Eurobodalla Shire Council
PO Box 99 MORUYA NSW 2537
DRAFT URBAN SETTLEMENT STRATEGY
The Coastwatchers Association supports most of the ideas in the draft Urban Settlement Strategy. We believe the new LEP and related planning instruments are crucially important. They will either make or break "The Nature Coast". Comments received from our members, in response to an email survey on urban settlement, are included in this submission.
It is very encouraging to see moves toward implementing the key recommendation of The Coastal Design Guidelines for NSW, 2003, to limit urban sprawl along the coast and protect local character 1. Urban sprawl was also identified as one of most important problems faced in the coastal zone by the Resource Assessment Commission (1993).2
Does the Coastal Capacity Planning project include information about the impact of predicted climate change, storm intensity and sea level rise on vulnerable coastal areas of the Shire - all settlements near beaches and coastal waterways, not just Batemans Bay?
As Hebert and Taplin pointed out in their paper "Climate Change Impacts and Coastal Planning in the Sydney Greater Metropolitan Region", Councils need to integrate predicted climate change effects into their planning. Climate Impact Assessments need to be an integral part of the Environmental Impact Assessments carried out by proponents of major developments.
There should also be some consideration given to ideas such as rolling easements where Councils or government acquire vulnerable property and lease it back until the hazard becomes too great. This allows for "the natural landward migration of the sea by eliminating the use of hard structures that protect properties and/or eliminating the burden placed on communities to renourish a beach."
The Key Issues - Employment (comments on other key issues are in other sections)
Coastwatchers supports the idea of strengthening existing centres as places for jobs.
There needs be to a diversification away from the construction industry as a major employer, as this puts great pressure on decision makers to approve unsuitable development proposals because of employment implications.
Investment properties, especially medium to high density developments, have burgeoned in recent years. Many of these proposals involve conversion of tourist facilities to residential apartments. If this continues it could have a negative effect on employment in the tourism industry.
Unfortunately, the capital gains tax structure still favours large investment in dwellings. Not only does this boost the construction industry it helps accelerate land values and so makes it more difficult for alternative industries to find affordable employment land.
The Illawarra and South Coast Employment Lands Strategy - Situation Paper No 1, Sept 2004, Diana Gibbs and Partners, says "Native Hardwood sawmilling has been limited by Government policy, with negative effects on employment in Eurobodalla and Bega Valley Shires." Coastwatchers argues that the main cause of the decline in employment has been the expansion of mechanised harvesting and the dominance of the woodchip industry. There has been little investment in processing of native hardwoods into higher value products.
While there has been a loss of jobs in the forests and sawmills there has been an expansion in the number of log trucks carting timber to Eden for export as woodchips. This has placed more pressure on the least adequate section of the Princes Highway.
State forests could be made much more of an asset to the tourism industry with well managed low-key facilities for holiday makers, permits and fees for use, etc. There is the potential for greater economic returns to the government and for more employment for locals if the state forests were used in environmentally sensitive alternate ways.
Directions and Priority Actions and Ideas
1. Balancing urban growth within ecological and coastal constraints
Our members reluctantly accept that population growth in Eurobodalla Shire is inevitable but are unanimous in wanting to keep settlements separate and protect wide natural vegetation/wildlife corridors between them. Ecologically viable corridors should be either side of creeks and drainage lines and should link to other water catchments.
While developers are obliged to carry out flora and fauna surveys of potential subdivisions this does not protect habitat on the resulting lots. These surveys should also identify those trees and shrubs that must be retained and protected from construction activities. Penalties could apply to the developer/owner should trees be poisoned or cut down, without the need to prove who did it, the assumption being the work was carried out for the advantage of the developer/owner by their agents.3
Forested areas that were singled out by our members as very important to conserve were -
All vulnerable ecosystems should be protected from development. The rural floodplain of the Moruya River was also noted as worthy of protection for historic and aesthetic/scenic values as well as its importance as productive land.
We would go further than the draft USS and say that all urban development should be kept to "areas with low environmental and scenic conflicts whose spare infrastructure is available and in proximity to existing services and facilities."
There should be good plans for areas prone to flooding and coastal hazards; all open space areas and waterways. These plans should be integrated into other planning instruments.
2. Strengthening the role of major centres
Our members strongly support the strengthening of the major centres in the ways suggested in the Draft USS.
