Community
Alliance of the
Northern
Suburbs
Planning and Development in the Northern Suburbs
1. Introduction
This report addresses various issues of planning in the northern suburbs of the Illawarra – from Bellambi Lane in the south to Helensburgh in the north.
CANS was formed in response to widespread community complaints about problems with current and proposed developments in the northern area and perceptions that there were severe deficiencies in the planning process.
The proposal by Wollongong City Council to revise the Local Environmental Plan (LEP 38) provided the stimulus for CANS to identify a broad community feeling for planning and development. This collection of community opinion is more widespread and thorough than ever before attempted by Council or any other organization.
The bulk of this document summarizes the opinions, arguments and some case-studies provided by the contributers to the community-based discussions. It can therefore be used as a resource in the planning process, which usually fails to seek this sort of community opinion, except as a response to specific development issues.
During the 9 months of community consultation, Wollongong City Council released two versions of the draft revision of LEP 38. This document therefore also addresses Council’s draft LEP, and makes a set of recommendations about that proposed plan.
2. Community Views of Development
2.1 Conclusions
This section summarizes the main outcomes of community discussions held by CANS. These points were frequently made in all precincts and represent a general view of potential development in the sub-region. Detailed comments relating to each precinct appear in Appendix 2. These detailed comments contain identification of many specific issues which will be relevant to detailed planning in each area.
1. The spectacular environmental characteristics of the adjacent coast, coastal plain and escarpment of the northern suburbs must be recognized explicitly as a resource to be protected at all costs.
2. In this context, large-scale commercial, industrial, residential or tourist developments on the coast, on the escarpment fringe, or on the escarpment top are completely inappropriate as they would substantially reduce the existing conservation, scenic and environmental values of the area.
3. In fairness to developers and to current and future residents, Council must impose a rigorous control over these areas, through zoning, so as to make it quite clear that such developments will not even be considered.
4. The northern suburbs should remain largely residential in character, with some increase in density and redevelopment of existing residences being the principal flexibility for growth. Opportunities for high-technology, clean industry and low-key, sensitive tourist projects exist but are limited.
5. Slip, erosion and flooding are issues of substantial concern to many residents in all northern suburbs. There are two main categories of problem:
(a) the perceived inability of Council to manage current watercourses to prevent erosion and flooding;
(b) a need to incorporate these constraints, particularly land slip, more explicitly in a northern suburbs planning process.
6. The escarpment is so important, for many reasons, that the current upper boundary of residential land must not be permitted to encroach further. Land instability, the need for tree cover to control soil moisture and erosion, and the need to protect watercourses mean that further clearing for development will generate intolerable problems to existing landowners downstream.
7. The current level of protection and management of land zoned for escarpment protection is considered inadequate. Future planning must recognize the multiple benefits of the escarpment – including scenic amenity, plant and wildlife protection and soil stability – and devise appropriate zonings.
8. The historical contribution of the coal mines to the current pattern of development must be recognized and, in some cases, retained. For example, some communities should remain village-like in character (e.g. Otford, Stanwell Tops, Coledale) with this factor developed as an asset in attracting visitors.
9. The dissection of the suburban strip with the retention of “green breaks” running east-west in various colliery lands should be viewed as a positive planning characteristic.
10. There is widespread agreement that the coastal fringe must be protected from unsightly and excessively high developments of town-houses or units. Approporiate zonings, good building design, control of parking and well-policed development controls are therefore essential.
11. Current access to and parking in northern suburbs are rapidly degrading these areas as attractive tourist destinations and angering residents. Improving vehicle (car and bicycle) access and controlling traffic are seen as very important objectives.
12. The current level of community conflict with Council is perceived to stem from three major shortcomings of the present approach of Wollongong City Council to forward planning and policing of existing policy. To resolve these conflicts, Council should adopt the following as policy in planning and development:
(a) community input to proposals must be sought sufficiently early to permit a real (rather than a token) community opinion to influence the future pattern of development;
(b) council must adhere to positions reached after consultation, so that the community does not feel the need to be constantly vigilant and frequently fighting the same battles;
(c) council must develop an effective mechanism of policing controls imposed on any development so that violations by developers will not compromise the objectives of an agreed zoning.
2.2 What is CANS?
CANS (Community Alliance of the Northern Suburbs) was formed in June 1987 as a coalition of more than 12 existing community groups active in the northern suburbs. It was evident that the areas receiving attention from these separate groups were experiencing a period of rapid change and increasing pressure for redevelopment. Many recent proposals for redevelopment had been in environmentally sensitive areas along the foreshore and in areas adjacent to the escarpment or catchment (Hacking River).
There was perceived to be a push for “fast-track” regional redevelopment on the part of the Council, in an effort to secure the future of the local economy, with the declining role of coal and steel, by actively promoting tourism, regional retailing complexes and the expansion of the suburban sprawl of Wollongong. Given these presures for redevelopment, it was anticipated that planners would be under strong pressure to relax development controls. There had been a string of controversies surrounding what were widely perceived to be insensitive planning decisions
A series of discussions among these community-based organizations and other resident groups revealed a great similarity in their concerns and recent experiences, including the following:
* a widespread dissatisfaction with the way the planning process appeared to be operating in the northern suburbs;
* this dissatisfaction was reflected in the large number of community-action groups in the northern suburbs, many of which exist because of single issues seen to be detrimental but requiring constant opposition;
* the need for an umbrella organization to co-ordinate the efforts of the individual, single-issue groups and to address broader-scale, planning issues;
* the need for thorough, ongoing community contact to address the issues of the future of the northern suburbs in a balanced way, focussing both on opportunities for appropriate development and on setting appropriate limits to development.
CANS was established with the following aims and objectives:
* to protect and enhance the natural and urban environment, particularly in the sensitive and important shoreline and escarpment areas of the northern Illawarra coastal plain.
* to promote planning concepts and residential, industrial, commercial, recreational and tourist developments which are compatible with the environmental objectives of the coalition;
* to promote active community involvement in the physical planning process, in order to advance the environmental objectives of the coalition;
* to act in concert with other community organizations and groups to further the objectives of the coalition;
* to act as a forum and resource for member organizations and individual members.
“The community in the north is quite cohesive. It is quite capable of addressing the real planning issues which the area as a whole faces over the next twenty years. We believe that, with this involvement, appropriate developments will be welcomed and strongly supported instead of being delayed and disputed.”
(CANS Press Release)
2.3 Discussions with the Community
Wollongong City Council, through Mr David Winterbottom (City Planner), invited CANS to contribute to the revision of Local Environment Plan 38. The letter of invitation (Appendix 1) stated:
Specifically, it [the review of LEP 38]will be looking at issues related to population, employment growth, to environmental protection and to reducing community conflict.
17th December 1987
Following this invitation, CANS developed a mechanism for widespread public discussion in the northern suburbs, focussing on these broad issues. The area was divided into nine “Precincts”, each with a CANS member as co-ordinator.
CANS Precincts
Precinct Co-ordinator
Helensburgh/Otford Jenny Donohue
Stanwell Park Tim Tapsell
Coalcliff Tom Williamson
Clifton/Wombarra Dallas Hall
Coledale Dave Beswick
Austinmer Cookie Lloyd
Thirroul Rob Whelan
Bulli Ray Brown
Woonona Stephen Green
Each precinct co-ordinator was provided with a package containing: (i) the then current zoning map for the precinct; (ii) key to the zonings and permitted uses; (iii) guidelines for discussion; (iv) questionnaire to fill in with information gained from community meetings (see Appendix 2). Precinct co-ordinators arranged the following activities within their areas:
1. Meeting of CANS members within the precinct for initial discussions;
2. Distribution of proposals and other information widely throughout precinct;
3. Public meeting to discuss future development in the region in general and the precinct in particular;
4. Collating of resolutions and/or discussions resulting from public meeting and communication to CANS planning committee.
From the responses to this widespread community consultation (summarized in Appendix 2), the CANS planning committee produced this report, which was presented at a CANS general meeting on November 16th 1988. This general meeting resolved to communicate the report to Wollongong City Council as a response to Mr Winterbottom’s invitation and also to circulate it widely within the community and to appropriate government bodies.
