The Director
Urban Assessments
Dept of Infrastructure, Planning and Natural Resources
GPO Box 3927
Sydney NSW 2001
Dear Sir,
BAY WATERS DEVELOPMENT PROPOSAL
MP 31-8-2004
Thank you for the opportunity to comment of the subject Master Plan. While we understand that this proposal might be within the bounds of the types of developments permitted by the zoning for this site, we object to the proposal and urge a moratorium on this and all population increasing developments until water and sewerage systems can cope.
Your Department is currently considering several development proposals for land in the vicinity of this proposal. Our Association urges you to look at them together for their cumulative impact on local wetlands, on traffic congestion, on water supplies and on the capacity of the sewerage system.
The proponents seek to acquire some of the old road reserve near the shore (2,158 sq m). This is public land beside the Bay. Even if it is the hillside, there is no reason why it should be included in the proponents' plans. The proposal should be re designed to set the buildings back further and keep a few more trees on the public land.
The proponents also argue that the approved car yard on nearby land sets a precedent that allows their service station. We would point out that the car yard has not been constructed and the land could yet be used for something more suitable.
In the Exec Summary mention is made of the need to consider the proposal in terms of SEPP 5 -Coastal Protection. We presume this should now be SEPP 71.
Water. Coastwatchers' policy is to oppose all population-increasing
developments until the infrastructure and supply capacity can
accommodate the development. In this case, there is likely to
be a marked increase in population resulting from the development.
Some 318 people are forecast to occupy the 187 residential units
proposed in lieu of the 56 room motel presently occupying the
site.
The proponents suggest in several places throughout the plan that
the existing water mains will provide adequately for the development…the
existing infrastructure is in place, but no detail is provided
about water saving proposals. The plan mentions (p106) that rainwater
is to be retained on site for reuse. Where and how is not mentioned
but needs to be explained.
Rainwater tanks and reticulation of harvested rainwater should be topics of more significant note. The proponent should be required to ensure that effective rainwater harvesting plans are provided. Communal non potable water requirements as well as domestic garden needs should be catered for from such source without the need for town water back-up. The use of high quality town water for garden use should be discouraged.
The document said the tanks will be for irrigation and outdoor
taps. We suggest further provision be made for connecting them
so as to provide for flush toilets and all non potable requirements.
There is a stated Bushfire management requirement for 22,000l
stored water. This figure seems wildly inadequate to provide firefighting
water for a development of this size. Perhaps the requirement
is for one 22,000l tank per residence?
There is a typo in the penultimate para of page 103…this should read Storz outlet…a brand name.
Water Sensitive Urban Design (WSUD) principles detailed at p102 suggest:
Sewerage. The available public sewerage infrastructure can accommodate only 30 residential units on the site. The proponents suggest but without detail, that some form of sewerage detention system might be incorporated within the development. These plans should be detailed …is on site disposal an option?
Mention is also made of coordinating sewerage detention with that provided on other nearby developments. Has any coordinated planning been investigated?
Stormwater. No detail is provided to support the outline of stormwater detention and reticulation plans. The plan at Fig 7.12 for example, shows that rainwater from the roof of a building being directed to a rubble drain to an unspecified destination. P116 ameliorates the question by adding that stormwater will treated on site and reused 'where possible'. This water source should be carefully harvested and used. However, with topsoil on the site only 0.1m to 0.4 m deep, what detailed plans have been made for effluent disposal or for stormwater rubble drains?
We have concerns about the calculations of the amount of runoff from the site. The "landscaped" areas detailed amount to 19,603 sq m (54.6% of the site) but the landscaping includes pools, BBQ areas, footpaths, tennis courts, volley ball courts and possible paved parking spaces, etc. The nearby Lincoln Downs existing residential area was calculated as being 30% impervious and it is a lot less dense. Here with the added sealed area for the service station and shop there will need to be lots of water storage to contain all the run-off.
There is planned to be a '… community association for the development would be responsible for the stormwater management and water detention systems.' (p106). How will such an arrangement be organized and controlled in the longer term? And where is the water to be detained?
At p106, '…stormwater will be treated …contributing to an improvement in the quality of water returned to the estuary.' Has comment on this been sought from the Batemans Bay Estuary Management committee?
Protection of the Environment. The Plan (P123) is said to enhance the environment of the site. How and where details are not given.
The plan (p104) mentions a community management tenure to include provisions to ensure that the quality of the environment is maintained. What does this mean? Is this a reference to a covenant or a community body to take some land management responsibility? How would this work?
Building Heights and Views. The proponents rely on the masking of the development by mature edge vegetation to reduce the visual impact particularly from across the river. With Council's inability to prevent the removal of trees which interfere with views in other places in the Shire, we question whether the existing vegetation could be expected to continue to provide the obscuring effect mentioned in the Plan.
