3 July 2006

Mr Paul Freeman,
South Coast Panel Secretariat,
GPO Box 3415
Sydney NSW 2001

SUBMISSION TO THE SOUTH COAST SENSITIVE URBAN LANDS REVIEW

Our Association confines its comments to the lands in the Eurobodalla Shire. For each location we have used the Terms of Reference as sub headings and a dot point format to keep this submission as brief and to the point as possible.

INTRODUCTION

The Panel should be guided in their decisions for sensitive urban land use, by the important, but still to be finalised Regional Conservation Plan, the Draft South Coast Regional Strategy, The Draft Eurobodalla Rural Lands Strategy and the Draft Eurobodalla Urban Settlement Strategy.

Regional Conservation Plan (RCP)

• The areas being considered by the Panel could be part of significant vegetation communities, threatened species habitat or important natural corridors that are yet to be identified by the RCP but which should be protected.

The Draft South Coast Regional Strategy (SCRS)

• We argue that new development cannot "maintain or improve the condition" of a waterway or wetland
• New development should "not be permitted in areas that might in future be subject to coastal hazards". This should include no new development below 5m AHD to allow for 100 year planning timeframe and climate change/sea level rise
• The SCRS says "Infill housing and new residential subdivisions located adjacent to existing well serviced centres and towns will be given priority in land release planning" and "No new towns or villages will be supported"

The Draft Eurobodalla Rural Lands Strategy (RLS)

• The RLS aims to base land use determinations on carrying capacity and makes the important link with climate change
• Constraints mapping is a good step towards assessing carrying capacity but the significant Fauna Habitat Layer should be an absolute constraint not a weighted factor.

The Draft Urban Settlement Strategy (USS)

• The USS is relevant to all the areas being investigated. Its objectives (pages 8,9) include:
• To protect and enhance cultural, social, ecological and visual characteristics of a locality
• To limit coastal sprawl by establishing separation and greenbelts between settlements.
• To integrate new development with surrounding land uses.
• To protect local character.
• To encourage new coastal settlements to be appropriately located.
• To ensure neighbourhoods are centred around services and facilities.
• Avoid strip or ribbon development along the coast.
• Ensure the efficient use of coastal land, orderly and economic development.
• Provide certainty to the community by respecting values associated with adjoining non-urban land, the rural landscape, natural ecosystems, tourism uses and agricultural activities
• Provide certainty as to what development occurs and where.

The Draft USS highlights the community's wish for "ecological preservation and sustainability" (page 10) and it "does not identify the need for any new centres either large or small outside of existing settlement boundaries" (page 13).

Of particular relevance is the Section in the Draft USS (pages 108, 109) on the issues, present and future opportunities and desired character of new settlements.

LONG BEACH URBAN EXPANSION AREA

The suitability of the site for urban development

There is community concern that residential subdivision of land designated for urban expansion would have significant cumulative impacts on the environmentally sensitive nature of the location and on the biodiversity of SEPP 14 Wetland No 217. Issues of concern are:

• Existing quarry - The quarry is still operational and would need to be rehabilitated.
• Bushfire risk - The location is shown on the Eurobodalla Shire Council Bushfire Hazard Map as bushfire hazard prone because of the density of vegetation, the degree of slope and the aspect. One heavily vegetated slope runs down to the wetland and is shown as being a major hazard requiring a 100m buffer zone by RFS.
• Impact on SEPP 14 Wetland No. 217 - effective control of run-off - Clearing of steep slopes would present an erosion/sediment hazard compromising the adjacent wetland. Drainage gullies discharging into the wetland combined with runoff from household waste discharge could also have a detrimental impact on the wetland.
• Asset Protection Zones - Clearing for APZs should allow for wildlife corridors or around potential habitat/feed trees for threatened species.
• Threatened species - There have been recorded sightings of threatened species within 2-5kms of this land, including Yellow-bellied Gliders and Powerful Owls. There are concerns regarding the potential impacts of clearing of associated native vegetation on protected and threatened species habitat of the SEPP 14 Wetland.
• Wide forested buffer to wetland - A small part of the designated land abuts the wetland and is within the SEPP 71 Sensitive Coastal Location - this area should remain as a wide forested buffer to the wetland protection and habitat corridor.
• Zoning - Rural/residential development with allotments of not less than 5000m2 to 1ha would be preferable to 2(g) residential for this location.
• Draft urban Settlement Strategy - Long Beach is described in the Draft USS as being a hamlet, achieving village status when the population reaches 2,000 within the next 10-15 years. Medium density or high-density development, as in towns, is not appropriate for this location.