2.4 Historical Overview and Future Pressures
CANS considers the current review of the Local Environmental Plan 38 to be particularly timely for that area of the northern suburbs with which this community group is concerned. For several reasons, the area is at an historical turning point. Certain pressures are just beginning to be experienced: how they are managed over the next five to ten years will determine the quality of the northern Illawarra as a place to live and to visit.
The magnificent physical setting of this area derives from the spectacular landscapes of the escarpment and the narrow coastal plain. Residential development in the area has been largely confined to the elongated “village” pattern by the natural physical (and cost) constraints of the steep and unstable escarpment to the west. North of Austinmer, the rugged and precipitous coastline has been an eastern barrier.
The urban sprawl of Wollongong has reached Thirroul only in the past ten years and has yet to penetrate significantly further north. This situation is not the result of explicit planning decisions. Adequate residential land was available closer to Wollongong and, more significantly, the northern townships and villages were separated by large parcels of land protected from residential and other developments because it was and is reserved for mineral extraction. Much of this land is still at least partially forested.
The pattern of settlement and physical development of this area has thus been shaped by the history of the coal industry even more directly than has been the case in the Illawarra as a whole. The settlements of the northern Illawarra were largely located and established in close relationship with the local coal mines, which were the largest source of employment in the area. The links of these communities to greater Wollongong in the south were strengthened by the development and expansion of the steel industry, which became the second major source of employment. This history is clearly evident in the string of villages and townships nestling between the escarpment and the ocean, close to the sites of the earliest coal mines.
The current turning-point in the history of the area is closely associated with the long-run economic changes being experienced in the coal industry. With the recent and imminent closures of pits in the area, large tracts of previously unavailable land, much of it bordering the escarpment, is potentially becoming available for uses other than coal mining. Other factors, and also changes in the regional economy, have coincided with the decline in the coal industry to generate significant pressure for more extensive and intensive residential and other development in the area.
These factors include the following:
* increased pressure on land supply in Sydney;
* improved commuter access to Sydney from the norhthern suburbs area, with the electrification of the railway line, and from there to Wollongong (if and when the “Northern Distributor” is completed);
* a movement of population from the area as jobs were lost in coal and steel in the 1982-83 recession, permitting an influx of people commuting to Sydney with an attendant increase in property values;
* the development of Thirroul as a sub-regional shopping centre (and proposals for further such development in Woonona) whcih would have the capacity to serve a much larger population to the north. This move is likely to give rise to local commercial activities which would seek more intensive and extensive residential development;
* Australia’s national trade imbalances have prompted a nation-wide push, at all levels of Government, to promote tourist developments – especially international tourism. Given the spectacular natural features of this area, its proximity to Sydney and Mascot, and the perceived availability of vast tracts of hitherto “vacant”, former colliery land close to the coast, the prospects of large scale tourist developments are receiving increasing attention, particularly from the NSW Government.
The processes of change reflecting the above factors are already evident in activities occurring over the past two to three years.
* New residential developments have been established or proposed on previously undeveloped land in the Russelvale area, at Thirroul, at Helensburgh and elsewhere.
* Modest cottages have been replaced by larger and more affluent dwellings, particularly on the coastal strip north of Austinmer.
* There has been “infill” of town-houses in some areas.
* Medium-density redevelopments have been established or proposed, especially in Thirroul and other beach-front areas.
* There are proposals for major residential subdivisions on the escarpment fringe in many areas, including Thirroul, Bulli.
* There have been proposals for various developments in the catchment of the Hacking River, near Helensburgh, including a considerable expansion in the size of the Helensburgh residential area.
* There has been a substantial increase in the level of day-visitors from western Sydney to Austinmer, Thirroul and other northern beaches.
* There have been several proposals and rumours about proposals for major tourist developments, including a large hotel complex in Bulli and a Grand Prix racing circuit on the escarpment rim above Austinmer and Thirroul.
There is a widespread perception in the community that the area is at a cross-roads. Were it not for the coal industry, this area may well have been developed in the post-war years, with little regard for planning objectives of any sort. There are abundant examples, in Queensland and elsewhere, of fragile coastal areas of great natural beauty, close to capital cities, which have been degraded by inappropriate, insensitive and uncontrolled development.
The coal-related history of the northern Illawarra has provided a respite from these earlier pressures. There is now the opportunity for enlightened planning decisions to determine the future “look” of the area. These decisions must secure the broader planning objectives stated in the draft LEP 38 (September 1988) and the draft Wollongong Development Guide and Plan (October 1987). These stated objectives include the following.
1. To encourage the proper management, development and conservation of natural and man-made resources, including agricultural land, natural areas, forest, minerals, water, cities, towns and villages for the purpose of promoting the social and economic welfare of the community and a better environment;
2. To protect the environment from degradation and despoilation by protecting environmentally sensitive areas from development, and minimising adverse impacts of urban development on both the built and the natural environment;
3. To protect and improve the quality of life and the social well-being and amenity of local residents;
4. To encourage economic diversification and growth of the business and industrial base to increase employment.
It is crucial that planning decisions taken now, within this general framework, incorporate an appreciation of the special physical and environmental constraints of the northern suburbs area and of the pressures to which the area is, and will increasingly be exposed.
2.5 The Issues Discussed
In the wide variety of community discussions (see Apendix 2), many issues were raised by concerned residents and discussed widely. There are too many to present in detail here. Instead, we have focussed on a set of broad-scale concerns which seem to be common to all precincts, from Helensburgh to Woonona.
2.5.1 Future “look” of the northern suburbs
Rich historical influences have steered development in the northern suburbs of Wollongong to their present, readily identifiable character. Moreover, there are unique and strong local links which bind many of the villages and suburbs, resulting in high levels of community cohesion and activity. Planning must address not only the physical issues involved in growth and development in the north, but must also consider the pre-existing and continuing needs and desires of the existing community.
Much of the past reaction to proposed developments can best, and sometimes only, be understood by realizing that for a very large proportion of residents, there is a commitment to a lifestyle which has been jealously guarded, perhaps for generations.
The current pressures from Sydney’s “spill-over” is already giving rise to rapid transformation of some areas. Rows of miners’ cottages are now being overshadowed by 30 square metre (and larger) brick-veneer dwellings. These, transposed from Sydney suburbia, do little for preserving the character of a local area.
The maintenance of levels of social cohesion of community and amenity, having regard to existing conditions, is seen as dependent upon future planning creating both a climate and guidelines which mean that changes can be made from a position of relative security for long-term residents.
Increased residential density can be achieved, and examples of this occurring with relatively little dislocation should provide planners and developers with a guide for the future. Two areas in Thirroul are instructive. On the eastern side of Lawrence Hargrave Drive, between Thirroul pool and the top of Kennedy’s Hill are the remnants of a past ad hoc planning policy. Three- and four-storey walk-up units are littered around the foreshore. By any criterion, these “boxes” are eye-sores which sit among Federation-style dwellings.
In contrast to this situation, significantly increased residential densities have been achieved in the Mountain Road area, after some initial difficulties, in a style more acceptable to the community generally. Planners, in consultation with the community, must identify areas where this sort of residential expansion can be accommodated. Progressive, selective and incremental rezoning of areas to medium density, rather than a scatter-gun response to individual development and rezoning applications, is seen as a rational way to cope with residential growth in the northern suburbs.
The demand for new, contemporary housing can be met too, without much of the conflict attending past developments. The Hooker estates on McCauley’s Hill at Thirroul, new subdivisions at Bellambi, and moderate expansion at Helensburgh are the only three areas left in the northern suburbs where new, detached housing can and should be located.
Pressures for increasing tourism can be met, as long as there is a recognition that natural features and characteristics of the area are capable of absorbing only relatively low-key developments which complement the natural beauty of the area. Adding imposing structures that detract from the natural beauty and vistas of the escarpment and foreshore is unacceptable.
2.5.2 Limits to development
CANS notes the discussion of the development potential of the northern suburbs in the “Draft Wollongong Development Guide and Plan”, prepared by the Town Planning Department in October 1987. This document is useful in addressing the larger issue of how the planning process can recognize and incorporate the development constraints in the area, in harmony with broader planning objectives which have been laid down.
