The Director
Urban Assessments
Dept of Infrastructure Planning and Natural Resources
GPO Box 3927
SYDNEY NSW 2001

DEVELOPMENT PROPOSAL
73 LOT RESIDENTIAL SUBDIVISION,
Lot 31 DP792506 Glasshouse Rocks Rd, Narooma
MP 53-12-2004

Our Association objects to this Master Plan and the subdivision it proposes. The strongest point made in community discussions of the Draft Settlement Strategy for Eurobodalla was the need to stop urban sprawl and protect remnant bushland on the coast. Lot 31 should never have been zoned Urban Expansion. It would not be zoned that way today, and the opportunity exists now with the development of the Narooma Structure Plan and the Eurobodalla Urban Settlement Strategy to correct past mistakes and rezone the Lot to Coastal Protection.

The Master Plan is very misleading firstly because it only looks at part of Lot 31 when the whole area should be considered simultaneously if any sensible planning decision is to be made. From text and diagrams in the Master Plan it appears that Lot 1 is zoned 4a (Gaia Research p 2) and so will be completely cleared for industrial development (although the text on page 2 of the main Plan appears to confuse the future uses of lots 1 and 3). Lot 2 will be developed as a dam with "fringing vegetation" which presumably means it will be mainly cleared. The subdivision on Lot 4 will need to be almost completely cleared to meet bushfire protection asset protection zones. And if any of the hollow trees remain they are sure to disappear when houses are built and people become worried by old trees that may drop branches. If Lot 31 is not protected by a more appropriate zoning the remnant bushland will be lost.

The Master Plan implies that the bushland of the site will remain intact.
1.51 Opportunities b) "The subject site comprises expansive natural bushland that provides bushland amenity." As can be seen from our paragraph above there will be little if any bushland left when Lot 31 is fully developed. Biodiversity opportunities will certainly not be maximised as the Plan claims.

Much of the claim to "retain the natural bushland character of the site" (4.1) is based on having building envelopes on the larger than usual subdivided lots. How will building envelopes be enforced? The Urban Expansion zoning allows even denser development than the Residential General zone, in fact it is so flexible as to be almost useless. With large lots it is much more likely that there will be more dwellings built on each lot than more trees retained. There will certainly be no understorey shrubs left if the asset protection zones are adhered to.

It appears that the only place where biodiversity could remain would be in the riparian buffer. This gully is already suffering from lantana infestations and an increase in run-off combined with garden escapes/dumping from adjoining properties will only increase the weed problem.

It is also very misleading for the Master Plan to say that "this subdivision will not result in soil disturbance as clearing for boundary definition only by slasher is proposed." Doesn't the Plan also intend that there will eventually be roads made; building construction; water, sewer and stomwater pipes laid; perhaps underground electricity, etc.

Coastwatchers does not see how this development can claim to take into account "the design principles and objectives of the Coastal Guidelines for NSW in respect to its sympathetic environmental and scenic amenity considerations."

The Master Plan is also misleading in that it claims that "the site is contained within present town boundaries under the Draft Narooma Structure Plan.". However, on page 12 it says "Under the Draft Sturcture Plan it is proposed to extend the urban town boundaries of Narooma to Glasshouse Rocks Rd" (note this is not south of the road). The paragraph goes on to say "The subject site is identified as being subject to detailed consideration of ecological matters."

On page 20 the Plan quotes the Rural LEP 1987 Objectives of the Urban Expansion 10 zone
(b) to ensure that consideration is given by Council to:-
(iv) the limits of urban development within the urban expansion zone in view of the fact that urban development will not necessarily proceed over all of the land within this zone".
For all of the above reasons Coastwatchers believes that this is a case where development should not proceed in the Urban Expansion Zone.

CONCLUSION
The review of Eurobodalla's Local Environmental Plans together with the Settlement Strategy and Narooma Stucture Plan provide a unique opportunity to remedy past planning errors. Coastwatchers urges you to reject this Master Plan and the subdivision it proposes.