23 February, 2007
The General Manager
Eurobodalla Shire Council
PO Box 99
MORUYA NSW 2537

DRAFT BATEMANS BAY CBD STRUCTURE PLAN

As for the original draft plan, Coastwatchers Association supports most of the ideas put forward and would like to see them implemented. We emphasise that it is necessary to have strong planning rules to mould the shape of the future town. Individual private developments and re-developments will not achieve a good town structure nor optimise public spaces unless proponents are made to take into account the public good.

We are disappointed that the Structure Plan is only equivalent to a DCP. The guidelines need to be rules and should be in an enforceable LEP.

Many of our original comments are summarised at the end of this submission. This does not indicate the priority we give to the concerns listed.

It is a shame to have spelling errors detract from the presentation of all the Structure Plans - the word "complement" should be used throughout not "compliment"

QUESTIONS AND COMMENTS REFERRING TO THE CURRENT DRAFT

Once again the Draft Structure Plan does not seem to adequately consider climate change.

Section 4 of the Coastal Hazard Management Plan, prepared by Webb McKeown and adopted by Council in 2003 says of the CBD that, "The adopted wave setup levels are similar to or higher than the existing CBD foreshore wall, and the surrounding roadway and ground level. Therefore, during design conditions, waves could overtop the training wall and encroach over the foreshore and backshore areas".

Since then Council has done work on the rock wall and extended Murra Murra Mia walkway but over summer 2006-07 waves were overtopping the new work. This reinforces our belief that Council is failing to grasp the implications of now inevitable climate change.

Sections 3-4

How will Council be able to keep the Foreshore Precinct for Tourism accommodation and ban private residential? Will this be a zone in the LEP that does not allow residential accommodation?

Coastwatchers fully supports the reduction in carparking spaces to allow the development of green spaces for the use of the public, for example, the foreshore park at Clyde Street. However, this is completely different to private developments. If there are to be reduced parking requirements to encourage development in the Foreshore Precinct where will users park? Given cost estimates for Council works are usually very much below the final construction costs, levies in lieu of parking spaces will probably not cover construction of parking areas close to town.

Sections 5-6

All streets and plazas should be guaranteed to be shadow free for the middle of the day - not just North St and Flora Cres.

Section 6

"Book end" sites seem a very doubtful way to break up the skyline as they have the potential to be so much taller than the rest of the town and could be visual eyesores (especially on the corner of Vesper and Clyde Streets).

"Discretionary" height limits are a concern to us as they leave gaping holes that could undermine the objectives of the Structure Plan.

Each site will have specific engineering problems as the whole CBD is on a sand bar that will be impacted by climate change, rising sea level and water table. How will tall buildings be able to put down firm foundations and what impact will there be on existing buildings from pile driving?

The sketch elevation of Clyde St is not to scale and appears to exaggerate the width of the foreshore park.

The setback and height limit shown on the Orient St North sketch is not sufficient to permit solar access to Blandford Mall - winter shade is already half way across the mall.

SUMMARY OF COMMENTS FROM COASTWATCHERS' SUBMISSION ON THE ORIGINAL DRAFT STRUCTURE PLAN BATEMANS BAY

COASTAL HAZARDS/ FLOODING

• Regarding inevitable sea level rise - the time will come when a levy is needed around the low-lying part of the town. It should be provided for in this plan even if it is not built for many years.
• It does not seem sensible to recommend underground carparking in low-lying areas already liable to flooding especially given that the water table will rise with sea level.
• Given that storms are predicted to become more intense, flash flooding in the flood basin is therefore more likely in future, especially as there will be more intensive development and more hard surfaces in the catchment. How does the Structure Plan provide for quick evacuation links to higher ground surrounding the flood basin?
• All proposals should have to completely satisfy the objectives and recommendations of the Coastal Hazards Management Plan and Study and this should be stated in the LEP.

GREEN SPACES

• A setback to Murra Murra Mia Walkway would enhance the appearance and usability of the waterfront and better link the town with green public spaces. The Green Boulevard is to have "a minimum 8m landscaped setback or plaza area" and this would be more appropriate for the waterfront too.

BUILDING HEIGHTS

• If taller buildings are safe to erect then ideally new buildings proposed by different proponents should be planned to link to one another on upper storeys so that there is easier access to commercial offices. Arcade type developments are good in this respect. They will need to provide elevators or similar so that elderly and disabled people and parents with strollers, etc can easily get to upper floors.

ENERGY AND WATER EFFICIENCY

• Energy efficiency requirements should also apply to residential and tourism developments, not just commercial ones. The goal should be to reduce energy use by making maximum use of passive solar design and natural ventilation not just by installing insulation and low energy lighting.

TRAFFIC FLOW AND PEDESTRIAN ACCESS/SAFETY

• The town will require a vastly improved access and traffic flow system. Otherwise the future development of the Town Centre will be severely impeded and its attraction as a tourism destination far less desirable.
• A pedestrian crossing is needed across Perry Street to and from the Stocklands Mall.
• Perry Street could become a one way street - from Beach Road to North Street - while still allowing access to all car parking facilities and maintaining the current bus access. This change would create a traffic loop to connect with Orient Street and exits onto Vesper Street via North Street and the traffic lights. This change would be relatively simple to implement and would reduce pedestrian safety problems in Perry Street.

Coastwatchers agree with the proposal to make Clyde Street one-way, including angle parking along the commercial side for uniformity with Orient Street and to eliminate the right hand turn across the highway to access the bridge.

Coastwatchers Association congratulates Council on the Structure Plan and asks that the final rules be made part of the LEP.

Jenny Edwards
Secretary