The Development Guide and Plan notes that opportunities for development in the northern sub-region, other than for high-income residential infill or redevelopment, are limited by a variety of factors. These include the high cost and current unavailability of resources and the relatively poor access along the coast (p. 6). The introduction to the document also notes:
The escarpment, Lake Illawarra and the beaches provide a high-quality setting to the local environment. Their protection and enhancement is a major factor in upgrading the quality of life in the area and at the same time providing tourism potential. (p. 3)
Because of the very limited and linear land area of the northern coastal plain, this planning objective limits the scale and nature of potential developments in the area. Since 1974, the Illawarra Escarpment, from Stanwell Park to Macquarie Pass, has been listed by the National Trust and classified as a “Landscape Conservation Area” (see Appendix 3). The reasons for this listing are as follows.
The Illawarra escarpment is considered of supreme importance to the drama of the Wollongong-Port Kembla landscape and to the South Coast landscape as viewed from the Princes Highway and Bald Hill. The combined effect of a narrow coastal plain, rugged escarpment and rich forest and pasture land gives a most unusual landscape of considerable grandeur which exceeds any other coastal plain and mountain landscape on the New South Wales Coast. There are many easily accessible vantage points on both escarpment and plain from which extensive vistas can be seen. Many smaller areas within the escarpment are of specific scientific, historic and scenic importance. The escarpment is located adjacent to one of the most heavily indistrialized and confined areas on Australia’s east coast.
The escarpment and coastal areas are also widely used as a regional recreational resource. There is some potential for limited international tourist participation, especially if there is improved access and management of the escarpment areas. Given the fragility of the coastal foreshores, and narrowness of the coastal plain adjacent to the northern escarpment, a few large-scale, intensive developments on the fringe of the escarpment or the coastline have the potential to blight the magnificent physical setting of the area as noted in the Development Guide and Plan.
In this context, CANS received comprehensive opposition to any large-scale development, coastal, escarpment fringe or escarpment rim, which would compromise the objective of protecting the natural assets of the northern region.
Permitting such developments would be extremely short-sighted, because the scale of the area means considerable qualitative loss (lifestyle and broad tourist potential) for little quantitative gain. The land mass of the area is simply not large enough to make much difference to the “land supply equation”. The regional economy would be far better served by recognizing and preserving the valued features of the area and actively enhancing its potential in these respects.
2.5.3 Improving visual amenity and quality of life
The issues of the retention of “green breaks” from the escarpment to the sea to articulate the city and reinforce the urban elements, as noted in the preface of the Guide and Plan, are particularly pertinent to the northern suburbs. As noted above (section IV), the colliery lands extending from the escarpment to the railway line have been major historical features of the area. Much of this land is “green” – either forest or a mixture of forest/regrowth and grazing land.
Not only have these lands established the boundaries between the former mining villages, but they have also been regarded as publically accessible, through policy of the mine owners and custom. “Keep Excelsior Green”, the name adopted by the community group opposed to residential development of the old Excelsior land between Thirroul and Austinmer, reflects public desire for retention of these green corridors.
As noted elsewhere in this document, the future use of the colliery lands is perceived to be one of the largest issues affecting the region. CANS submits that it is necessary for planning decisions to be taken about the future fate of these lands now, bearing in mind that the Council has the opportunity , through the planning process, to contribute to the “greening” of the City by recognizing that the “green breaks” in the north should be substantially retained and properly managed.
The considerable effort required to create a “green corridor”, where clearing and development have already proceeded too far is seen in the Keira Green Corridor. If the green areas of the northern coastal plain are lost now, they will probably never be reclaimed.
2.5.4 Soil stability, erosion & flooding
These issues are stongly felt throughout the northern suburbs, and some residents in most precincts have anecdotes about battles with Council in attempts to resolve specific problems. The fact that all precincts reported problems stimulated CANS to call a special public meeting (July 21st 1988) to address the issues. The resolutions of that meeting, attended by over 200 residents from Helensburgh to Woonona, are presented in Appendix 5. In order to solve these problems, the following should be addressed:
* identify adequately, and advertise the location of slip-prone lands and failure to provide a mechanism to protect future potential residents from disaster;
* recognize that excessive land clearing higher in the escarpment and residential development will inevitably lead to increased peak water flows in the watercourses draining the escarpment;
* develop land management strategies for higher in the catchments (e.g. protection or replacement of tree-cover) to reduce the likelihood of slip problems appearing in existing residential areas;
* recognize that although individual developments may not appear to have a significant effect on runoff and drainage, the real impact is the sum of many small, incremental effects. Therefore, in these escarpment areas, the impact of development must be studied for a whole catchment, not one development application at a time;
* the identification of areas on the coastal plain which have flooded frequently in the past and the need to investigate management strategies to prevent future flooding;
* recognize the significane of the temporal pattern of rainfall in the area, which produces infrequent but substantial water-flows to the coastal plain from the escarpment creeks. The natural consequence of this pattern was a narrow, meandering creek channel with a flood-plain inundated only in periods of heavy rain. These small flood plains should be recognized as constraints to residential development, and a more appropriate and creative use made of them.
2.5.5 Limits to residential growth and development of the area
Community discussions revealed several limits to residential growth which should be obvious. The relatively small area of land in the narrow coastal strip is the ultimate constraint to overall development. There are aesthetic and tourism reasons for defining eastern and western boundaries to development: there must be a coastal strip reserved for open-space/recreation where-ever possible and the current escarpment vegetation must be retained. These requirements will preserve the attractive look of the beaches from the lookouts and of the escarpment from the coastal plain.
In addition to these arguments, a well-vegetated escarpment is crucial to the stability of land, including the land further down-slope and already developed, and to the control of watercourse erosion and flooding. It is likely that future problems may be averted if further escarpment clearing is controlled, and areas that were one cleared may need to be revegetated with natural vegetation. Unfortunately, neither the State Government nor the Council has attempted a broad scale survey to define where current and potential problem areas are and just how development should be controlled (see below).
The escarpment has additional value as a corridor for wildlife movements. This is recognized in the plan of management for the State Recreation Area. However, the Council is risking the value of the area for wildlife by failing to secure the northern end of the escarpment. It is important that the escarpment vegetation links with Royal National Park.
Given the above comments about the importance of a well-vegetated escarpment, there is a very strongly and widely held belief that residential development has reached its western limit: in several places it has probably exceeded this limit.
2.5.6 Current deficiencies in the planning process
Council planners, in considering recommendations regarding development consents in escarpment areas, have paid inadequate attention to the issue of the broad development constraints of the area. These are set by geological, topographical and rainfall conditions and by environmental attributes.
Instead of engaging these issues directly, in a professional manner, there have been many instances when planning decisions have been based on peripheral issues such as “is water available?”, “will the development require the removal of trees in contravention of the tree preservation order?”
These peripheral issues are, of course, relevant, but they must not be relied upon as a substitute for the more substantive, important and difficult issues of protecting the overall character of the northern suburbs and acknowledging the constraints to development.
An example of the problem is seen in a report of Council’s LEP Review Sub Committee (26th April 1988):
It is evident that there is a need to tighten up the conditions under which development will be permitted in Environmental Protection zones.
The matter has become rather more urgent now that the Water Board has abandoned its stance of opposition to any development which did not have a piped water supply, thereby placing much more emphasis on the other planning arguments if development is to be restricted.
CANS fully supports the recommendations contained within this report regarding the requirements to be complied with in Environmental Protection zones. Many of the longer-running controversies regarding rezoning recommendations and development consents on land adjacent to the escarpment in the northern areas have festered on because Council refused to engage the broader range of development constraints when the matter first arose.
The reluctance of planners and Council to base planning decisions on this broader range of constraints is clearly evident in the consideration of a large-scale residential subdivision on the upper bench of the escarpment at Thirroul (see Appendix 4), where decisions on a development control plan were based solely upon the Council’s perception of the availability of water supply. There are many unfortunate consequences of this approach:
* by the reduction of issues solely to water availability, the applicant for development consent is left with the incorrect perception that this factor is the only impediment to the proposal proceeding;
* community groups which are principally concerned with the broader issues of the proposal are left with the impression that the officers of Council are not interested in these issues, preferring to defer their decision;
* if the single constraint (in this example, water supply) is removed, for example by a change in Water Board regulations, it becomes very difficult indeed for Council to engage broader development constraints in a professional manner. If Council, at this later stage, does address additional constraints, the developer is left perceiving that Council has “given ground” to pressure from residents;
* this situation implies that the relative importance placed on various development constraints is at Council’s discretion encourages both developers and community groups to believe that political pressure is more important than a professional approach to planning;
* proposals which could have been rejected of modified to an acceptable form at the outset, from a consideration of broader issues reflecting development constraints, are left unresolved for long periods. This imposes avoidable costs and uncertainty on the developer and produces suspicion within residents’ groups, who believe that the battle will have to be fought again and again.
