To Eurobodalla Shire Council

SUBMISSION ON THE DRAFT URBAN SETTLEMENT STRATEGY

Our Association supports the main thrust of the Draft Urban Settlement Strategy (USS) and is enthusiastic about many of its proposals. However, the USS seems premature when the LEP Template and the South Coast Regional Strategy are still to be finalised. The Dept of Environment and Conservation is also still preparing a full conservation plan for the region and this too could require major changes to the USS.

It was disappointing that so many of the settlement snapshots were inaccurate as this failing throws doubt on all the other "facts and figures" supporting the strategy. Some of the errors we noted are listed at the end of this submission.

We would have liked to see zones within urban areas identified for medium density housing. It would make sense to have these areas in close proximity to the main streets /centres of towns and villages rather than scattered throughout.

Strengthening the role of the three main towns.
Coastwatchers strongly endorses the Strategy's aim to confine major regional services and facilities to the main towns (eg hospital, regional sports/aquatic centre, etc)

We refer to such statements in the Strategy as --

P6 - "about matching facilities to demographic needs, where they are easily accessed and a range of transport options are available"
- "strengthened role for the major centres of Batemans Bay, Moruya and Narooma"
- "important that regional services are co-located in existing centres"

P 11 - IRIS found most people support one regional hospital.
"Most participants believed a new regional hospital should be located somewhere in the Moruya area, representing the most equitable point of access for all Shire residents."
However, there is still the need for local a Medical Centre to deal with day surgery and specialist consultations in the Batemans Bay area, preferably adjacent to the existing Emergency Centre

P13 - "the plan co-locates major public uses in existing centres to strengthen commercial viability and provide opportunities for more locally run businesses. The plan does not identify the need for any new centres either large or small outside of existing settlement boundaries."

P 36 Infrastructure - "Ensure any new public services are based on the centres plan"

"Ensure that schools, playing fields and other major shire wide public facilities are located within the urban boundaries of towns."

OTHER COMMENTS

The following comments follow the layout of the USS.

Surf Beach industrial area
P7 - "Similarly, negotiations are underway to facilitate the development of industrial land at Surf Beach. It is proposed to develop mixed use activities, comprising light industry, bulky goods warehousing and retail and some residential uses on this site"
Why put residential in this industrial area? Won't this ensure conflicts?
What effect will bulky goods retailing here have on the viability of the town centre?

Loss of motels and caravan parks
P 7 "…the conversion of large tourism establishments, such as motels and caravan parks, to permanent residential. This loss in tourism accommodation coincides with increasing visitor numbers to the Shire. Council therefore supports the development of tourism facilities in identified locations where demand may be satisfied and environmental attributes are preserved.
Will the tourism facilities satisfy the same demand as those lost such as camping and caravan sites?

Principles and objectives
Pp 8,9 - Coastwatchers supports the principles of sustainable development as set out here and endorses the objectives listed.

Structure plans and place-based plans
P 9 - Structure plans are only as good as a DCP, that is they are easily undermined. For instance the much commended Narooma Structure Plan that was supported by the community reference group looks like being changed to satisfy a small group of landowners (southern boundary of the settlement) and a supermarket owner (larger retail floor space on the flat).

What settlements will have place-based plans? These plans will need to be included in the LEP to be of any worth. If this does not happen then community wishes will be over-ruled as unsuitable development proposals are inevitably approved.

The importance of environment protection
We were pleased to see the reference to the importance that the Shire's residents and ratepayers place on protecting the environment --
P 10 - IRIS findings -" the issue of ecological preservation and sustainability remained at the forefront of every workshop discussion, informing most aspects of planning and management."

Foreshore development
P 15 - We support the directions and responses, especially Response 5 --
Avoid the remodelling of foreshore areas to ameliorate coastal processes by buildings or other structures"

This is particularly relevant for proposed developments such at the units at Wharf Rd, Batemans Bay

Settlement Boundaries
(7) "Support the need for clearly defined pedestrian access routes through foreshore reserves to reduce the impact of traffic through dunes, coastal vegetation and other fragile areas.
This is particularly relevant to locations with diminishing dunal protection, such as Long Beach.

Setbacks
P 16 - The section on setbacks it very sensible and long overdue, in particular--
1) the need to address erosion, climate change, etc;
2) foreshore setbacks of 50m or more for new development;
3) foreshore setbacks should be kept vegetated and be 100m or more near ecologically sensitive areas or where coastal hazard requires it; and
4) there should be 100 year planning timeframe to address sea level rise, etc
11) & 13) - scenic areas and ecological corridors should not be compromised by bushfire buffers, especially to allow excessive development close to these areas.

How does the clause on setbacks to arterial roads fit with the Rural Lands Strategy (p 76) intention to clear roadsides?
13) "setbacks to arterial road corridors to include the vegetation canopy and understorey.."

Settlement hierarchy and foot print plans
Coastwatchers supports the rationale behind increasing accommodation capacities in settlements but believes the medium density zones need to be specified.