The priority and timing of any recommended releases for urban development including an assessment against forecast population growth trends.

There should be no further release of land for urban expansion until the Batemans Bay Bridge is duplicated and infrastructure upgraded to address existing traffic and access problems. If access to subdivision is to be from Long Beach Road and/or Northcove Drive, then these roads will require significant upgrades.

What (if any) alternate land uses might be suitable for each site in the event that urban development is not considered suitable.

As it is in close proximity to the Murramarang National Park it could be incorporated into the Park along with the SEPP 14 Wetland. Alternatively, it could be rezoned to 1(c) - Rural Small Holdings. Large-scale commercial development, such as Stocklands type shopping centres, should not be permitted on this land.

MALUA BAY URBAN EXPANSION AREA

The suitability of the site for urban development

• The area is important for east-west habitat connectivity
• Wide forested buffers to streams will help maintain corridors
• Some land is too steep for sensible urban development
• The area does not meet the SCRS or USS aims of preventing urban sprawl along the coast and protecting character of existing settlements
• The scale and type of any recommended land release having regard to the site's biophysical constraints, servicing and infrastructure issues
• Malua Bay and Lilli Pilli should be regarded as a village/s as defined in the USS. They are not part of Batemans Bay town as they are too far from the town centre and have their own character and sense of community
• Public transport is poor so expansion will significantly increase private vehicle use.
• The scale of development should be the same as the current residential development - i.e. a village as defined in the USS but allowing for 5-15% increase in medium density. The medium density should be near the shops.
• The western section and land with more constraints should have large lots and lower density accommodation.

The priority and timing of any recommended releases for urban development including an assessment against forecast population growth trends

• Land should not be released until other areas closer to Batemans Bay are filled
• Any future land releases should be staged so that the population increase is a minor proportion of the current population to enable the character of the village/s and a sense of community to be maintained.

What (if any) alternate land uses might be suitable for each site in the event that urban development is not considered suitable.

• Some suitable land needs to be set aside for playing fields and passive recreation

ROSEDALE URBAN EXPANSION AREA

The suitability of the site for urban development

• The bushfire risk is high at the edges of the cleared area and along gullies where native forest and understorey needs to be maintained for ecological reasons
• Spotted Gum forest in the north east of the area is habitat for the threatened species Yellow-bellied Gliders and Bent Wing Bats.
• Bevian Wetland (SEPP 14 Wetland 197) will be significantly degraded by run-off
• The Endangered Ecological Community (Casuarina glauca Swamp Oak Forest) which fringes Bevian Wetland will have to be partly cleared and the wetland edge filled if Bevian Road is used as an access to the site.
• A setback of at least 400m is needed to the Sewage Treatment Plant.
• If developed it will undermine the Regional Strategy by ensuring strip development of the coast.
• Scenic protection - most of the area is highly visible from George Bass Drive, Melville Point and Barlings Beach. A setback to the arterial road including vegetation canopy and understorey is also required (USS page 16)
• The Master Plan for 450 lots on part of the area being investigated was rejected partly because it did not conform to the strategic context requirements of the NSW Coastal Design Guidelines - it is not a logical extension of existing hamlets and does not connect well with them. Current proposals are for up to 1278 lots.