2.5.7 Opportunities for increased residential density
The general community feeling is that the northern suburbs is, and should continue to be, predominantly a region of private residences. There are many reasons for this.
* This is the environment current residents wish to have: for many, the juxtaposition of natural areas of escarpment and an urban or village area is the reason they moved here in the first place.
* There will be a demand for “higher income residential infill” in these areas with increasing pressure for expansion of Sydney. This will not occur if the nature of the area changes.
* It is inappropriate to encourage industry to the area except where it will not compromise the residential nature of an area. Moreover, transport is a problem and more centralized, industrial estates are being made available nearer Wollongong.
* There is little opportunity for appropriate resort-style tourist developments in the northern suburbs.
It is generally felt that the northern suburbs areas are already nearing the capacity for acceptable residential development. There are two components to increasing the population in a region: (i) increasing the area available; and (ii) increasing the density.
There is a strong opinion that the area that has already been made available for new residenial development is excessive, especially at the western margin of the northern suburbs. Potential land instability problems and aesthetic arguments lend substance to these opinions. Increasing density therefore seems to be the sole mechanism for increased population.
The problem is perceived to be twofold. Firstly there is the need to plan for increased density before development applications are dealt with case-by-case. As described above (2.5.1, p.7), this scattergun approach to planning has produced the scattering of 3-storey “walk-ups” in the Thirroul-Austinmer area, which should never have been contemplated. “Incremental creep” is well illustrated in this area of planning, where each approved, individual development application may seem to have an insignificant impact, but many individual blocks scattered through an area will ruin the character of the whole area. Thus many people view Smith’s Hill as a failure of proper planning which must never be allowed to occur in the northern suburbs. Council must be prepared to propose, and discuss with the community, possible areas in which higher-density housing can be confined.
Secondly, there must be (and be seen to be!) stringent controls over the style of developments permitted within higher density areas, especially near the northern beaches. Council’s Residential Standards Control Plan (diagram on p. 36) contains a recommendation about building heights in relation to topographic features that is relevant for the northern suburbs beaches. “A control in terms of meters at any point above natural ground encourages buildings to follow topography.”
Along these lines, the community response received by CANS indicates a strong desire to prohibit any further building of two-or-more storey structures on the beachfront (i.e. in the “first line” of dwellings) in any zoning. The fact that some already exist does not prevent an alteration in the regulations. In agreed high-density residential areas, taller buildings could be permitted as defined by the topography.
Design of units is especially important in the northern suburbs areas, because the future demand here will be for high quality, sensitively designed units. Important factors here include: adequate side-setbacks to ensure privacy and prevent overlooking; all parking to be off-street; imposition of a height limit related to topography.
2.5.8 Reducing community conflict
It is clear from the above discussions that a common concern is an apparent inability of Wollongong Council to resolve planning issues to the satisfaction of residents. We identify three components to this:
* inadequate involvement of a sufficient number of residents in the planning process sufficiently early for their views to be incorporated in a real way;
* constant change of Council’s position in response to new development proposals such that residents are forced to fight repeatedly for a particular issue;
* a demonstrable inability of Council to enforce development controls of various sorts (i.e. tree preservation orders, development control plans), without local residents having to perceive the violations and agitate about them.
These points significantly determine the strength of community opposition to Council’s zoning proposals, and will affect the community’s response to a revised LEP 38. While the community perceives that it will have to fight again in the future to retain a zoning which contains agreed and appropriate objectives, there will be pressure to impose a more constraining and protective zoning in the first place. While the community perceives that the current planning process does not ensure adherence to regulations which are designed to constrain development within the agreed objectives of a zoning, there will be constant pressure to impose more restrictive zonings.
The Excelsior Colliery land between Thirroul and Austinmer provides a clear example of the first of these problems. Some of this land is considered by many local residents to be suitable for a variety of purposes. However, the belief that Council will entertain future proposals for what are considered unacceptable developments has forced residents to argue that a 7(e) Environmental Protection (escarpment) is necessary.
The proposed 7(c) Environmental Protection (Living Area) Zone provides a good example of the second problem. An objective of this zoning is “to cater for residential and village development in selected areas possessing special environmental qualities or which may be affected by environmental hazards; and to allow some diversity of activities which will not … detrimentally affect the environmental quality or character of the locality…” Such zonings exist in the escarpment fringes, where tree cover is important, both aesthetically and as a means of binding surface soil against erosion and reducing soil moisture by transpiration. The creeks in this area, which run through current residential areas, and drain onto the flood-prone plain, are subject to severe erosion in high-rainfall events. Careful control of tree clearing, damage to creek margins during preparation of lots for building and diversion of subsequent runoff away from creek lines is clearly of great importance. Yet there are many instances of too-severe clearing unnoticed by Council, blockage of creeks during clearing and construction, and severe erosion and flooding downstream.
Reducing community conflict regarding development issues will clearly require changes in practise and attitude on the part of Wollongong City Council.
3. CANS Responses to Draft LEP 38
3.1 Introduction
During the set of community discussions held by CANS and the compilation of this report, Wollongong Council has been proceeding with the revision of the Local Environmental Plan. A draft plan is currently on display, accompanied by documents defining (i) residential standards and (ii) commercial and industrial development.
CANS members have had an opportunity to review these documents and relate them to the outcomes of community discussions described above and in Appendix 2. It should be noted that community consultation organized by CANS has taken about twelve months. Council has prepared a series of draft plans and placed the draft documents on exhibition within that time.
This timing must indicate that community input will be responsive to proposals formulated by Council, through comments on the draft plan, rather than formulative. CANS believes that there must be substantial community consultation about the limits to development and other issues before proposals have become firm. This is especially true of the northern suburbs sub-region, which has a unique social and industrial history and a special set of physical constraints.
For these reasons, and for others outlined below, CANS proposes that the Draft LEP 38, at least the sections of it relating to the northern suburbs, should not be enacted until substantial further work and community consulatation can be conducted.
This submission by CANS regarding the LEP 38 is in three sections:
* General comments regarding the draft Plan.
* Detailed comments on some aspects of the Plan as proposed in Council’s draft document.
* Comments on the supporting documents (i.e. Residential Standards).
3.2 General Comments
1. The current draft LEP 38 should be withdrawn and revised to take into account the following deficiencies. If this is not practicable, the application of the proposed changes to nothern suburbs areas must be delayed until further study of the northern suburbs is completed. Procedural matters requiring immediate attention are:
(i) discussion of limits to population growth in the northern suburbs;
(ii) adequate definition of “advertised development consent” with the legal implications for third party rights of appeal;
(iii) preparation and circulation for public discussion of comparisons of the past and proposed LEPs.
In addition, there is a need for a longer-term, detailed, environmental and development study of the northern suburbs, incorporating input from local residents, which should be commissioned or co-ordinated by Council.
2. There are serious problems with the rationale behind two zonings in particular: Zone 1 – Rural, and Zone 7(c) Environmental Protection (Living Area). Both of these zonings obscure the actual uses to which the Council proposes to put some of the land, namely residential. CANS proposes that land considered suitable and appropriate for residential development should receive a residential zoning (i.e. Zone 2), thus clearly distinguishing it from what should properly be reserved for rural activities or for environmental protection.
3. These problems are of such magnitude that Council should defer any action on these zonings until a study can be carried out, with community participation, with the aim of constructing rational zonings and deciding on the allocation of lands to new zonings.
