalists, birding groups are often keen to involved in monitoring flora/fauna numbers]

· Monitor and report on status of flora and fauna … the spread and types of weeds, fauna species diversity, control processes and any new threatening issues.

· Provide information setting out and justifying tree policies and vegetation choices.

Minimal adverse environmental impact of Council’s, other landowners’ and agencies’ activities on habitats and ecosystems.

· Review sources of all materials used … systems. Where alternatives are available, use appropriate substitute materials. (hopefully in keeping with green and environmentally sustainable principles)

· Investigate applying Council’s current purchasing policy … in relation to biodiversity and environmental impact.

Need an overriding Implementation section that incorporates the Desired Outcomes, Indicators and Measures that more comprehensively address the objectives, strategies and actions in the theme, with targets and timelines.

Need to assess other animals, not just birds, e.g. invertebrates and other native animals, together with reduction in pest animal numbers.

Need to address condition and viability of plant species, reduction/control of weed species, etc.

Simplistic to only quantitate ‘trees’ when the bigger ecological picture, i.e. increased biodiversity, includes the quality and quantity of open spaces, land links and waterways, numbers and spread of diverse plants and animals, increased viability of plants, especially trees, reductions in requirements for pest control, energy and labour costs, land, air, water improvements …..

The objectives for this theme focus on achieving a “right balance” for parks in the context of a range of community needs. The theme headnote refers to “recreational, environmental and economic goals”, in that order. This priority order is reiterated in the 3^rd key direction. The most important objective is balancing the use of parks, gardens and other open space first and foremost in the interests of environmental sustainability, biodiversity and protection of heritage values against state and local community goals, passive and active recreation and public and commercial uses.

We have serious concerns that the emphasis is placed on managing a green space’s capacity to host an increasing number of “events” and built facilities; for it to meet unspecified economic goals; and altering existing policies to facilitate increased car parking, etc. The issue of ‘exploring a park’s capacity to host increasing number of events’ is totally in conflict with increasing its greening and environmental sustainability. Sporting, recreational and leisure policies for the City’s parks, gardens and other open spaces should fit in with the greening and environment sustainability policies, not the other way around.

Public parks should have sufficient public resources to be maintained without the need for private/commercial uses of parklands. Commercial uses should be phased out rather than encouraged.

Importantly, the focus of this theme does not address the important goal of making the municipality’s neighbourhoods, including the CBD, more liveable. The draft Recreation and Leisure Strategy has a more informed introduction to the changing needs of residents in the municipality and their needs for, and use of, public open space. This direction contrasts to the current emphasis on capital city functions and activities that have increasingly occupied some parks and gardens. The draft Recreation and Leisure Strategy recognises that there may in the future need to be a limit on visitor use of the municipality’s public open spaces to allow for the increasing number of local residents, who often have little private open space, to access both passive and active leisure and recreation activities.

The increasing urban intensity is recognised at a global level by the greenways movement[5]. An attractive greenways idea that could be taken up in Melbourne is the creation of car-free routes for pedestrians and cyclists to commute and to use during leisure time.

Melbourne’s parks, gardens, open spaces and recreation reserves should meet the diverse needs of increased residential, worker and visitor populations. Increased green spaces and environmentally sustainable processes will be required to meet the City’s Growing Green challenge. Green spaces should be equitably distributed and accessible for people of different abilities. Existing parks should be reclaimed as parks, with new sites sought to accommodate dedicated active recreational facilities. Attractive, well-designed and flexible facilities will support a range of activities, which meet environmental and recreational goals. Public transport access to parks and recreational facilities will be encouraged with car parking in parkland phased out.

Key directions should be changed to reflect the above green/environmentally sustainable emphasis:

Ensuring equity …, however, no objective or strategy is linked with this direction. Reference to the Cambridge Open Space Plan is provided in the footnote.[6]

Reorder to give priority to the green/environmental sustainability objectives for our parks, gardens, reserves and open spaces in meeting all recreational uses (active and passive). The “broader economic use of the parks” should not be a consideration. Using parks as commercial generators is unacceptable. Public open space should be publicly funded.

