A new report recommends banning commercial horse training in the Levys Point beach area after significant cultural history was uncovered during an inspection that barely "scratched the surface".
The report by Deakin University scientist John Sherwood recognises the area as an Indigenous sacred site and adds new weight to calls to protect the dunes from racehorses.
Dr Sherwood, who was involved in the recent discovery of possible human occupation 120,000 years ago at Moyjil, near the mouth of the Hopkins River, east of Warrnambool, said he found middens at Levys that could be up to 6000 years old.
Dr Sherwood undertook the study pro bono at the request of the Belfast Coastal Reserve Community Action Group (BCRAG), which has led the fight against commercial racehorse training on beaches for the past three years. The study focused on dunes at Hoon Hill, about five kilometres west of Levys Point. There he found fossil soils, cultural material including historic shell fragments and fragments of flint.
"The shell fragments, including estuarine and marine species, including wavy turbo and edible mussel, suggests collection and transport to this sheltered location by Aboriginal people," Dr Sherwood said.
"Interestingly, rocky marine or estuarine habitats able to support these species do not presently occur near Hoon Hill indicating shell collection sometime in the past, possibly at least a few thousand years.
"Also found at this site were two sharp-edged fragments of flint and a small cobble of basalt, again suggesting transport to this location.
"The proposed Hoon Hill horse access track runs across the shell scatter area. Racehorse training along the proposed track will greatly exacerbate erosion and cause further damage to this cultural site."
Dr Sherwood also investigated the environmental impacts that large-scale horse training would have on the site.
"When I visited, two hooded plover nesting areas were visibly fenced off on the beach, and they are a threatened species," he said.
"The problem too is that heavy seas come right up almost to the dunes where the plovers nest, leaving less beach. The proposed training regulations allow horses to be ridden up to five metres inland of the water line, occupying about half the beach width.
"The beach simply isn't wide enough for that when the tides are high and would seriously disturb hooded plover nesting sites."
The narrow access track to Hoon Hill is around one kilometre each way through coastal heath.
A few hundred metres from the beach, two lines of white survey pegs mark out the proposed access track for racehorses from the beach into the dunes, around 10 metres apart.
Fossil soils probably at least 1000 years old are also exposed in the dunes, and indicate a former land surface of the dune now buried, according to the scientist.
"The hooves of the horses would damage the dunes substantially," he said. "My concern is that a lot of the cultural heritage there is not well-documented and a lot of it is buried under the cover of sand. Damage will be done without proper care, which threatens these midden sites.
"I'm surprised these haven't been picked up in the original surveying that is supposed to have been done."
Dr Sherwood's seven-page report found that racehorses should not be allowed to train on the stretch of beach.
If approved, this will set a very ugly precedent.Dr John Sherwood
"I'm sympathetic to banning horses on the beach. If the approvals go ahead it will be a dangerous precedent to set for Victorian beaches everywhere," he said.
"That kind of commercial activity that isn't coastally-dependent shouldn't be permitted. To grant permission is almost in breach of the Victorian Coastal Strategy. I know it's been opposed by some fairly high profile groups, including Birdlife Australia, the science panel of the Victorian Coastal Council and the Australian Conservation Foundation.
"These are credible people objecting, it's not the radical fringe here."
Dr Sherwood believes the site should be protected potentially as a national park.
It currently falls under the classification of coastal reserve, which does permit limited commercial horse training on the beach, Parks Victoria confirmed.
"The Belfast Coastal Reserve Management Plan was finalised in July 2018 and permits limited commercial horse training at Levys Beach and Hoon Hill," Parks Victoria acting district manager Michael Smith said.
"As land manager for the reserve, Parks Victoria will implement the plan."
A commercial licence regulating training is currently being drafted in consultation with Warrnambool Racing Club.
The narrow roads running in and out of the coastal reserve would have to accommodate heavy vehicles large enough to transport up to 160 horses daily.
Parks Victoria said the roads fell under Warrnambool City Council's jurisdiction. Mr Smith said there were no plans to change the reserve's status.
A Department of Environment, Land, Water and Planning (DELWP) spokesman said racehorse training at Levys was temporary and expired in November 2019, after which the training access would be relocated to Spookys Beach car park.
DELWP said racehorses were currently not using the beach and before training at Levys Beach could resume, an Environmental Monitoring Plan had to be prepared and approved by all relevant parties. "We understand the community interest in the future use of Levys Beach and look forward to considering the findings of this report when it is received," the spokesman said.
Marine and Coastal Act consent for horse training at Levys/Hoon Hill was granted last week. Dr Sherwood's April site-visit report advises against horses on beaches.
"Even with my non-obtrusive observations I've been able to see how significant the site is and I didn't even go digging or excavating, I only scratched the surface just enough to see there is a midden material there," he said.
"There's a story of shellfish harvesting and a rocky coast with species that we don't find there anymore.
"It verifies the traditional owner claims that there are sites in this area, probably many of them undiscovered, unexplored, uninvestigated. This is just a clear one at ground zero for the horse training."
He said the issue had surpassed local status. "This is an issue that might dog this government for quite a while. It's a very deep-seated environmental concern. If approved, this will set a very ugly precedent for the rest of the state and the country."