4. The Environmental Protection zonings should be revised to recognize the unique set of objectives for protection in each area and the unique set of constraints which define permissible developments in the light of the objectives. CANS proposes a revision to the 7 zonings, based on an hierarchy of levels of protection, as follows:
7(a) Environmental Protection (Preservation) provides the greatest protection;
7(b) Environmental Protection (Community Recreation) permits community access to and passive recreation in land with significant environmental attributes;
7(c) Environmental Protection (Special Uses) provides opportunities for appropriate recreational and tourist activities
5. The 7g (Living Area) (=proposed 7c) zoning should be abolished, and lands currently with this zoning should be reviewed.This review should incorporate resident input and would rezone 7(g) land in either a highly controlled 2 (residential) zoning or an appropriate environmental protection zoning.
6. In the light of the extreme importance and sensitivity of the escarpment areas and other environmentally sensitive areas, in the current climate of pressure for residential expansion and other development, any proposed development in any area zoned for Environmental Protection, or any proposed rezoning of an Environmental Protection area should be subjected to public exhibition.
7. The LEP must set in place a consistent and stringent set of controls over higher density residential development in the coastal fringe of the northern suburbs.
8. Council should incorporate in the LEP all recommendations put forward by various Total Catchment Management committees, including the Hacking River committee and the Lake Illawarra committee. Moreover, these Total Catchment Management committees illustrate the need to apply the same, broader-scale approach to all propsed new developments in the northern suburbs.
3.3 Detailed responses (page references relate to draft LEP of 20/10/88)
3.3.1 Aims, objectives and strategy (clause 5, p.2)
1. CANS supports the general aims of this LEP as stated. However, there is considerable doubt about whether these sorts of aims have been achieved in the past. Moreover, it is not clear who should make the subjective judgements about “social well-being and amenity of local residents” (clause 5.1(c), p.3).
2. Council should establish a mechanism for periodic evaluation of whether planning decisions in an area have indeed satisfied the aims stated here. Such a mechanism should deliberately seek community opinion; not solely through responses to documents prepared by Council but also by active soliciting of views through community groups and other avenues.
3. CANS supports strongly the Residential Standards accompanying the LEP. These clearly stipulate many stringent and appropriate controls over development, and CANS urges that Council develop a mechanism for policing these controls (clause 5.2(a), p.3). This is an area in which Council has been demonstrably ineffective in the past. Careful adherence to these standards will, in our opinion, reduce the amount of community conflict over proposed rezonings and proposed developments within existing zonings which could otherwise be considered appropriate or reasonable.
3.3.2 Interpretation (clause 6, p.3)
1. CANS expresses serious concern over the definition of “Camp or Caravan Sites” (clause 6, p.4). As stated, this category of development includes structures called “cabins”. Cabins are not defined – they should be. Moreover, standards for cabins do not appear to have been set in Control Plan No. 9.
2. There are many places, especially in the northern suburbs, where cabins are completely inappropriate although a low-service camping ground may be acceptable. There is a history, especially in the Helensburgh area for “cabins” to be interpreted so loosely that proposed structures resemble large “dwelling houses”.
3.3.3 Zone 1 (Rural Zone) (clause 9, p.15)
1. CANS takes issue with this zoning as presented in the plan. It appears to treat rural land as a reservoir for suburbs of the future – “to cater for planned natural urban growth… or environmental protection” (Zone 1, 1(a)(i)& (ii), p.15). These objectives make a mockery of the name of the Zoning. If the land is to be earmarked for residential development, then it should be proposed for rezoning to a 2 zoning, and community comment invited. In fact, many of the developments proposed to be permitted after advertised development consent are completely incompatible with retaining the rural character of an area.
2. CANS proposes that this zoning should be used to identify land that is most appropriate as rural! Wollongong must not be viewed as an ever-increasing sprawl, producing the crises of increasing costs of servicing and transport seen in so many Australian cities. However, the landscape surrounding Wollongong does contain rural areas which should have their character retained, as is the case with the Jamberoo valley (see National Trust listing quoted in section 2.5.2, p.9; see also Appendix 3).
3. In the light of the above comments, the proposed zoning of the eastern portion of the old Excelsior Coal Mine land as 1 Rural is completely inappropriate. More reasonable possibilities include: 6(a) Recreation (Open Space); 2(d) Residential (Controlled Development); 7(b) Environmental Protection (Community Recreation). [Note: these zoning use terminology suggested by CANS in this document]
3.3.4 Zone 2(b) (Residential “B” Zone) (clause 9, p17)
1. Under 1(b), the density – or range of densities – proposed here should be defined explicitly. Presumably this zoning represents medium density residential areas, and precise figures for the range to be permitted will reduce future misunderstandings and conflict between potential developers, the Council and local residents.
2. Similarly, scale and height [1(c)(i)] ought to be defined clearly. It is not acceptable to relate the height and scale of a proposed residential development to existing buildings for several reasons. Firstly, existing but completely inappropriate buildings now determine the characteristics of the locality but should not be duplicated or treated as an acceptable benchmark. Secondly, the proposed definition allows for “incremental creep” of inappropriate developments. It is relatively easy to “give in” to a single, isolated development application which is only slightly outside the acceptible scale and height. However, once built, this single building makes policing the objectives more difficult in the face of future development applications.
3. This zoning, and the Residential “C” Zone, should make a clear statement about the heights of buildings adjacent to the coast, especially in the northern suburbs. CANS proposes that the Residential Standards Control Plan should make careful stipulations about the heights and designs of buildings in coastal areas, in particular restricting all buildings in the “front line” (i.e. within 200 m of the coast – beach or cliff-top) to single-storey dwellings, regardless of the zoning.
3.3.5 Zone 2(c) (Residential “C” Zone) (clause 9, p.18)
1. Criticism “2” in 3.3.4 above relates also to this zoning.
2. It is inconsistent to expect to attract high-density, residential development [1(a)] with little increase in traffic generation [1(b)(ii)]. This should state clearly that increased traffic (including a need for off-street parking) will be generated and must be accommodated for by the developer.
3. In view of the problems outlined for these two residential zones, CANS proposes that size, scale and density thresholds be set such that any proposed developments exceeding the stated threshold should be advertised for public comment (Zone 2(c), 4, p.19). The serious long-term effects of bad development decisions in relation to high density housing makes it important for third-party rights-of-appeal to be preserved here.
3.3.6 Zone 6(a)(b)(c) (Open Space) (clause 9, pp.24-26)
1. With the trend towards more leisure time and the expansion of higher-density development, it is imperative that sufficient recreation and open space areas be put aside. In new developments, these areas should be identified as the areas most appropriate for open space/recreation, and not simply the remnant patches of land unsuitable for any other use.
2. If the 6(a) (Open Space – Recreation) zoning really has as its objective the provision of recreation facilities in the open, the objective of the zone should be “… to provide for passive recreation” and “… to promote the development of appropriate facilities for the benefit of nearby communities. One of the problems with existing Open Space – Recreation areas is that they have simply been identified, and provide no benefit to nearby communities.
3. Given that the aim of this zoning is the provision of recreation facilities in the open, many of the activities listed under 3 (only with development consent) belong more properly in other zonings. For example, if an area is to be used for agriculture, it should be zoned 1 (Rural). Entertainment facilities and registered clubs, as they are broadly defined in clause 6 (Interpretation) may well also be incompatible with an Open Space, especially if they are private clubs which do not benefit the whole community: 6(b) is an appropriate zoning for such activities.
4. Under Zone 6(b) 3 (Only with development consent), the following represents an incomprehensible piece of information: “…dwellings used in conjunction for a purpose [for?] which development consent is required and situated on the land on which the development for that purpose is carried out…”
5. Once again, it is hard to see how many of these activities under Zone 6(b) 3 can reasonably be viewed as “Open Space”.
6. CANS suggests that the Open Space zonings be renamed “Recreation”. Thus there would be: Zone 6(a) Recreation (Public Open Space); Zone 6(b) Recreation (Private Facilities); and Zone 6(c) Recreation (Tourism). Management plans should be prepared for all these zonings, especially Public Open Space, and placed on public exhibition for comment. Furthermore, all proposed development in the 6(a) zone, or any proposed rezoning from a 6(a) zone, should be advertised and placed on public exhibition.