The scale and type of any recommended land release having regard to the site's biophysical constraints, servicing and infrastructure issues

• If developed according to current subdivision proposals this will be a new settlement similar in population to Tomakin-Barlings Beach combined.
• Significant natural areas need to be left to separate any new settlement from Rosedale and Barlings Beach and to protect the scenic values.
• There should be no release for many years if ever - then only small releases in least environmentally sensitive areas and safest from fire.
• Large buffers are needed around the wetland. The Draft USS says foreshore setbacks should be kept vegetated and be 100m or more near ecologically sensitive areas, and there should be a 100 year planning timeframe to address climate change and sea level rise (page 16).
• Effective stormwater control will be needed to enable natural filling and drying of wetland and minimise pollution
• A wide buffer will be needed to protect the Swamp Oak Forest

The priority and timing of any recommended releases for urban development including an assessment against forecast population growth trends

• There should not be any release until the approved subdivision at Barlings Beach and areas closer to Batemans Bay and Moruya are filled. Then the whole area between Batemans Bay and Broulee should be reassessed to determine the most suitable site for expansion.

What (if any) alternate land uses might be suitable for each site in the event that urban development is not considered suitable.

• Retain all or most as rural land

MORUYA HEADS URBAN EXPANSION AREA

The suitability of the site for urban development

• The area does not meet the SCRS or USS aims of preventing urban sprawl along the coast and protecting character of existing settlements.
• The northwestern section drains to a major wetland.
• The southern section encompasses Gilmores Creek and a saline wetland.
• The bushfire risk is high.
• The sections near the river will have high scenic impact.

The scale and type of any recommended land release having regard to the site's biophysical constraints, servicing and infrastructure issues

• This land should not be released at this time. There are many more suitable and less sensitive areas near town.

The priority and timing of any recommended releases for urban development including an assessment against forecast population growth trends

• There should be no release of land until other suitable areas adjacent to Moruya have been filled. Then the whole town and surrounding areas should be reassessed to determine the most suitable site for expansion.

What (if any) alternate land uses might be suitable for each site in the event that urban development is not considered suitable.

• Retain all or most as rural land

EXPANSION AREA SOUTH OF NAROOMA

The suitability of the site for urban development

• East of highway is not suitable for the following reasons:
  - it has good remnant forest with hollows for habitat;
  - it drains to a stressed lake and urban run-off will worsen pollution;
  - it is scenically important; and
  - it is adjacent to land zoned Coastal Protection and there should be a gradation to this use.
• West of Highway is probably suitable. It is less ecologically sensitive than forested Urban Expansion land at Dalmeny near Duesbury Rd.
• The Narooma Structure Plan includes the following principles:
  - ecological conservation takes precedence over built aspects where conflicts arise;
  - reassessment of future Urban Expansion and Rural 1c zoning to reduce its impact on the scenic setting south of Narooma; and
  - protection of the important forested area between Kianga and Dalmeny.

The scale and type of any recommended land release having regard to the site's biophysical constraints, servicing and infrastructure issues

• Present sewer infrastructure cannot cope with development of the sites at South Narooma. Residents report pumping problems including sewage overflows into Little Lake which drains to the main surf beach
• West of the Highway may be suitable for low-density development with some dual occupancies (5-15%)
• Development on the western side of the Highway should dedicate and regenerate a forested habitat corridor on its southern edge to link to the east and to serve as scenic protection
• Master Plan 53-12-2004 for a 73 lot residential subdivision of Lot 31 DP792506 Glasshouse Rocks Rd, Narooma was completely unsuitable. It did not meet Coastal Design Guidelines; would have meant the loss of the remnant forest; and would have degraded the scenic qualities of the site as the tourist entrance to Narooma from the south.

The priority and timing of any recommended releases for urban development including an assessment against forecast population growth trends

• There should be no release of land east of Highway until other areas are filled. Then the whole town and surrounding areas should be reassessed to determine the most suitable site for expansion.
• Consider releasing the land west of the Highway instead of an equivalent area or forested land near Duesbury Rd, Dalmeny

What (if any) alternate land uses might be suitable for each site in the event that urban development is not considered suitable.

• The land proposed to be zoned 4a Industrial could be used for industrial given appropriate pollution control and stormwater treatment.
• The rest should be zoned Coastal Protection - eco tourism development?

CONCLUSION

We trust that our submission, prepared with input from local community groups and advice from relevant authorities, will assist the Review Panel to determine the suitability of designated sensitive urban lands for urban development and/or suitable alternative land uses in the event that urban development is not considered suitable.

Jenny Edwards
Secretary

Reina Hill
Committee Member (Long Beach)