A greening strategy should not undo a key objective for our parks and gardens (c.f. Parks Policy, City Plan) by proposing that parking only “on grass” be phased out, rather than “parking in parkland”. This is totally unacceptable since it could encourage an increase in sealed car parks, which is inconsistent with the main purpose of parkland (land for recreation space). Waiting until “alternative opportunities arise” is also unacceptable if that implies alternative car parking spaces. In most situations, it is both expensive and/or impossible to construct more car parks in the immediate neighbourhood. If the Council is to be seen and to act more environmentally responsibly in regard to our parks, then vehicle parking in parks, gardens, reserves, etc. must be phased out with defined timeframes. Measures should be put forward for implementation (not just motherhood statements) to ensure that the many car parks (private, public, institutional) in the city are multi-purpose (business, shopping, visitors, recreational and other events; parking after hours and at weekends). More extensive and varied park and ride ticketing systems should be set up for sporting and other events and venues.

· Improving public open space amenity in the city and neighbourhood streetscapes with appropriate median and other street plantings (instead of parked cars).

1. Publicly accessible open space and recreational facilities of sufficient quantity and quality to meet community needs.

[It is simplistic to just consider ‘parks’. In the 50-year time frame of the Growing Green plan, community needs, open space and recreational facilities may be met also by providing other open spaces (e.g. street medians, green spaces arising from traffic calming measures, green land links, waterways) and purpose-built, non-park sited facilities.

2. Open space and facility assets managed in line with best practice, environmentally sustainable principles. [ “Environmental” is too loose a term.]

3. Access to open space and recreational facilities provided by environmentally friendly transport modes. Public transport access will be facilitated and promoted.

4. Car and vehicle parking in the City’s parks, gardens, reserves and other green open spaces will be phased out in specified time frames.

· Report periodically on net gain/loss in public open space across the municipality

· Ensure private, larger developments include on-site shared/public open space, particularly in neighbourhoods with identified lack of open space. [This approach is reviewed in The Trust for Public Land at http://www.tpl.org.]

To provide recreational opportunities that are appropriate to each of the City’s open spaces.

· Encourage multi-use/shared community use of sporting and recreation facilities (e.g.. North Melbourne Recreation Reserve, State Hockey Netball Centre).

· As appropriate, progressively relocate dedicated built sporting facilities out of parkland.

To balance community use of the City’s open spaces and recreational facilities in keeping with environmental sustainability principles.

· Use demographic data …. to establish changes in demand on open space and recreational facilities.

· Promote awareness in user groups of the Council’s greening and environmental sustainability objectives in managing its open spaces and recreational facilities. [This is the more positive approach.]

· Fund ecological and conservation projects in green open spaces through user-pays (of recreational facilities) principles.

We refer to and reiterate our comments at the beginning of this Theme. This section should be completely rewritten placing the emphasis on the greening and environmental sustainability of the open space, ensuring any “event” conforms with those objectives. Put into public debate - what type and number of events, attendee numbers, associated infrastructure, built structures, setting up and taking down times, access, impact on other users and surrounding uses, etc. are appropriate in keeping with greening and environmental sustainability principles for a given open space.

We oppose developing a cost structure “based on event size and the resources required to reinstate sites to pre-event condition”. An event should not be held if damage to the open space will ensue; alternate sites should be sought. Where is the data about long-term damage to parks and gardens from “events”? Many “events” can be held in other facilities, such as hotels, clubs and reception centres, not in parkland or other sensitive open spaces. Continuous community access to public open space must be the priority. With increasing population in the City, there is an increasing need for our parks to provide peaceful green open space.

Reword so that emphasis is on the environmental sustainability and protection of heritage significance for an event held in a park, garden, reserve, etc. and this is reflected in the accompanying Actions.

· Develop criteria for assessing environment impact of new open space and facility assets.

· the type of activity permitted in a park, open space, etc. should be compatible with the type of open space so that negative impacts on access by, and the amenity of, local residents is minimised

· public parks should have sufficient public resources to be maintained without the need for private/commercial uses

· Develop an information strategy promoting the ecological values and benefits of parks and open spaces and providing more comprehensive information about neighbourhood plants, animals and ecosystems.

Need to include an additional strategy and actions that address enforcement of by-laws and assessment of maintenance and other contracts to effectively protect the City’s parks, gardens, recreation reserves and open spaces.