The towns
We know that Council is considering the area between Broulee and Moruya River as a possible location for a major hospital, aged care facilities, recreational facilities such as an aquatic centre and/or cultural facilities such as an arts centre. Good planning dictates that these should be located in towns where there is sufficient infrastructure in place. Constructing these facilities in the Broulee-Moruya River location would require upgraded public transport, fire break clearing, signage and support facilities such as accommodation and shopping. This will encourage the strip development that the government and Council say they are trying to eliminate.5
Members were willing to have higher population densities in the town centres and medium density in nearby surrounding suburbs provided it is well planned. Of course, the environmental capacity of the land, infrastructure such as water, sewage, stormwater controls, and public transport would all need to be adequate. There was also the assumption that the towns would have generous public open spaces, pedestrian precincts with shade and seating, cycleways, suitable low impact recreation facilities, and underground power and communication cables to allow street plantings of native trees.
However, most members said that existing height limits in the towns and other settlements should not be exceeded (although a couple thought that towards the centre of towns buildings up to 5 storeys in appropriate locations, and in less visible sites away from the waterfronts may be acceptable).6
For tourists the Eurobodalla offers an alternative experience
to most other destinations and the suburbs that most people live
in. It is important that the Shire maintains this difference,
by retaining these unique qualities. Areas such as Coolangatta
and Port Macquarie have lost their original attractiveness through
over development.
There was a call for architectural codes for the towns that require
a minimum standard of design, colours and finishes for large scale
commercial developments. We will refrain from giving examples
of why these are needed for fear of defamation proceedings.
Members were unanimous about the need for developers to provide
all the off-street parking spaces required by the relevant development
control plans or policies. They should not be allowed to make
a payment in lieu of providing the spaces. Perhaps in the future
fewer spaces will be needed if the new plans are successful in
reducing car ownership and improving public transport, in which
case the DCPs can be amended.
3. Sustaining coastal places and communities and valuing non-urban areas
Coastwatchers supports the plan to define each settlement as a coastal town, village or hamlet. The suburbs around the towns should also be defined (for example the strip between Batehaven and Malua Bay, Long Beach, and the areas around Narooma)
Increasing the density of appropriate settlements by well-designed dual occupancies or integrated developments is supported by most of our members provided current height limits are implemented.7 The new housing also needs to be well-designed to maximise passive solar access, as well as energy and water efficiency.
We agree that there should be housing choice for all ages and that settlements should be planned to allow as much variety as possible providing that it is well designed. However, housing is becoming less and less affordable due to rising real estate values.
The ratio of land that can be covered with buildings and hard surfaces also needs to be limited, say to 60%. This would allow some room for absorption of runoff, and retention or replanting of native trees. Trees are key elements of the areas scenic quality.
The lack of a capital gains tax on the family home places great pressure on the natural environment as over-sized houses on increasingly small lots mean there is no retention of native vegetation let alone trees. Perhaps there is some other way that this tax anomaly can be overcome.
Coastal settlements and hamlets
Place-based plans are needed for each settlement. What is appropriate
in 2g zoned land in Sunshine Bay, for example, is not appropriate
for a hamlet like Durras, Rosedale, Guerilla Bay, Congo or Mystery
Bay. These villages should have a lower density, developments
designed to blend in with their surroundings, a limit on expansion
and provide low-key tourism development such as camping grounds
rather than large motels or resort style developments.
An increase in the number of zones will be needed to ensure that development is tailored to fit the capacity of the land and the character of settlements.
Bushfire protection
There is an urgent need for less stringent bush fire clearing requirements. If people choose to live in bushland settings, the risk of being burnt out should be borne by them. If they do not want to live in the bush there are many other settlements in which they can live.
However, residents should be provided with information on how to design and maintain their homes to make them as safe as possible, and how and when to evacuate in case of fire. Firefighters should not be expected to fight fires in such settlements and residents should be aware of this.
If this is politically unacceptable then, at the very least, asset protection zones should be reduced and shared by neighbours, wherever possible.
Rural land
It is essential that productive farmland be protected from development. This includes appropriate buffers around these areas so that agricultural activities can be conducted without affecting residential neighbours.
It may be necessary for the tax structure to help support farmers while they adjust to changes. For example a rates levy on urban properties could assist farmers to move to more profitable and/or less environmentally damaging production.
Renew existing areas
Most of our comments are included in the previous section. Placed based planning may help retain the character of existing areas.
We are concerned that old subdivisions and other developments can still go ahead and are not assessed by Coastal Capacity Planning nor are they subject to the new rules.
The discussion paper suggests that Narooma Structure Plan can be used as a model for other areas. However, many of the Narooma reference group were disappointed that there were only two meetings and felt that this was only paying lip service to community consultation.
