The Director General                                                           8 February,  2009
Department of Planning
information@planning.nsw.gov.au

We are an environmental group that was formed 25 years ago and have a membership of more than 250 individuals. We cover the whole of the Eurobodalla Shire and have actively engaged with all levels of government in that time.

We have been particularly involved in reference groups looking at the settlement strategy and structure plans for the towns and settlements in the shire.  Coastwatchers has also been participating wherever possible in the shaping of the new LEP.   From these activities and close liaison with other community groups we believe we have a good understanding of the sort of development that the people of our shire desire.

It was therefore very disappointing to see the proposal for East Moruya Village as the developers seem to have completely ignored the Local Environmental Plan (residential flats and many of the proposed businesses for the Village Square are prohibited in the 2g zone), current design guidelines, the Regional Strategy, Eurobodalla Settlement Strategy and the Moruya Structure Plan.

SUMMARY
While we believe part of the site is suitable for a development, it should be a sensitive plan that:

• does not impact on the Endangered Ecological Community – a recovering Eucalyptus tereticornis woodland-Themeda australis grassland; and
• does not impact on the wetland.

Other features of the existing plan which need changing are:

• the poor design of the proposal’s Village Square and Botanica buildings;
• the size of the proposal’s commercial centre which is too large and will impact on the town’s existing businesses;
• the density of the proposed development; and
• traffic impact at the intersection of South Head Rd and the Princes Hwy.

There also needs to be considerable attention paid to the social impact of the proposal.

Protection of the Endangered Ecological Community
From the plans and reports to Council it appears that the developers have made no attempt to protect the endangered Forest Red Gum/ Themeda Grassland community.  This has to change and provision needs to be made to keep the remnant community in some sort of reserve.

Poor design of the proposal’s Village Square and Botanica buildings

The proposed buildings are over height, too bulky, ignore planning guidelines, do not suit the topography and are of poor architectural merit. 

The Eurobodalla Settlement Strategy, referring to Moruya as an inland coastal town, calls for the settlement character to be recognized and development controls implemented to ensure that new development, including subdivision, respects and reinforces the existing character.

We are totally opposed to allowing the developers to ignore the wishes of the community and set a terrible precedent for the town and the shire.  The buildings should be reduced to no more than two storeys and redesigned to reduce their bulk and complement the site and the nearby town.

The size and impact of the proposal’s commercial centre

This development is within 10 minutes walk of the central business district of Moruya. The creation of a commercial precinct within the subdivision will undermine the viability of the existing township; discourage interaction within the existing community and represents poor planning outcomes.

The proposal ignores the directives in the Eurobodalla Settlement Strategy to:

• Protect and reinforce the existing hierarchy of commercial centres, and towns and village main streets as the commercial hearts of settlements
• Manage retail development so that new development does not cause adverse economic or social impacts on existing centres
• Ensure that all new commercial development is situated within existing settlement boundaries and within identified business zones

The density of the proposed development and heritage impacts

Similarly, the density of the urban component of the development should be reviewed.  Townhouses are classed as residential flats and are prohibited in the 2g zone.  The lot sizes are so much smaller than the rest of Moruya that the new development will not suit the character of the town.  We would like to see a minimum lot size of 800 square metres.

The Moruya Structure Plan specifically calls for:

• A 40 metre landscaped buffer to the Princes Highway
• The application of Moruya Style building design guidelines to ensure that local built form character is respected
• Subdivision layout that builds upon the existing town layout and promotes social interaction     (as distinct from gated communities)
• The existing Bunya pine and outbuildings listed as heritage items are preserved as features of any new subdivision.

All of these requirements should be met by any proposal for the site.

Traffic impact at the intersection with the highway
The intersection at South Head Rd and Princes Highway is already a problem particularly during holiday periods. There are no future plans to solve this problem and the proposed dense development with its large commercial component will only exacerbate it. 

Social impact

We are also concerned that very little thought has been given to the social impact of dramatically increasing the aged population of Moruya with this “gated” community. Occupancy is unlikely to be limited to the Shire’s existing residents. 

The health infrastructure of the town is already overwhelmed and existing medical services would not be able to cope.  There seems little likelihood of a larger, better equipped hospital and more specialists, doctors and nurses in the foreseeable future.

CONCLUSION

Aged care is needed in our Shire but it should not be at such high environmental, planning and social costs when a modified design could eliminate those costs.

Yours sincerely
Jenny Edwards
For the Secretary   Phone  (02) 4471 5032