· Work with the State Government, sporting organisations and major event organisers to provide sufficient, safe … facilities.

· Work with the above groups to develop transport/parking/ticketing plans that will promote and facilitate access to major events and venues by public transport.

· Promote and facilitate public transport access to parks and open spaces. Consider extension of the City Loop as a long-term strategy. Consider free public transport links to key public open spaces and neighbourhoods.

· Phase out vehicle parking on parkland and other green open space areas within specified time frames, as follows:

· Vehicle parking in the City’s Parks and Reserves will be rationalised and significantly reduced in a three-year time frame.

· All vehicle parking in the City’s Parks and Reserves will be phased out in longer, specified time frames.

· Access to public open spaces by public transport will be actively facilitated and promoted.

This strategy could be developed to include ‘greenways’ between parks, gardens, reserves and other open spaces, for leisure walking removed from intrusive traffic impacts (e.g. Pelham St, Carlton between the Museum and University Square). Greenway commuter trails could be planned for people to move to/from the CBD. These could be pedestrian and bicycle only streets with local vehicular traffic access only.

Need an overriding Implementation section that incorporates the Desired Outcomes, Indicators and Measures that more comprehensively address the amended objectives, strategies and actions in this theme, with targets and timelines.

Measures should include satisfaction with public open space, equity, access, use as ‘greenways’. Measurement of “user numbers by population/city visitors” is limited as an indicator of park use. There is no measure of the use of public open space by children (important in local neighbourhood open spaces), older adults or disadvantaged groups.

The impact of parkland use on people living in adjacent neighbourhoods needs measurement.

There is no measure of how people travel to public open space, with comparisons between different modes. Targets for % shift to non-car modes should be set.

The focus of this theme is strongly supported, including building on biodiversity and recognising heritage. The objective for more greening and less asphalt is seen as entirely appropriate for the “Garden City”.

Melbourne will build…destination. Parks, gardens, reserves, streets and other open spaces will contain indigenous, native and exotic plants that are part of ecosystems adapted to Melbourne’s climate and urban landscape setting, including its heritage setting.

3^rd para: Trees and other plants provide habitat and contribute to the biological diversity of a city. [Grasses are important plants re habitat; they are not always green]

Exotic plantings reflect the European character of Victorian architecture and complement the heritage values of heritage areas.

4^th para: “A desired effect” begs the question of what that effect is to be. Reference should be made to the desired character for the particular area as determined by the public open space review.

Maintaining Melbourne’s heritage landscapes and plantings is also important. A tree replacement program with timelines is necessary to ensure significant tree avenues and stands are retained.

6^th para: … such as roads and above-ground power and telecommunication lines.

7^th para: Managing large areas of green grass …. nature strips can be water and resource intensive …

8^th para: First, to reduce the intensity and frequency of irrigation in some areas by allowing longer grass lengths or some yellowing of grass in summer periods. Or to replace existing turf with a more drought-tolerant grass species.

Granitic sand (gravel) is seen as an environmental pollutant because it frequently washes into the stormwater channels. It is not seen as a “greening” feature in local areas, where it is used in kerb extensions and to surround kerbside and nature strip trees. Plantings and mulch alternatives are strongly preferred.

9^th para: The goal for the future … increased areas of plantings, … [to also fit with the document’s objective of increasing biodiversity.]

As Melbourne’s population grows, open space will be exposed to greater demands and additional open space will be necessary. [Open space can be green or otherwise – to serve different purposes. The distinction between open space and growing green should not be blurred by the (ominous) use of the term “green” in inverted commas.]

While these new spaces will go towards meeting community needs, where planted as green spaces, different species of plants will be used that are less resource intensive, contribute to increased biodiversity and managed more environmentally sustainably, creating in turn a more sustainable local environment.

· ensuring that future built and infrastructure development around parks, gardens and open spaces is in keeping with the human context and environmental sustainability of the parks, etc.

· ensuring maintenance regimens protect and enhance the viability of trees and other plantings;

· increasing the diversity and robustness of tree species by implementing street tree replacement as part of wider ecosystems.

· encouraging complementary planting on private land, particularly larger and commercial sites.