There was concern that Narooma could eventually have four shopping precincts since Woolworths is unwilling to give up the Plaza and instead intends to extend it, and the IGA supermarket at Dalmeny was not counted. The Narooma Structure Plan also lacked input from the RTA on land needed for future road works. Was there any consideration given to climate change given the potential impacts on the flat?
The planning approval process
Coastwatcher's members were unanimous in calling for consistent implementation of whatever new rules are introduced. Precedents set by variations to the current planning guidelines, such as over-height or over-large buildings should not guide decisions under the new plan. We should start with a clean slate.
To avoid the perception or possibility of corruption, there should be adherence to the regulations with strict procedures in place to disallow any modifications to building requirements that refer to the past or to precedents. The onus should be on proponents to prove that modification is absolutely necessary for other than reasons of profit, and that it will have no deleterious impact on the environment or on neighbours.
The development approval process has not been successful in the past. Too often Councils in NSW have been influenced by the development lobby with resultant degradation of the environment and other problems. DIPNR is theoretically at arm's length but it lacks local knowledge, is under staffed and remote from the people who will be affected by proposals.Perhaps enforceable planning instruments with less flexibility are a better solution.
Target infrastructure
The ideas suggested in the Draft USS are very sensible. Infrastructure
should come before development and new technologies should be
encouraged.
Power and communication cables should go underground in all settlements. Communication should be regarded as an essential part of the infrastructure needed before settlement is allowed. Not only does it facilitate home office/professional employment, it is also essential for social networking, facilitates further education, and helps aged/disabled people live at home.
The need for a secure water supply has naturally been in the spotlight. However, the focus should not be solely on a new storage dam. There need to be better incentives/requirements for water efficiency and more lateral thinking on the supply side. There is still virtually no capturing and re-use of stormwater and very little use of treated effluent.
Water and sewerage infrastructure should only be provided to
existing coastal hamlets if the residents of each settlement unanimously
ask for them. People who moved to these places often have done
so because of the lack of facilities. There are other ways of
ensuring adequate water supplies and non-polluting on-site treatment
of sewage if the density of the each settlement remains at an
appropriate level. People who want reticulated water and sewerage
have plenty of other serviced areas in which they can live.
Road and bridge planning need to be sped up so that land can be
set aside where needed. For example, the proposal for the Bay
Waters Inn redevelopment will take land that is required for new
roadworks and essential for future duplication of the Clyde River
Bridge.
ADDITIONAL NOTES
1. The Coastal Design Guidelines for NSW, 2003, stateObjectives
- To limit coastal sprawl by establishing separation and greenbelts
between settlements. This is a key objective at both
regional and local scales. Coastal settlements have a boundary
or footprint that is defined by the edge between urban and non-urban
lands, such as rural lands and natural areas. A clear
boundary to a settlement is important in coastal areas because
it limits impacts on the surrounding environment and ensures settlements
do not sprawl or form strip and ribbon development along the coastal
edge and between coastal catchments. In this way the diversity
of character in coastal settlements can be protected and enhanced….
To protect local character. Local character can be protected or eroded by different kinds of development. At the same time, it is important to acknowledge that each settlement has particular qualities, whether they are environmental, social, economic or urban, which make it different from its neighbours. The guidelines promote diversity consistent with identity and enhance local cultural and natural values.'
2. The Commonwealth Department of the Environment & Heritage states: 'Coastal strip development along the coastal edge places increasing pressure on specific coastal habitats. Urban sprawl was identified as one of most important problems faced in the coastal zone by the Resource Assessment Commission (1993).'
3. A thorough ornithological survey could be conducted (possibly co-ordinated by volunteers with council backing) to establish the species, variety and number of birds in bushland areas set aside for urban development. A follow up survey would discover any increase/decrease in numbers and species following development.
4. One member who is a professional planner commented, "George Bass Drive is a duplication of the Princes Highway and is a planning mistake. No further development should take place on either side of this section of George Bass Drive."
5. Another planner amongst our membership said, "Council land is our land held in trust by the Council. Why do they feel it is necessary to sell it off? The thrust should be to limit development, especially on publicly owned land. They are promoting the natural beauty of the area for tourism. Why spoil it with further development?"
6. One respondent suggested that the open space in towns
should be plazas surrounded by a mixture of town houses, villas,
apartments and shops as in the south of France or Tuscany. There
would be no shopping centres and no major supermarkets.7. One
experienced planner said that increased density might even bring
back some limited shopping. "A good example of this would
be Hunters Hill outside of Sydney. This suburb is in fact a peninsula
and could not expand. It is a lovely residential area with parks
and greenery and now with a good deal of dual occupancy."