Ms Paulina Hon
Dept of Planning
SYDNEY

Re 06_0201 72 Lot Sub-division Moruya

Dear Ms Hon,

This submission draws your attention to relevant issues in relation to the above application to the Dept of Planning for a 72 Lot urban sub-division, South Head Road, Moruya.

This association objects to this application on the grounds that it is not wholly consistent with the South Coast Regional Strategy (SCRS), Eurobodalla Settlement Strategy (ESS) and needs to be processed with regard to other developments in the locality of East Moruya.

Of major concern is the applicants desire to place associated infrastructure, roads etc, on land zoned rural 1(a). This is inconsistent with the aims of both the South Coast Regional Strategy and the Eurobodalla Settlement Strategy. The SCRS states that “agricultural lands will be protected from urban expansion” (Jan 2007 p28) and “the location of non-compatible uses in core productive agricultural areas will be limited” (Jan 2007 p29).

Furthermore, the ESS explores the benefits of containing urban sprawl to the boundaries of land use zones. These include the ability to efficiently provide infrastructure whilst retaining productive agricultural land (5.2 Urban Settlement Boundaries, Dec 06, p 65).

As this development is situated at the eastern edge of the Moruya urban settlement footprint and abuts rural land all infrastructure associated with this development would need to be contain within the urban zoning to remain consistent with State and Local Government planning policies.

This development seems to bear some relationship to a major development to the South and West known as the East Moruya Village, 06_0322. The preliminary Assessment contains the sub-division layout of Application 06_0201 in the housing mix Master Plan. This indicates that the two developers seem to be working in tandem and has implications for the assessment process in relation to traffic flow. This association believes that, when developed, traffic to Moruya and South Heads, will use the access via the 72 Lot sub-division. This will exacerbate the peak flows at the intersection of the Princes Highway.

In a submission to the Independent Panel Review for sensitive lands on the South Coast the Roads and Traffic Authority (RTA) strongly indicated that “ direct access to the major routes Princes Hwy from any proposed adjoining urban and industrial development should, as a matter of course, be denied (RTA, ref no 98M3, 06/07/2007). If this is the case for the East Moruya Village traffic will flow through this proposed sub-division and the adjacent existing suburb to Moruya.

The RTA also note that “all development be assessed mindful of the requirement of the developers to fully fund appropriate road infrastructure in accordance with RTA standards” (ibid). In other words developers generally should be require to pay for deterioration of the broader road network through an appropriate infrastructure fund. In the absence of such a fund this development should not proceed.

This association recommends that this sub-division plan be refused for the above reasons and if the developer wishes to proceed then any future application be assessed in conjunction with the adjoining Moruya East Village application.

Yours Sincerely

Mark Fleming