3.3.7 Environmental Protection: 7 Zonings (clause 9, pp.26-29)
1. The basis upon which the Environmental Protection zonings were formulated in LEP 38, and which continue to underpin the draft LEP, is extremely confused and unsatisfactory. An examination of the existing zonings reveals that some reflect a land use [e.g. 7(c) Water Catchement, 7(g) Living Area, and 7(h) Hacking River Catchment], others are based largely on inherent environmental values [e.g. 7(a) Wetlands, 7(b) Estuarine Wetlands, 7(e) Escarpment, and 7(f) Foreshore]. This system is further complicated by 7(d) Scenic.
2. This approach was unacceptable, and CANS believes that the most productive way of proceeding to a reorganization of these zonings is to abandon the unsatisfactory approaches of the LEP 38 and the new draft, adopting instead a clear hierarchy of levels of protection. This would be complementary to other zoning classifications (e.g. residential, business, industrial) and would provide a rational system if increasing levels of protection for environmentally sensitive land.
3. There can be no doubt that current attempts to collapse the eight individual, environmental protection zonings into three results from partial recognition that zonings based solely on environmental characteristics are unworkable. Largely this is because different areas within each classification will require different zonings. For example, not all escarpment areas, or foreshore areas have the same values or attributes.
4. Many of the problems that have attended the current 7(e) zoning have been attributable to the fact that the zoning has had to nbe loose in order to accommodate the very different levels of development that have been sought. At one end of the spectrum, a large tourist/recreation/motel/convention centre/parking area complex has had to be accommodated within the 7(e) zoning along the escarpment, while at another location, a single dwelling can be refused or prohibited.
5. A single zoning that is so broad that it can permit such a wide range of activities against a backdrop of “environmental protection” must be seriously questioned. Similarly, a zoning that is applied equally to the most pristine areas of escarpment and to severely degraded, ex-mining sites has dubious value. The transfer of the bulk of current 7(e) land to a proposed 7(b) zoning is merely changing the label of this problem.
6. CANS recommends the following solution to these problems. The Environmental Protection zonings should identify a hierarchy of “levels of protection” 7(a) (Environmental Protection – Preservation), 7(b) (Environmental Protection – Community Recreation), and 7(c) (Environmental Protection – Special Uses). Proposed revisions are as follows:
7(a) Environmental Protection (Preservation)
Objectives of the zone: To afford the highest level of protection to areas of foreshore, escarpment, wetlands, floodplain or woodland because of their environmentally unique or ecologically sensitive character. To retain and enhance the quality of catchement areas providing water for human consumption.
Development permitted without consent: Nil
Development only with advertised development consent: Water storage dams, buildings and installations associated with such storage facilities, utility installations, recreation areas, mines and ancillary activities.
Prohibited: Any purpose other than a purpose for which development may be carried out with or without development consent.
7(b) Environmental Protection (Community Recreation)
Objectives of the zone: To permit and promote controlled community access to and passive recreational use of land withe significant environmental attributes. To permit the development of related educational, camping and visitor facilities. To protect sites of significant geological, biological and visual importance. To protect general catchment areas not related to stored waters (e.g. Hacking River).
Development permitted without consent: Nil
Development only with advertised development consent: Recreation areas, camping areas, educational facilities, utility services, visitor facilities, roads.
Prohibited: Any purpose other than a purpose for which development may be carried out with or without development consent.
7(c) Environmental Protection (Special Uses)
Objectives of the zone: To provide opportunities for recreational and tourist activities which are compatible with sensitive environmental area. To allow development which carries significant public benefit providing there is no degradation of ecological, aesthetic or scenic qualities.
Development permitted without consent: Nil
Development only with advertised development consent: Recreation areas, camping facilities, hotels, restaurants, horticulture, education facilities, tourist facilities, visitor facilities, car parking, mines, utility installations.
Prohibited: Any purpose other than a purpose for which development may be carried out with or without development consent.
7. If areas are to be treated seriously as environmental protection (7(a) or 7(b), above), especially as maintaining land stability and minimizing downstream flooding are factors contributing to the objectives of the zoning, activities such as agriculture and buildings used in conjunction with agriculture must be specifically excluded. In areas which have been devoted to agricultural activities in the past, an objective should be the revegetation of already disturbed land with native tree cover, especially adjacent to water courses.
8. In view of the need to place more escarpment land into public ownership, to give it the level of protection afforded by the State Recreation Area, CANS proposes that Council identifies, with an appropriate zoning, land which should be incorporated in State Recreation Area but is currently in private ownership. Such land would thereby be protected from further degradation or development until funds can be mobilized to purchase the land.
3.3.8 Environmental Protection – Living Area
1. CANS argues that this zoning is unacceptable and should be dropped altogether from the LEP. This 7(g) zoning has proved to be a failure since its inception and there is little evidence or reason to suggest that it would operate any more effectively under the proposed title of 7(c).
There are two reasons for the failure of the 7(g) zoning. Primarily, it has sought to address two often incompatible objectives, namely environmental protection and residential development. In as much as it has been used as a zoning/land use device, it has failed to achieve any effective control or restraint over the environmentally sensitive land to which it has been applied. Many have interpreted it as a thinly veiled technique for converting or extending escarpment and foreshore land to a residential use.
Secondly, the 7(g) zoning has failed in its envisaged role as a development control device. This has been largely due to the absence of clear guidelines and/or standards that apply to what has become little more than a glorified residential zoning. The recently approved cliff top developments in Scarborough, the three-storey developments at Coledale and the subdivisions at Thirroul are all indicative of the failure of 7(g) to achieve any measure of control in relation to building height, scale, placement or design.
2. It is the strongly held view of CANS that the 7(g) zoning (7(c) as proposed) be abandoned. CANS proposes the following strategy for the successful, long-term resolution of zoning the sensitive escarpment and foreshore lands:
3. Firstly, a programme of identification must be commenced, which, in consulation with the community, will determine two ways of treating land currently zoned 7(g). Firstly, there are parcels of land that have been previously developed or degraded to such an extent that to apply an “Environmental Protection” zoning makes a mockery of the zoning. Where there is sufficient information available to Council to determine that, in the long term, it would be impractical to retreive the situation, Council should adopt an “up-front” residential zoning[CANS proposes Zone 2(d) (Residential – Controlled Development Zone) see below], accompanied by appropriate development controls which would address the specific constraints of the sites.
4. Secondly, there are large parcels of land currently zoned 7(g), especially at the escarpment/urban fringe, which are as yet undeveloped and about which there is too little information to apply a zoning with confidence. The effect of even well-controlled development on the stability, flooding and erosion on existing residences downslope is often not known. Equally, there are pockets of foreshore land that have sustained only minor incursions of residential development. CANS proposes that, in the long term, these lands which are identified as having been only minimally affected by development or other degradation should revert to public ownership.
5. CANS proposes that, for the great majority of land currently zoned 7(g) – proposed 7(c), and especially those parcels so zoned but as yet undeveloped, the zoning be deferred. Deferral should be used as an opportunity for the processes of identification (mentioned above) to take place. These processes will include a series of local environmental studies and community consulatations to determine the best long-term zonings. If land owners desire to develop such deferred lands during this process, the minimum requirement for evaluation (including public display) must be a local environmental study, commissioned by Council but paid for by the applicant.
6. Following local environmental studies and community consultations, these deferred lands will be zoned either for environmental protection (7(a), (b) or (c), as appropriate) or a stongly controlled residential zoning (2(d), see below).
7. CANS proposed a new residential zoning to accommodate land currently zoned 7(g) but which is accepted as being more properly in a residential zoning:
2(d) Residential (Controlled Development) Zone
(a) to cater for limited, very low density residential and village development in selected areas possessing special environmental qualities or which may be affected by environmental hazards;
It is feasible that a zoning such as this could include Agriculture as a development with consent, especially if the area so zoned is adjacent to a specified Rural zoning. However, agriculture is seen as a prohibited development within any of the “Environmental Protection” zones.
3.3.9 Developments always requiring development consent (clause 10, p.31)
1. This clause should include: “alteration to or obstruction of natural watercourses by means of fill or excavation.”
2. Also: “filling of land with coal wash or mine waste, exceeding some threshold volume.”
3. (m) “clearing” and “partial clearing” needs to be defined.
3.3.10 Advertised development consent (clause 11, p.33)
1. The new category “advertised development consent” is not properly defined. Its implications are not clear and have not been explained to the community.