P 19 We are very pleased to see the settlement boundary for Broulee ends at Broulee Rd and does not include Council land to the south.

Rosedale is a hamlet but the Marsim land adjoins and is shown as a village as is the Barlings Beach extension of Tomakin (see also table 2, p 25)
Where are the natural areas left to break up the settlements?

P.20 - (2) (Definitions) "Coastal villages… have some development potential and provide services for local population… but rely on coastal towns for commercial and recreational functions that are not required daily…"

P 24 - Centres Plan (Definitions) Support the efficient and viable operation of a diverse range of businesses and services…ensure that the scale and design of retail and commercial outlets matches the settlement size and characteristics."

Coastwatchers agrees with the above definitions to ensure that commercial development is appropriate for the provision of the daily needs of a coastal village, and that the scale and design matches the settlement size and characteristics. Any commercial development proposal that exceeds what is defined should not be considered in the first instance.

P 21 - It is a sensible idea to put the objectives and directions in Council's Management Plan where other staff beside planners may see them more often.

We support the aim to limit increased density (eg 5-15% in villages) but how will this be achieved?

P 26 - Coastwatchers is very supportive of the outcome of providing "a consistent approach to decision making…" This has often been a failing of the system in the past.

P.28 - Access Plan - Village settlement entry roads, "…this road is a looped configuration and has two highway junctions…. Whilst this may be the ideal it is not the norm. The village main street in some settlement snapshots is incorrect and the location shown could not match the definition due to zoning restrictions - in some instances the name of the main street differs from the snapshot location

Roads
P 29 - We look forward to the time when "The scenic values of streets and roads are analysed, mapped and protected."

P 30 - Referring to the action -
"The coastal drive (Beach Road and George Bass Drive) from Batemans Bay bridge to Malua Bay has the potential to become a 'Coastal Boulevard'."
Sea level / climate change impacts will need to be carefully considered, especially between Batemans Bay and Catalina and at Caseys Beach.

Scenic values
P 33 Our Association supports the need to protect identified scenic values "in perpetuity" - not just at the planning stage but at construction and occupancy.

P 34 "Scenic landscapes along the coast most at risk are those located along Coastal Drives and Settlement Entry Roads"
Wharf Road would be a prime example where scenic attributes (views from the town and bridge) are likely to be lost due to unsuitable developments. The proposed Tourism Corridor between Mogo and Tomakin (Rural Lands Strategy) is also a risk to these scenic landscapes.

Settlements
Coastwatchers endorses the sections on Present and Future Opportunities and on Desired Future Character of towns and coastal villages

a) Coastal Villages
P 50 - Issues include "larger scale tourist developments located on the outskirts of the settlement eroding its compact footprint",
This is relevant to such proposals as The Oaks plans for residential/tourism and the proposed Mogo to Tomakin Tourism Corridor in the Rural Lands Strategy

P 51 - "A special uses zone is to be applied to land currently occupied by caravan parks. Should redevelopment for residential uses occur, subdivision layout and the scale and massing of buildings is to remain low density, reflecting the character of adjoining urban areas."
This is a very necessary and timely clause.

P 58 Catalina - The 'shops' shown on the map are only a service station.
Is there a plan for shops in the west if urban expansion occurs near the Link Rd?

Have the present and future populations of aged care residents been counted in Catalina, Denhams Beach and elsewhere?

Batemans Bay to Catalina may be better considered as part of the town. It would be sensible to allow greater density on the higher land near the town but not along the waterfront.

We would like to see the Strategy earmark properties fronting the present and future marina for low scale commercial use rather than see more public land taken for boat repairs/sales, and the like.

P 66 The line of separation between Lilli Pilli and Malua Bay would be better if it followed a continuous vegetated drainage reserve such as from Mosquito Bay inland. We support the settlement boundary to the south of Malua Bay as shown. The road sign currently showing the southern end to Malua Bay should be moved to reflect this boundary (at present it is near Rosedale).

P 71 The Strategy should be revised to include Barlings Beach lots and population capacity. It should also make some estimate of the development potential of the Urban Expansion zone at Rosedale (the Marsim development). The latter should be a separate settlement to Rosedale and Guerilla Bay unless it can be made to fit the character and visions statements for those settlements.

P 72 The Residential 2(EC) zone at Mossy Pt and elsewhere should remain low density. How will this affect predicted population capacity?

P 74 Broulee - The properties shown as existing or possible future shops is unrealistic. Most of these lots have residential units or new houses and dual occupancies. It would be good to relocate the present post office/general store/ fuel outlet to a safer location than its present corner but the site near George Bass Drive would be much less convenient for beach and van park users.

P 80 Dalmeny - Have the land capacity constraints been given due weight in considering expansion of the settlement to Duesbury Rd?