It is not just the number of trees and plants that are important, but the mixture/ interrelationships/ecosystems/biodiversity of the trees and other plants. Theme 3 should link with Theme 1.

1. An increased number of trees and plants that enhance biodiversity in a range of ecosystems in keeping with Melbourne’s original and post-European settlement landscapes.

2. An increased robustness of trees and other plants with selection band appropriate for local climatic conditions and Melbourne’s urban setting, including its heritage settings.

3. Improved management regimes to protect and enhance viability of trees and other plantings and increase habitat value.

· Review the current purpose and capacity of street space to identify new areas for planting, in keeping with heritage parameters as appropriate.

· Investigate the proportion of permeable surface in streets to achieve reduced runoff and enhance vegetation. [This action needs reconsideration in the light of the current Council practice of cement grouting the bluestone channels in our streets, which removes a valuable source of water for kerbside and footpath trees.]

· Actively work with other agencies and authorities to develop a scheduled program for the undergrounding of power and telecommunication lines wherever possible

· Work with other public land managers to increase the quantity of plants and trees and biodiversity in the City.

· Work with local communities to prepare and implement street tree and planting schemes.

· Investigate root barrier treatment for significant trees near heritage buildings

· Strengthen Council’s Environmental Reserve to provide for substantial funding for the greening program.

· Provide information on vertical/rooftop gardening in appropriate locations, where the amenity of neighbours or the heritage values of an area do not stand to be compromised.

[As stated earlier, vertical/rooftop greening gives rise to heritage/amenity issues, which should qualify support for such gardening. The CBD may be the place for rooftop greening emphasis.]

· Increase the range of species planted in the City to enhance biodiversity and in keeping with a range of ecosystems.

· Develop a sustainable boulevard management strategy, including an elm replanting strategy with timelines.

· Select, wherever possible and where appropriate, species of trees for planting to minimise resource inputs.

Amend Objective and add Strategies and Actions in keeping with the suggested Objective 3 above - Improved management regimes to protect and enhance viability of trees and other plantings and increase habitat value.

The selection of alternatives to brushcutting around trees must be included.

Each park, garden and other open space will have …the city. ….. Parks, gardens, reserves, other open spaces and facilities will be responsive to community expectations for the protection and enhancement of their heritage and respectful of environmental sustainability.

A city’s built environment reflects its cultural history and community values developed over time.

Parks, gardens (e.g. Fitzroy and Treasury Gardens, Flagstaff Gardens, Royal Park, Princes Park, Fawkner Park) and boulevards (e.g. St. Kilda Rd, Royal Parade and Flemington Rd), are nominated as important under planning scheme heritage overlays.

Living landscapes … scope to improve their biodiversity and environmental management …

6^th para: The general link between parks and other open spaces as public lands …

Some key directions that will aid the ongoing acknowledgement of our heritage are:

· ensuring interpretation and activities are appropriate to the nature and significance of the park, garden or facility;

· ensuring that the heritage character of these places will be maintained and enhanced for future generations to enjoy.

[“available” does not recognise the special significance of heritage parks and gardens which require protecting if they are to survive for future generations “to enjoy” for those heritage values.]

· ensuring that the heritage significance of streetscapes and precincts is recognised and maintained in greening programs.

1. Heritage assets recognised and managed in a culturally and environmentally responsible way. [ see Burra Charter guidelines]

2. Ongoing recognition of the links between indigenous culture and existing parkland and other open spaces.

To optimise the environmental management of key heritage assets including the Fitzroy, Treasury, Carlton and Flagstaff Gardens, Royal Park, Princes Park, Fawkner Park (must list all parks that are included in a Heritage Overlay under the Melbourne Planning Scheme) and the Melbourne City Baths, without compromising their cultural heritage value.

· To the extent that they are consistent with the maintenance of the heritage values of these parks and gardens, apply actions of using resources wisely …. areas.

To accelerate the installation of infrastructure in heritage areas which is in keeping with the area’s heritage significance and reduces overall environmental impacts.

· Replace general park infrastructure … systems in keeping with their heritage significance.

Ensure Aboriginal culture is adequately recognised and represented in parks and other open spaces and facilities.