2. This third tier of development appears to be replacing “spot rezonings” in such a way as to avoid the current delays of processing by the Department of Planning. CANS believes that there are many instances in which proposed development should be advertised but not in the “fast-track” way indicated by “advertised development consent”. Under no circumstances should advertised development consent be applied to proposals for environmentally sensitive areas (e.g. 7 zonings) or areas that are for public use (e.g. 6 zonings).
3. The implications of this new development category for “third party rights of appeal” after failed objections to proposed developments must be made clear. The process of involvement of residents and other parties, who are not directly affected by a proposed development but who have a real contribution, is especially important in the northern suburbs.
3.3.11 Subdivision of land (clause 13, p.34)
1. 13(3) is incomprehensible and needs to be reworded. It is presumed that the intention here is to provide allotments for non-dwelling houses.
3.3.12 Items of Environmental Heritage (clause 33, p.44 and Schedule 2 p.56)
1. CANS strongly supports Council’s dedication to the preservation of items of natural heritage and historic significance. Community suggestions should be solicited by Council and attention is drawn to the suggestions brought forward to CANS during our communitty consultations (see Appendix 2).
3.4 The strengths of the supporting documents
In contrast to many of the concerns held about zonings, outlined abve, CANS believes that the Development Control Plan No. 9: Residential Standards is carefully prepared and contains many appropriate controls. This situation implies that the application of standards has not received sufficient attention in the past. The following comments highlight those portions of the Development Control Plan which have particular relevance to northern suburbs areas.
3.4.1 Densities (p.6)
See CANS proposal for 2(d) residential zoning: 3.3.8 – 2, above.
3.4.2 Set Backs (p.7, pp.37-40)
CANS supports strongly the need to control the style of residential flat developments, both to protect adjacent residents from being overlooked and to discourage the box-like, walk-up developments of the past. A 1:1 side setback is seen to be the most effective way of encouraging imaginative and sensitive developers. It is argued that both the current real estate market and the profit margins of good developers will easily tolerate this ratio.
3.4.3 Submissions (p.10-11)
1. CANS supports the need for an assessment of environmental quality to accompany every development application, and agrees with the list of items to be addressed by an applicant. In the northern suburbs, at least, storage and re-use of topsoil and prevention of erosion have frequently been neglected by developers (see Photograph). Clearly this development control must be more thoroughly applied.
2. With respect to areas known to be susceptible to landslip (p.11; also p.25 “Submissions”), CANS argues that a geotechnical report for the site alone is inadequate. Tree clearing and other activities during development and altered drainage after development may make adjacent and down-stream land more susceptible to slip. CANS has argued the need for a special zoning for such land (see Appendix 5, below; and section 3.2 – 6, above).
3.4.4 Subdivision – soil and water (p.13)
CANS supports the approach of the Lake Illawarra Catchment Committee regarding the need for a soil and water management plan for new subdivisions. However, this need is not confined to the Lake Illawarra catchment. The impact of clearing for subdivisions is potentially severe in the northern suburbs, given the steep terrain and the erodible creeklines. A proposed subdivision in this area should also contain a water management plan, which includes a mechanism for keeping stormwater runoff out of local watercourses.
3.4.5 Definitions (p.28)
The definitions here should also include an acceptable definition of “cabin”, because such a term occurs in the draft LEP in relation to camping grounds and other temporary tourist residences. Several cabin developments have been proposed for the Helensburgh and other areas, and this Control Plan should be extended to cover such proposals.
3.4.6 Building heights (p.33)
1. CANS agrees with the statements in the Development Control Plan No. 9 regarding the importance of controlling building heights: “… if they are placed immediately adjacent to features like rivers, bays lakes or parks, they can detract from use and enjoyment of these and obstruct views.” It is appropriate to list two additional, specific locations common in the northern Illawarra to which these comments pertain: namely, coastal headlands, and escarpment rim.
2. In relation to coastal residential developments, CANS proposes that the principles illustrated on p.36 relating to graduating the heights of building according to topography should apply specifically. Thus the buildings immediately adjacent to the coastal strip should have a 1-storey height limit (3.5 m ??), even in high density areas (Zone 2(c)). Increasing height may be permitted, according to the topography, with increasing distance from the coast.
3.4.7 Trees (pp.58-65)
1. The amount and detail of planning of recommendations regarding retention of existing trees and landscaping after development is most impressive in the Residential Standards document. Council clearly has available to it a great deal of local information, expertise and appropriate policy. This information should be much more widely disseminated to developers and the community in general – perhaps with the next rates notice!
2. The Council’s “Tree Plan”, described on p.60, should be made available for public information and comment as soon as possible.
3. Particular attention should be given to the statements regarding the control of tree clearing within development area (p.60). As there is apparently a “Landscape Manual” which includes information on how to protect trees, no developer should have an excuse for unnecessary damage during site clearance. This should be policed stringently by Council.
3.4.8 New Subdivisions (pp. 66-76)
1. The principles stated here are fully supported by CANS . Any new subdivision should “…make the most of the natural features of the site”, “…allow dwellings to be properly related to their environment”, and “…exclude through traffic and promote pedestrian priority.” The problem as indicated by the style of current and past development is how to promote these principles.
2. In relation to stormwater runoff (p.74), CANS supports Council’s desire to achieve a more efficient and “ecologically viable” drainage system, because this is of particular concern in the northern suburbs. Thus retention of natural vegetation wherever possible is necessary, and Council’s planners should exercise tight control over precisely how much clearing is to be permitted.
3. However, the suggestion that natural watercourses in their natural state should be used for stormwater is unacceptable in the steep, northern suburbs. Replacement of natural vegetation by residential buildings and associated roads increases runoff, especially during the peak of heavy rains. Thus diversion of stormwater into creeks will produce heavier peak flows downstream than ever experienced before development. Since downstream development has usually preceded new subdivisions, increased erosion and flooding is inevitable. Council could be seen to be liable for erosion or flooding damage downstream once it has been informed of the potential danger here. The solutions are either to limit further developments in the urban fringe of the escarpment or to ensure that stormwater is not directed into existing watercourses.
3.4.9 Soil and Water Management (p.77)
1. As stated in the Residential Standards document (p.77), erosion and weed infestation follow urban development. Topsoil is essential for revegetation and landscaping of sites after clearing and building, yet even today, most new developments fail to adopt the techniques needed to stop topsoil loss. It is during the development phase that topsoil is most susceptible and material washed down creeks at this time clogs stormwater drains downstream and causes local flooding.
2. Although the Total Catchment Management committee for Lake Illawarra has apparently recognized this problem, it has been demonstrably ignored by Council in the northern suburbs (see photographs). Since the Residential Standards contains such clear guidelines, it is to be assumed that policing of this policy is at fault. Council must develop a mechanism for policing the standards set for (i) tree preservation; (ii) prevention of excessive water runoff during development; and (iii) disposal of stromwater away from escarpment creeks.
APPENDIX 1
Letter from Wollongong City Council inviting response from CANS
APPENDIX 2
Summary of precinct responses (based on responses to the attached questionnaire)
Helensburgh (1 members/groups meeting; 1 public meeting)
(1) Residential densities to be kept low – perhaps existing block sizes too small.
(2) Extreme importance of Hacking River (Class “P” under Clean Waters Act) means that Helensburgh Development must be curtailed and existing problems addressed.
(3) No expansion of development outside existing urban boundaries.
(4) Current open space adequate though not maintained by Council.
(5) 7(h) “Hacking River” zone must be retained to protect this sensitive resource. Current 7(h) boundary does not protect sensitive land east of Walker St. (Carrington Estates, Helensburgh Heights, Knowsley Park).
(6) Escarpment rim is not sufficiently well protected and must become part of SRA as soon as possible.
(7) Heritage Values: Court House (Parks St.); Post Office (Parks St.); Old Railway Tunnel; Station Master’s house; Big Dam and Small Dam (Cawley’s Rd.); Aboriginal Sites; Railway Station; Natural Spring; Helensburgh mine.
Otford (1 members/groups meeting; 1 public meeting)
(1) No further development outside “Otford Village”.
(2) No further subdivisions within Otford Village.
(3) Council priorities should be (i) establish minimum lot size; (ii) sewerage; (iii) water supply; (iv) upgrade existing roads; (v) police tree-preservation.