P 82 Mystery Bay - Coastwatchers is very pleased to see the intention to swap the urban expansion land to a less environmentally important area near the hamlet. The forested area should be protected from urban development.

b) Coastal Hamlets
P 85 - The Strategy lists these as -
Durras, Maloneys Beach and North Batemans Bay (Batemans Bay Group), Rosedale, Guerilla Bay, Moruya Heads, Congo, PotatoPoint, Kianga, Central Tilba, Akolele

North Batemans Bay does not fit in this group. With all the medium density housing approved or proposed it would be better as an extension of the town itself.
The site of proposed units on the waterfront at Wharf Rd should be acquired and made parkland to service the other medium density developments nearby. Not only is the waterfront site especially at risk from coastal hazards, but it may have been illegally given conditional approval (according to legal advice received by our Association and copied to Council).

Mystery Bay should be included as a Coastal Hamlet as it better fits the character of these smaller settlements. Central Tilba would be better classed as an Inland Hamlet.

P 86 Durras - Coastwatchers supports the character and visions statements.
Why is reticulated water proposed when most residents do not want it?

P 92 Guerilla Bay and Rosedale - Again we endorse the character and vision statements.

P 94 Moruya North Head - The settlement shown nearest Moruya on the map with its surrounding urban expansion area may justify making it a separate hamlet.

P 102 Central Tilba - The Strategy should refer to the need to include the content of the current DCP.

c) Inland Coastal Settlements
Pp 106,107 - The Strategy lists these settlements as Nelligen, Mogo, Bodalla and,Central Tilba. Central Tilba was previously included in the Coastal Hamlets

Many of the points of the Desired Future Character as stated in the Strategy do not fit these settlements, for example --
"they act as a centre for secondary commercial, retail, industrial uses…"
"the main street has a mix of building types including. ..residential flats…"
"Surrounding the centre are …town houses…terraces…retail, professional offices…"
"large industrial, commercial and tourist developments…"
If the settlements are changed to suit the Strategy then it would undermine the intentions to prevent ribbon development and to strengthen the role of the three main towns.

d) New Settlements
P 108 - We endorse the Strategy's statements regarding Present and Future opportunities and Desired Future Character.

The last paragraph should be reworded - environmental constraints should be taken into account for all subdivision design not just large subdivisions.

P 71 The Strategy does not include Barlings Beach lots or population capacity, nor does it deal with the Urban Expansion zone at Rosedale (the Marsim development). The latter should be a separate settlement to Rosedale and Guerilla Bay unless it can be made to fit the character and visions statements for those settlements.

One of the Strategies mentioned expanding the settlements of Turlinjah and Nerrigundah. This would undermine the USS's stated aim of confining settlement to present urban boundaries. Turlinjah is of particular concern because the reed beds to filter septic effluent are struggling to cope with present households and there would be a high risk of further pollution of Tuross Lake. Nerrigundah is too remote from other settlements to encourage population expansion there.

SOME ERRORS
P 24 Maloneys Beach shop is shown in the wrong location (see p 90)

P 30 Surfside - Wharf Rd should be the settlement exit - Peninsula Drive is the entrance

P 54 Surfside - Peninsular Drive and the adjoining subdivision are not shown.

P 55 The Sewerage Treatment Plant should be Surf Beach ( it is always referred to that location in other documents)

P 56 Long Beach - eastern shops are non-existent and western ones are not yet approved

P 66 Malua Bay does not have shops on the western side of George Bass Drive and proposals for commercial development there has been discouraged by council in the past.

P 67 and elsewhere - Wrong settlement snapshots for Surf Beach, Lilli Pilli/Malua Bay, Tomakin, Mogo, Rosedale and Guerilla Bay

P 68, 69 Mogo - local shops, service station and tourist shops are not shown on the map

P 70 Tomakin - local shops - The service station is not shown - most of the area identified for shops is now houses. Tomakin store is on the wrong corner (should be SW)

The Moorings - the waterfront is shown as absolute constraints but units are already constructed or approved for here

P 78 Bodalla - Local shops are not shown on the map. It would be better to include the primary school in the settlement boundary

P 86 Durras - The local shops are in the wrong location - the location shown is the caravan park store - the local village shop is on the southern side of the coastal boulevard.

P.88. North Batemans Bay - not local shops - restaurant and boat hire only

P 89 North Batemans Bay is not a hamlet and the table is wrong - there is no primary school but there is vacant subdivided land.

P 90 Maloneys Beach - land shown as absolute constraints to the NE of the hamlet is not all National Park - there is an eco-village proposal for some of the privately owned rural land.
The shop is in the wrong location. Table 2 is a repeat of Table 1

P 96 Congo - The map shows the wrong entrance road - there is no bridge from Moruya Head. The scenic rural/bush drive should be Congo Road.

P 103 Central Tilba - the map does not show any local shops. Table 1 is wrong - there cannot be only 8 lots in total and a resident population of 106 ! Table 2 indicates 18 residents if correct.

P 104 Akolele - the tables are wrong - there cannot be 64 lots in total including 12 vacant but 64 dwellings when there are only separate houses and not dual occupancies etc.

Thank you for the opportunity to comment. We look forward to a new LEP incorporating this strategy.

Jenny Edwards,
Secretary