Interpretation of heritage values should include improving the quality and availability of information about heritage landscapes/streetscapes. Access to this information could be measured as one of the social indicators.

Resource use and management will be well understood … particularly the link between resource consumption, recreational outcomes and environmental sustainability.

3^rd para: Recreational facilities … swimming pools, golf courses and sporting fields, …

5^th para: Add: In addition, water lost through ageing irrigation infrastructure and inappropriate watering regimens also needs to be reduced by increased maintenance/ replacement and operational programs.

Light spill is a resource and environmental issue and should be addressed here [in keeping with the Objective 1 Strategy (3)]

9^th para: The use of chemicals … reviewed to ensure that it is safe and environmentally appropriate and managed …have less effect on the environment and reduce the overall impact on the environment. [The safety of chemicals on human safety also needs reviewing; “appropriate” and “managed” should be environmentally appropriate and environmentally managed]

· reducing chemical use and environmental impact in parks, facilities and reducing off-site impacts;

· seeking joint agreements and programs with other agencies, landowners and managers in responsible resource management;

· considering the establishment of a ‘greening fund’, incorporating developers’ open space contribution levies, parking fee contributions towards streetscape greening, private and public benefactor contributions, and a levy similar to the Parks Levy raised with the water rates.

1. An overall reduction in energy, water and chemical use in the management of parks, open spaces and recreational facilities, whilst recognising special needs in relation to heritage areas.

Objective (strategies and actions) in keeping with suggested key direction above for a ‘greening fund’

· Adopt overall targets, consistent with the Council’s Sustainable Energy and Greenhouse Strategy and other policies.

· Undertake trials to reduce the amount of water … applied to trees and other plantings in parks, medians, nature strips and other green spaces without compromising the viability and longevity of the trees and plants.

· Identify areas of grass and lawn where more appropriate drought-tolerant species can be planted, longer grass lengths or greater summer browning would be acceptable to enable water use to be reduced.

· Replace turf with more durable surface …[It is considered that the replacement of turf with granitic sand is not appropriate in most situations and is widely opposed.]

· Improve the environmental performance of plantings in regard to watering requirements by application of biodiversity and environmental sustainability principles.

· Work with residents to encourage planting and self maintenance of nature strips in residential areas. [This ignores heritage aspects, whereby plain grassed nature strips and medians are included in Heritage Overlay areas. It ignores reality of inner Melbourne’s predominant residential built form as row housing, where mowers would be required to be carried through houses. It ignores the large amount of rental housing in Melbourne, which is generally associated with low interest/maintenance of nature strips outside rented premises. Nature strip and median maintenance is seen as a long-standing Melbourne City Council service provided to all sections of the City. Nature strips and medians are part of the limited open green space in many areas.]

· “Use the Flagstaff Bowling Club redevelopment as a pilot project …” [It is inappropriate to include a specific development in a 50-year strategic document. A generalised statement about future redevelopment projects offering the opportunity to trial renewable energy and alternative materials should instead be used.]

· Include requirement for ongoing water, energy and chemical efficiency in all design briefs.

Increase the amount of renewable energy used in parks and other open spaces and recreational facilities.

· Investigate co-generation at swimming pools [Co-generation opportunities need to be approached with some caution due to potential detrimental environmental and aesthetic impacts of air emissions on neighbouring/residential areas. The Royal Melbourne Hospital co-generation plant is a case in point.]

Revise wording: Substitute chemicals with products with less environmental impact.

Environmental section needs revision, e.g. Decrease in renewable (not natural) resources is desired; measurement of the reduction in chemicals: concentration and volume, is required. Social section should be community satisfaction with levels of resource consumption relative to maintenance of assets. Measure should not be community acceptance of changed appearance of “some” assets when “some” is unspecified and maintenance of appearance may be the desired outcome.

Waste generated through Council operations and park, other open space and facility users will be … Reducing, reusing and recycling are integral …

[Why keep isolating out “parks”, when the Growing Green document refers to parks, gardens, reserves, links, waterways, other open spaces…. It is giving a confusing message, not only in this theme but throughout the draft document. The use of the term ‘public open space’ is preferred.]