(4) Only area suitable for open-space/recreation is inaccessible (no bridge) and is too isolated. Only area for children to use is school grounds.
(5) The escarpment area to the east of Otford (“Bulgo”) should be incorporated into the SRA or Royal National Park as soon as possible.
(6) Heritage Values: Otford School and Residence; Tunnels; Rainforest; Hacking River; Bulgo Huts in the Royal National Park.
Stanwell Tops (1 members/groups meeting; 1 public meeting)
(1) Current residents moved here specifically because of its isolation and natural environment. Subdivision and inappropriate residential development will compromise this environment. Runoff must go either to Hacking River catchment or over escarpment to Stanwell Park.
(2) Current 2(a) “Residential” zoning should be 7(g) “Environmental Protection: Living Area” to constrain future development.
(3) Current open space/recreation is adequate though not maintained by Council.
(4) The escarpment land surrounding the village (zoned 7(e) and 7(h)) are considered to be under constant threat by development which is “allowable with consent”. Residents do not believe that Council has the capacity or the desire to prevent inappropriate developments in these zones.
(5) All land surrounding the current Stanwell Tops residential boundaries should be included in the Illawarra Escarpment SRA.
(6) Heritage Values: Kelly’s Falls Reserve; Princess Marina Walk; Hanging Swamp vegetation; Mineral Pool and Building; Bald Hill lookout; Pristine valley with rainforest upstream of Stanwell Park viaduct.
Coalcliff (1 public meeting)
(1) Future development must be restrained to maintain the village-type atmosphere.
(2) Townhouse-type development should not be permitted within the areas currently zoned 2(a) and 2(b).
(3) The coastal (east of L-H Drive) areas zoned 2(a) (or “deferred”?) should be zoned 7(g) “Living Area”.
(4) When mine land is released, it should be zoned 7(e) and disturbed areas regenerated to native escarpment vegetation or open space/recreation where appropriate.
(5) Walking trails along the escarpment should be established. Bush and beach-based recreation are the only suitable tourist developments in the area. The beaches are already overwhelmed by day visitors in Summer.
(6) Escarpment protection is not considered to be secure until Council makes a firm commitment to the future of land released by mining companies: should become 7(e).
(7) There should be no commercial activity on the escarpment top/rim. Walking trails are the only suitable activity.
(8) Heritage Values: Bullock Track.
Clifton/Wombarra (1 members/groups meeting; 1 public meeting)
(1) Only commercial developments which should be permitted are small-scale tourist businesses within existing buildings (i.e restaurants, gift shops).
(2) There should be no further subdivision of land zoned 7(e) with the exception of land owned by mining companies. When this land becomes available, vegetated portions should be retained as 7(e); cleared areas should become open space/passive recreation with a small amount of residential development (7(g) “Living Area”) at the eastern edge of badly scarred areas.
(3) Rainforest area north of South Clifton Colliery should be protected and access permitted (for passive recreation) from both north and south.
(4) Current boundary of escarpment protection zone is considered appropriate but some doubt expressed about Council’s ability or desire to protect it from further development.
(5) There must be no commercial or other development on the escarpment top/rim.
(6) Heritage Values: Rainforest north of South Clifton Colliery; Mansion on Morrison Ave., Wombarra (The grounds of this late 1800’s house have already been subdivided – inappropriate).
Thirroul (1 members/groups meeting; 1 public meeting)
(1) The constraints to future development in the area will be geographical (proximity to escarpment and coast) and the desired style of development (predominantly low-density residential). Day-tourism to beaches in Summer is considered to be at saturation already. Some contribution to maintenance of beaches/parking etc. should be made by other councils (e.g. Campbelltown & Liverpool). Perhaps a parking charge near beaches, except for residents.
(2) “Intensive” residential development must be confined to areas already so zoned (2(a), 2(b)). Council must exercise tougher controls on the style of residential development near the coast – especially with respect to height. Two-storey, town-house development with sufficient setbacks and complete off-road parking is the limit which should be tolerated.
(3) Some future development may be possible at the eastern edge of the Excelsior land, adjacent to the railway reserve. This could be light industrial.
(4) The 7(g) “Living Area” zoning (off Fords Road) is considered inappropriate given the unstable nature of the land and the impact which clearing will have on residences along watercourses downstream, once clearing starts. Moreover, residents have no confidence that Council can, or will attempt to, police development controls during development.
(5) There should be no further incursions into the land currently zoned 7(e). Council must attempt to control access to 7(e) land by trail bikes, which cause severe environmental degradation.
(6) Land zoned 2(e) at the southern end of Thirroul adjacent to the beach (6(a)) zone is of concern to residents. Proposed residential development here should be zoned 2(a) or (b). Preferably, it could be incorporated in the 6(a) area. This portion was once wetland (and should therefore have been zoned 7(a)) and has the potential to be reconstructed as an attractive wetland with the reintroduction of native vegetation and wildlife (this has been successfully done in Newcastle).
(7) Concern expressed about the future of the AIR brickworks site. This should not be entirely developed because of its potential as green area, especially viewed by tourists from the escarpment lookouts (their first look at Wollongong). In fact, much could be done now by Council to green this area.
(8) There is not considered to be sufficient flat open space/recreation to the west of L/H Drive. It is possible that a portion of the unstable, filled Excelsior land at the northern end of Philip Street could be converted to playing fields, mini golf course, etc.
(9) Walking trails up to and within the escarpment areas should be extended and maintained by Council. The cycle path should be extended to Thirroul beach, as soon as possible, to provide an alternative route to the Princes Highway for school children riding to school.
(10) There should be no major development on the escarpment top/rim. Existing developments must be prevented from becoming any more obtrusive when viewed from the coast.
(11) Some concern was expressed about the need for an additional roadway to connect Thirroul (north of the railway bridge) to the Princes Highway south of the bottom of the Bulli Pass.
(12) Heritage Values: Wyewurk; small-leaved fig tree on L/H Drive near railway bridge; RSL monument; Old RSL building; old jetty at “Bulli Harbour”. It was suggested that Council should instal plaques on heritage items and areas and produce a booklet of these.
Bulli (1 members/groups meeting)
(1) Concern was expressed that current residential zonings were not being adhered to (e.g. medium density permitted in 2(a) areas).
(2) The area zoned 4(c) O’Briens Road & Summerville St. could be appropriate for well-controlled residential development and/or caravan park – camping ground. Other tourist development may be appropriate provided it is adequately controlled.
(3) The historic nature of Bulli Township must be maintained and enhanced, because this is the first commercial area visitors see after descending the Bulli Pass.
(4) Foreshore areas must be retained as open space and kept free of building developments. Future flats/units type developments must be controlled to be 2-storeys near coast and 3 otherwise, with adequate setbacks and all parking off-road.
(5) This area has great potential for attracting tourism with appropriate marketing and developments (e.g. Grevillea Park, Bulli Spinners, beaches as alternatives to Austinmer/Thirroul, caravan park/camping ground, bushwalking in escarpment, Bulli Township).
(5) The area zoned 2(a) along Wilcoth St., between Bulli Spinners and the High School could be zoned for higher density residential development.
(6) The Bulli-Wonoona area has the potential for small businesses (clothing boutiques, delicatessens, small supermarket, mixed businesses etc.). However, the success of proposals such as these will depend upon sufficient off-highway parking (between the highway and the Bulli railway station) and an improvement to the visual amenity (tree-planting and landscaping).
(7) Escarpment protection (7(e) zoning) is not seen to be secure partially because of council’s inability to control access by trailbikes and 4-WD vehicles. The old pit site at Bulli Tile & Bricks may be suitable for bike or BMX riding track, if noise could be controlled.
(8) Walking trails should be established in the escarpment areas, with suitable access. A trail up Rixon’s Pass would be a good tourist walk.
(9) There is an urgent need to develop children’s play areas on the western side of the highway (e.g. Organs Road/Gwyther Ave., Highlands Pde.).
(10) Heritage Values: Bulli Township; old Rixon’s Pass.
APPENDIX 3
National Trust Escarpment Classification
APPENDIX 4
Water Supply to “off Fords Road” Thirroul
APPENDIX 5
Resolutions passed at CANS Public Meeting on slip, flooding and erosion.
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