The development plan acknowledges that the proposal exceeds
the height restrictions of the LEP and the DCP (although the LSCREP
OK's building heights up to 14m…no wonder we get confused!!).
The plan is also said to conform to the objectives of the relevant
DCP but some aspects of the proposed built form may vary from
its acceptable solutions.
The Coastal Design Guidelines for urban areas(p113) provide for 'generally heights up to two storeys'. This proposal goes up to 3-4 storeys. The Pole buildings will have 3 storeys plus a loft while the apartment buildings will have also have underground parking…one building 2 levels of parking.
The DCP (Res Design and Devel Guidelines for MD Housing) lists some specific requirements;
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| Max Height.. |
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| Private open space |
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The DCP requires that buildings should appear no more than one storey higher than surrounding buildings. The plan does not meet this requirement.. refer Section BB at Fig 7.9
Landscaping. On figure 7.1 the plan identifies a 'Possible Location for Gateway Lanscaping (sic) Treatment'. Is this some form of road side advertising structure?
The proposed service station is also to have 'lower than normal signage' to minimize visual impact. But who is going to police same?
The native endemic plantings (p100) will be regularly watered using water obtained from???
There is mention of drainage lines being sited to enhance 'riverine' character and also being able to use roof water to create swales that offer small wetlands to strip nutrients and for groundwater recharge. Is this just so many words or is there really a plan to effectively harvest the rainwater? There seems no plan of the drainage lines provided.
Further, the plan shows three swimming pools, Fig 7.17. Are these to be chlorinated pools and if so what will be their effect on nearby vegetation?? Are the pools to be fenced? How are pools to be maintained in these times of severe water restrictions and will filling from onsite water storages be utilized?
Transport and Access. The proposals to improve the pedestrian access under the bridge are welcomed but how this is to be achieved? By whom and at who's cost is unclear. The plan announces that car usage is to be minimized within the site and that walking is to be encouraged. Interestingly, the site plan, Fig 7.1 shows a capacity crowd of vehicles parked at the swimming pool.
This development is going to create increased traffic flow. The quoted RTA guidelines for estimating additional traffic generation (6 trips per day per residence) determine a greater traffic generation than is quoted in the plan. Again, the peak volumes (0.8 veh per hour per residence during the peak hours) calculate at a higher figure than that quoted in the plan. Notwithstanding, the plan helpfully advises that a more realistic peak traffic volume of 80-100 vph can be assumed.
If the RTA guidelines are not to be used for these sort of calculations, why have them at all?
The traffic volumes through the roundabout as a result of the development proposal are 'expected to increase by not more than 200vph'. This again is curious for a development that is encouraging the residents to walk to town. The odd segue about the ' development would foster a strong sense of community and encourage walking into the town centre' is interesting but let's not be too picky.
The RTA (p98) has also apparently commented verbally to the proposers about the future development of the bridge. Surely, the bridge redevelopment is of such importance to the area that a more definite statement of RTA's intentions for the bridge should be sought.
…and what please, is 'undercroft parking' (p97)?
Setbacks. The proponents state without explanation that the, '…setbacks proposed… would enhance the quality of the foreshore.' We question that the foreshore of the bay will be enhanced by this development.
The LEP requires setbacks to the Highway of 7.5m. The plan (p98 and Fig 7.1 show that setbacks are reduced (to 1.5 m in one spot). There is no reason why this change to the LEP requirement should be considered. Further, should RTA require to take possession of the land identified for eventual widening of the bridge approaches, the setback will be further significantly reduced.
The geotechnical report (p134) further questions the siting of the development in relation to the Highway. The report requires that no building should be placed within 10m of any batter of more than 2m vertical height.
Obviously, the way to achieve the required setbacks is to reduce the number of dwelling units rather than to seek to reduce the setback requirements.
Architectural Themes. The Plan explains that the development, '…translates modern coast house architecture into a medium density typology.' That maybe so but some explanation of such would have been helpful. What does it mean? At p113 buildings are again described as being designed to reflect the coastal location. What is this about and what are the coastal architectural themes which are said to be incorporated? The proposal to use recessive colours is welcomed but what instrument will guarantee the continued use of such schemes?
Conclusion
We accept that this development is within the bounds of the types
of developments permitted for this site. However, we are particularly
concerned about;
We reiterate that no further development likely to accommodate increased populations should be agreed to until Shire infrastructure and capacity is available.
We look forward to your response to the Master Plan and trust that decisions made will preclude the placing of a large development on a significant site, like this, without strong and effective conditioning.
Yours sincerely
Martyn Phillips
President