· ensuring Council by-laws are applied to effect waste-wise practices in parks and other open spaces;

· working with government and industry to introduce measures to reduce littering, e.g. drink container deposits;

The proposed initiatives in this theme are supported. An additional strategy/actions to specifically address the problem of cigarette litter (butts and packaging), with measures to effectively reduce it, are required. [Cigarette butts are a significant component of litter and of high environmental detriment.]

Amend: To reduce the volume of litter, including cigarette butts and dog faeces, in parks, gardens, reserves, other open spaces and recreational facilities, recognising that such litter often ends up polluting waterways and the Bay.

· Implement educational campaigns and effective enforcement for the responsible disposal of cigarette butts throughout the City.

Strict application of triple bottom line thinking and actions to projects and capital works may not be suitable in the case of heritage parks and open spaces where higher environmental costs may have to be tolerated. The exception for heritage parks and open spaces should be recognised here and throughout.

[1] See Council’s Parks Policy, Tree Policy, the Master Plans (Fitzroy Gardens, Flagstaff Gardens, Royal Park, Princes Park, Holland Park), Municipal Strategic and Local Area Plans (City Plan 2010, NorthWest 2010, Carlton 2010, Southbank Structure Plan), the Sustainable Energy and Greenhouse Strategy, Precinct Tree Planting Schemes

[2] Draft Recreation and Leisure Strategy, Towards 2006 - City of Melbourne Sports Policy, and Baby Boomers and Beyond, Strategies for Over 55s: Draft Forward Plan for Older People 2003-2006 and the Heritage Statements of Significance for heritage precincts presently being developed.

[3] Additional Notes (from comments kindly provided by Zoe Wilson and Ken Simpson, members, Bird Observers Club of Australia):

In a birds & gardens survey (Melbourne City Birdwatch, Bird Observers Club of Australia Report No. 7, 1997), mixed plant gardens had as many bird species as the ‘predominantly native’ gardens, although in the gardens with the highest numbers of species, the gardens were described as ‘mainly native’. Expert opinion is that, in heritage situations, a judicious choice of exotic and native plant species would complement the heritage, aesthetics and would be a valid choice for bird value. Australian plants chosen to blend with European style gardens are a legitimate choice. For example, trees could be exotic but other plantings a mixture of indigenous/native/exotic. There are very many introduced plants that are used by native birds. Banning exotic trees would be unwise for a number of reasons, including heritage, sun control, prevailing climate. There are greater problems for native birds and animals than a park full of elms. Management for biodiversity is required, including choice of appropriate plant species, whether indigenous/native/exotic; discouragement of imported invaders, such as common Mynas and Starlings, which take over hollows of native species (birds, possums); control of foxes, cat and dog impacts; retention of fallen limbs, bark and plant litter as insect habitat. Increasing biodiversity requires as much attention to structure as choice of plants. From a bird perspective, three tiers of plantings are required: upper storey, middle storey and ground level plants - to provide food source, shelter and nesting sites.

The birds species that are likely to come into the city setting are those that are the more adaptable feeders. Intensive planting of nectar trees (e.g. spotted gum as street trees) has encouraged predominantly lorikeets, wattlebirds and other aggressive honeyeaters. Plant provision for nectar, seed and invertebrate production should be equally addressed in the biodiversity schema.

[4] Refer: LIH Landscape Information Hub: Greenways at www.lih.gre.ac.uk/plan/greenways.htm

People and Spaces Strategy, Parks Victoria

[5] See: http://www.londonlandscape.gre.as.uk/udp.htm

http://www.tpl.org

http://www.ci.cambridge.ma.us/~CDD/commplan/greenribbon

http://www.parkweb.vic.gov.au/resources/08_0535.pdf,

[6] The Cambridge Open Space Plan in the United States was developed after an extensive community review of the public open space available to ensure equity and accessibility. One indicator was open space acres per 1000 persons, based on population and open space within ¼ mile of each census block point. There were also figures for the number of 0-14 year old and older people in the neighbourhood, and families below the poverty line. Location of schools and access to sporting facilities were included in the criteria for the review. Strategies were developed to achieve new open spaces in priority areas and shuttlebus services to improve public transport access to public open spaces. The report can be seen at http://www.ci.cambridge.ma.us/~CDD/commplan/ greenribbon.